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Privacy Policy

Privacy Policy

Last Updated and Effective: June 26, 2023

INTRODUCTION

This Privacy Policy applies to websites, mobile applications and other interactive features and online services provided by Sazerac Company, Inc., a Louisiana corporation and/or one of its subsidiary or affiliated companies (“Sazerac,” “we,” or “us”) in the United States and that post a link to or include this Privacy Policy (collectively “Site” or “Sites”). Sazerac includes, without limitation, businesses operated under the following brand names: click here to visit the brands page. The goal of this Privacy Policy is to inform you about the data we gather about you, how we use and share that data, and how we safeguard that data. This Privacy Policy applies to data we collect through the Site and data we collect offline, which we may combine with online data. Please take a moment to review this Privacy Policy and our Terms of Use which govern your use of the Sites. Please note that certain features or services discussed in this Privacy Policy may not be offered on the Sites at any particular time.

By using this Site, you consent to our collection, use, and disclosure of data as described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy and the applicable Terms of Use, please do not access or use the services or provide personal data to us. By using this Site, you also certify that you are 21 years of age or above. If you are under 21 years of age, please leave the Site immediately.

TABLE OF CONTENTS

1.     Individuals Under 21 Years of Age

2.     Personal, Sensitive, and Non-Personal Data We Collect and How We Use and Disclose It

3.     Additional Details About Our Data Practices

    a.     Data Collected Automatically: Device ID/Interaction Information

            Location Data

            Cookies and Similar Technologies

            ·       Cookies and Local Storage

            ·       Web Beacons

            ·       Embedded Scripts

            ·       Data Collected through Mobile Devices and SDKs

            ·       Session Replay Technology

    b.     Data from Other Sources

    c.      Data You Provide Directly

            Chat

            Sweepstakes, Contests, & Promotions

            User Submissions

            Employment Applications

    d.     Disclosure of Data to Third Parties

            Third Parties Whose Features are Integrated into our Sites

            Sazerac Family of Companies

            Legal Requirements, Safety, and Loss Prevention, and other Business Purposes

            Business Transfers/Merged or Acquiring Entity

4.     Third Party Advertising and Analytics/Privacy Controls

5.     Your Choices

6.     Third Party Links and Content

7.     Data Security

8.     Consent to International Transfer

9.     Changes to this Privacy Policy

10.  Privacy Contact

11.  State Specific Rights

12.  California Privacy Notice


 

1.      Individuals Under 21 Years Of Age

This Site is intended only for adults who are at least 21 years of age, and does not knowingly collect data online from anyone who is under the age of 21. Please contact us via the instructions provided in the Contact Us section of this Privacy Policy if you believe this Site has collected data from anyone who is under 21 years of age.

2.     Personal, Sensitive, and Non-Personal Data We Collect and How We Use and Disclose It

We collect data from you directly, automatically when you interact with us via the Sites through cookies and other technologies, and sometimes from third parties. Some of this data may be considered ”personal information” or “personal data”, and some of which may be considered “sensitive”, under various applicable laws. We consider data that identifies you as a specific, identified individual (such as a user’s name, email address, or phone number) to be personal data. We will also treat additional data including IP addresses and cookie identifiers as “personal data” where required by applicable law.

Note that we may de-identify or pseudonymize personal data so that it is non-personal, such as by aggregating or converting it to a code, sometimes using a function commonly known as “hash”. We maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements. We will treat de-identified or pseudonymized data as non-personal to the fullest extent allowed by applicable law.

The following chart sets out the category of personal data collected (“Category”), the purposes for which the information is collected (“A. Purposes”), the categories of third parties to whom the information may be disclosed for a business purpose ("B. Disclosed To”), and the categories of third parties to whom the data may be sold for monetary value or other valuable consideration or shared for cross context behavioral advertising/targeted advertising (“C. Sold/Shared To”).

Please also see the “Additional Details About Our Data Practices” section below the chart for additional information on certain types of personal data collection and use.

 

Category of Data

A. Purpose for Collection

B. Categories of Third Parties the Data is Disclosed To

C. Third Parties to whom the Data is Sold/Shared for Targeted Advertising

 

Contact Information

This may include your first and last name, phone number, email address, and mailing address.

 

A. Purposes for Collection:

(1) Provide you the Sites (to process and fulfill transactions and fulfill your orders; respond to your inquiries and send you information you have requested, including to process orders and deliveries; administer your participation in sweepstakes, contests, surveys, and promotions; permit you to submit reviews and testimonials; facilitate your access to the Sites; register and service your personal account; provide customer support and to alert you about product information, including recalls; to verify your identity);

(2) Advertising Activities and Marketing Messages (to send you offers and promotions from us, our advertisers, and third-party partners online and offline);

(3) Personalization (to tailor and personalize the Sites, including our content, recommendations, and offers to you; identify your preferences); (4) Administrative (to communicate with you regarding your use of the Sites, content, features, or products you use and updates to our policies; provide you access to Wi-Fi service at our locations or events);

(5) Internal Business Purposes (to operate the Sites; improve our products and services; facilitate your job application;  detect and troubleshoot problems; analyze trends and usage patterns; market research);

(6) Legal (to resolve disputes; enforce our agreements and policies; cooperate with government or other legal inquiries, including investigation on public safety matter or investigation into claims of intellectual property; fulfill regulatory reporting obligations; protect our or others’ rights/assets);

(7) Security (to protect the Sites; investigate, detect, prevent, and protect against issues of our systems, fraud, crime, or other activities that violate our policies or applicable laws; to protect the health and safety of our users or the general public);

(8) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence);

(9) Other Purposes as Disclosed at the time of collection or with your consent.

B. Categories of Third Parties the Data Is Disclosed to: 

(1) Third Party Advertising and Analytics Providers (such as advertising and analytics companies);

(2) Technology Systems Service Providers (such as webhosts, database hosts, cloud computing providers, software-as-a-service providers, third-party developers, and technology maintenance and repair vendors);

(3) Social Media and Other Third Party Platforms;

(4) Order Fulfillment Vendors (such as payment processors, fulfillment centers, delivery services, order tracking vendors);

(5) Communication Services Providers (such as email delivery vendors and chat agents);

(6) Sweepstakes/Contest Partners (such as administrators, other prize providers, and prize fulfillment vendors);

(7) Government Agencies and Law Enforcement/Where Required by Law  (including third parties in connection with a court or other legal proceeding);

(8) Security Vendors;

(9) Affiliated Companies and Brands;

(10) third parties in the course of Business Transitions;

(11) third parties to whom you agree or direct us to share your data;

(12) other service provider who solely use your data to provide services to us or to you.

C. Categories of Third Parties to Whom the Data is Sold/Shared for Targeted Advertising: 

(1) Third Party Advertising and Analytics Providers (such as advertising and analytics companies

 

Payment and Financial Information

This may include your credit card number, billing address, or other payment card data.

