PRIVACY NOTICE

Effective as of November 30th, 2018

We value our relationship with you and take your privacy seriously. The purpose of this Privacy Notice is to identify how we may process, collect, store, disclose, share and use (collectively, “use”) your personal information that we collect from you or from others in connection with your use of our websites (including www.drinkspindrift.com and shop.drinkspindrift.com) or purchase of products, webinars, content or other services from us (collectively, our “Services”).  This Privacy Notice also identifies your rights with respect to your personal information, all as described in more detail below.

We may update this Privacy Notice at any time, by posting the amended version on this site including the effective date of the updated version. We will announce any material changes to this Privacy Notice through an alert on our websites and/or via email. We may also provide other privacy notices on specific occasions when we are using your personal information in ways that differ from what we have described here, so that you are aware of how and why we are using such information and what your rights are with respect to such use.

This Privacy Notice contains the following information, which you can access by scrolling down:

1. The personal information we collect about you
2. How we may use personal information about you
3. Who we may share your personal information with
4. How we safeguard your personal information
5. How long we store your personal information
6. Your rights and options regarding your personal information
7. Our policy on children’s information
8. Links to other websites and services
9. How to contact us with questions about our use of your personal information

1. The information we collect about you.

What is personal information?

Personal Information is information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.  We do not consider personal information to include information that can no longer be used to identify a specific natural person, whether in combination with other information or otherwise.

We collect information from you both when you provide it voluntarily and also automatically when you use our Services.  We may also collect personal information from other sources, as described below.

For more information about the personal information we collect, read on below.

We collect personal information from you and any devices (including mobile devices) you use when you: use our Services, register for an account with us, make a purchase, provide us information on a web form, engage or connect with us through one of our social media pages, update or add information to your account, chat with a customer support specialist, or when you otherwise correspond with us.

In addition, we also collect personal information about you from third parties in connection with our Services, including from the following sources:

• E-commerce service providers
• Email, chat and other communications service providers
• Customer service providers
• Data analytics service providers
• Advertising providers
• Social media platforms

For more information about the types of your personal information we may use, see the detailed descriptions below.

General Personal Data

We may use the following categories of personal information in connection with your use of our Services:

• Personal contact details, such as name, title, addresses, telephone numbers, and personal email addresses
• Date of birth
• Gender
• Social media account information
• Account preferences
• Financial information, such as credit card numbers
• Location information
• Device ID or unique identifier, device type, ID for advertising, order ID, and unique device token
• Computer and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history, and your web log information

Special Categories of Data

We never request or require you to provide any of the following special categories of data, but through our chat services and customer services interactions, we know that sometimes customers and users of the Services choose on their own to share the following kinds of personal information with us:

• Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions
• Information about your health, including any medical conditions, diagnoses and/or injuries

Again, we will never request or require this type of information!  But if you decide to share it with us, our business partners who provide tools to support our chat and customer service interactions generally maintain a copy of transcripts and recordings for all customer service transactions, but we do not use or disclose it for any purposes other than resolving or analyzing complaints, suggestions or issues brought to our attention by you.

Other Information We Collect About You

Cookies

Our Services use “cookies” and similar technologies.  Cookies are small text files sent by your computer or device each time you visit our Services, which are unique to your account, browser or device.  Cookies make web surfing and browsing easier for you by saving your preferences so that we can use these to improve your next visit to our Services – for example, remembering your login information.  Cookies help us learn which areas of our Services are useful and which areas need improvement. You can choose whether to accept cookies by changing the settings on your browser. However, if you choose to disable this function, your experience with our Services may be impaired and some features may not work as they were intended. When we use cookies or other similar technologies, we may set the cookies ourselves or ask third parties to do so to help us.

Cookies may be either persistent or temporary (or session) cookies.  A persistent cookie retains user preferences for a particular website allowing those preferences to be used in future browsing sessions and remains valid until its set expiry date (unless deleted by the user before the expiry date). A temporary cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Pixels, Beacons

We or third party ad servers may use invisible pixels or beacons on the Services to count how many users visit certain pages or content. This information is collected and reported in the aggregate. We may use this information to improve our marketing programs and content, and to target advertisements to you.

