PRIVACY POLICY
Last Updated: January 1st, 2024
We at Krugmann Markenspirituosen GmbH&Co.KG are committed to protecting the privacy of your personal information. This Privacy Policy will discuss how we process your personal information and your privacy choices and rights. This policy does not apply to the practices of companies or persons that we do not control or employ.
We maintain our websites for the use of individuals who are of legal purchase age of alcoholic beverages under applicable law, and you must be of legal purchase age where you reside to access our websites or provide any information to us. We do not solicit or knowingly collect personal information from any individuals under such legal purchase age, and we do not knowingly market our products or services to persons under such legal purchase age.
INFORMATION WE COLLECT
The types of personal information we collect depend on how you use our website or otherwise interact with us. The categories of personal information we collect about you may include the following:
- Identifiers, such as your name, email address, telephone number, mailing address, shipping address, date of birth, zip code, credit card information (for purchases), debit card information (for purchases), and IP address. We may also ask you to provide your photograph and/or government-issued identification card, but only for identity or age verification purposes.
- Customer Records, such as the Identifiers above, your signature, and we or our service providers may collect your bank account number, credit card number, or debit card number.
- Protected Class or Demographic Information, such as age, date of birth, sex, and gender.
- Commercial Information, such as a record of products purchase or considered, purchase history, purchase price history, or other information related to purchasing or consumer histories.
- Professional and Employment-related Information, such as your job history, education history, and other information that you might include on a resume or cover letter when you apply to work with us.
- Internet or other Electronic Network Activity Information, such as browsing history, search history, clickstream patterns, session information, browser and operating system type, navigation paths, date/time stamps, cookie identifiers, language preferences, and other information about how you interact with our Site.
- Non-Precise Geolocation Data, which we may derive from your IP address.
- Audio, Electronic or Visual Information, such as photographs or videos taken of you when you interact with us at our events. If you participate in a focus or marketing research group for our products, we may also obtain a recording of your image and/or voice from the third-party organizer in order to analyze your comments and reactions and improve our products.
- Inferences drawn from the information we collect about you to create a profile about you reflecting your preferences, behaviors, and characteristics.
Some of the data we collect may be considered sensitive personal information, including your driver’s license, government issued identified number, and demographic information.
We may collect your personal information from a variety of sources:
- Directly from you, such as when you enter promotions or contests on the website or purchase an item. We may also collect your information when you contact us, send us a message via social media, or comment on our social posts.
- Automatically through tracking technologies, such as cookies, when you use our websites and navigate through our online features.
- From third parties, such as marketing partners and social media partners. If you apply for employment, we may also collect information about you from background check providers and the references you list on your application.
We often combine the information we collect from tracking technologies and third party sources with the information that we collect from you directly for the business and commercial purposes listed below.
HOW WE USE PERSONAL INFORMATION
The specific ways we use your personal information depends on the business and commercial purposes why we collected it, which may include the following:
a. Identify and Age Verification
To comply with our legal obligations, we may ask for your year and/or full date of birth to verify that you are of Legal Purchase Age in order to access our services. We may also request that you provide us with your government-issued identification card and/or photograph to verify your age when you make purchases from us or verify your identity.
b. Communications
We use your personal information to communicate with you, including to respond to your feedback, complaints, and questions, as well as to send you announcements, such as updates to this Privacy Policy and other legal documents and notices about your account, our company, or our services. We may also use your personal information to communicate with you about our products and services, or potentially other third party products and services. You can always opt out of receiving marketing communications from us.
c. Marketing Analysis
We may use information for internal marketing analysis, for example, to assess trends among our consumers or to measure the amount of traffic to our websites.
d. Transactional Purposes
We may use your personal information in order to respond to your queries and requests and to manage transactions such as credit card payments for any goods that you order from us or any of our agents, or for the fulfillment of such transactions (e.g., delivery). The personal information you provide may be used by an authorized vendor to fulfill that order.
e. Improve and Personalize
When you provide us feedback or participate in insight or research groups related to our products, we may collect your personal information in order to analyze and understand your opinions of our products. Our analysis of this information allows us to create and improve our products. We also use your personal information to personalize our services, including to provide information about where you can find our products in your area or to customize the content on our websites based on your preferences.
f. Evaluate your Application
If you apply for a job, we will use your personal information to evaluate your application or employment and to contact you with updates regarding your application. We may also contact you about other jobs that we think might interest you.
g. Enforcement
We may use your personal information to investigate violations of our policies and agreements with you, and to otherwise comply with our legal obligations.