A. Purposes for Collection:

(1) Provide You the Sites (to process transactions and fulfill your orders; provide customer service);

(2) Administrative (to verify your identity);

(3) Security (to detect and protect against misuse of our systems, fraud, or other crime);

(4) Internal Business Purposes (to operate our Services; detect and troubleshoot problems; conduct sales auditing);

(5) Legal (to resolve disputes; enforce our agreements; comply with our contractual obligations; cooperate in governmental or other legal inquiries; fulfill regulatory reporting obligations);

(6) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence);

(7) Other Purposes as Disclosed at the time of collection/ with your consent

B. Categories of Third Parties the Data Is Disclosed to: 

(1) Order Fulfillment Vendors (such as payment processors, fulfillment centers, order tracking, delivery service);

(2) Technology Systems Service Providers;

(3) Security Vendors;

(4) Communications Service Provider (such as customer support);

(5) Government Agencies and Law Enforcement/Where Required By Law (including third parties in connection with a court or other legal proceeding);

(6) Affiliated Brands;

(7) third parties in the course of Business Transitions;

(8) third parties whom you otherwise agree or direct us to share your data;

(9) other service providers who solely use your data to provide services to us or to you.

C. Categories of Third Parties Data is Sold/Shared for Targeted Advertising to:

This category of data is not sold or shared for targeted advertising.

 

Device ID/Interaction Information

This may include details about the device you use the access the Sites, such as website browser, operating system, the URL or advertisement that referred you to the Sites, search terms entered into a search engine that led you to the Sites, the next website you visit after leaving the Sites, and IP address.

 

A. Purposes for Collection:(1) Provide you the Sites (to process and fulfill transactions and fulfill your orders; permit you to navigate the Sites and facilitate your access to the Sites and connect to our services; facilitate your participation in sweepstakes/contests; permit you to post reviews; provide customer support; to verify your identity; recognize you across the services and devices);

(2) Advertising Activities and Marketing Messages (to send you offers and promotions from us, our advertisers, and third-party partners online and offline);

(3) Personalization (to tailor and personalize the Sites, including our content, recommendations, and offers to you; identify your preferences);

(4) Administrative (to communicate with you regarding your use of the Sites, content, or features; provide you access to Wi-Fi service at our locations or events);

(5) Internal Business Purposes (to operate the Sites; improve our products and services; facilitate your job application;  detect and troubleshoot problems; analyze trends and usage patterns; market research);

(6) Legal (to resolve disputes; enforce our agreements and policies; cooperate with government or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights/assets);

(7) Security (to investigate, detect, prevent, and protect against issues of our systems, fraud, crime, or other activities that violate our policies or applicable laws);

(8) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence);

(9) Other Purposes as Disclosed at the time of collection or with your consent

B. Categories of Third Parties the Data Is Disclosed to: 

(1) Third Party Advertising and Analytics Providers (such as advertising and analytics companies);

(2) Technology Systems Service Providers (such as webhosts, database hosts, cloud computing providers, software-as-a-service providers, third-party developers, and technology maintenance and repair vendors);

(3) Social Media Platforms;

(4) Order Fulfillment Vendors (such as payment processors, fulfillment centers, delivery services, order tracking vendors);

(5) Communication Services Providers;

(6) Sweepstakes/Contest Partners (such as administrators, other prize providers, and prize fulfillment vendors);

(7) Security Vendors;

(8) Government Agencies and Law Enforcement/Where Required by Law (including third parties in connection with a court or other legal proceeding);

(9) Affiliated Companies and Brands;

(10) third parties in the course of Business Transitions;

(11) third parties to whom you agree or direct us to share your data;

(12) other service provider who solely use your data to provide services to us or to you.

C. Categories of Third Parties to Whom the Data is Sold/Shared for Targeted Advertising: 

(1) Third Party Advertising and Analytics Providers (such as analytics companies)

 

Precise/Specific Location Data

Such as longitude/latitude coordinates from a global positioning system (GPS).

 

A. Purposes for Collection: 

(1) Provide you the Sites (to locate products; process transactions and fulfill your orders; facilitate your access to the Sites and connect to our services);

(2) Advertising Activities and Marketing Messages (to tailor content recommendations we display to you);

(3) Personalization (to tailor the Sites and related content, recommendations, and offers based on your location);

(4) Internal Business Purposes (to operate the Sites; improve our products and services; detect and troubleshoot problems);

(5) Legal (to resolve disputes; enforce our agreements and policies; cooperate with government or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights/assets);

(6) Security (to investigate, detect, prevent, and protect against issues of our systems, fraud, crime, or other activities that violate our policies or applicable laws);

(7) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence);

(8) Other Purposes as Disclosed at the time of collection or with your consent

B. Categories of Third Parties the Data Is Disclosed to: 

(1) Government Agencies and Law Enforcement or Where Required by Law;

(2) Technology Systems Service Providers (such as webhosts, database hosts, cloud computing providers, software-as-a-service providers, third-party developers, and technology maintenance and repair vendors);

(3) Security Vendors;

(4) third parties in the course of Business Transitions;

(5) third parties to whom you agree or direct us to share your data;

(6) other service providers who solely use your data to provide services to us or to you

C. Categories of Third Parties Data is Sold/Shared for Targeted Advertising to:

This category of data is not sold or shared for targeted advertising.

 

Photo/Video Data and Other User Generated Content

This may include photos you upload when submitting reviews or in connection with a contest, sweepstakes, or other promotion. It may also include information you disclose in connection with a chat.

A. Purposes for Collection: 

(1) Provide You the Sites (to permit you to post reviews; provide you customer support and respond to your inquiries; to send you information you have requested; to facilitate your participation in promotions);

(2) Internal Business Purposes (to improve our products and services; detect and troubleshoot problems)

(3) Legal (to cooperate in governmental or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights/assets);

(4) Security (to investigate, detect, prevent, and protect against misuses of our systems, fraud, crime, or other illegal activities or activities that violate our policies);

(5) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence);

(6) Other Purposes as Disclosed at the time of collection/ with your consent.

B. Categories of Third Parties the Data Is Disclosed to: 

(1) Social Media Platforms;

(2) Government Agencies and Law Enforcement / Where Required by Law (including third parties in connection with a court or other legal proceedings);

(3) Affiliated Brands;

(4) Order Fulfillment Vendors (such as fulfillment centers, delivery services, order tracking vendors);

(5) Technology Systems Service Providers (such as webhosts, database hosts, cloud computing providers, software-as-a-service providers, third-party developers, and technology maintenance and repair vendors);

(6) Sweepstakes/Contest Partners (such as administrators, other prize providers, and prize fulfillment vendors);

(7) Security Vendors;

(8) third parties in the course of Business Transitions;

(9) third parties to whom you agree or direct us to share your data;

(10) other service providers who solely use your data to provide services to us or to you.

C. Categories of Third Parties Data is Sold/Shared for Targeted Advertising to:

This category of data is not sold or shared for targeted advertising.

 

Transaction Information

This may include data about the products you purchase, returns/exchanges, customer service contacts, and sweepstake or contest participation.

