FORTUNE MANAGEMENT COMPANY, INC. (SEAFOOD CITY) – PRIVACY POLICY

July 14, 2016

1. OUR COMMITMENT TO PRIVACY

Scope. Fortune Management Company, Inc., a California corporation and its affiliates(“Seafood City”, “we,” “our,” or “us”), respect and protect your privacy. This privacy policy (“Privacy Policy”) discloses the information that is collected by Seafood City or its third parties, the ways in which Seafood City, or our third parties processes and, sometimes, shares such information, and your rights and options with respect to such information.

Services. This Privacy Policy covers information collected from users of any of Seafood City’s websites (such as www.seafoodcity.com & www.grillcity.com), applications, online services and other interactive properties, including for example, Seafood City Store and Grill City, that links to this Privacy Policy and all features, content, and other services that we own, control and make available through such websites, applications, services and properties (each a “Service” and collectively, the “Services”). Before using or submitting information to the Services please review this Privacy Policy carefully, as well as the terms of use (the “Terms of Use”), which governs your use of the Services. A specific Service may have additional terms and policies regarding privacy for that specific Service, so in that instance, those additional privacy terms and policies will also apply. Should there be a conflict between this Privacy Policy and those additional privacy terms and policies, then the additional privacy terms and policies will control.

Advertisements, Content, Promotions and Services. The Services may include, without limitation, advertisements and promotions, displayed on or through such Services (collectively, “Advertisements”), text, images, photos, audio, music, videos, materials, comments, or other content displayed on or shared through the Services, whether provided by or on behalf of Seafood City, or uploaded or posted by users (collectively, “Content”), and sweepstakes, contests, rewards programs, special offers or other promotions (collectively, “Promotions”).

Other Websites and Mobile Applications. Except where otherwise expressly indicated herein or on the Services, this Privacy Policy applies only to information collected on the Services and does not apply to information collected outside of the Services by other websites or mobile applications. Before using or submitting information to other websites or mobile applications, please review their privacy policies carefully.

Members. Certain areas of a Service contain information intended only for users who create an account, join or otherwise register to use these areas on such Service (“Members”) and Seafood City reserves the right to limit these areas to Members. This Privacy Policy addresses Seafood City’s privacy practices relating to general use of the Services, as well as use of the Services by Members.

2. INFORMATION SEAFOOD CITY COLLECTS

Seafood City collects the following types of information from users of one or more of theServices:

Personal Information. Seafood City may collect and process any information that you choose to enter on a Service or provide to Seafood City in any other way that would allow Seafood City to identify you or contact you (collectively “Personal Information”). The Personal Information that you provide will be used by Seafood City only in accordance with this Privacy Policy. Examples of Personal Information Seafood City may collect from you and use are:

You can choose not to provide Seafood City with certain Personal Information, but then you may not be able to take advantage of many features of a Service, such as posting comments, uploading or sharing Content, registering to use certain restricted areas of a Service, participating in Seafood City’s online community, entering or participating in Promotions, purchasing products in the Seafood City Store or Grill City, or receiving e-mail alerts or newsletters.

Automatic Information. Seafood City may collect and process certain types of information whenever you interact with Seafood City through the Services. Seafood City automatically receives and records your browser information, operating system information, IP address, Device ID, cookie information and the page you requested. This information will not be stored in a manner that is personally identifiable with you.

Aggregate Information. In connection with your visit or use of the Services, Seafood City may automatically collect usage information, such as the numbers and frequency of users and their characteristics and information about similar groups of users, certain age groups or users that live in a particular geographical area. This data is only used in the aggregate as a statistical measure and not in a manner that would identify you personally. Aggregate information generally is collected through the use of cookies and Web Beacons as discussed below.

