Spirits of America Privacy Policy

Introduction

Spirits of America (“Company” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• Websites operated by us from which you are accessing this Privacy Policy (the “Websites”);
• Through email, text, and other electronic messages; and
• Through mobile and desktop applications you download from our website, which provides dedicated non-browser-based interaction between you and our Websites (the “Apps”).

Collectively, we refer to the Website, electronic messages, and Apps as the “Services.”

This policy does not apply to information collected by:

• us offline or through any other means, including on any other website operated by Company or any third party; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Websites.

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 the Services. By accessing or using the Services, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

If you are a California resident, please see the “Additional Information for California Residents” section below, for additional details on how we handle your personal information and how to exercise your rights under the California Consumer Privacy Act.

Children Under the Age Of 16

The Services are not intended for anyone under 21 years of age. No one under age 16 may provide any information to or on the Services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on the Services 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: info@spiritsofamerica.org.

Information We Collect About You and How We Collect It

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

• by which you may be personally identified or your company be 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”); and
• about your internet connection, the equipment you use to access our Services and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies.

Information You Provide To Us.

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

• Information that you provide by filling in forms on our Services. This includes information provided at the time of registering to use our Services, subscribing to our service, or posting material (if available). We may also ask you for information when you report a problem with our Services.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your search queries on the Services.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Services, or transmitted to other users of the Services or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of our Services with whom you may choose to share your User Contributions. Please note that any User Contributions you post or disclose through the Services may be available to other users and the general public.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Services, 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 Services, including traffic data, location data, logs, clickstream data, usage data, and other communication data and the resources that you access, download and use on the Services.
• Information about your computer and internet connection, including your IP address, operating system, and browser type. We may also derive your approximate location from your IP address.

The information we collect automatically helps us to improve our Services 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 Services according to your individual interests.
• Speed up your searches.
• Recognize you or your company when you return to our Services.

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 that allows us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies in online advertising to track responses to our ads. 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 Services. 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 Services.
• Flash Cookies. Certain features of our Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Websites. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Pixel tags and other similar technologies.
• Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
• Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• For information about managing your privacy and security settings for cookies, see Choices About How We Use and Disclose Your Information.

Third-Party Online Advertising

Some content or applications, including advertisements, on our Services are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you or your company with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

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

• To provide our Services to you or your company.
• To provide you or your company with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide the information.
• To notify you or your company about changes to our Services or any products or services we offer or provide though it.
• To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information or offers tailored to your interests.
• In any other way we may describe when you or your company 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 information that does not identify you specifically, such as information that has been aggregated in such a manner that it no longer reveals your specific identity, 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 efforts and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• 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 policies and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Spirits of America, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use And Disclose Your Information

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

• Cookies and Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you do not want Flash cookies stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel and instructions found on the Global Storage Settings Panel. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. We do not respond to Do Not Track signals.
• Third Party Online Advertising. To learn how to opt out of third-party online advertising in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/. You may download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.
• 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 third-party promotional purposes, you can opt out by sending us an email stating your request to info@spiritsofamerica.org.
• 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 checking the relevant box located on the form on which we collect your data (the registration form) or at any other time by sending us an email stating your request to info@spiritsofamerica.org. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions or, if available, follow instructions in the email to unsubscribe.
• 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 checking the relevant box located on the form on which we collect your data (the registration form) or at any other time by sending us an email stating your request to info@spiritsofamerica.org.

Third Party Services

This policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps.

Sensitive Information

Unless we request it, we ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, health, biometrics or genetic characteristics, or criminal background) on or through the Services or otherwise to us.

Accessing And Correcting Your Information

You can review and change your personal information by logging into the Services and visiting your account profile page.

If you delete your User Contributions from the Services, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other users of our Services. Proper access and use of information provided on the Services, including User Contributions, is governed by our Terms of Use.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Services like message boards. The information you share in public areas may be viewed by any user of the Services.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

Changes To Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this 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 Services 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 info@spiritsofamerica.org.

Additional Information For California Residents

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following details regarding the categories of personal information that we collect (both online and offline), use, and disclose about California residents. This section does not apply to our job applicants, employees, contractors, owners, directors, or officers where the personal information we collect about those individuals relates to their current, former, or potential role with us. Under the CCPA, “personal information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household.

Collection And Disclosure Of Personal Information

The following chart details which categories of personal information we plan to collect, as well as the categories of personal information we have collected and disclosed for our operational business purposes in the preceding 12 months. We collect this personal information from you and your devices when you use our Services or otherwise communicate with us, as well as from our company affiliates and subsidiaries, publicly available databases, and social networking sites.

As described above in this Privacy Policy, under “Disclosure of Your Information,” we may have disclosed personal information to legal authorities to respond to requests or to protect and defend legal rights, which may include personal information in the categories listed above.

We do not sell personal information and have not sold personal information within the preceding 12 months, as “sale” is defined under the CCPA. We do not sell the personal information of minors under age 16.

Use Of Personal Information

We use personal information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, as described in detail above under “How We Use Your Information.”

Rights And Requests

If you are a California resident, you have the right to make the following requests:

(1) Request to Know

You may request that we disclose to you the following information covering the 12 months preceding your request:

• The categories of personal information we collected about you and the categories of sources from which we collected such personal information;
• The specific pieces of personal information we collected about you;
• The business or commercial purpose for collecting personal information about you; and
• The categories of personal information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such personal information (if applicable).

(2) Request to Delete

You may request that we delete personal information we collected from you.

To make a Request to Know or a Request to Delete, you may contact us at info@spiritsofamerica.org.

We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. We may need to request additional personal information from you, such as email address, state of residency, mailing address, or your connection to our company, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your personal information. If you make a Request to Delete, we may ask you to confirm your request before we delete your personal information.

You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

Authorized Agents

If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable:

• Proof of your registration with the California Secretary of State to conduct business in California;
• A power of attorney from the California resident pursuant to Probate Code sections 4000-4465;
• Written permission that the California resident has authorized you to make a request on the resident’s behalf. This permission must be signed (via physical or e-signature) by the California resident.

If you are making a Request to Know or a Request to Delete on behalf of a California resident and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4000-4465, we may also require the resident to:

• Provide you with a written permission signed by the resident to make the Request to Know or Request to Delete on the resident’s behalf;
• Verify the resident’s own identity directly with us;
• Directly confirm with us that the resident provided you permission to submit the Request to Know or Request to Delete.