A. Purposes for Collection: 

(1) Provide You the Sites (to process transactions and fulfill your orders; send order and account related communications such as receipts and confirmations; respond to your inquiries and send you information you have requested; permit you to post reviews; provide customer service);

(2) Administrative (to verify your identity; contact you regarding your use of the Services and your purchases);

(3) Internal Business Purposes (to improve our products and services; detect and troubleshoot problems; analyze trends and usage patterns; market research);

(4) Advertising Activities and Marketing Messages (to send you special deals, offers, and information from us and third parties online and offline);

(5) Internal Business Purposes (to provide and improve our products and services; detect and troubleshoot problems; analyze the effectiveness of our marketing efforts; analyze trends and usage patterns; market research);

(6) Legal (to resolve disputes; enforce our agreements and policies; cooperate in governmental or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights/assets);

(7) Security (to investigate, detect, prevent, and protect against misuses of our systems, fraud, crime, or other illegal activities or activities that violate our policies);

(8) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence);

(9) Other Purposes as Disclosed at the time of collection/ with your consent.

B. Categories of Third Parties the Data Is Disclosed to: 

(1) Order Fulfillment Vendors (such as payment processors, fulfillment centers, delivery services, order tracking vendors);

(2) Technology Systems Service Providers (such as webhosts, database hosts, cloud computing providers, software-as-a-service providers, third-party developers, and technology maintenance and repair vendors);

(3) Government Agencies and Law Enforcement / Where Required by Law (including third parties in connection with a court or other legal proceedings);

(4) Affiliated Brands;

(5) Sweepstakes/Contest Partners (such as administrators, other prize providers, and prize fulfillment vendors);

(6) Security Vendors;

(7) third parties in the course of Business Transitions;

(8) third parties to whom you agree or direct us to share your data;

(9) other service providers who solely use your data to provide services to us or to you.

C. Categories of Third Parties Data is Sold/Shared for Targeted Advertising to:

This category of data is not sold or shared for targeted advertising.

 

User Account Information

This may include information such as username, password, communication preferences, and account settings.

 

A. Purposes for Collection: 

(1) Provide You the Sites (to create and manage your account; identify you across devices; process transactions and fulfill orders; send account related communications; facilitate your access to the Sites and connect to the services);

(2) Administrative (to verify your identity when you create an account);

(3) Internal Business Purposes (to improve our products and services; detect and troubleshoot problems);

(4) Personalization (to understand your preferences and tailor content);

(5) Legal (to resolve disputes; enforce our agreements and policies; cooperate in governmental or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights/assets);

(6) Security (to investigate, detect, prevent, and protect against misuses of our systems, fraud, crime, or other illegal activities or activities that violate our policies);

(7) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence);

(8) Other Purposes as Disclosed at the time of collection/with your consent.

B. Categories of Third Parties the Data Is Disclosed to: 

(1) Technology Systems Service Providers (such as webhosts, database hosts, cloud computing providers, software-as-a-service providers, third-party developers, and technology maintenance and repair vendors);

(2) Security Vendors;

(3) Government Agencies and Law Enforcement or Where Required by Law;

(4) Affiliated Brands;

(5) third parties in the course of Business Transitions;

(6) third parties to whom you agree or direct us to share your data;

(7) other service providers who solely use your data to provide services to us or to you.

C. Categories of Third Parties Data is Sold/Shared for Targeted Advertising to:

This category of data is not sold or shared for targeted advertising.

 

 

Information About Your Interests and Preferences

This may include information such as information derived from interactions with the Sites, including when you leave reviews.

 

A. Purposes for Collection:

(1) Advertising Activities and Marketing Messages (to send you offers and information from us or third parties online and offline);

(2) Internal Business Purposes (to improve our products and services, including to analyze trends and usage patterns; detect and troubleshoot problems; analyze the effectiveness of our marketing efforts; market research);

(3) Personalization (to tailor content to you);

(4) Administrative (to contact you regarding your use of the Services, content, features, or products you use or request);

(5) Legal (to resolve disputes; enforce our agreements and policies; cooperate in governmental or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights/assets);

(6) Security (to investigate, detect, prevent, and protect against misuses of our systems, fraud, crime, or other illegal activities or activities that violate our policies);

(7) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence);

(8) Other Purposes as Disclosed at the time of collection/ with your consent.

B. Categories of Third Parties the Data Is Disclosed to: 

(1) Third Party Advertising and Analytics Partners;

(2) Government Agencies and Law Enforcements / Where Required by Law (including third parties in connection with a court or other legal proceedings);

(3) Order Fulfillment Vendors;

(4) Technology Systems Service Providers;

(5) Security Vendors;

(6) Communication Services Providers;

(7) Affiliated Brands;

(8) Social Media Companies;

(9) third parties in the course of Business Transitions;

(10) third parties to whom you agree or direct us to share your data;

(11) other service providers who solely use your data to provide services to us or to you.

C. Categories of Third Parties to Whom the Data is Sold/Shared for Targeted Advertising: 

(1) Third Party Advertising and Analytics Partners;

(2) Social Media Companies.

 

Demographic Data

This may include your age, date of birth, gender, income, nationality.

A. Purposes for Collection: 

(1) Provide You the Sites (to permit access to the Sites; process transactions and fulfill your orders; facilitate your participation in sweepstakes, contests, research);

(2) Personalization (to tailor content, recommendations, and offers we display to you, including advertisements in our content and elsewhere online);

(3) Administrative (to verify your identity);

(4) Advertising Activities and Marketing Messages (to send you special offers, invites, and similar information from us or third parties);

(5) Internal Business Purposes (to provide and improve our products and services; detect and troubleshoot problems; analyze trends and usage patterns);

(6) Security (to detect and protect against misuse of our systems, fraud, or other crime);

(7) Legal (to resolve disputes; enforce our agreements and policies; cooperate with government or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights/assets);

(8) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence);

(9) Other Purposes as Disclosed at the time of collection/with your consent.

B. Categories of Third Parties the Data Is Disclosed to: 

(1) Technology Systems Service Providers;

(2) Security Vendors;

(3) Communication Services Providers (such as chat agents);

(4) Order Fulfillment Vendors;

(5) Sweepstakes/Contest Partners (such as administrators, other prize providers, and prize fulfillment vendors);

(6) Government Agencies and Law Enforcement / Where Required By Law (including third parties in connection with a court or other legal proceedings);

(7) Affiliated Brands;

(8) third parties to whom you agree or direct us to share your data;

(9) third parties in the course of Business Transitions;

(10) other service providers who solely use your data to provide services to us or to you.

C. Categories of Third Parties to Whom the Data is Sold/Shared for Targeted Advertising: 

This category of data is not sold or shared for targeted advertising.

 

Government Identification

Such as your driver’s license and similar government issued identification.

A. Purposes for Collection:

(1) Provide you the Sites (to verify your age and residency in connection with your purchases; process a transaction);

(2) Administrative (to verify your identity);

(3) Internal Business Purposes (to comply with legal obligations; detect and troubleshoot problems);

(4) Legal (to resolve disputes; enforce our agreements and policies; cooperate in governmental or other legal inquiries; fulfill regulatory reporting obligations; protect our or others’ rights/assets);

(5) Security (to  investigate, prevent, and detect, and protect against misuse of our systems, fraud or other crime or illegal activities, or activities that violate our policies);

(6) Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, affecting all or part of our assets, including during due diligence);

(7) Other Purposes as Disclosed at the time of collection/ with your consent.