E-mail, Sharing and Communications. When you send an e-mail to Seafood City, either through the button on a Service or otherwise, Seafood City may retain your e-mail address and the contents of the e-mail that you send. When you post, upload or share Content through the Services or communicate with other users through a Service, Seafood City may retain copies of your Content. If you want to keep the information in your e-mail(s), posting(s), upload(s), share(s) or communication(s), private or proprietary, please do not send, post, upload, share, or communicate, such information or Content to Seafood City or through any Service. To help Seafood City make its e-mails more interesting and helpful, Seafood City also may receive a confirmation when you open e-mail from Seafood City if your computer or device supports this type of program.

Purchases. If you interact with a Service which allows for the purchase or goods or services, Seafood City may retain the information regarding your purchase, but Seafood City will not retain any credit card information (although such credit card information may be retained by a third party which processes transactions for Seafood City).

Social Network Profile Information. If you interact with Seafood City, a Service, Content, Promotions, through a social network or by connecting your Member account with your social network account, then you may be permitting Seafood City to access certain information from your social network profile (such as your name, e-mail address, your friend list, photos, age, gender, location, birthday, social networking ID, current city, or the people/sites you follow). If you don’t want to allow a social network to share such information with Seafood City and other third parties, please review the privacy settings and instructions of the applicable social network before you connect your Memberaccount with your social network account.

3. INFORMATION COLLECTED BY THIRD PARTIES

Seafood City may allow third parties to display or provide Advertisements, Content, Promotions or other services on or through a particular Service, such as, for example, our website. Seafood City, its partners and/or advertisers, or social networks, may use third party servers to serve or present the Advertisements, Content, Promotions or the Services and to conduct research about the Advertisements, Content, Promotions or Services. Any of these third party servers may collect non-personal information, such as your browser, operating system, date/time of viewing, IP address, Device ID, or clickstream data. Seafood City cannot control the activities of such third parties, websites or social networks.

Furthermore, Seafood City may use third party services to enable online purchasing or e-commerce functionality as part of Seafood City Store, Grill City or other service which involves the sale of Seafood City’s products and services. These third party services may provide credit card or other payment processing services where they collect Personal Information and other financial information from you.

PLEASE NOTE THAT THIS POLICY DOES NOT COVER THE COLLECTION AND USE OF INFORMATION BY SUCH THIRD PARTY SERVICES, SERVERS OR SOCIAL NETWORKS. PLEASE REFER THE PRIVACY POLICIES OF EACH SUCH THIRD PARTY.

4. TRACKING TECHNOLOGIES

Seafood City or its third parties may use tracking technologies, such as cookies and Web Beacons, to collect information about users who visit or use the Services and view or interact with Advertisements, Content, and Promotions.

Cookies. Seafood City uses “cookies” to help you access and navigate the Services more efficiently and to statistically monitor how many people are using a Service.

Web Beacons. During your use of a Service, you may encounter Web Beacons, which may come from Seafood City or from third parties that display or provide Advertisements, Content, or Promotions or services on such Service.

DO NOT TRACK DISCLOSURES

5. HOW SEAFOOD CITY USES INFORMATION

When you provide Seafood City with your Personal Information, Seafood City may use it to manage Seafood City’s registry of Members, facilitate communication between Seafood City and you and/or between Members of a Service, notify you of features or special events and provide you with other information Seafood City feels may be of interest to you. Seafood City also uses information collected to customize, analyze, adjust and improve our Services, Content, and Promotions and to meet Seafood City’s users’ needs and expectations. Seafood City also may use the information to oversee adherence to Seafood City’s guidelines for user content which are provided in the Terms of Use for the Services to enforce Seafood City’s agreements with you, to prevent fraud and other prohibited or illegal activities and for other legally permissible purposes. These uses of your Personal Information may include, without limitation, the following:

Public Areas. A Service may feature groups, discussions, member profiles, comment areas, blogs and similar areas where users can share information about themselves and their opinions, as well as post questions and Content that may contain Personal Information (“Public Areas“). Other visitors to a Service may view information posted in Public Areas. Further, Seafood City may include all or a portion of the information posted in Public Areas in the newsletters described in this Privacy Policy. By using the Public Areas, you hereby acknowledge and agree that any information you share in a Public Area (including, without limitation, Personal Information) is available to the public. Information you post to a Public Area may be viewed, accessed, or collected by, or disclosed to, third parties and may be used by others in ways neither you nor Seafood City are able to control or predict, including, without limitation, to contact you for unauthorized purposes.

