Privacy Policy
This privacy policy has been compiled to better serve those who are concerned with
how their ‘Personally Identifiable Information’ (PII) is being used online. PII, as described in U.S. privacy
law and information security, is information that can be used on its own or with other information to identify,
contact or locate a single person, or to identify an individual in context. Please read our privacy policy
carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally
Identifiable Information in accordance with our website.
What personal information do we collect
from
the people that visit our blog, website or app?
When ordering or
registering on our site, as appropriate, you may be asked to enter your name, email address, phone number or
other details to help you with your experience.
When do we collect information?
We
collect information from you when you subscribe to our platform, fill out a
form, use Live Chat or enter information on our site, provide us with feedback on our products or services, or
enter into a contract with us.
How do we protect your information?
We
maintain organizational, technical, and physical safeguards to help protect the information we collect and use.
These safeguards vary depending upon a variety of factors including the sensitivity of the information we
collect and use. Despite all our reasonable efforts, please be advised that no security method is
infallible.
How do we use
your information?
We may use the information we collect from you when
you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf
the website, or use certain other site features in the following ways:
- To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
- To improve our website in order to better serve you.
- To allow us to better service you in responding to your customer service requests.
- To administer a promotion, survey or other site feature.
- To ask for ratings and reviews of services offered
- To follow up with them after correspondence (live chat, email or phone inquiries)
How long do we use your data for?
We keep data only for the time necessary to execute the
contract, achieve the
objective pursued, meet your needs, or meet our legal obligations.
The data
retention criteria we have established includes:
- The term of the contract entered into by you with us;
- The retention period required by applicable law (i.e., accounting or archiving obligations);
- The duration of your consent for a specific use;
- For prospective customers of our services (in the absence of any subscription or purchase): 1 year or less from the day of the data collection; 6 months or less for cookies or 13 months in specific cases
When we no longer need to process your data, we delete it from our systems and
databases or anonymize it so that you can no longer be identified.
How do we protect your
information?
Your personal information is contained behind secured
networks and is only accessible by a limited number of persons who have special access rights to such systems,
and are required to keep the information confidential. In addition, all sensitive/credit information you supply
is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when
a user enters, submits, or
accesses their information to maintain the safety of your personal information.
All transactions are
processed through a gateway
provider and are not stored or processed on our servers.
Do we use ‘cookies’?
Yes.
Cookies are small files that a site or its service provider transfers to
your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s
systems to recognize your browser and capture and remember certain information. For instance, we use cookies to
help us remember and process the items in your shopping cart. They are also used to help us understand your
preferences based on previous or current site activity, which enables us to provide you with improved services.
We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can
offer better site experiences and tools in the future.
We use cookies to:
•
Understand and save user’s preferences for future visits.
• Keep track of advertisements.
• Compile
aggregate data about site traffic and site interactions in order to offer better site experiences and tools in
the future. We may also use trusted third-party services that track this information on our behalf.
You
can choose to have your computer warn you
each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser
settings. Since every browser is a little different, look at your browser’s Help Menu to learn the correct
way to modify your cookies.
If you turn cookies off, some of the features that
make your site experience more efficient may not function properly. It won’t affect the user’s experience that
make your site experience more efficient and may not function properly.
Third-party
disclosure
WHEN WE SHARE
YOUR INFORMATION
We may share your information with:
- Advertisers, Advertising Networks, and Other Third Parties: We may share information about how you use the Services and interact with content or ads to better tailor services, products, marketing and advertising on the Services and on third-party platforms. To enable these purposes, we may share certain demographics information, user-generated content, device information and identifiers, connection and usage data, geolocation data, public and commercial information, and social media information. These third parties may use their own tracking technologies, or “cookies”, to collect or request information about you,
- Partners: We may share your information with third party partners. For instance, if you enter a contest or sweepstakes sponsored by a third party, we may share the information you provide for that entry with the sponsor. Depending on the partnership, we may share certain information including contact information (at your direction), identification and demographic information, transactional information, user-generated content that you provide, research and feedback, device information and identifiers, connection and usage information, public and commercial information, and social media information. We may also share your information with third parties that alcohol delivery services if you purchase a wine to enjoy through our website.