B. Categories of Third Parties the Data Is Disclosed to: 

(1) Affiliated Brands;

(2) Order Fulfillment Vendors (such as payment processors);

(3) Technology Systems Service Providers;

(4) Security Vendors;

(5) Government Agencies and Law Enforcement/Where Required by Law;

(6) third parties in the course of Business Transitions;

(7) third parties to whom you agree or direct us to share your data;

(8) other service providers who solely use your data to provide services to us or to you.

C. Categories of Third Parties Data is Sold/Shared for Targeted Advertising to:

This category of data is not sold or shared for targeted advertising.

 

 

3.     Additional Details About Our Data Practices

We provide in this section additional detail about the information practices listed in the chart above, where it would be helpful for your understanding of such practices.

a.     Data Collected Automatically: Device ID/Interaction Information.  We and our third party service providers and other business partners may receive and store certain types of data using a variety of technologies that automatically or passively collect certain data when you interact with our Site, our emails, and our online advertisements (“Device ID/Interaction Information”). Device ID/Interaction Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we will treat it as personal data. Device ID/Interaction Information may include, but is not limited to:

·       Device Information, including device model, operating system and browser type you are using.

·       How you use and interact with the Sites, including your search terms, the path you take through pages you view on our Site, among other data.

·       Your IP address or other unique identifier for your computer, mobile phone, or other device used to access the Site.

·       Your non-precise (approximate) location. We may also infer your non-precise location through data we collect, such as your IP address.

Location Data. We may automatically collect data about your precise location when your mobile device is set to provide location data. For example, your device may allow us to show you the location of the retail store that offers Sazerac products that is closest to your location. We may also be able to recognize the location of your device in locations where we provide free WiFi access. Our mobile applications and services may also collect precise data about the location of your device through your device before our mobile applications and services obtain such location data from technologies like GPS, Wi-Fi, or cell tower proximity (or a combination of these technologies). Sazerac and our service providers may use and store this data, in combination with other location-based data such as IP address and billing or postal code provided by you at time of your mobile application registration, to provide enhanced location-based services, such as search results and other content.

Please see the “Your Choices” section of this Privacy Policy for more information.

Cookies and Similar Technologies. We may use the following tracking technologies to collect Device ID/Interaction Information:

Cookies and Local Storage.  Cookies and local storage are pieces of data (small text file) that a website or email may save to your browser and store on your hard drive, computer, tablet or smartphone. We may use “cookies” and similar technologies to recognize you as you use or return to the Site. These technologies may be used for many purposes by us and our third party partners, such as automatically collecting Device ID/Interaction Information, enabling features, and remembering your preferences, ultimately to allow us to provide a continuous and more personalized experience for you. You can find more information about cookies and how they work at www.allaboutcookies.org. Certain browsers or browser add-ons may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our Site makes use of this local storage. You can also adjust your cookie preferences by using our cookie management tool, which can be accessed by clicking the link in our footer titled “Cookie Settings”.

Web Beacons. Small graphic images or other web programming called web beacons (also called pixel tags or clear gifs) may be included on our web pages and email messages. Web beacons and similar technologies may be used for a number of purposes, including to allow us to count visitors to the Site, monitor how users interact with the Site, to know if a certain page was visited, an email was opened, or if ad banners on our Site and other sites were effective.

Embedded Scripts. An embedded script is programming code that is designed to collect data about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.

Data Collected Through Mobile Devices and Software Development Kits (SDKs). SDKs are a software package that contains a set of tools that can be used to help build applications and implement new features in existing apps. These tools can be used to create and operate features that collect data from your device.  We use embedded scripts and the tools provided in SDKs to collect data from mobile devices such as the hardware model, operating system and version, identification numbers assigned to your mobile device, such as the ID for Advertising (IDFA) on Apple devices, and the Advertising ID on Android devices, mobile network data, and website usage behavior.

Session Replay Technology. Sazerac may record through session replay technology your interactions with the Sites, including what pages you visit on the Sites, how long you visit those pages, the links you click, and your path through the Sites. We use this information for our internal business purposes, such as for website analytics purposes, to address functionality issues, and to improve the Sites and our products and services.

In addition, we may use a variety of other technologies that collect similar data for mobile application push messages, security, fraud detection, and maintenance purposes.

b.     Data from Other Sources. We also may collect data about you from third party sources.

The data we collect from third party sources may include things like demographic data and purchase preference data. The third party sources may include public databases, social media pages, joint marketing partners, data append services, data sharing cooperatives and others, for various purposes, such as to provide you with information, services, or enhance our services.

We may the combine data we receive from third parties with data we collect through the Site. In those cases, we will apply this Privacy Policy to the combined data.

c.     Data You Provide Directly. We may ask you to provide data to us when you use the Sites, for example, in the following ways:

Chat. When you participate in any chat feature Sazerac may provide, Sazerac can record and use your communications and the data you provide in order to assist you during the chat session, and provide customer support, to improve our products and services, and for marketing purposes. If you do not consent, please do not continue with chat assistance.

Sweepstakes, Contests, & Promotions. We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern that Promotion, which may contain specific requirements of you (including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, personal data may be disclosed to third parties (including, without limitation, a co-sponsor) or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s terms or official rules (such as on a winners list).

User Submissions. The Sites may provide you the opportunity to submit data to us, including stories, testimonials, ratings, reviews, or other content to the Site for possible posting on the Site (“User Submissions”) (which means any and all data and content that you submit or post to the Sites, including, without limitation, photos, audio, video, messages, text, files, or other content you provide us and as further described in our Terms of Use).  If you submit User Submissions, we may publish that data or content online or offline, including in connection with our advertising, marketing, publicity, and promotional activities, as further described in our Terms of Use.

Photos and Videos.   We allow you to post photos and videos on the Sites or to submit them to us as described in the chart above.  Applicable laws and regulations may vary with respect to whether such materials are considered to be biometric information.  For clarity, Sazerac does not create a record of facial geometry from your photos or videos, and does not use your photos or videos for the purposes of facial recognition, facial surveillance, or otherwise as a biometric identifier.  Please note, however, that to the extent that you post your photos or videos publicly on our Sites, or we share – as described elsewhere in this Privacy Policy – such materials with third parties who are permitted to use these materials in accordance with their own privacy policies, we do not control the actions of third parties, and their use of your photos or videos may differ from ours.

Employment Applications. If you apply for a job with Sazerac or any of our subsidiaries or affiliates, we or our service provider(s) may ask you to provide self-identifying data (such as veteran status, gender, and ethnicity) in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission and other federal, state and local regulatory agencies. Providing such self-identifying data is voluntary, but if you do provide such data, we and/or our service providers may submit that data to the appropriate government or regulatory agencies to fulfill reporting requirements and use that data to defend against employment-related complaints.

d.    Disclosure of Data to Third Parties. We may share non-personal data that we collect, such as certain Device ID/Interaction Information, aggregate user statistics, and hashed or otherwise de-identified or pseudonymized data (including email addresses), and/or our analyses derived from such data, with third parties in our discretion, including for targeted advertising purposes, in accordance with applicable law. We share personal data as disclosed when you provide it, with your consent, and as described in this Privacy Policy. However, we do not share personal data with unaffiliated third parties for their own marketing purposes without giving you the chance to consent (opt-in or where permitted by law, opt-out).

