DAMASCUS BAKERY GENERAL PRIVACY POLICY

Last updated: January 12, 2026

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL DATA AND YOUR CHOICES AND RIGHTS.  IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE OUR SERVICES.


INTRODUCTION

Damascus Bakery Opco, LLC, together with its affiliates and subsidiaries (collectively, “we,” “our”, or “us”) specializes in producing artisanal bread products, including pita, lavash roll-ups, and unique Brooklyn Bred offerings.  We value your privacy and believe in transparency. This Privacy Policy (the “Policy”) describes how we collect, use, share, protect, and disclose your personal data (as defined below) when you purchase our products directly from us, interact with our business operations, or participate in sweepstakes, contests, or marketing activities we sponsor (together, “Services”).  Individuals who provide us with personal data, directly or indirectly, in connection with the Services are collectively referred to as “you” or “your”.

PLEASE NOTE: This Policy does not apply to (i) data processed as a result of our HR operations, including for job applicants, employees, independent contractors, or corporate officers; or (ii) data collected via cookies or similar technologies placed by us or by third parties on certain websites under our control, where applicable.  Where applicable, a separate notice will govern such data collection and processing activities. 


INFORMATION WE MAY COLLECT

We may collect information that could directly or indirectly identify you as an individual from you, your devices, your interactions with our Services, and/or from third-party sources and may include the following (together, “personal data”), as described below:

  • Contact and Account Information, including your first and last name, email address, mailing address, telephone number, professional title, and business name. We may also collect information you provide to create an account or profile, such as your username and password.
  • Communications Data, such as information you provide through online web forms, when you contact us (or our representatives) with questions, feedback, surveys, or other correspondence.  
  • Transaction Data, such as information about payments to and from you and other details of your interaction with the Services, including payment methods, billing details, among others.  We may use a third-party payment processor so that we do not have access to your payment method details or otherwise receive or store any billing data where payment is made for paying and renewing your subscription. 
  • Marketing Data, such as your preferences for receiving communications about our activities and services, and details about how you engage with our communications. 
  • Social Media Integration. We use certain social networking features and connections, including "share" buttons (e.g., Meta or Google). These features from third party websites may gather your IP address or information about any links that direct you to or from these social media sites or other websites.  If you use these services, integrations, and/or features on social media websites, you authorize these social media websites to share with us certain personal data. This may include your name, social media account ID, email address, location information, and/or IP address.
  • User Content, including content that you create and share with us on third-party social networks. For example, some tools may allow you to enter and display certain information, and to engage with our Services. The content you choose to upload using those features may be visible to us and others. Examples may include photos, videos, comments, reviews, or other similar media or content. 


HOW WE MAY USE OR SHARE YOUR INFORMATION

1.     How do we use the information:  

To the extent permitted by applicable law, we may use the information described above in connection with certain business or commercial purposes, including:

 a.     Provision and Improvement of Services and Products

  • Provide you with our Services, content, and other products or offerings.
  • Improve, develop, and evaluate existing and new offerings, products, and content.
  • Fulfill and manage your orders, payments, returns, and exchanges made through the Services.
  • Operate, maintain, and manage our applications, databases, and systems, including communication records and backups.

b.     Business Operations and Administration

  • Support our business operations, including maintaining accounting records, analyzing financial results, complying with audit requirements, obtaining or maintaining insurance coverage, managing risks, and obtaining professional advice.
  • Administer promotional or marketing initiatives.
  • Manage our business relationships with you, including enforcing our terms of use and other agreements.

c.     Communication and Customer Engagement

  • Communicate with you and respond to your feedback, requests, questions, or inquiries.
  • Solicit your feedback and inform you about our Services or other offerings.
  • Post customer testimonials on our Services that may contain personal data.  

d.     Marketing and Analytics

  • Assess the effectiveness of our marketing campaigns and enhance our marketing efforts.
  • Analyze your interactions with our Services, content, or other offerings, including preparing aggregate and anonymized traffic and usage information.
  • Share aggregate or de-identified data with affiliates, business partners, and other third parties for lawful purposes.
  • Send newsletters, promotions for our products, third party products and services, or special events.
  • Administer contests, sweepstakes, promotions, and surveys.  

e.     Identify Usage Trends: Recognize and remember your preferences and interactions to better understand customer experience.
 
f.      Legal, Compliance, Security, and Risk Management

  • Detect, investigate, and prevent activities that may violate our policies or applicable laws. 
  • Mitigate risks to the privacy and security of our Services, including fraud and phishing detection.
  • Protect the rights or safety of our company, users, or others.
  • Comply with applicable laws, regulations, court orders, or requests from government or law enforcement authorities.
  • Exercise or defend legal rights or claims.

g.     Corporate Transactions: Facilitate business transactions, such as mergers, acquisitions, reorganizations, or sales of assets, where your information may be part of the transferred assets. 

h.     Others. Accomplish any other purposes described to you at the time your information is collected, for which you have provided consent, or those related or ancillary to the purposes described in this Policy.


