LNJ GROUP LLC
Dated April __, 2022
- Types of Information We Collect
- Personal Information; Anonymous Information. We collect both Personal Information and Anonymous Information about our users. “Personal Information” is information that can be used to contact or identify you or individuals about whom you enter information as part of your activities on our Services, such as first name, last name, age, gender, e-mail address, phone number, street address, zip code, comments, testimonials, other personal information you make publicly available through the use of the Services, date of birth, company name and address, IP address, username and/or mail address in combination with a password or security questions and answers, account numbers or credit/debit card numbers, even without a security code, access code, or password if the account could be accessed without such information, as well as information that is linked to the forgoing information. “Anonymous Information” or de-identified information is information that cannot reasonably be used to contact or identify you and is not linked to information that can be used to do so. It includes passively collected information about your activities on or through the Services such as usage data, to the extent that information is not linked to your Personal Information.
- “Aggregated Anonymous Information” is the combination of your Anonymous Information with the Anonymous Information of other users. Aggregated Anonymous Information does not allow you to be identified or contacted.
- Non-Personally Identifiable Information. Through your use of the Services, we may also collect certain non-personally identifiable information from you (“NPII”). NPII is not associated with you as an individual. It is measured anonymously and only in the aggregate.
- Cookies; Pixel Tags. We may also use tools such as cookies and pixel tags to gather information as well. “Cookies” are small pieces of information that a website sends to your device while you are viewing the Website or using the Services. We use both session Cookies (which expire once you close your web browser), persistent Cookies (which stay on your device until you delete them) and third-party Cookies (which are placed by a website from a domain other than ours) to provide you with a more personal and interactive experience. Persistent Cookies can be removed by following web browser help file directions. "Pixel Tags" (sometimes called "web beacons" or "clear gifs") are a snippet of code that collects information about a visitor’s behavior on a website, and then sends the information back to the originating platform to be processed and reported. View the list of cookies we collect Here.
- Unique Device Identifiers. Users can access and browse a majority of the Website without disclosing Personal Information, although, like most website providers, we passively collect certain information from your devices, such as your IP address, browser information, unique device identifier (“UDID”) and/or your mobile operating system.
- User-Provided Information. We collect information that you provide directly to us when you engage in the following:
- Purchase products or services from us
- Register an account with us
- Purchase our products or services through third party ordering platforms (e.g., Drizly or others)[TO CONFIRM]
- Update or change your account information
- Register for our Newsletter
- Submit a product review
- When you share a product review, message, link or other content through the Services
- Follow, link with other otherwise join us on any supported social media application, including Facebook, Twitter, Instagram, LinkedIn, and YouTube
- Submit a request for support or assistance
- Submit User Content
- Communicate with us via e-mail, telephone, video conference, or other methods
- Inquire about, apply for, or initiate employment
- Complete a survey for, submit information to, or request information from us
- If/when you are working for the Company
- Geolocation. If you access the Services through a desktop or mobile device, we may access, collect, monitor and/or remotely store geo-location data.
- Third-Parties. We may also obtain information from other sources and combine that with information we collect directly. For example, we may collect information about you from third parties, including but not limited to identity verification services, fraud detection service providers, credit bureaus, mailing list providers, review sites and services, shipping carriers, sales partners, and publicly available sources. If you create or log into your account through a social media site, we will have access to certain information from that site, such as your name, account information and friends lists, in accordance with the authorization procedures determined by such social media site.
We use third-party services, such as Google Analytics, Google AdWords, Facebook Pixel, DoubleClick and Twitter Conversion Tracking, to track and analyze online behavior of our Users. These services may help inform, optimize, target and serve ads based your visits to our Services. We do this to better understand how you use the Services, with a view to offering improvements for all Users, and to tailor our business and marketing activities accordingly. If you would like to opt out of Google Analytics, please download and install the browser plugin at http://tools.google.com/dlpage/gaoptout?hl=en. You can also manage your Facebook privacy settings and preferences by going to your account and navigating to the Settings & Privacy page of your account. Users can also opt out of third party interest based advertising by visiting the Network Advertising Initiative’s deactivation website at www.networkadvertising.org/choices/.
When you interact with us through social media networks, such as when you follow us, share content or contact us through Facebook, Twitter, Instagram, YouTube, Snapchat or other sites, we may receive information about you, including your profile information, picture, user ID associated with the social media account, friends list, and any other information you permit the social media network to share with third parties. The data we receive is dependent upon your privacy settings with the social network in question.