Please note that we are not responsible for the privacy practices of any third party. If you decide that you do not want to receive communications from a third party, or have questions about their privacy practices, you will need to contact that third party directly.

Third Parties Whose Features are Integrated into our Sites. Sazerac may use third party service providers to perform operational or other support services for us or on our behalf, such as direct mail vendors, shipping service providers, and otherwise improve our product and service offers and our Site. We give these third parties access to your personal data (or allow them to collect information from or about you) so that they can provide the services.  We may also share your personal data with those third parties in connection with your accessing those features and content – such as for purposes of website hosting, conducting website usage analytics, sending email, text, or other communications, fulfilling orders, providing marketing assistance and data analysis, processing payments, and other services. For example, if you apply for a job with Sazerac or any of our subsidiaries or affiliates, we may utilize a careers portal that is operated by a third party, in which case your use of the careers portal will be subject to the third party’s privacy practices as disclosed on the portal, and not to this policy. Additionally, we may share various information relating to our users and fraudulent or potentially fraudulent activities with our fraud prevention and similar service providers, and they will use this information to help us and their other clients prevent fraudulent and illegal transactions.

Your direct interactions with a third party are subject to their privacy policy and terms of use. When you choose to connect certain third party services or applications with our Sites, data collected by the third party may be shared with us in connection with the integration and treated consistently with this Privacy Policy. We may combine data about you that we have with data we obtain from these third parties. In those cases, we will apply this Privacy Policy to the combined data. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly. In addition, unless otherwise disclosed to you, our service providers are not authorized to use or disclose your personal data for their own marketing purposes.

Sazerac Family of Companies. Sazerac includes several brands and companies, some of which operate as subsidiaries, affiliates, or joint ventures. When Sazerac collects data from one of our Sites, it will be accessible across the Sazerac family of brands and companies. The data will be used for business, operational, and marketing purposes.

Legal Requirements, Safety, and Loss Prevention, and other Business Purposes. Sazerac may disclose your personal data in other special circumstances. For example, we may provide personal data about you to regulatory authorities and law enforcement officials in accordance with applicable law, when we otherwise believe in good faith that the law requires it, or to respond to requests from government authorities. There may be instances when we may use or disclose your personal data in order to protect or defend the legal rights, property or operations of Sazerac or our employees or agents; to protect the rights, privacy, safety or security of users, members or others; to protect against fraud; and to allow us to pursue available remedies or limit the damages that we may sustain. We may also use Device ID/Interaction Information to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers, or law enforcement agencies, in our discretion.

Business Transfers/Merged or Acquiring Entity. Data about our users and the Site are a business asset of Sazerac. Therefore, data about our users, including personal data, may be disclosed or transfer without your further consent as part of any corporate restructuring or stock sale or other change in corporate control, including a merger or acquisition, creation of a separate business to provide use of the Site; debt financing, sale or pledge of company assets, insolvency, bankruptcy or receivership in which personal data would be transferred as one of Sazerac’s business assets, or other transaction (including, without limitation, during the course of any due diligence process). By providing your personal data, you agree that we may transfer such data to the acquiring entity without your further consent, except where required by law.

4.     Third Party Advertising and Analytics/Privacy Controls

Sazerac may participate in interest-based advertising. In doing so, we may use third-party business partners, such as network advertisers, ad agencies, and other advertising partners to display ads tailored to your individual interests through our Sites and elsewhere online based on how you browse and shop online.

We also use analytics providers to provide us with information regarding the use of Sites and the effectiveness of our advertisements. These third parties may set and access their own tracking technologies on your device (including cookies and web beacons) and they may otherwise collect or have access to data about you, some of which may be personal information or personal data under various state laws. We and our third party advertising and analytics providers may collect personal data over time when you visit the Sites or other online websites and services.

These companies may use data such as click stream data, browser type, time and date, subject of advertisements clicked or scrolled over, hardware/software data, cookie/session ID, and IP address, during your visits to this Site and other websites. We may also share (or permit third parties to collect) certain data, such as Device ID/Interaction Information, aggregated or de-identified, pseudonymized or hashed data (including email addresses), with these third parties for similar purposes.

If you would like to opt-out of third party advertising and analytics, there are a variety of tools available to you:

Our Tools. To disable sharing through cookies set on our site by third parties for advertising and analytics purposes, please adjust your settings by clicking here. Certain jurisdictions provide their residents further rights, please see State Specific Rights below regarding additional rights you have.

Do Not Track. Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and/or other web services you encounter while browsing to stop tracking your activity. To find out more about and set up “Do Not Track”, please visit www.allaboutdnt.com.

Global Privacy Control. Global Privacy Control (“GPC”) is a technical specification in your browser settings that you can use to automatically inform websites of your privacy preferences with regard to third party online tracking.  To find out more about and set up GPC, please visit here.

NAI/DAA Opt-Out. As explained above, Sazerac participates in online interest-based advertising. Some of the companies we use may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”). The NAI provides information regarding targeted advertising and the opt-out procedures of NAI members, including opt-out mechanisms for web browsers, mobile and other connected devices, and a tool to opt out from participating NAI members using your hashed email address for interest-based advertising. You may also want to visit the DAA's website, which provides information regarding targeted advertising and offers an opt-out for DAA-participating companies. . Please note that the NAI opt-out mechanism relies on cookies to remember your choices with respect to ad-serving on websites. If you delete your cookies, use another computer or device, or change browsers, you will need to repeat the opt-out process.

Google Analytics and Adobe Analytics. We also use Google Analytics and Adobe Analytics, which use cookies and similar technologies to collect and analyze data about use of the Sites and report on activities and trends. These services may also collect data regarding the use of other websites, apps, and online services. You can learn about Google’s practices by going to google.com/policies/privacy/partners, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at tools.google.com/dlpage/gaoptout. More information about Adobe Analytics and links to Adobe Analytics’ Privacy Policy and an opt-out tool for Adobe Analytics, available at: http://www.adobe.com/privacy/analytics.html.

If you do opt-out of interest-based advertisements, you may still see advertisements on websites you visit, but those ads will not be based on your browsing behavior. Your opt-out choices are browser and device specific; if you disable your cookies or upgrade your browser after opting out, or if you use different computers or browsers, you will need to indicate your opt-out choices across those other computers and browsers.

5.     Your Choices

Marketing Communications from Us.

Emails. If you would like to opt out of our promotional emails, please follow the unsubscribe link at the bottom of each such email.

Direct Mail. If you would like to opt out of receiving direct mail from us, please do so by emailing Privacy@Sazerac.com. Please put OPT-OUT in the subject line and provide us your name and mailing address.

Please be aware that, even if you opt out of receiving marketing communications from us, we reserve the right to send you certain communications relating to your account or use of the Sites (for example, order confirmations, responses to communications we receive from you, service notices, or recalls) and these transactional account messages may be unaffected if you opt-out from marketing communications.