 

2.     How we may disclose or share the information:

Where permitted by applicable laws, we may disclose your personal data described above for business purposes in the following contexts:

  • Third-Party Vendors or Partners: We may share your personal data with other parties who perform functions or work on our behalf, including third-party vendors, service providers, contractors, or agents who may require access to certain information in providing services to us or fulfilling the terms of certain Promotions (as defined below). 
  • Our Distribution Partners:  We may share your information with our trusted distribution partner(s), including when you contact us for products, offerings, or services so that we can match you with a distribution partner in your area.
  • Corporate Affiliates: We may share your personal data with our subsidiaries or affiliates, and with their respective officers, directors, or employees.
  • M&A or Similar Transactions: If we sell, transfer, or otherwise share some or all of our assets in connection with a merger, reorganization, liquidation, dissolution, bankruptcy, or sale of assets, we may disclose your personal data as part of the assets transferred as a result of the transactions.  
  • Law Enforcement; Legal Defense: We may disclose personal data as required by law, court orders, subpoenas, or other legal processes, or if we reasonably believe such action is necessary to comply with law.  We may also share information to establish or exercise our legal rights or claims; to defend against a legal claim; and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our contracts or terms. We may also disclose personal data as needed to protect vital interests.
  • Professional Advisors: We may share your personal data with our attorneys, accountants, and/or other fiduciaries and consultants that need access to your information to provide business, operational, or other support on our behalf.
  • Other Entities With Your Consent: We may ask, from time to time, if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy.  We may disclose your information in this context with your permission or upon your direction.   

 

SWEEPSTAKES, CONTESTS, AND PROMOTIONS

We may offer sweepstakes, contests, and promotions (each, a “Promotion”), including any Promotion jointly or solely sponsored or offered by other parties, which may require submitting your personal data to such third parties. If you voluntarily choose to enter a Promotion, your personal data may be disclosed to, or shared with, Promotion co-sponsors or administrators, our service providers, social media sites (e.g., Instagram), and/or other third parties.  For example, if you are notified by us that you are a winner of our Promotion(s), we will ask you to provide us with your full name and contact information. This information is required for us to fulfill your prize (as applicable) and for our legal compliance and recordkeeping purposes.

By participating in one or more Promotions we sponsor, you are agreeing to the official rules that govern that Promotion, which may include consent to additional or differing privacy practices from those contained in this Policy. Please review those official rules carefully.

 

DATA RETENTION

We retain and use your information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our Services, and to enforce our agreements.

We take reasonable steps to delete the personal data we collect when (1) we have a legal obligation to do so; (2) we no longer have a purpose for retaining the information; or (3) you ask us to delete your personal data, unless we determine that doing so would violate our legal, regulatory, dispute resolution, contractual, or similar obligations.  

 

DATA SECURITY

We recognize the importance of safeguarding your personal data and we endeavor to maintain reasonable and appropriate physical, technical, and organizational safeguards to protect your personal data against accidental loss and unauthorized access, use, alteration, or disclosure, and to detect fraudulent identity verification activity and mitigate risks concerning your personal data.

While our security measures seek to protect your information in our possession, no security system is perfect, and no data transmission is 100% secure. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information transmitted to or from the Services.  To the extent our Services allow you to set up an account, please keep your password confidential.  Do not share your password with anyone.  

 

YOUR RIGHTS AND CHOICES REGARDING PERSONAL DATA

Communication Preference. If you no longer wish to receive communications from us via email, you may opt out by clicking the “unsubscribe” link at the bottom of our emails, or by contacting us via the “Contact Us” details at the end of this Policy and providing your contact information so that we may identify you in the opt-out process. If you opt out of marketing emails, we may still send you non-promotional emails, such as those about your account, relationship with us, or our existing business relations. 

Accuracy and Updating Your Information. If any of the information you have provided to us changes, please let us know via the “Contact Us” details at the end of this Policy.  If you become aware of inaccurate personal data about you, you may update your information.  We are not responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete Personal Data that you provide to us.

Contact Us. If you believe your rights relating to your personal data have been violated, please contact us via the “Contact Us” details provided at the end of this Policy. To exercise any privacy rights described below, please also use the “Contact Us” details.