- How We Use Your Information
- Personal Information. We may use your Personal Information for the following representative purposes:
- Set up and maintain your user account;
- Review, process and fill your product purchases, whether through us or through a third party ordering platform, and any applicable promotions or discounts
- Send communications to you, including product information and administrative e-mails
- Arrange for shipping and delivery of the products you purchase, whether through us or through a third party ordering platform,
- Satisfy our contractual obligations to you
- Send you promotional/marketing information, newsletters, offers or other information
- Perform internal operations, processing services, maintain user accounts, resolve disputes, establish, exercise, and defend legal claims, prevent and identify fraud, verify your identity and authenticate users
- Personalize and tailor the features, performance and support of the Services
- Analyze, benchmark and conduct research on user data and interactions with the Services and our products and services
- Provide the materials, goods and/or services we offer and/or that you request
- Identify your preferences, so we can notify you of new or additional products, services, and/or promotions that might be of interest to you
- Improve our services, products, content, customer service, and overall Services experience by aggregating and analyzing our customer data
- Analyze the use of our products and services and information about visitors to the Services to enhance our marketing efforts
- Communicate with you by e-mail, video conferencing, telephone, text message, or other means for the purpose of providing you with customer service and support, as well as information about our company, our products, or other information that we believe may be of interest to you
- Send you notices of a transactional, administrative or relationship nature, or as required by law
- Anonymous Information. We may use Anonymous Information for the following representative purposes:
- Perform internal operations on the Services
- Improve the Services and customize the user experience
- Aggregate the information collected via Cookies and Pixels to use in statistical analysis to help us track trends and analyze patterns
- Both Personal Information and Anonymous Information. We may use a combination of Personal Information and Anonymous Information that we collect to target and measure the performance of advertisements to Users both on and off of the Services on our own and through different ad networks and exchanges, using the following data, whether separately or combined: (i) data from advertising technologies such as Cookies, Pixels, web beacons, ad tags and device identifiers; (ii) User-provided information; (iii) data from your use of the Services; (iv) information from others (e.g., advertising partners, publishers and data aggregators); and (v) social media platforms.
- Targeting. We may use Personal Information and Aggregated Information that we collect to target and measure the performance of advertisements to Users both on and off of the Website on our own and through different ad networks and exchanges, using the following data, whether separately or combined: (i) data from advertising technologies such as Cookies, Pixels, web beacons, ad tags and device identifiers; (ii) User-provided information; (iii) data from your use of the Website; (iv) information from others (e.g., advertising partners, publishers and data aggregators); and (v) social media platforms.
- Performing a contract with you, or to take steps at your request prior to contracting with you
- Protecting your vital interests or the interests of another person
- Complying with our legal obligations
- Pursuing our legitimate interests, including without limitation:
- Providing, improving and customizing our products and service offerings;
- Administration of our operations;
- Understanding how the Services are being used;
- Exploring ways to develop and grow;
- Enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks; and
- Meeting our obligations and enforcing our legal rights
- How We Share and Disclose Personal Information
- We may disclose your Personal Information to outside individuals and/or companies that help us bring you the products and services we offer and to create, operate, and maintain our Services. For example, we may work with third-parties to: (a) manage a database of customer information; (b) assist us in distributing e-mails; (c) assist us with direct marketing and data collection; (d) provide data storage and analysis; (e) provide fraud prevention; (f) provide customer service; (g) fulfil your product orders and deliver your products; and (h) provide other services designed to assist us in developing and running our Services and maximizing our business potential. We require that these outside companies agree to keep all information shared with them confidential and to use the information only to perform their obligations to us.
- Use of Non-Personally Identifiable Information.
- We use NPII to maintain and administer the Services, analyze trends, gather demographic information and comply with applicable law. We may share Aggregated Anonymous Information with third-parties. We may share this information with others without express notice to you or consent from you, and we may exploit, use and disclose your NPII without limitation of any kind. We authorize certain service providers to utilize NPII for their business purposes and in accordance with their privacy policies, such as to report on usage or industry trends to their customer base.
- We may also use Pixel Tags, which help us analyze users’ online behavior and measure the effectiveness of the Website and our advertising and marketing. Pixel Tags or Clear gif files are tiny graphics with a unique label that work in a similar way to cookies and are used to monitor the user’s online activities. In contrast to cookies that are saved on a user’s computer hard disk, clear gif files are embedded invisibly in websites and are about as big as the full stop at the end of this sentence. Where appropriate, we may combine the information collected by such Pixel Tags with the Personal Information of our customers. We may also use other analytical tools to evaluate site performance through the use of aggregated data, which contain no Personal Information. We work with service providers that help us track, collect, and analyze this information.
- Cookies, Pixel Tags, and/or other analytical tools that we may use on the Website may collect information about your visit, including the pages you view, the features you use, the links you click, and other actions you take in connection with the Website. This information may include your computer's Internet protocol (IP) address, your browser type, your operating system, date and time information, and other technical information about your computer. We may also track certain information about the identity of the Website you visited immediately before coming to the Website. Cookies, pixel tags, and/or other analytical tools in our e-mails may also be used to track your interactions with those messages, such as when you receive, open, or click a link in an e-mail message from us. We may also work with businesses that use tracking technologies to deliver advertisements on our behalf across the Internet. These companies may collect information about your visits to the Website and your interaction with our advertising and other communications, but no Personal Information is shared with them.