Opt-Out of Location Data Collected Through Mobile Application.  Users of our mobile applications and services may use the following mechanisms to opt-out of the collection and use of your precise location data:

·       You can stop all collection of data by our mobile applications by uninstalling the mobile application. You may use the standard uninstall processes available as part of your mobile device or via the mobile application marketplace or network. If you uninstall a mobile application from your device, the Sazerac unique identifier associated with your device may continue to be stored. If you re-install the application on the same device, Sazerac will be able to re-associate this identifier to your previous transactions.

·       You may at any time opt-out from further allowing us to have access to your location data by adjusting the permissions on your mobile device. However, please note that we may still be able to collect or infer your approximate location through other data we collect, such as IP address. In addition, some mobile service providers may provide us or our third party service providers with data regarding the physical location of the device used to access the Sites.

Data Privacy Choices. If you would like to change or delete your account data from the Site, please do so by emailing Privacy@Sazerac.com. Please put ACCOUNT INFORMATION in the subject line and provide us your account information and instructions on the data that you want changed or deleted. Please note that, while we will do our best to address requests to change or delete your account data, we may be unable to delete all information associated with past communications or transactions.  Please be sure to include your full name, phone number, email address, the types of communications you would like to receive or not receive, and all relevant contact data in any communication you send to us. For example, if you would like to opt-out of receiving direct mail, please make sure to include your mailing address in your communication to us. Please allow a reasonable time for your preferences to be processed. It may take up to 10 days to process your requests related to email and up to 30 days to process other requests.

You may have additional specific rights depending on where you are a resident, please see State Specific Rights section, below.

6.     Third Party Links And Content

The Site may link to or incorporate websites or content hosted and served by third parties over which we have no control and which are governed by the privacy policies and business practices of those third parties. Sazerac is not responsible for the privacy practices or business practices of any third party.

7.      Data Security

Sazerac employs commercially reasonable and appropriate physical, administrative, and technical controls to protect your personal data. While we work very hard to protect your privacy, no data transmission over the internet, wireless transmission, or electronic storage of data is guaranteed to be 100% effective or secure, and Sazerac cannot guarantee that the Internet or mobile device will be completely secure and cannot warrant or ensure the security of any data we collect. Sazerac also cannot be responsible for the actions of those who may gain unauthorized access to your personal data. We make no warranties, express, implied or otherwise, as to the ultimate effectiveness of our reasonable and appropriate safeguards. You are also responsible for taking reasonable steps to protect your personal data against unauthorized disclosure or misuse. You use our Sites and provide us data at your own risk.

8.     Consent to International Transfer

This Site is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your personal data may be stored and processed in the United States or any other country in which Sazerac or its service providers maintain facilities. Visitors who use the Sites and reside outside the United States do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. By using this Site, you consent to the transfer of data to countries outside of your country of residence, including the United States, which may have different data protection rules than in your country and may not provide the same level of protection as the laws of your country.

9.     Changes To This Privacy Policy

We may change or add to this Privacy Policy without prior notice to the extent allowed by applicable law, so we encourage you to review it periodically. We will notify you of material changes by posting the updated Privacy Policy on the Sites. We may also provide notice to you in other ways, such as through contact data you have provided. Any changes will be effective immediately unless otherwise specified. The top of this Privacy Policy identifies the date the Privacy Policy was last updated. Your continued use of any of the Sites after the effective date of the revised Privacy Policy will constitute your consent to those changes to the fullest extent allowed by applicable law.

10.  Privacy Contact

If you have any questions about this Privacy Policy or how your personal data is handled, please contact us by sending a letter to:

Sazerac Company
Attn: Compliance Department
10101 Linn Station Road, Suite 400
Louisville, KY 40223

You may also contact us by email through the Contact Us link info@sazerac.com on our Site.

11.   State Specific Rights

Residents of certain U.S. states may have the ability to exercise additional rights and choices regarding their personal data. We will take reasonable steps to accommodate your request, but may need to verify your identity before doing so. Please see additional information below.

·       Colorado, Connecticut, Utah, and Virginia. We set forth above the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared. Residents of Virginia, Colorado, Connecticut, and Utah have certain privacy rights with respect to this data, as described below.  If you are a Consumer residing in one these states (as defined in each state’s respective law) and would like to exercise your applicable rights, please complete this form or call 866.729.3722 to submit a request.

Access Your Information/Data Portability (CO, CT, UT, VA Residents) - To confirm whether we are processing your personal data and request to access such data, please complete the form. This includes to obtain a copy of the personal data previously provided by you to us and, to the extent feasible, in a readily usable format to allow data portability.

Delete Your Information (CO, CT, UT, VA Residents) – Request to delete your personal data.

Correct Your Information (CO, CT, VA Residents) – Correct the personal data we hold about you.

Opt-Out of Targeted Advertising – Sazerac engages in online advertising practices (and certain analytics or similar activities) that may be considered “targeted advertising” under these states’ laws. To opt out of certain tracking cookies set by third parties that may be considered targeted advertising under such laws, please modify your cookie settings by clicking on the link titled “Cookie Settings” on the footer of our Sites. Please also review the Third Party Advertising and Analytics section above for information on industry tools and device settings that may be available to you.

Opt-Out of Sales of Your Personal DataSazerac may sell your data as defined by CO and CT. To opt-out of the sales of your personal data please complete this form.

Right to Appeal (CO, CT, VA Residents) - If, for any reason, you would like to appeal our decision relating to your request and you are a resident of Colorado, Connecticut, or Virginia, you have the right to submit an appeal and can do so by submitting this form this form or calling 866.729.3722. Please include your full name, the basis for your appeal, and any additional information to consider.

Sensitive Data – If you are a Virginia, Colorado, or Connecticut resident, we will obtain your consent to the processing of any Sensitive Data (as defined by the applicable state law) we collect.  If you are a resident of Utah, we will notify you at or before the time of collection of Sensitive Data (as defined by Utah law). If you wish to opt out of our processing of your Sensitive Data (as defined by the applicable state law), please complete this form.

Authorized Agents Submitting Opt-Out Requests for Sales and Targeted Advertising (CO and CT Residents) - If you are an authorized agent submitting a request to opt-out of sales or targeted advertising on behalf of a Colorado or Connecticut resident, please submit the request pursuant to the above instructions. We may require documentation to authenticate the resident’s identity and that you are authorized to submit the request on the resident’s behalf in order to be able to fulfill your request. Please keep in mind that if we cannot authenticate that you are authorized to act on the resident’s behalf or we cannot authenticate the resident’s identity, we may deny the request.

·      Nevada. Sazerac does not currently sell your covered information as those terms are defined under applicable Nevada law. However, you may still submit an opt-out request and we will honor that request as required by Nevada law if Sazerac were to ever engage in such a sale in the future. If you are a Nevada resident and would like to opt-out of future sales of your covered information, please submit your request to 1-866-729-3722. Your request must include your full name, street address, city, state, zip code, and an email address so that we can contact if needed regarding this request.  You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request.  Sazerac will respond to your request within sixty (60) days either confirming that your request has been processed or indicating that we need an additional thirty (30) days to complete the request.