Other Non-Personal Information

In addition to personal information you choose to provide us or that is automatically collected by us and our third-party service providers when you use the Services, we and our third-party service providers may use a variety of technologies to automatically collect certain usage information whenever you visit or interact with the Services. This information may include browser type, operating system, the page served, the time, the source of the request, the preceding page view, and other similar information (collectively, “Usage Information”).

2. How we may use information about you.

We will only use your personal information for the purposes identified below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose described here. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Some of your personal information, such as a way to identify you, is necessary to enter into our [ Terms and Conditions] or other agreement we have with you. The provision of all other personal information is voluntary, but may be necessary in order to use our Services, such as registering and viewing a webinar or receiving support and customer service through customer support chat.

General Personal Data

In general, your personal information may be used for the following purposes:

In connection with our provision of Services to you, which may include the following:

• Managing and fulfilling your orders
• Providing webinars
• Providing programs and courses
• Payment processing and account management
• Providing customer support and responding to your questions or comments
• Operating and improving our Services
• Managing your rewards account
• For us to comply with our legal obligations, including assessing compliance with our regulatory requirements (e.g., using customer order information in the aggregate, including revenues generated in connection with our regulatory tax requirements).
• For our other legitimate interests to make available and highlight content and opportunities that are relevant to you, improve our Services, maintain our relationship with you, and protect users of our Services and customers, where your rights and freedoms do not outweigh these interests.  We both benefit when we use your information to:
• Improve our Services, for example by reviewing information associated with stalled or crashed pages experienced by users allowing us to identify and fix problems and give you a better experience
• Offer new features, programs and opportunities
• Decide which ads to show you by only showing you those that “match” your past viewing, browsing and shopping activity. Many advertising services collect and use data from your web and mobile app activity both on and off the Services to help show you ads that are more targeted to your interests
• Contact you via email or postal mail in order to offer you coupons, discounts and special promotions, poll your opinions through surveys or questionnaires and inform you about our Services, as authorized by applicable law
• Deliver targeted marketing, service updates, and promotional offers based on your communication preferences
• Measure the performance of our email marketing campaigns (e.g. by analyzing open and click rates)
• Contact you regarding your account or an order, to troubleshoot problems with your account or an order, to resolve a dispute, to collect fees or monies owed or as otherwise necessary to provide you customer service
• Monitor and improve the information security of our websites
• Keeping our Services safe, secure and operational
• Prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities
• Customizing content that includes items and services that you may like in response to actions that you take
• Provide other services requested by you as described when we collect the information
• Conduct analytics on who is using the Services and what they are doing. For example, by reviewing how often people read certain content, we can learn and understand which content is most valuable and helpful to you and others
• Use your geo-location to provide location based services

With your consent, we may use your personal information to:

• Provide you with marketing via email, SMS or text
• Provide you with marketing from third parties

We may also use your personal information in the following situations, which are likely to be rare:

• Where we need to protect your interests (or someone else’s interests).
• Where it is needed in the public interest.

Special Categories of Data

Notwithstanding the above, we will only use the “special categories” of data described in the “The Information we collect about you” section above in very limited circumstances and only with your express consent or, less commonly, we may use this type of data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

We will never ask you for such special categories of information, but if you provide it to us in your communications with us, such as, for instance, in customer support chats, we and our third party service providers who we employ to assist us manage customer- and visitor-provided requests and communications will store, but not otherwise use or disclose, such information in accordance with our standard data retention policies.

If you do not wish for us to have such special categories of personal information, please do not disclose it to us.

Other Information We Collect About You

Cookies and Tracking Technologies.

• We use cookies and other tracking technologies to assist you navigating and using our Services, analyzing your use of our Services, and assisting with our promotional and marketing efforts (including advertising to you based upon your interests).
• We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use our Services and other websites, apps or online services, based on information relating to your access and use of our Services and other websites, apps and services on any of your devices, as well as information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.
• Do Not Track Signals. At this time, we do not respond to browser ‘do not track’ signals, as there are not yet standards for how such signals should be interpreted. Third parties, including our service providers, may collect information about your online activities over time and across different websites, including when you visit our website.
• Usage Information. We may use Usage Information for a variety of purposes, including to enhance or otherwise improve the Services. When analyzed, Usage Information helps us determine how our Services are used, such as what types of visitors arrive at the Services, what type of content is most popular, what type of content you may find most relevant and what type of visitors are interested in particular kinds of content and advertising. We may associate your Usage Information with the personal information you provide, but we will treat the combined information as personal information.

