Introduction

 

We at Infinium Spirits Inc. (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit www.infiniumspirits.com, www.zayarum.com, or www.seagramsvodka.com, including any content, functionality and services offered on or through such Websites (collectively, the “Websites”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On this Website.
• In email, text, and other electronic messages between you and us.

It does not apply to information collected by:

• Us on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information.

If you believe we might have any information from or about a child under 16, please contact us at:

510 Market Street, Suite 200
San Diego, CA 92101

[email protected]

Or you may call us at: 800-574-7538.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);
• That is about you but individually does not identify you; and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our business partners.

Cookies

• We use a cookie to track your affirmation that you are of the legal drinking age in your country of residence. This cookie is set when you enter our website and it ensures that you do not need to re-answer the same question on every page within the site.
• We use analytics cookies that tell us the site you navigated from, if any, as well as information about your use of our website. This information is shared with the cookie provider but is not used for delivery of targeted advertisements by us.

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. We may also ask you for information when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses) if you contact us.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is aggregated for statistical purposes, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To present you with social media content or interact with you on social media.
• To provide you with information, products, or services that you request from us.
• To administer promotions, events or other marketing activities.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To allow you to participate in interactive features on our Website.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
• To provide you with our products, including to take steps to enter into a contract for sale or for services, process payments, fulfill orders, send service communications, and conduct general business operations such as accounting, recordkeeping, and audits.
• To give recommendations, deliver personalized marketing and advertising to you about our products, and to enable additional features on our services and to provide you with a personalized service.
• To deliver tailored advertising on our services based on your preferences or interests across services and devices and measure the effectiveness of ads.
• To protect and secure our services, assets, network, and business operations, and to detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• “Do Not Track”. Your browser or device may include “Do Not Track” functionality. We do not honor Do Not Track signals at this time.
• Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by emailing [email protected], with the subject line: Opt Out. You can also always opt out by sending us an email stating your request to [email protected].
• Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt out by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by sending us an email stating your request to [email protected].

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can learn more about ad serving companies and the options available to limit their collection and use of your information by visiting the websites for the Network Advertising Initiative and the Digital Advertising Alliance.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: [email protected]. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. See the section titled “California Consumer Privacy Act Notice,” below. Additionally, California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] or write us at: 510 Market Street, Suite 200, San Diego, California 92101. You may also call 1-800-574-7538.

Changes To Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Attention: Privacy Policy
510 Market Street, Suite 200
San Diego, CA 92101

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), Infinium Spirits Inc. is providing the following additional details regarding the categories of Personal Information about California residents that we have collected or disclosed within the preceding 12 months. This list encompasses information that is collected from all sources, not solely websites and social media. Accordingly, some of the data listed below may only be collected, for example, if you apply for a job with us or if you are employed by us.

For purposes of this CCPA notice, “Personal Information” is as defined in the CCPA, and means “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”

(1) We collected the following categories of Personal Information:

1. Identifiers, such as name, contact information, online identifiers and Social Security numbers and other government-issued ID numbers;
2. Personal information, as defined in the California customer records law, such as name, contact information, insurance policy number, education, employment, employment history, financial information, medical information and health insurance information;
3. Characteristics of protected classifications under California or federal law, such as sex, age, race, religion, national origin, disability, medical conditions and information, citizenship, immigration status and marital status;
4. Commercial information, such as transaction information, purchase history and financial details;
5. Internet or network activity information, such as browsing history, online behavior, and interactions with our and other websites, applications and systems;
6. Geolocation data, such as device location and IP location;
7. Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities;
8. Professional or employment-related information, such as work history, prior employer, information relating to references, CV, details of qualifications, skills and experience, human resources data and data necessary for benefits and related administration services; and
9. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

We may collect this Personal Information from you and from other categories of sources: information received as part of routine card verification (fraud) checks; social networks; publicly available databases; job applications; and joint marketing partners, when they share the information with us.