12.  California Privacy Notice

This California Privacy Notice is effective as of June 26, 2023.

This notice supplements Sazerac’s privacy policy and applies only to California residents.  This California Privacy Notice sets forth disclosures and rights for California consumers regarding their personal information, as required by the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020 (“CPRA”), and any implementing regulations adopted thereunder.  Terms (including capitalized terms) used in this California Privacy Notice have the same meanings given in the CCPA and CPRA and the associated regulations, unless otherwise defined.

EXERCISING YOUR CALIFORNIA RIGHTS

California consumers have the right to request: (1) that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the categories and specific pieces of Personal Information we have collected about you (“Right to Know”); (2) that we delete the Personal Information we collect about you (“Right to Delete”); (3) that we correct inaccurate Personal Information we hold about you (“Right to Correct”); (4) to opt-out from the sharing of your Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising) (“Right to Opt-Out of Sharing”), and (5) to opt-out from the sale of their Personal Information (“Right to Opt-Out of Sale”), all subject to meanings and exceptions set forth in the CCPA and CPRA. More information on each of these rights is below.

In your request, you must provide enough information to allow us to verify you are the person about whom we collected personal information, or their authorized representative. You must also describe your request with enough detail so that we can understand, evaluate, and respond to it. We can’t respond to your request if we can’t verify your identity. Making such a request does not require you to create an account with us, and we will only use the information you provide in a request to verify your identity.

Verifying Your Requests

We will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making.

When you exercise your Right to Know, Right to Delete, and/or Right to Correct, we may ask that you provide us with information, beyond your full name, in order to verify your identity and fulfill your request. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.

Agents

If you are an authorized representative submitting a request on a user’s behalf, please complete the applicable request per the instructions below. We will follow up to request a signed, written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. The written permission must state your full legal name, the full legal name of the individual who is the subject of the request and needs to be clear about the permission granted. Alternatively, you may submit a copy of a power of attorney under California Probate Code sections 4000-4465. In either case, please also indicate in your email the nature of your request. The California resident’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may also ask the California resident to directly confirm with us that they provided you permission to submit a request.  Please keep in mind that if we do not receive adequate proof that the agent is authorized to act on your behalf, we may deny the request.

Right to Know

California Consumers have the right to know what information we have collected about you (the categories and specific pieces of information).

If you are a California Consumer and would like to exercise your Right to Know, please submit your request at this form or by calling us at 1-866-729-3722.

In order to have us provide specific pieces of information, we may require a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.

Right to Delete

California Consumers also have the right to request that we delete personal information we have collected from you.

If you are a California Consumer and would like to exercise your Right to Delete, please submit your request at this form or by calling us at 1-866-729-3722.

Please note that as part of the verification process, once you submit a request to delete, we may follow up and require you to confirm that you want your information deleted.  

Right to Correct Inaccurate Information

California residents have the right to request that we correct inaccurate information we hold about you. If you are a California resident with whom we have a direct business or potential business relationship and would like to exercise your Right to Correct, please submit your request at this form or by calling us at 1-866-729-3722. 

Right to Limit the Use and Disclosure of Sensitive Personal Information

Under the CPRA Regulations, a business must only provide the Right to Limit The Use and Disclosure of Sensitive Personal Information when Sensitive Personal Information is collected or processed for the purpose of inferring characteristics about a consumer, or does not fall under certain statutory exceptions, pursuant to CPRA §1798.121. Sazerac does not collect Sensitive Personal Information for the purpose of inferring characteristics about a consumer and/or falls under certain statutory exceptions, and we therefore do not offer this right at this time.

Do not Sell My Personal Information or Share for Cross Contextual Behavioral Advertising

Right to Opt-Out of Sharing for Cross Contextual Behavioral Advertising

California residents have the right to opt-out of the sharing of your Personal Information to a third party for cross-context behavioral advertising (i.e., targeted advertising), whether or not for monetary or other valuable consideration. If you would like exercise your Right to Opt-Out of Sharing, please submit your request at this form.

Right to Opt-Out of Sale

California Consumers have the right to opt-out of the sale of your Personal Information. If you are a California Consumer and would like exercise your Right to Opt-Out of Sale, please submit your request at this form.

Cookie Based Opt Outs for Do Not Sell or Share

Sazerac engages in online advertising practices (and certain analytics or similar activities), which may be considered a “sale” or “share” for cross-context behavioral advertising as defined in the CCPA and CPRA. To opt out of certain tracking cookies set by 3rd parties that may be considered "sales" or “sharing” under the CCPA and CPRA, please modify your cookie settings by clicking on the link titled “Cookie Settings” on the footer of our Sites.

In addition, the Digital Advertising Alliance also offers tools for California consumers to send requests under the CCPA and CPRA to opt out of the sale of personal information by some or all of the participating companies https://www.privacyrights.info/.

Data Retention

We will retain all categories of personal information described in this California Privacy Notice for as long as it is reasonably necessary for the purposes set out in this California Privacy Notice, considering the time period reasonably necessary to: provide to you; exercise the choices and rights you have requested; comply with our contractual obligations; enforce our terms for use of the Sites; and comply with legal and regulatory requirements. Except as noted differently on specific pages or apps, we retain your personal information while you have an account with us, or while you are using our Sites or continuing to visit us.

Users Younger than 16

Sazerac does not knowingly sell or share Personal Information of users younger than 16 years of age.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

California consumers have the right to not receive discriminatory treatment for exercising CCPA and CPRA rights.  We will not discriminate against you for exercising your CCPA and CPRA rights.

Notice of Financial Incentive

From time to time, we may provide loyalty or similar programs to consumers. Under California regulation, certain aspects of those loyalty and similar programs, which provide benefits to consumers, may be considered a financial incentive program. We may collect personal information from you in connection with our loyalty program, e.g. contact information (name, email address, residential address) and commercial information (like purchase history) for a number of reasons, including to administer the program, contact you with regard to your account (if any), to provide the benefits to you, to better serve you, and to fulfill your requests associated with the program.

To opt into these loyalty or similar programs, as set forth herein you will need to provide certain information, register for an account and agree to the applicable program terms, or otherwise follow the instructions associated with the loyalty or other similar programs. Participation in our loyalty or other similar programs is voluntary and you can withdraw at any time.

To the extent that we provide programs that may be considered a financial incentive because the program is directly or reasonably related to the collection, deletion or retention of consumer personal information, the value is reasonably related to the overall value we receive from the personal information participants provide specific to the program minus the costs and expenses we incur in providing the program.

PERSONAL INFORMATION SAZERAC COLLECTS

The Personal Information we collect about you will depend upon how you use our Sites or otherwise interact with us. Accordingly, we may not collect all of the below information about you. 

In addition to the below, we may also collect and/or use additional types of information and will do so after providing notice to you and obtaining your consent to the extent such notice and consent is required by the CCPA and CPRA.

Category of Personal Information Collected

Categories of Sources from which the Information was Collected

Business or Commercial Purpose(s) for which Information is Collected

Categories of Third Parties to whom this type of Personal Information is Disclosed for a Business Purpose

Categories of Third Parties to Whom this Type of Personal Information is Sold or Shared for Cross Context Behavioral Advertising

Identifiers
This category includes information such as name, contact information, driver’s license number, and online or device identifiers.

