1. Introduction This website is operated by Spa Girl Cocktails, LLC. All references to ‘our’, ‘us’, ‘we’ or ‘company’ within this policy and within the opt-in notice are deemed to refer to Spa Girl Cocktails, LLC, its subsidiaries, affiliates and associates.
3. What is Personal Information? Personal information is information about an identifiable individual, as defined by applicable law.
4. Collecting Personal Information: It is your choice to provide us with personal information. We will only collect personal information that you choose to provide. In certain instances, we may provide you with the option to select whether you would like to receive information from us or from trusted third parties (for example, by choosing to opt-in or opt-out of receiving special promotional offers). In some circumstances, you will not have the option to opt-out, such as when we are satisfying the obligations of a contract with you, administering a transaction requested by you, or as required by law.
We primarily use information from cookies for the following purposes:
• Traffic monitoring, e.g., the IP address from which you access the site, the type of browser and operating system used to access the site, the date and time of your access to the site, the pages you visit, and the Internet address of the website from which you accessed the site.
• To register you in programs and to recognize your website preferences.
• To recognize repeat visitors for statistical / analytical purposes.
• Anonymous tracking of interaction with online advertising, e.g., to monitor the number of times that a banner ad is displayed and the number of times it is clicked.
• To compile and report to third parties (such as advertisers) aggregate statistics about our users in terms of numbers, traffic patterns and related site information.
We may also connect the information that we collect through cookies and clear gifs with other personal information that you provide to us in order to:
• Customize or personalize your experience of the site; for example, so that we can greet you on the site by name;
• Conduct transactions, such as credit card sales; and
• Monitor your use of our website(s) in order to make our communications to you as relevant as possible and for other marketing and advertising research purposes.
HOW TO CONTROL COOKIES
If you wish to prevent cookies being set before you visit this website, or most other websites, you can set your browser to block cookies. Most browsers allow you to do this in their settings.
You can also visit www.allaboutcookies.org for details on how to delete or reject cookies and for further information on cookies in general.
6. Use of Personal Information: We may use personal information collected from you in order to provide you with specific services that you request as well as in order to provide you with additional services that may be of interest to you. For example, we may use your personal information in the following ways:
• Marketing Communications: We may use your personal information in order to communicate with you about our products and services and those of our subsidiaries, affiliates, and parent companies and any of their related businesses.
• Marketing Analysis: We may use information for internal marketing analysis, for example, to assess trends amongst our consumers or to measure the amount of traffic to our websites.
• Transactional Purposes: We may use your personal information in order to respond to your queries and requests, maintain your accounts, 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).
• Forward to a Friend: When you provide us with information regarding another individual, such as when you request that we send someone information from one of our website, we will only send that individual the information that you specifically requested that we send. We will not send them additional communications based on you providing us with their information.
We use the “visitor action pixels” from Facebook Inc (1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”)) on our website.
This allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users.
However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data
Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes.
The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.
Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.
You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.
7. Disclosure of Personal Information: We value your personal information and only share such information with third parties that provide adequate protection for such information. From time to time we may disclose personal information to:
(a) third parties to whom you have provided your consent;
(b) our service providers and subcontractors, including our affiliates, retained to perform functions on our behalf or to provide services to us, such as warehousing and delivery; marketing and advertising; credit card and data processing; age verification; software development; website hosting and management; information technology and office services; legal, accounting, audit and other professional service providers; and other services related to our business; and further, provided such service providers and subcontractors do not collect, use or disclose the personal information for any purpose other than to perform such functions on our behalf or to provide services to us or as otherwise required by law;
(c) third parties who, in our reasonable judgment, are providing or seeking the information as the authorized or appointed legal agent of the subject individual; or
(d) carefully selected third parties, including our affiliates, to send you third party marketing and promotional information that may be of interest to you. In such circumstances your personal information may be disclosed to these organizations that will be bound by confidentiality obligations and restrictions on use of personal information. We will obtain your express permission before we allow a third party that is not an affiliate to send you any such marketing and promotional information;
(e) a person or entity, including our affiliates, in the event of a sale, merger, consolidation, change in control, transfer of substantial assets, financing, reorganization or liquidation, whereby we transfer, sell, or assign to such third party information concerning your relationship with us, including without limitation, personally identifiable information that you provide and other information concerning your relationship with us; and
(f) law enforcement, governmental or regulatory agencies, or other third party in order to comply with law or where we believe such action is necessary in order to comply with law or 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 our corporate policies, procedures, legal and contractual obligations.
9. Security: We take security seriously and we take precautions to keep your personal information secure. We have put in place commercially reasonable physical, electronic and managerial procedures to safeguard the information we collect. We have no control over the privacy of any communications while in transit to us. We recommend that you not include confidential, proprietary or sensitive information in such communications. In the unlikely event that we believe that the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail.
10. Unsubscribe, Access, Questions and Further Information: At your request and where the law requires us to do so, we will confirm what personal information we hold about you, update your information, remove your information, fulfill specific opt-out requests, including requests where you have previously opted-in with respect to the use of your personal information, and/or correct any inaccuracies in such personal information if you contact us using the unsubscribe details provided below.
If you would like to unsubscribe from Spa Girl Cocktails communications or from all communications about Spa Girl Cocktails, please contact: email@example.com
12. Your California Privacy Rights: We will not share any Personal Data with third-parties for their direct marketing purposes to the extent prohibited by California law. If our practices change, we will do so in accordance with applicable laws and will notify you in advance.