We share this Personal Information with our affiliates, successors-in-interest, clients, service providers, data processors, business partners, auditors, advisors and public or government authorities.

We may use or disclose this Personal Information to for the reasons listed above under “How We Use Your Information” and, generally, to operate, manage, and maintain our business, to provide our products and services.

(2) We disclosed the following categories of Personal Information to third parties (such as our service providers, data processors, business partners, auditors, advisors and public or government authorities) for our operational business purposes:

1. Identifiers, such as name, contact information, online identifiers and Social Security numbers and other government-issued ID numbers;
2. Personal information, as defined in the California customer records law, such as name, contact information, insurance policy number, education, employment, employment history financial information, medical information and health insurance information;
3. Characteristics of protected classifications under California or federal law, such as sex, age, race, religion, national origin, disability, medical conditions and information, citizenship, immigration status and marital status;
4. Commercial information, such as transaction information, purchase history and financial details;
5. Internet or network activity information, such as browsing history, online behavior, and interactions with our and other websites, applications and systems;
6. Geolocation data, such as device location and IP location;
7. Audio, electronic, visual and similar information, such as images and audio, video or call recordings created in connection with our business activities;
8. Professional or employment-related information, such as work history, prior employer, information relating to references, CV, details of qualifications, skills and experience, human resources data and data necessary for benefits and related administration services; and
9. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

(3) We “sold” the following categories of Personal Information to third parties (such as our service providers, data processors, and business partners) for our operational business purposes:

1. Identifiers, such as name, contact information, and online identifiers;
2. Commercial information, such as transaction information, purchase history and financial details;
3. Internet or network activity information, such as browsing history, online behavior, and interactions with our and other websites, applications and systems;
4. Geolocation data, such as device location and IP location;

(4) You have the right to opt out of any sale of your personal information by us to third parties. Under the CCPA, a business “sells” personal information when it discloses it to a third party for monetary or other benefit. A company may be considered a third party either because the purpose for its sharing of personal information is not for an enumerated business purpose under California law, or because its contract does not restrict it from using personal information for other purposes. To exercise your right to opt out of the sale of your personal information, please email us at [email protected]. Please note that your right to opt out does not apply to our sharing of personal information with service providers.

(5) You have the right to request access to personal information collected about you and information regarding the source of that personal information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You also have the right to request in certain circumstances that we delete personal information that we have collected directly from you. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

If you are a California resident, you may request that we:

1. Disclose to you the following information covering the 12 months preceding your request:
   1. The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
   2. The specific pieces of Personal Information we collected about you;
   3. The business or commercial purpose for collecting Personal Information about you;
   4. The categories of Personal Information about you that we otherwise shared, disclosed or sold, and the categories of third parties with whom we shared or to whom we disclosed or sold, as applicable, such Personal Information.
2. Delete Personal Information we collected from you.
3. Do not sell your Personal Information.

We will respond to your request consistent with applicable law. Nonetheless, you have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

Verification Procedures

In order to process your request to know/access or delete personal information we collect, disclose, or sell, we must verify your request. We verify your identity by asking you to provide personal identifiers we can match against information we may have collected from you previously and confirm your request using the email or telephone account stated in the request. We verify your identity by asking you to provide personal identifiers we can match against information we may have collected from you previously and confirm your request using the email or telephone account stated in the request.

We will not use personal information we collect in connection with verifying or responding to your request for any purpose other than responding to your request.

How to Make Requests

If you are a California resident, you may make a request for the disclosures described above, make a request to delete Personal Information, or not to sell Personal Information we collected from you, by contacting us at:

Infinium Spirits Inc.
Attention: Privacy Policy
510 Market Street
San Diego, CA 92101

[email protected]

Or you may call us at: 800-574-7538.

You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf through these means.

Changes to this CCPA Notice

We may change or update this CCPA Notice from time to time. When we do, we will post the revised CCPA Notice on this page with a new “Last Updated” date.