We may collect this type of information from:

  • Consumer,
  • Cookies and Tracking Technologies,
  • Third Party Service Providers,
  • Third Party Social Media Companies,
  • Third party Business Partners,
  • Third Party Data Resellers.

We may use this type of information:

  • To respond to and fulfill your requests for products and services and communicate with you about those requests;
  • To register and service your account;
  • To administer surveys, sweepstakes, contests, and promotions;
  • To provide customer service and alert you to product information, including recalls;
  • To help us improve and customize our service offerings, websites, and advertising;
  • To send you information about our products, services, and promotions via various channels including email; and
  • To protect the security or integrity of our Sites and our business.

We may disclose this type of information to:

  • Service Providers, such as third parties who help manage our websites and deliver our communications,
  • Third parties we partner with for contests, sweepstakes, or promotions,
  • Third party advertising and analytics companies,
  • Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition,
  • Third parties or affiliated companies when you agree to or request that we share your information with them,
  • Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders).

Third party advertising, analytics, and other marketing business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances.

Any categories of personal information described in subdivision (e) of Section 1798.80

 

This category includes name, address, and phone number, information about your employment or education, and other categories of information classified as “personal” under this California law.

We may collect this type of information from:

  • Consumer,
  • Cookies and Tracking Technologies,
  • Third Party Service Providers,
  • Third party Social Media Companies,
  • Third Party Business Partners,
  • Third Party Data Resellers.

We may use this type of information:

 

  • To respond to and fulfill your requests for products and services and communicate with you about those requests;
  • To register and service your account;
  • To administer surveys, sweepstakes, contests, and promotions;
  • To provide customer service and alert you to product information, including recalls;
  • To help us improve and customize our service offerings, websites, and advertising;
  • To send you information about our products, services, and promotions via various channels including email; and
  • To protect the security or integrity of our Sites and our business.

We may disclose this type of information to:

  • Service Providers,
  • Service Providers, such as third parties who help manage our websites and who deliver our communications,
  • Third parties we partner with for contests, sweepstakes, or promotions,
  • Third party advertising and analytics companies,
  • Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition,
  • Third parties or affiliated companies when you agree to or request that we share your information with them,
  • Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders).

Third party advertising, analytics, and other marketing business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances.

Commercial information

This category includes, for example, payment information you provide for goods, services, customer service records, and information about the products you have purchased.

We may collect this type of information from:

  • Consumer,
  • Third Party Service Providers,
  • Third Party Business Partners.

We may use this type of information:

  • To respond to and fulfill your requests for products and services;
  • To administer surveys, sweepstakes, contests, and promotions;
  • To provide customer service;
  • To help us improve and customize our service offerings, websites, and advertising; and
  • To protect the security or integrity of our Sites and our business.

We may disclose this type of information to:

  • Service Providers, such as third parties who help manage our websites,
  • Third parties we partner with for contests, sweepstakes, or promotions,
  • Third party advertising and analytics companies,
  • Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition,
  • Third parties or affiliated companies when you agree to or request that we share your information with them,
  • Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders).

 

Internet or other electronic network activity information

This category includes information about the web browser and operating system you are using, the website or ad that referred you to our Sites, areas of the Sites that you visited, and terms entered into a search engine that led you to the Sites.

We may collect this type of information from:

  • Consumer,
  • Cookies and Tracking Technologies,
  • Third Party Service Providers,
  • Third Party Business Partners,
  • Third Party Data Resellers.

We may use this type of information for:

  • To respond to and fulfill your requests for products and services;
  • To provide customer service;
  • To help us improve and customize our service offerings, websites, and advertising; and
  • To protect the security or integrity of our Sites and our business.

We may disclose this type of information to:

  • Service Providers, such as third parties who help manage our websites,
  • Third party advertising and analytics companies,
  • Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition,
  • Third parties or affiliated companies when you agree to or request that we share your information with them,
  • Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders).

Third party advertising, analytics, and other business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances.

 

Audio, electronic, visual, thermal, olfactory, or similar information

 

This category includes, for example, photos or videos you upload (which, depending on what they capture, could be considered Personal Information under CCPA)

We may collect this type of information from:

 

·       Consumer,

·       Third-party social media companies.

 

We may use this type of information:

 

·       To allow you participate in the Service, such as to post reviews,

  • To provide customer service;

·       For our marketing and similar internal business purposes.

 

We may disclose this type of information to:

·       Service Providers, such as third parties who help manage our websites,

·       Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition,

·       Third parties or affiliated companies when you agree to or request that we share your information with them,

·       Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders).

We do not “sell” or “share” this information.

Geolocation Data

We may collect this type of information from:

 

·       Consumer,

·       Cookies and Tracking Technologies.

 

We may use this type of information:

 

·       To allow you participate in the Service, such as to locate products,

  • To provide customer service;

·       For our marketing and similar internal business purposes.

 

We may disclose this type of information to:

·       Service Providers, such as third parties who help manage our websites,

·       Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition,

·       Third parties or affiliated companies when you agree to or request that we share your information with them,

·       Other third parties (including government agencies) as required by law (such as pursuant to subpoenas or court orders).

We do not “sell” or “share” this information.

Inferences drawn from any of the information identified above to create a profile about a consumer

These inferences may relate to your perceived interests, preferences, characteristics, or behavior

We may collect this type of information from:

  • Consumer,
  • Cookies and Tracking Technologies,
  • Third Party Service Providers,
  • Third party Social Media Companies,
  • Third Party Business Partners,
  • Third Party Data Resellers.

We may use this type of information:

  • To help us improve and customize our service offerings, websites, and advertising.

We may disclose this type of information to:

  • Service Providers,
  • Third parties we partner with for contests, sweepstakes, or promotions,
  • Third party advertising and analytics companies,
  • Third parties who may acquire your information as a result of a merger, acquisition or other ownership transition,
  • Third parties or affiliated companies when you agree to or request that we share your information with them.

Third party advertising, analytics, and other marketing business partners may have access to this data, and this may be considered a “sale” or “share” under the CCPA and CPRA under certain circumstances.

 

Contact for More Information

You can contact us for more information by writing us at Sazerac Company, Attn: Compliance Department, 10101 Linn Station Rd., Suite 400, Louisville, Kentucky 40223 or emailing Privacy@Sazerac.com

CA Shine the Light Disclosure. Pursuant to California Civil Code Section 1798.83, residents of the State of California who provide us personal information have the right to request and obtain from us one time per calendar year information about the customer information we shared, if any, with third parties for their own direct marketing purposes during the preceding year.  If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately preceding calendar year.

If you are a California resident and Sazerac customer, you can request a notice disclosing the categories of information we have shared with third parties for the third parties’ direct marketing purposes during the preceding calendar year. This information will be provided in a standardized format and will not be specific to you individually. To make such a request, please send a letter to the following address:

Sazerac Company

Attention: California Shine the Light Request

10101 Linn Station Road, Suite 400

Louisville, KY 40223

You must include the statement “Your California Privacy Rights” on your letter. You must include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.