HOW WE DISCLOSE PERSONAL INFORMATION
a. Service Providers
We may disclose your personal information to third parties that assist us in operating our Services and our business by providing services related to hosting, data management, billing, fulfillment, marketing, background checks, and other operational services. We take steps to ensure that our service providers protect the personal information we share with them and require that they not further share, sell, disclose, or otherwise use the personal information we share with them for any purpose other than providing services to us.
b. Business/Advertising Partners
We may disclose your personal information to business partners, such as marketing agencies, consulting firms, and others. In some cases, these business partners may use your personal information in ways that are different from how we use it.
c. Affiliates
We may disclose your personal information to our corporate affiliates for business purposes including for marketing purposes.
d. Third Parties Involved in a Sale or Transfer
In the event of a sale, merger, consolidation, change in control or transfer of substantial assets to a third party, we may transfer or assign to such acquiring third party information concerning your relationship with us, including without limitation, personal information that you have provided and other information concerning your relationship with us.
e. Legal Purposes
We may use your personal information in order to respond to subpoenas, court orders or as otherwise required by any law, regulation, legal process or government request or where we believe such action is necessary in order to detect, protect or defend us and/or other third parties against error, negligence, breach of contract, theft, fraud and other illegal or harmful activity, to comply with our audit and security requirements, and to audit compliance with or corporate policies, procedures, legal and contractual obligations.
PUBLIC (OR INTERACTIVE) AREAS OF THE WEBSITE
Information that you post on or through the public areas of our websites, if any (such as chat rooms, bulletin boards or discussion groups) are generally accessible to and may be collected by other parties. This may result in unsolicited messages or other unwelcome contact from third parties not related to us. Users of our websites are encouraged to exercise caution when providing personal information about themselves in public (or interactive) areas of our websites. We are not responsible for any unsolicited or unwelcome contact from third parties as a result of you providing any information in public (or interactive) areas of our websites.
YOUR CHOICES
a. Receiving Marketing Communications
We may be interested in sending you certain information (digitally or otherwise) regarding our products, services, promotions, or upcoming events that we believe may be of interest to you. You may unsubscribe from receiving marketing emails from us by clicking the “unsubscribe” link included at the bottom of every marketing email you receive from us. We try to honor your request to opt-out immediately, but it may take up to 10 business days for your request to go through.
b. Editing or Deleting Your Account Information and Preferences
You may request that we edit or delete your account information and preferences, by sending an e-mail to export@krugmann.com.
c. Privacy Rights Certain U.S. Residents
The laws in your state may give you the right to request the following: • To access to your personal information, including the categories of personal information we have collected, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, and the categories of third parties to whom we disclose personal information. • To correct inaccuracies in your personal information. • To delete your personal information that we have obtained. • To receive a copy of your personal information in a portable and readily usable format. • To opt in or opt out of certain types of sensitive personal information processing • To opt out of the sale of your personal information or the sharing of your personal information for targeted advertising purposes • To opt out of the processing of your personal information for purposes of automated decision-making or profiling in furtherance of decisions that produce a legal or similarly significant effect on you.
To exercise the above rights, you may submit your request by email at export@krugmann.com. You may also authorize another person to exercise these rights on your behalf. We will take steps to verify your identity and the identity of any agent (including to request proof of their authorization to act on your behalf) prior to reviewing certain requests. As part of this verification, we may ask that you provide personal information about you that we can use to compare with the information we maintain in our records.
When you submit your request, please: • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
The above rights are subject to various exclusions and exceptions under the law, and, under certain circumstances, we may be unable to implement your request. We will advise you of any reason for denying or restricting a request. We will not discriminate against you in any way if you choose to exercise your privacy rights.
Special Instructions for Opting of Targeted Advertising: To opt out of the sharing of your personal information for targeted advertising purposes, please adjust your cookie preferences as described in the Use of Cookies section below. You may also submit an opt-out request using a preference signal that is sent in a commonly used and recognized format, such as the Global Privacy Control.
YOUR CALIFORNIA PRIVACY RIGHTS
California residents have the right to receive the following additional disclosures under the California Consumer Privacy Act (CCPA):
a. Categories of Personal Information
We have collected in the preceding 12 months the categories of personal information detailed in the Information We Collect section above.
b. Sources of Personal Information
We have collected personal information from the categories of sources detailed in the Information We Collect section above.
c. Use and Disclosure of Personal Information
We have used and disclosed personal information for the business and commercial purposes detailed, respectively, in the How We Use Personal Information to the following categories of third parties listed in the How We Disclose Personal Information sections above. Specifically:
We may disclose personal information to the following categories of third parties: • Service providers with whom we have engaged to perform services on our behalf including for account management, providing customer service, processing orders, data security services, verifying information and collecting payment. • Affiliates, such as those in our portfolio of brands. • Public or governmental authorities, such as regulatory agencies, which may be required by law. • Marketing agencies and networks including platforms used for marketing services. • Data analytic providers such as companies that provide analytics of use of our websites and services.