Email, Sharing and Communications. A Service may offer the ability to share Content or communicate directly with other users via e-mail and other communications. If you use e-mail or other communications, Seafood City will use the recipient’s e-mail address or other means of identification in order to send the Content and Seafood City will also ask for your e-mail address or other means of identification. Seafood City does not use the recipient’s e-mail address or other means of identification for any other purpose unless the recipient gives Seafood City permission to do so.

Member Areas. If you have access to certain areas of a Service because you are a Member (“Member Areas“), the Member Areas may contain groups, discussions, member profiles, comment areas, blogs and similar areas where Members can share information about themselves and their opinions, as well as post or share Content. Personal Information or Content you post or share through a Member Area may be viewed, accessed, or collected by, or disclosed to, other Members and may be used by other Members in ways neither you nor Seafood City are able to control or predict, including, without limitation, disclosure of your Personal Information or Content to the public or to contact you for unauthorized purposes. Seafood City uses the Personal Information you provide when registering to become a Member to send you Seafood City publications, information about Member benefits and special offers, features included in the Member Areas and other information that Seafood City believes is relevant and useful to its Members. By using the Member Areas, you hereby acknowledge and agree that any information you share in a Member Area (including, without limitation, Personal Information) is available to other Members and to Seafood City for use as provided herein.

Profiles. If you register to become a Member of a Service, the information that you provide to Seafood City may be associated with one or more profiles, which may be stored on third party servers. These profiles, or a portion thereof, may be viewed by other Users of a Service, including, but not limited to those who are not Members of such Service.

E-Newsletters. If you register at a Service or subscribe to any features or services, you may choose to receive a newsletter via e-mail from Seafood City which may include information such as highlights from different areas on a Service, and information about new features, Content, Promotions or other Services. You can unsubscribe from the newsletter at any time by clicking on the “manage your preferences” link at the bottom of any e-mail newsletter sent to you and following the instructions. You also may unsubscribe at any time by logging in to the applicable Service where you created your profile and changing your preferences. Furthermore, you may elect to turn off notifications in a mobile application.

Promotions. Often times, Promotions offered on a Service are sponsored by unaffiliated third parties. Information that you provide as part of an entry into a Promotion sponsored by an unaffiliated third party will be shared with the sponsor if Seafood City advises you of such in the Promotions official rules. Some Promotions also may require consent to the release of information contained within the entry form for background check purposes or tax purposes if you become a winner. You should carefully review the official rules of each Promotion that you enter as they may contain additional important information about Seafood City’s or the sponsor’s use of your Personal Information.

Features and Services. Seafood City may retain other third parties and individuals to provide features and Services consistent with Seafood City’s Privacy Policy on Seafood City’s behalf. Examples include customer support specialists, web hosting companies, fulfillment companies (e.g., companies that fill product orders or coordinate mailings), data analysis firms and e-mail service providers.

Editorial. Seafood City also may use your Personal Information in response to a solicitation for editorial, online or for marketing and promotional purposes in connection with such solicitation. If such information is used online, on a mobile application or in a telecast, no Personal Information, other than name, city and state, will be disclosed without your consent.

Social Network Features. Seafood City and the Content, Promotions and Services, may include features that connect to social networks and allow you to share or like Content, Promotions or Services with your friends or other users of the social networks. These social networks may collect information, such as your IP address, which page you are visiting on a Service, the videos you viewed, or the Content, Promotions or Services that you shared, and may set a cookie to enable the features to function properly. The social network providing the features on a Service may be able to collect information about you, even if you don’t use those features. To control this sharing of information, please review the privacy policy of the relevant social network.