COOKIES AND SIMILAR TECHNOLOGIES

We (and where applicable, in conjunction with third parties) may use cookies (which are small text files stored by your web browser when you use websites) as well as related technologies (collectively “Cookies”), to collect and store information about when and how you access certain websites we control.  Where applicable, a separate “Website Cookie Policy” will be displayed. 


CHILDREN’S PRIVACY

The Children’s Online Privacy Protection Act (“COPPA”) restricts the collection, use, or disclosure of personal data from and about children under 13 online.  Further, our Services are not directed to children aged 18 or younger, nor is information knowingly collected from children under the age of 18.  No one under the age of 18 may access, browse, or use the Services or provide any information to or on the Services.  If you are under 18, please do not use or provide any information on the Services (including, for example, your name, telephone number, or email address).  If we learn that we have collected or received personal data from a child under the age of 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child, please contact us via the “Contact Us” details provided at the end of this Policy.

For more information about COPPA, please visit the Federal Trade Commission's website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule. 


CONSUMER RIGHTS

To the extent you are a resident of certain U.S. states with comprehensive state privacy laws, you may be eligible for one or more of the following consumer rights as authorized by applicable U.S. state privacy laws.  This Section provides an overview of these rights: 
 
Right to Access. Subject to certain conditions set forth in the applicable U.S. state privacy laws, you have the right to know and see what personal data we have collected about you and receive a copy of such information in a portable format, purposes for which we collect your personal data, recipients of your personal data to whom we disclose or share, which in some states may include categories of personal data collected, categories of sources of collection, business or commercial purposes for data processing, and categories of third parties with whom we disclose that information.  

Right to Correct. Subject to certain exceptions set forth in the applicable U.S. state privacy laws, you have the right to request that we correct any inaccurate personal data that we have collected about you.

Right to Delete. Subject to certain exceptions set forth in the applicable U.S. state privacy laws, you have the right to request that we delete the personal data we have collected about you.

Right to Opt-Out. Subject to certain conditions set forth in the applicable state privacy laws, you have the right to opt out of targeted advertising, profiling, the sale or sharing of your personal data, to the extent such instances occur (as defined under applicable state laws).  We do not have actual knowledge that we sell personal data of minors under 16 years of age.  

Right to Non-Discrimination. You have the right not to be discriminated against for exercising any of your rights under the state privacy laws. 

Right to Appeal.  To the extent the applicable state privacy laws provide such rights, you may appeal our denial to act on your consumer rights under the applicable state privacy laws within a reasonable time. We will respond within designated period for responding to U.S. data subject requests and may exercise the right to extend this response period (to the extent authorized by applicable state privacy laws).

Right to Limit Use and Disclosure of Sensitive Personal Data.  If any state privacy laws classify your information we collect as “sensitive personal data,” we use such data as reasonably necessary to perform services.  While this right is not applicable to how we collect or use your sensitive personal data, we provide this information as this is one of the consumer rights provided under certain state privacy laws. 

 

OTHER IMPORTANT INFORMATION

Third Party Websites, Applications, or Technologies. In using our Services, you may encounter links to third-party websites, which may have privacy practices that differ from this Policy.  We have no control over and do not endorse the privacy practices of websites or applications that are owned or operated by third parties.  If you follow any links that direct you away from the Services, including links to or from social media sites or to other websites, your activities on these third-party sites will be subject to their privacy policies. Therefore, please check the URL to confirm if you are no longer accessing our Services and review each third-party site’s privacy policy carefully.

California Shine the Light. Under California Civil Code Section 1798.83, California residents who provide personal data in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response.  As part of the California Online Privacy Protection Act, all users of our Services may make any changes to their information at any time via the “Contact Us” details at the end of this Policy.  

“Do Not Track” Signals. Some browsers transmit “Do-Not-Track” (“DNT”) signals, which inform websites that you do not want to be tracked.  We currently do not support or take actions in response to the DNT signals. 

Changes To This Policy. We may change this Policy at any time. You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Services, and from time to time, so that you are aware of any changes.  Your continued use of the Services after the “Last Updated” date indicates your acceptance of the changes.  All changes are effective on the date listed at the top of this page and will apply to all information that we have about you. 

 

CONTACT US

For more information, or if you have any questions or concerns regarding this Policy, you may contact us using the information below, and we will do our best to assist you. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone.


In Writing:      Damascus Bakery Opco, LLC
                         60 McClellan Street, Newark, NJ 07114
                                                
By Email:  biteofbrooklyn@brooklynbred.com