Collectively, we refer to the Websites, Social Media Pages, emails and offline business interactions as the “Services”.
Within this Policy you will find:
Personal Information is information that identifies you as an individual or relates to an identifiable individual:
We and our service providers collect Personal Information in a variety of ways, including:
We and our service providers use Personal Information for legitimate business purposes including:
We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
We will engage in this activity with your consent or where we have a legitimate interest.
We will provide personalized services either with your consent or because we have a legitimate interest.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
We disclose Personal Information:
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:
In addition to Personal Information, we and our third-party partners, also collect certain Other Information when you visit our Websites, use our Services, read our emails, or otherwise engage with us. “Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. This includes:
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the Contacting Us section below.
Your choices regarding our use and disclosure of your Personal Information We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt- out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
How you can access, change or delete your Personal Information
If you would like to request to review, correct, update, suppress, restrict or delete Personal Information, object to the processing of Personal Information, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), please send an email to email@example.com. We will respond to your request consistent with applicable law. If you are a California resident, please refer to the “Additional Information Regarding California” section at the end of this Policy for more information about the requests you may make under the CCPA. In your request, please make clear what Personal Information you would like to have changed, or whether you would like to have your Personal Information suppressed from our database. For your protection, we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for record-keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
Some of the products that we sell on our Services are highly regulated and age-restricted. We are required and committed to preventing sales to anyone under the legal purchasing age. We will only send you marketing materials and information that encourage or facilitate a purchase of our products after you have certified that 1) you are of legal purchasing age for the product you wish to purchase, and 2) that you understand that providing false information may constitute a violation of the law.
Before you can make a purchase from a product specific newsletter mailing list, we will verify your age through a non-affiliated third-party service provider to perform an age and identify verification check for adherence to this requirement. We utilize these trusted verification services to verify the information that you provide and ensure that you qualify to access and purchase products from the Services. This process has been developed with your privacy in mind with detailed information neither shared nor accessible.
In some cases, in compliance with applicable law, we may require that you provide a government-issued identification (“ID”) or other forms of valid ID. If through the third-party verification service we are not able to verify your age and/or identity, you will be requested to upload a copy of your government ID so that our team can manually verify your date of birth. Photo ID’s are uploaded to our third-party partner’s secure database and we simply process the result that they provide – we do not receive a file with your ID to be stored on our servers or database.
The Services are not directed to individuals under the age of twenty-one (21), and we do not knowingly collect Personal Information from individuals under 21.
Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
1095 Broken Sound Parkway NW, Suite 300
Boca Raton, Florida 33487
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
You may also lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details: We collected and disclosed the following categories of Personal Information of our customers, prospective customers, visitors to our websites, social media pages, and stores and other premises, and other individuals who engage with our Services, in the preceding 12 months:
|Category||We Collect||We Disclosure|
|A. Identifiers such as real name, alias, postal address, online identifier, IP address, email address, account name (including for social media) and driver’s license or other government- issued ID number (solely for the purposes of required age verification – see Age Verification above).||YES||YES|
|B. Personal information as defined in the California customer records law, such as name, contact information, account information, profile picture and social media account ID, and driver’s license or other government-issued ID information (solely for the purposes of required age verification – see Age Verification above).||YES||YES|
|C. Characteristics of protected classifications under California or federal law, such as age.||YES||YES|
|D. Commercial information, such as transaction information, purchase history, financial details and payment information.||YES||YES|
|E. Biometric information, such as fingerprints and voiceprints.||NO||NO|
|F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our Websites, applications, systems, emails and advertisements.||YES||YES|
|G. Geolocation data, such as device location and IP location.||YES||YES|
|H. Audio, electronic, visual and similar information, such as call recordings and CCTV footage created for quality assurance, safety and security purposes.||YES||YES|
|I. Professional or employment-related information.||NO||NO|
|J. Education information subject to the federal Family Educational Rights and Privacy Act, such as student records.||NO||NO|
|K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.||NO||NO|
As described above in Collection of Personal Information, we collected this Personal Information from you, our affiliates, publicly available databases and social media providers (when you make this public and/or elect to share this information with us). Also as described above in Use of Personal Information and Disclosure of Personal Information, we use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform age verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; facilitate corporate transactions; and exercise and defend legal claims. Finally, as described above in Disclosure of Personal Information, we share this Personal Information with our affiliates, service providers and other vendors (including data analytics providers), social networks (when you elect to share or post this information), public or government entities and third parties to facilitate corporate transactions (mergers, acquisitions etc.).
We collect the following categories of Personal Information of employees, independent contractors, owners, directors, officers and job applicants, as well as their emergency contacts, dependents and beneficiaries:
|A. Identifiers, such as name, contact information, online identifiers and Social Security numbers and other government-issued ID numbers.||YES|
|B. Personal information, as defined in the California customer records law, such as name, contact information, education information, employment history, financial information and medical and medical insurance information.||YES|
|C. Characteristics of protected classifications under California or federal law, such as sex, age, race, religion, national origin, disability, medical conditions and information, citizenship, immigration status, request for leave and marital status.||YES|
|D. Commercial information, such as transaction information and payment information, in each case for employee-only deals and discounts on our goods and products.||YES|
|E. Biometric information, such as fingerprints and voiceprints.||YES|
|F. Internet or other electronic network activity information, such as browsing history and interactions with our Websites, applications, systems, and emails.||YES|
|G. Geolocation data, such as device location and IP location.||YES|
|H. Audio, electronic, visual and similar information, such as call recordings and CCTV footage created for quality assurance, safety and security purposes.||YES|
|I. Professional or employment-related information, such as work history, prior employer, information relating to references, details of qualifications, skills and experience, human resources data, and data necessary for benefits and related administration services.||YES|
|J. Education information subject to the federal Family Educational Rights and Privacy Act, such as student records.||YES|
|K. Inferences drawn from any of the personal information listed above to create a profile or summary.||YES|
We use this Personal Information for the purposes of operating, managing, and maintaining our business, managing our workforce, and accomplishing our business purposes and objectives, including, for example, using Personal Information to: manage workforce activities and personnel generally, including for recruitment, employee training, leaves, promotions and discipline; manage payroll, wages, tax forms and filing, stock grants and bonuses; administer benefits; maintain and secure our facilities and systems; protect the health and safety of our workforce and others; conduct research, analytics, and data analysis to assist in planning succession and to ensure business continuity; perform accounting, audit, and other internal and business functions; obtain legal and other professional advice; facilitate corporate transactions; comply with law, legal process, investigations, internal policies and other requirements; and establish, exercise or defend legal rights.
We have not “sold” Personal Information for purposes of the CCPA.
If you are a California resident, you may have the right to request that we:
Disclose to you the following information covering the 12 months preceding your request:
The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
The specific pieces of Personal Information we collected about you;
The business or commercial purpose for collecting (if applicable) Personal Information about you; and
The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
Delete Personal Information we collected from you.
To make a request for the disclosures or deletion described above, please either:
send an email to firstname.lastname@example.org; or
call us toll-free at 1-833-466-7787.
We will respond to your request consistent with applicable law. For your protection, we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.