Ecommerce and Subscriptions. Seafood City may also use cookies to enable you to use a “shopping cart” if you want to enroll in a subscription or purchase goods or services while on a Service, to store your preferences associated with purchased goods or services or other Content offered from a Service and to offer you products, programs, or Promotions based on purchases, subscriptions and Service usage behavior that you and/or other customers have exhibited. If you purchase a subscription or goods and services through a Service, your Personal Information and payment information(other than credit card or debit card information) will be collected and stored by us with your account.

Videos. Certain cookies that are set when some video products are accessed on a Service, called local shared objects or Flash cookies, may not be managed using the settings in your web browser. If you set your browser or Adobe Flash options not to accept cookies or local shared objects, you may not be able to take advantage of certain ecommerce Services, videos on a Service. You agree that Seafood City may share your viewing of videos with, or obtain information about your viewing of videos from, analytics providers and advertising partners and third-party social media sites unless you withdraw your consent.

Reports. The aggregate information collected by Seafood Citymay also be used to create profiles of the audience for a Service that include anonymous statistical demographic information but no Personal Information. This aggregated information is used to, among other things, determine trends and needs and supply market research to potential advertisers and partners to help them understand s Service’s audiences. For example, Seafood City may create a report that tells advertisers that thirty percent of Seafood City’s Members are females under forty years, so that they can determine which of their Content, Promotions or Services are most appropriate for Seafood City’s Members.

Administration. From time to time, in Seafood City’s sole discretion, Seafood City may use your Personal Information to send you important administrative information regarding the Services or changes to Seafood City’s terms and policies. Because this information may be important to your use of the Services,you may not opt out of receiving such communications.

6. WITH WHOM SEAFOOD CITY SHARES INFORMATION

Seafood City may share your Personal Information with third parties, as follows:

Advertisers. If you “opt in” to receive information about identified advertisers or their services or products, Seafood City may share your Personal Information with them. If you have questions about how these companies use your Personal Information, Seafood City encourages you to review and understand their respective privacy policies. You may at any time “opt out” of having your Personal Information as part of Seafood City’s marketing mailing list or otherwise.

Advertising Partners. Advertisements appearing on a Service may be delivered to users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer or device each time they send you an online Advertisement to compile information about you or others who use your computer or device. This information allows ad networks to, among other things, deliver targeted Advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by the Services and does not cover the use of cookies by any advertisers, each of whom maintain their own privacy policy.

Service Providers. Seafood City engages service providers to perform functions and provide services to us or on our behalf, including Promotions, Advertisements, and other programs. Seafood City may share your Personal Information with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your Personal Information only on our behalf and pursuant to our instructions.

Payment Processors. Seafood City shares your payment information with payment services providers to:

If such information is stored with Seafood City, Seafood City may share your credit or debit card number with payment services providers or card networks to monitor card transactions at participating merchants and track redemption activity for the purposes of providing card-linked services.

Government, Law Enforcement or Third Parties. Seafood City may disclose any information, including without limitation Personal Information that Seafood City deems necessary, in its sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. Seafood City also may exchange information, including without limitation Personal Information, with other companies and organizations for credit fraud protection, risk reduction and related activities or to protect the rights, property of safety of Seafood City and its agents, employees or affiliates or others. Seafood City reserves the right to disclose a user’s Personal Information if Seafood City believes the user is in violation of Seafood City’s Terms of Use, even without a subpoena, warrant or other court order.

7. SALE OR TRANSFER OF INFORMATION

In the event of a sale, merger, liquidation, dissolution or sale or transfer of substantially all of the assets or equity of Seafood City or the Services, Personal Information and/or other information collected about you from the Services may be sold, assigned or transferred to the party acquiring all or substantially all of the equity and/or assets of Seafood City or the Service(s) in order to permit the party to continue the operation of the applicable Service or Services. Subject to your ability to opt-out, you consent to the sale and transfer of your information as described in this paragraph.