- Social Networks: We may share your information with social media platforms for example, if you click on a Facebook “like” button on the Services, the “like” may appear on your Facebook account. To control this sharing of information, please review and adjust your privacy settings for the relevant social network. Depending on your privacy settings and actions on such network, we may share contact information, identification and demographic information, user-generated content, device information and identifiers, connection and usage data, and social media information.
- Service Providers: We engage vendors to perform services for business purposes on our behalf and share information with them to enable them to provide us with such services, including research and analytics, hosting, transaction and payment processing, promotion administration, fraud prevention, identity management, acquisition and other services. Service providers may use such information for their operational purposes in order to provide their services to us.
- Search Engines: You may be able to engage with other members of the Services or the public. This may make the name and photo associated with your profile and any comments or user-generated content you provide visible to other members of the Services or the general public. If the information is available to the general public, it may also be searchable by search engines.
- Law Enforcement, Regulators, Anti-fraud Coalitions and Other Groups: We share any of the categories of information we collect, as appropriate, with these third parties in order to: protect and enforce the legal rights, privacy, and safety of ourselves and our visitors; protect against possible fraud or other illegal activity; respond to requests from government and other authorities; and otherwise comply with legal process.
- Other Sharing: We may share information about you, often along with a hashed or masked identifier, with third parties so they may better personalize your experience with them and the advertising and other offers they show or otherwise send you and to determine advertising effectiveness. With your appropriate consent when required, and consistent with applicable law, we may share your video viewing behavior with third parties including service providers, advertising companies, analytics partners, and social media sites.
- Sale or Transfer of All or Part of Our Business or Assets: In the event that COLLECTIV (or any COLLECTIV business) is involved in a merger, acquisition, transfer of control, bankruptcy, reorganization or sale of assets, or diligence associated with such matters, we may sell or transfer the information described in this Privacy Policy as part of that transaction.
- Sale of Personal Information: Under California law, certain of the information sharing described above may be categorized as the “sale” of “personal information” under certain circumstances. To the extent that it does constitute such a “sale”, you may opt out of that sale through the mechanism set forth in the “Your Rights” provision below.
We will keep your information only for as long as it is necessary to fulfill the
purposes described above, unless a longer retention is required or permitted by law. We may delete or
de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under
applicable law. The retention period that applies to your information may vary depending on the Services you use
and how you interact with them.
YOUR RIGHTS
Depending on where you live,
you may have certain rights with respect to your information. For example, under local laws, you may be able to
ask us to:
- provide access to certain information we hold about you, in some cases in a portable format, if technically feasible
- update or correct your information
- delete certain information
- restrict the use of your information
We will respond within the time period prescribed by applicable law. Please note
that many of the above rights are subject to exceptions and limitations.
Some
Services can be provided only if we have your information, therefore deletion of your information will result in
termination of such Services.
We will take reasonable steps to verify your
identity, including authenticating you through the email address we have on file. We may require further
documentation such as a password and user ID before granting access to your information.
You may submit the
following types of requests as follows:
- Request Categories of Information: If you, or someone acting on your behalf, would like to request that we tell you the categories of personal information we collect, the categories of sources from which personal information is collected, the business or commercial purpose for collecting or selling the personal information, the categories of third parties with which the business shares personal information, the categories of information about you that we sell, the categories of third parties to whom the personal information was sold, or the categories of personal information that was disclosed for a business purpose, send an email to [*please provide the appropriate receptacle]
- Request Deletion: If you, or someone acting on your behalf, would like to request that we delete information that we hold about you, you may send an email to [*insert appropriate receptacle here] Note that certain information about you will not be deleted if you request such a deletion, as may be permitted by law. Also note that we will not be able to provide you with certain Services upon a deletion. You will also need to clear your cookies.
