PRIVACY POLICY

Last updated and effective as of May 24, 2019

 

Welcome to Thirstie.com (“Site”), a website maintained and operated by Thirstie Inc. (“Company”, “we”, “our” or “us”). Thirstie offers a white-label enterprise solution for liquor brands (“our Customers”) to enable e-commerce. Thirstie’s advanced API integrates directly with our Customers’ websites, connecting our Customers with localized retailers (“Retailers”) that deliver directly to consumers (“Consumers”). Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and share your personal information and to assist you in exercising the privacy rights available to you. By using or accessing the Site, you signify your agreement to be bound by this Privacy Policy.

Scope. This Privacy Policy applies to personal information processed by us in our business, as collected on our website, from the employees of our business-to-business customers and other related online or offline offerings (collectively, the “Services”).

How it Works. Consumers visit our Customers’ websites and provide information via the Thirstie enterprise solution that is needed to fulfill e-commerce transactions for products and services. Retailers who agree to participate in Thirstie’s platform will receive limited information about Consumers only as needed to deliver those products and services. This limited information includes name, address, and contact information such as phone number or email for both the purchasers and the recipient, if the purchase is intended as a gift for another person. Thirstie also receives additional information from Consumers, such as product preferences, to enable Consumers to identify products or services for purchase during their shopping experience. The Thirstie enterprise solution is governed by our customers’ Privacy Policies. Our Customers are responsible for providing the appropriate notice to their end-clients (Consumers) and obtaining any required authorizations to permit us to further process the personal information. We encourage you to read each of our Customer’s privacy policies in detail.

Personal Information We Collect. We do not collect personally identifiable information about you unless you voluntarily submit that information to us as described in this Privacy Policy. Your provision of your personally identifiable information to us is completely voluntary; it is not a statutory or contractual requirement.

Information Provided to Us.

User Information. To facilitate our Services, we collect contact information such as name, date of birth, phone number, address, username, password, order history, company name, store manager contact information. In the event that the product is a gift from the individual who places the order, we collect recipient’s name, phone number and company name.

Communications with Us. We collect personal information such as email address, phone number, or mailing address when you request information about our Services, request customer or technical support, or otherwise communicate with us.

Interactive Features. We may offer interactive features such as commenting functionalities, review forums, blogs, chat services, and social media pages. We and other individuals who use our Services may collect the information you submit or make available through these interactive features. Any information shared on the public sections of these channels will be considered “public” and may not be subject to the privacy protections referenced herein.

Non-Personal Or Aggregate Information. When you visit or use the Site, we may automatically collect certain non-personally identifiable information about you. In addition, we may also aggregate information collected from our users. Non-personally identifiable information or aggregate information may be disclosed and/or used for our business purposes in accordance with applicable law.

Cookies and Similar Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

 

  • Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to stop or restrict the placement of cookies and similar technologies on your device or flush them from your browser by adjusting your browser or device preferences, in which case you may still use our Site, albeit with limited functionality. Further information on cookies is available at www.allaboutcookies.org.

  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

  • Analytics We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

Information from Other Sources.We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application such as a third-party login service, we may collect information about you from that third-party application that you have made available via your privacy settings. This supplemental information allows us to verify information that you have provided to us and to provide you with the Services.

HOW WE USE YOUR INFORMATION

We use information for a variety of business purposes, including to:

Fulfil our contracts and provide our Services, such as:

 

  • Managing account information;

  • Responding to questions, comments, and other requests;

  • Providing access to certain areas, functionalities, and features of our Services;

  • Communicating with you about your account, activities on our Services and policy changes;

  •  and Answering your requests for customer or technical support.

Analyze and improve our Services pursuant to our legitimate interest, such as:

 

  • Measuring interest and engagement in our Services;

  • Conducting research and development;

  • Developing new products and Services;

  • Ensuring internal quality control;

  • Verifying your identity and preventing fraud;

  • Detecting bugs or other software issues;

  • Preventing potentially prohibited or illegal activities;

  • Enforcing our Terms; and

  • To comply with our legal obligations, protect your vital interest, or as may be required for the public good.

Use De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.

DISCLOSING YOUR INFORMATION TO THIRD PARTIES

We may share your personal information with the following categories of third parties:

Service Providers.We may share any personal information we collect about you with our third-party service providers. The categories of service providers (processors) to whom we entrust personal information include: IT and related services; information and services you have requested; payment processors; customer service providers; and Retailers to support the provision of the Services. Service Providers receive limited personal information only as needed to deliver those products and services.

Brand Customers.We provide your personal information to our Customer, a liquor brand, whose product you have purchased. Personal information may include contact information, order history, and fulfillment by retailers.

Affiliates.We may share personal information with our affiliated companies.

Advertising Partners.Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you.

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and Consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. To separately make choices for mobile apps on a mobile device, you can download DAA's AppChoices application from your device's app store. Alternatively, for some devices you may use your device's platform controls in your settings to exercise choice.

Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

Disclosures to Protect Us or Others.We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers.If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

YOUR CHOICES

General.You have certain choices about your personal information. Where you have consented to the processing of your personal information, you may withdraw that consent at any time and prevent further processing by contacting us as described below. Even if you opt out, we may still collect and use anonymous information regarding your activities on our Services and for other legal purposes as described above.

Communications with Us; Opting Out.By providing your email address to us, you expressly consent to receive emails from us. We may use email to communicate with you, to send information that you have requested or to send information about other services provided by us, provided that, we will not give your email address to another party to promote their products or services directly to you without your consent or as set forth in this Privacy Policy. To opt-out of any future messages from us, you should send an unsubscribe request to us at privacy@thirstie.com. We will process your request within a reasonable time after receipt. However, we are not responsible for removing your personal information from the lists of any third party who has previously been provided with your information in accordance with this Privacy Policy or your consent. Please note that if you opt out in this manner, certain aspects of the Site may no longer be available to you. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law.

“Do Not Track”.Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Your Privacy Rights.In accordance with applicable law, you may have the right to:

 

  • request confirmation of whether we are processing your personal information;

  • obtain access to or a copy of your personal information;

  • receive an electronic copy of your personal information or ask us to send that information to another company;

  • restrict our uses of your personal information, including the right to opt in or opt out of the sale of your personal information to third parties, depending on applicable law;

  • seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; and

  • request erasure of personal information held about you, subject to certain exceptions prescribed by law.

If you would like to exercise any of these rights, please contact us by email at privacy@thirstie.com. If you do not want your personal information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at privacy@thirstie.com. We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.

SecurityWe have undertaken and will continue to undertake commercially reasonable efforts designed to prevent unauthorized access to user data retained in our servers. However, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties. By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

Data Retention.We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Third Party Links.The Site may contain links to other websites not maintained by us. We encourage you to be aware when you leave the Site and to read the terms and conditions and privacy statements of each and every website that you visit. We are not responsible for the practices or the content of such other websites or services. The existence of a link between the Site and any other website is not and shall not be understood to be an endorsement by us of the owner or proprietor of the linked internet website, nor an endorsement of us by the owner or proprietor of such linked website.

International Data Transfers.Our Site is maintained in the United States of America. By using the Site, you freely and specifically give us your consent the transfer, processing, and storage of your personal information anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States.

Children’s Information.The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

Supervisory Authority.If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

Changes to Privacy Policy.We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time. Your continued access of the Site after such changes conclusively demonstrates your acceptance of those changes.

Contact.For questions or concerns relating to this Privacy Policy or your information, or if you wish to submit a request to exercise your rights as detailed in this policy, please contact our Data Protection Officer by email at privacy@thirstie.com.