8. ACCESSING, CORRECTING OR REMOVING YOUR PERSONAL INFORMATION

If you are a Member and would like to review, update or deactivate your profile, please log in to and select the profile in which you would like to review, modify or deactivate (i.e., the Personal Information you have provided to us). In order to delete your profile, please contact itdept@seafoodcity.com.

Choice. Seafood City respects the privacy of your Personal Information. If you tell Seafood City that you do not wish to have this information used as a basis for further contact with you, Seafood City will respect your wishes. You also may choose not to provide Seafood City with certain information, but that may result in you being unable to use certain features of a Service. You may instruct Seafood City to stop sending you certain promotional materials (e.g., e-mail messages, newsletters, postcards and letters) by following the unsubscribe instructions provided in those materials or by turning off the notification feature on a mobile application. Seafood City may, however, continue to contact you to provide service to your account. Please note that if you use more than one name or e-mail address when communicating with Seafood City or participating on a Service, you may continue to receive communications from Seafood City to any name and/or e-mail address which you have not specified in your opt-out request.

Correcting or Removing Your Personal Information. For Personal Information Seafood City holds, you can request that we correct the data if it is inaccurate or remove the data if we are not required to retain it by law or for legitimate business purposes. Seafood City may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Seafood City provides you with the following options for correcting or removing your Personal Information from Seafood City’s database for marketing purposes:

You can send an e-mail to itdept@seafoodcity.com; or you can send mail to the following postal address:

Fortune Management Company, Inc.
2883 Surveyor Street
Pomona, CA 91768
Attention: IT Department -Privacy

Canceling Your Account or Subscription. To cancel your account or subscription, you cane-mail itdept@seafoodcity.com subject “Cancel My Account” or “Cancel My Subscription” and include the e-mail address that you registered your account or subscription with (if different from the e-mail address you’re sending the e-mail from). Remember that even after you cancel your account, copies of some information from your account may remain visible in some circumstances – where, for example, you have shared information with a third-party application or website. Seafood City may also retain backup information related to your account on our servers for some time after cancellation for fraud detection or to comply with applicable law or our internal security policies. Because of the nature of caching technology, your account may not be instantly inaccessible to others, and there may be a delay in the removal of the content from elsewhere on the Internet and from search engines.

Data Retention. Seafood City will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law or unless otherwise limited by law.\\

9. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION

Third Party Links. The Services may contain links to third-party web sites. Please be aware that Seafood City cannot control and is not responsible for the information collection practices of such web sites, which may differ from those of Seafood City. Seafood City encourages you to review and understand the privacy policies of these websites before providing any information to them.

Data Security. Seafood City(either itself or through third party service providers) maintains a variety of commercially reasonable physical, electronic and procedural safeguards designed to protect your Personal Information from unauthorized access and disclosure. For example, Seafood City uses accepted tools and techniques to protect against unauthorized access to Seafood City’s systems. You should be aware that Seafood City has no control over the security of other sites on the Internet that you might visit or with which you might interact even when a link may appear to another site from one of the Services. Seafood City wants you to feel confident using the Services but no system can be completely secure. Therefore, although Seafood City takes steps to secure your information, Seafood City does not promise, and you should not expect, that your Personal Information, searches or other communications will always remain secure. In the event of a breach of the confidentiality or security of your information, including your Personal Information, Seafood City will notify you as necessary and if possible so you can take appropriate protective steps. Seafood City may notify you under such circumstances using the e-mail address(es) that Seafood City has on record for you and/or by regular mail (if available). You also should carefully handle and disclose your Personal Information. Please refer to the Federal Trade Commission’s web site athttp://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.