- The Services contains links to and/or enables certain third-party functionalities to enhance your experience on the Services, including social plug-ins, tools and APIs. Prior to using any third party functionalities (e.g., Facebook “Like” button) on the Services, you should consult the privacy notices of the third party providers of such functionalities (e.g., Facebook), as we have no control over information that is submitted to, or collected by, such third parties, or how they may use the information. The privacy policies and data practices of such third parties may significantly differ from ours, and we make no representation or warranty whatsoever about their policies and practices. Your communications and interactions with such third parties are solely between you and them and are at your own risk.
- Data Retention.
- Where we are processing Personal Information based on our legitimate interests, we generally will retain the data for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects.
- Where we are processing Personal Information based on your consent, we generally will retain the information for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Information erased (see Section 8, Deleting, Changing & Updating Your Personal Information).
- Where we are processing Personal Information based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.
- Ad Industry Opt-Outs. You can opt out of Internet-based and mobile advertising on your mobile device by visiting TRUSTe’s Ad Preference Manager, currently available at https://preferences-mgr.truste.com/. You may can opt out of receiving online behavioral or internet based advertising by using the tools located at the Digital Advertising Alliance’s consumer choice page, currently available at http://www.aboutads.info/choices/ or the Network Advertising Initiative (NAI) opt out tool currently available at http://www.networkadvertising.org/choices/. When using the ad industry opt out tools, note that: (a) if you opt-out we may still collect some data about your online activity for operational purposes (such as fraud prevention), but it will not be used by us for the purpose of targeting ads to you; (b) if you use multiple browsers or devices you may need to execute this opt out on each browser or device; and (c) other ad companies’ opt-outs may function differently than our opt-out, and we have no control over the practices of any third parties. We do not make any representations or warranties about such opt-out services. Such services are independent from us, and we have no control over, or responsibility for their performance.
- Text Messages. If you prefer not to receive text or wireless promotional communications on your mobile device, you can opt out by replying STOP to any text you receive from us. You can also contact us by email at email@example.com to request we stop sending you text messages.
- Deleting, Changing & Updating Your Personal Information
- You may correct, update or revise your Personal Information that is inaccurate or request that we delete your Personal Information from our system. In certain cases, you may also have a right to: (i) to restrict or limit the ways in which we use your Personal Information; (ii) to object to the processing of your Personal Information; and (iii) to obtain a copy of your Personal Information in an easily accessible format.
- To submit a request, please send an e-mail message to [e-mail]. We do not want to take any action regarding your Personal Information at the direction of someone other than you and may therefore ask you for information verifying your identity.
- Notice to Californian Users Regarding Your Privacy Rights
- Shine the Light. Pursuant to California Civil Code Section 1798.83, also known as the "Shine The Light" law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that individual, that a business has disclosed to third-parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third-parties. We do not share Personal Information with third-parties for those parties’ direct marketing. To request the above information, California residents can e-mail us at [e-mail] or write to us at LNJ Group, LLC, Attn: Privacy Office, [mailing address]. Please note that, under California law, a business is only required to respond to such a request twice in any calendar year.
- Do Not Track. Some web browsers may let you enable a "do not track" feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting cookies, as browsers with a "do not track" feature enabled may still accept cookies. There is currently no industry standard for how companies should respond to "do not track" signals, although one may develop in the future. We do not respond to "do not track" requests or signals at this time.
The Services are not directed to or intended for children under 13 years of age. We do not knowingly solicit, collect or maintain information from those we actually know are under 13, and no part of our is targeted to attract anyone under 13. We also do not send e-mail correspondence to anyone who advises that they are under the age of 13. If we later obtain actual knowledge that a User is under 13 years of age we will take steps to remove that User’s Personal Information from our systems. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at [e-mail] or write to us at Attn: Privacy Office, [mailing address] so that we may delete and remove such information from our system.
- Security; Legally Required Disclosures
- Security. We strive to keep your Personal Information private and safe. We take commercially reasonable physical, electronic and administrative steps to maintain the security of Personal Information collected, including limiting the number of people who have physical access to database servers, as well as employing electronic security systems and password protections that guard against unauthorized access. In addition, it is our policy to never send your credit card number via e-mail. Any payment transactions will be encrypted. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored Personal Information or "Personal Information" (as defined in applicable state statutes on security breach notification) to you via e-mail, text or conspicuous posting on the Website in the most expedient time possible and without unreasonable delay, insofar as it is consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. Your consent to such purpose remains valid after termination of our relationship with you.
Unfortunately, despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we will use reasonable means to ensure the security of information you transmit through the Services, any transmission of Personal Information by you is at your own risk. We cannot guarantee that such information will not be intercepted by third-parties and we shall not be liable for any breach of the security of your Personal Information resulting from causes or events that are beyond our control, including, without limitation, your own act or omission, corruption of storage media, defects in third party data security products or services, power failures, natural phenomena, riots, acts of vandalism, hacking, sabotage, or terrorism, and we are not responsible for circumvention of any privacy settings or security measures contained on the Services.
- Legally Required Disclosures. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "Personal Information" (as defined in applicable state statutes on security breach notification) to you via e-mail and/or conspicuous posting on the Services in the most expedient time possible and without unreasonable delay, insofar as it is consistent with (i) the legitimate needs of law enforcement; or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
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