3. Who we may share your personal information with.

In connection with our services, we may share your personal information with the following types of recipients:

• Our service providers, who we engage to help us run our business and perform the Services, including:
• Software and service providers we use to manage and process your information (e.g., payment processing software)
• Software and service providers we use to communicate with you (e.g., e-mail marketing service providers)
• Advertising service providers we use to assist us in providing personalized advertising
• Hosting providers that provide database storage for our business
• Shipping providers for purposes of shipping products you have ordered
• Internally, among different departments and with our investors and trusted advisors

Additionally, we will share your personal information with third parties where required by law, where it is necessary in connection with our Services or where we have another legitimate interest in doing so.

Most, if not all, of the third parties with whom we may share your personal information are located and store your information in the United States, although some may store your information outside of the United States.

If we are subject to a merger or acquisition with/by another company, we may share information with them in connection with the transaction. Should such an event occur, we will require that the new combined or acquiring entity follow this Privacy Notice with respect to your personal information.

4. How we safeguard your personal information.

We store your personal information in the United States or other countries outside your home country. The privacy protections and the rights of authorities to access your information in these countries may not be the same as in your home country.

We have put in place appropriate security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. Other than third parties with whom we share personal information in connection with our performance of Services, third parties we engage in our business who may have access to your personal information will only process your personal information on our instructions and they are required to only use your data as necessary to perform their contract with us.

5. How long we store your personal information.

We may store your personal information following completion of transactions with you to the extent required to comply with our legal, accounting, or reporting requirements and to provide information about our Services (such as your order history) requested by you. Additionally, we may continue to store your personal information contained in our standard back-ups.

6. Your rights and options regarding your personal information.

Your data belongs to you, not us. Therefore, you have choices about how we use your personal information to communicate with you and send you marketing information. You can opt out from receiving future marketing communications from us at any time by:

• Using the unsubscribe function in the email you receive from us; or
• Contacting us as set forth under “How to contact us” below

In addition, depending on where you live*, you may have the following rights with respect to your data under certain circumstances:

The right to request access to your personal information and the following information regarding our use of your personal information:

• The purpose of such use
• The categories of your personal information that we have used
• Who we have disclosed your personal information to
• The right to request us to correct any inaccurate personal information concerning you.
• The right to request us to erase your personal information when we no longer need such data in connection with our services or, with respect to “special categories” of personal information, if you withdraw consent to our use of such information.
• The right to withdraw consent to our use of “special categories” of personal information.
• The right to request us to restrict our use of your personal information (e.g., suspend our use of your personal information).
• The right to object to our use of your personal information where we are not using it to perform Services you have requested from us.
• The right to receive a copy of your personal information.
• The right to lodge a complaint with the supervising authority of your country.

If you want to exercise any of the rights listed above, please contact us through one of the methods listed in the “How to contact us” section below.

In addition, regardless of where you live, you have choices available to you through the device or browser you use to access the Services.  For example:

• The browser you use lets you control cookies or other types of local data storage.
• Your mobile device lets you choose how and whether your location, advertising identifiers and other data is shared with us.

* The rights listed in this section apply if you reside in the European Union.

7. Our policy on children’s information

Children under 13 are not allowed to use the Services. If you are based in the European Economic Area (EEA), you may only use the Services if you are over the age at which you can provide consent to data processing under the laws of your country or if verifiable parental consent for your use of the Services has been provided to us. If you are a parent and you learn that your child is using the Services and you don't want them to, please contact us.

8. Links to other websites and services

The Services may have links to other websites that are not operated by us. We have no control over how these websites may collect your information and no liability for the practices, policies and security measures implemented on these websites. You should read the privacy notices on those other websites before you submit your information through them.

9. How to contact us

If you have any questions or concerns about our use of your personal information, please do not hesitate to contact us through any of the methods listed below. If you have a complaint or concern about how we are using your personal information, then we will work to address such concern(s).

Mail:

55 Chapel St.
Suite 401
Newton, MA 02458
Email: support@drinkspindrift.com