- Do Not Sell My Personal Information: If you would like to request that we do not sell your personal information, please send an email to [*please provide the appropriate receptacle]
Please note that you may be located in a jurisdiction where we are not obligated,
or are unable, to fulfill a request. In such a case, your request may not be fulfilled. If you have any
unresolved concerns, you may have the right to complain to your local data protection authority.
Additional
Rights for California Residents: Residents of the State of California
may request a list of all third parties to which the Services have disclosed certain personal information (as
defined by California law) during the preceding year for those third parties' direct marketing purposes. If you
are a California resident and want such a list, please contact us at [*please provide appropriate address] For
all requests, you must put the statement "Your California Privacy Rights" in the body of your request, as well
as your name, street address, city, state, and zip code. In the body of your request, please provide enough
information for us to determine if this applies to you. You need to attest to the fact that you are a California
resident and provide a current California address for our response. Please note that we will not accept requests
via the telephone, email, or by facsimile, and we are not responsible for notices that are not labeled or sent
properly, or that do not have complete information.
Third-party links
Occasionally,
at our discretion, we may include or offer third-party products or
services on our website. These third-party sites have separate and independent privacy policies. We therefore
have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek
to protect the integrity of our site and welcome any feedback about these
sites.
Google
Google’s advertising requirements
can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for
users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We use Google AdSense Advertising on our website.
Google, as a third-party vendor, uses cookies to
serve ads on our site. Google’s use of the DART cookie enables it to serve ads to our users based on previous
visits to our site and other sites on the Internet. Users may opt-out of the use of the DART cookie by visiting
the Google Ad and Content Network privacy policy.
We have implemented the following:
• Remarketing
with Google AdSense
• Demographics and Interests Reporting
We, along with third-party vendors such
as Google
use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick
cookie) or other third-party identifiers together to compile data regarding user interactions with ad
impressions and other ad service functions as they relate to our website.
Opting
out:
Users can set preferences for how Google advertises to you using the Google Ad
Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by
using the Google Analytics Opt Out Browser add on.
California Online Privacy Protection
Act
CalOPPA is the first state law in the nation to require
commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond
California to require any person or company in the United States (and conceivably the world) that operates
websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy
policy on its website stating exactly the information being collected and those individuals or companies with
whom it is being shared.
See more at:
http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf
According to CalOPPA, we agree to the following:
- Users can visit our site anonymously.
- Once this privacy policy is created, we will add a link to it on our homepage or as a minimum, on the first significant page after entering our website. Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.
- You will be notified of any Privacy Policy changes on our Privacy Policy Page
- You can change your personal information by emailing us
How does our site handle Do Not Track signals?
We
honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser
mechanism is in place.
Does our site allow third-party behavioral tracking?
It’s also important to note
that we allow third-party behavioral tracking
COPPA
(Children Online Privacy Protection Act)
When it comes to the
collection of personal information from children under the age of 13 years old, the Children’s Online Privacy
Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the United States’ consumer
protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must
do to protect children’s privacy and safety online.
This site is only intended
for use by persons above the age of 21. As such, we do not market to children under the age of 13 years
old.
Fair
Information Practices
The Fair Information Practices Principles form
the backbone of privacy law in the United States and the concepts they include have played a significant role in
the development of data protection laws around the globe. Understanding the Fair Information Practice Principles
and how they should be implemented is critical to comply with the various privacy laws that protect personal
information.
In order to be in line with Fair Information Practices we will
notify you via email within 7 business days of discovery if a data breach should occur.
We also agree to the
Individual Redress Principle which requires that individuals
have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to
the law. This principle requires not only that individuals have enforceable rights against data users, but also
that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance
by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law
that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the
right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We
collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions
- Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CAN SPAM, we agree to the following:
- Not use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or site headquarters.
- Monitor third-party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can email us at [*enter appropriate receptacle here], or you can follow the instructions at the bottom of each email, and we will promptly remove you from all general email correspondence; however, we will continue to email you in response to your specific requests for information and other important information about activity in your account.