Children. The Services are intended for general audiences and are not intended for children under thirteen (13) years of age. Seafood City requires that only persons thirteen (13) years of age or older use any of the Services. By using any Service, you hereby represent that you are at least thirteen (13) years old. Seafood City does not knowingly market to, solicit information, accept service or collect information from children under the age of eighteen (18). A Service may ask users for their birth dates to ensure that such Service is not collecting information from children under age thirteen (13) or to identify when additional steps may need to be taken in connection with information collected from children under age thirteen (13). When a Service has actual knowledge that it collects information from children or offers a service directed toward children, it will comply with applicable laws, including the U.S. Children’s Online Privacy Protection Act of 1998. In the event that Seafood City learns that we have collected Personal Information from a child under age thirteen (13) without parental consent, we will delete that information as quickly as possible. If you believe that we might have any Personal Information from or about a child under thirteen (13), please contact us at: admindept@seafoodcity.com.

Changes to this Privacy Policy. At any time without prior notice, Seafood City may update this Privacy Policy to reflect changes in Seafood City’s practices. When Seafood City posts changes to this Privacy Policy, Seafood City will revise the “Last Updated” date at the topof this page. Seafood City encourages you to bookmark this Privacy Policy and to periodically review it to inform yourself of changes to it or any of Seafood City’s other policies. Any changes to Seafood City’s Privacy Policy will become effective upon Seafood City’s posting of the updated policy. Use of any Service that inks to this Privacy Policy constitutes your acceptance of the terms of this Privacy Policy then in effect.

California Privacy Rights. If you are a resident of California (“California Users“), in addition to the rights set forth in this Privacy Policy, you may have certain additional rights. You generally have the right to request information from Seafood City regarding the manner in which Seafood City shares certain categories of Personal Information with third parties for their direct marketing purposes. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information by us to third parties for the third parties’ direct marketing purposes. Under the law, however, a business is not required to provide this information if it adopts and discloses to the public (in its privacy policy) a policy of not disclosing customer’s personal information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy. Rather, the business may comply with the law by notifying California Users of their rights to prevent disclosure of personal information and providing a cost free means to exercise that right.

Please note that whenever you opt in to receive future communications from a third party, your information will be subject to the third party’s privacy policy. If you later decide that you do not want that third party to use your information, you will need to contact the third party directly, as Seafood City has no control over how third parties use information. You should always review the privacy policy of any party that collects your information to determine how it will handle your information.

Please note that Seafood City is only required to respond to one request per customer each year. Seafood City is not required to respond to requests made by means other than through this e-mail address:admindept@seafoodcity.com.

California residents who are minors under eighteen (18) years old may request the removal of any information that they posted to a Seafood City Service by contacting admindept@seafoodcity.com. Upon such request, Seafood City will anonymize or remove from public view any content posted by a minor to a Service, unless required by law to retain such content or information.

Users from Other Jurisdictions or Outside the United States. By visiting a Service, submitting information or using any of Seafood City’s Content, Promotions or Services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and consent to having your data transferred to and processed on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. If you do not accept this Privacy Policy, please do not use the Services. The Services are is controlled and operated by Seafood City from the United States. If you are not a resident of the United States or you are located outside United States and choose to provide information to Seafood City, please note that Seafood City will transfer the information, including Personal Information, to the United States and process it there unless otherwise prohibited by law. Your acceptance of this Privacy Policy followed by your submission of such information represents your agreement and consent to that transfer. Seafood City does not represent or warrant that any Service, or any part thereof, are appropriate or available for use in any particular jurisdiction. Those who choose to access a Service do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. You also are subject to United States export controls in connection with your use of the Content, Promotions or Services thereto and are responsible for any violations of such controls, including, without limitation, any United States embargoes or other federal rules and regulations restricting exports. Seafood City may limit the availability of theContent, Promotions or Services, in whole or in part, to any person, geographic area or jurisdiction that Seafood City chooses, at any time and in Seafood City’s sole discretion.

No Rights of Third Parties. This Privacy Policy does not create rights enforceable by third parties.

Contacting Seafood City. If you have any questions about this Privacy Policy, the practices of the Services or your dealings with us, please feel free to contact Seafood City at:

Fortune Management Company, Inc.
2883 Surveyor Street
Pomona, CA 91768
Attention:Administration Department – Privacy
admindept@seafoodcity.com