We only use and disclose your sensitive personal information for the following purposes: • Performing services or providing goods reasonably expected by an average consumer • Detecting security incidents • Resisting malicious, deceptive, or illegal actions • Ensuring the physical safety of individuals • For short-term, transient use, including non-personalized advertising • Performing or providing internal business services • Verifying or maintaining the quality or safety of a service or device.
d. Sales and Sharing of Personal Information
We do not sell personal information, including the personal information of minors under age 16, except in the context of targeted advertising (to the extent that is considered a sale). When interacting with our website, we do share personal information with third parties for targeted advertising purposes.
e. Financial Incentives
From time to time, we may offer a financial incentive when you complete onboarding assessments, surveys, tracks, or other programs that ask you to share your feedback or other Personal Information with us. The specific instructions for how to participate in these programs and related incentives may vary and will be set out within each program. Our good-faith estimate of the value of your personal information is the value of the benefit we offer to you. We have calculated that value by using weighing our expense of operating the program against the benefit. Participation in these incentive programs is always optional, and you can terminate program participation at any time as explained in the applicable program terms. You can also contact us by using the contact information provided below to unsubscribe or cancel your program participation.
f. Privacy Rights
The CCPA grans California consumer the right to access, delete, correct, limit the use of sensitive personal information, and opt out of sales and sharing of their personal information as described above.
In addition, residents of California also have the right to request once per calendar year certain information with respect to the types of personal information (as defined by California law) we share with third parties for those third parties‘ direct marketing purposes, and the identities of the third parties with whom we have shared such information during the immediately preceding calendar year. You may contact us to request this information at export@krugmann.com
USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES
As is common with many websites, we may use “cookies” and “pixels” to help us gather and store information about visitors on this website. • A cookie is a small data file that our server sends to your browser when you visit the website. Cookies permit a website to, for example, recognize you each time you visit the website visits using that computer or device. • A pixel is a type of code or transparent graphics that contain a unique identifier. These technologies provide analytical information about the user experience and help us customize our marketing activities. In contrast to cookies, which are stored on a user’s computer hard drive, these technologies are embedded invisibly on web pages.
We use cookies, pixels, and similar tracking technologies to help us understand how you interact with our websites, to keep our websites secure, and to provide advertisements that are relevant to you. These technologies may also share data with third parties (including social media and AdTech companies) to help us track conversions, build custom audiences, and tailor our marketing campaigns.
a. Google Analytics
We use Google Analytics, a web analysis service provided by Google Inc. Google Analytics uses cookies to help us evaluate your use of our website, compile reports on website activity, and provide related services. You can prevent the installation of the Google Analytics cookie on your computer by downloading Google browser plug-in (available at HTTPS://TOOLS.GOOGLE.COM/DLPAGE/GAOPTOUT?HL=EN).
b. Interest-Based Advertising
You may see advertisements for our company or other companies and services on your devices, whether or not you are logged into your account. These ads may be targeted to you based on information that we, the advertiser, and/or other third parties have collected about your online behavior or interests. For example, if you view a product on our website, we may use that activity to show you an advertisement for that product, or a similar product, on other websites you visit. These ads are called interest-based or targeted ads.
We work with third parties, including advertising networks, to collect information about you, serve interest-based ads for us and others, and measure the ads’ effectiveness. For example, we engage third party services like Google Ad Manager to collect data and to deliver, personalize, and measure ads for the products we sell on our website. The advertisers and advertising networks’ use of tracking technologies and of the information collected through those technologies is covered by their own privacy notices.
c. Do Not Track
Do Not Track is a public-private initiative that has developed a “flag” or signal that an Internet user may activate in the user’s browser software to notify websites that the user does not wish to be “tracked” by third parties as defined by the initiative. Please note that this website, like many digital service operators, does not recognize or respond to “Do Not Track” signals.
d. Setting Preferences
You can delete cookies at any time or you can set your browser to reject or disable cookies. You may also opt out of interest-based advertising by companies who are part of the National Advertising Initiative by visiting their opt-out page.
EXTERNAL LINKS
Our website may include links to other websites whose privacy policies we do not control. Once you leave our servers (you can usually tell where you are by checking the URL in the location bar on your browser), use of any information you provide is governed by the privacy policy of the operator of the site you are visiting (unless otherwise stated). That policy may differ from ours. If you can’t find the privacy policy of any of these sites via a link from the site’s homepage, you should contact the site directly for more information.
If a consumer wants their data to be deleted, they may email export@krugmann.com.
TRANSFER OF INFORMATION TO THE UNITED STATES
When you are using our website from outside of the United States, your information will be transferred to, stored, and/or processed in the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. If you are located outside of the United States, the transfer of personal information may be necessary to provide you with the requested information and service and/or to perform any requested transaction. By using any portion of the Services, you acknowledge and consent to the transfer of your information to our facilities in the United States.
CHANGES TO THIS PRIVACY POLICY
We may amend this policy from time to time. If we make any substantial changes in the way we use your personal information we will notify you by posting a prominent announcement on our pages.
DRINK RESPONSIBLY
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