Privacy Policy

1. PERSONAL INFORMATION WE COLLECT AND WHY

We collect or process various categories of Personal Information as part of running our business. We may obtain your Personal Information:

from you, for example, when you subscribe to any service we offer, or when you contact us;
from your device, operating system or browser;
from our partners, such as advertising networks, service providers (including Internet service providers), social networks, data brokers, vendors and suppliers;
from other members of our group of companies;
from publicly available sources (for example, if you work for one of our business partners, your company website).

These are the categories of Personal Information we might collect about you:

CATEGORY	DO WE PROCESS ANYTHING IN THIS CATEGORY?
Identifiers	Yes. We may process names and surnames, addresses and other contact details, online identifiers, internet protocol addresses, information about operating systems and browser types, email addresses, usernames and passwords, identification documents, or other similar identifiers. Please see our Cookie Policy, too.
Personal information [Categories of Personal information in Cal. Civ. Code 1798.80(e)]	Yes, we may process names and surnames, addresses, signatures, telephone numbers and other contact details, identification documents, employment information, bank account numbers, payment card numbers. Please see our Privacy Policy for candidates, too.
Sensitive information [Characteristics of Protected Classifications under California or Federal Law]	Yes, we may process age and gender identity or expression. We might also be able to infer this kind of information from other pieces of information about you, that we might obtain from you or third parties. If you are visiting one of our premises, we might learn about your health conditions, impairments or dietary restrictions. Please see our Privacy Policy for candidates, too.
Commercial information	Yes, we may process information about products or services obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric information	No.
Internet or Other Electronic Network Activity Information	Yes, we may process your browsing or search history, information regarding your interaction with our websites, applications or advertisements.
Geolocation	Yes, we may process information about your location.
Sensory information	Yes, we may process your image or voice.
Professional or employment-related information	Yes – please see our Privacy Policy for candidates.
Inferences drawn from personal information	Yes, we may process your preferences, characteristics and behaviors.

We may also collect:

information you submit to us when you contact us posting materials, comments, reviews or requesting our services;
responses you provide as part of our surveys, competitions, games and other interactive services;
language of our communications;
preferences regarding online marketing, advertising and tracking – Please see our Cookie Policy;
category you belong to (e.g. consumer, supplier, existing or prospective customer);
system login information, if you are permitted access to our systems.

These are the purposes we will be using your Personal Information for, and the legal basis justifying its processing:

WE MAY USE YOUR PERSONAL INFORMATION TO:	WHAT ARE OUR LEGAL BASES FOR PROCESSING YOUR PERSONAL INFORMATION:
Provide you with the service you are asking for (including location-based ones): navigating seamlessly on our websites or applications, creating an account, participating to our promotions or events, purchasing our products and delivering it to you or answering to your questions.	Our legitimate interest to provide you with the best possible experience when you interact with us. The performance of a contract, when you expressly require a service.
Learn about your browsing patterns (on ours and other parties’ websites and applications), the performance of our websites and applications, and your interaction with them. We will use this information to create anonymous statistics, but also to personalize the content of our websites and applications based on what we know about you (see “Profiling”). We will also invite you to participate to surveys and researches.	Our legitimate interest to understand our users and the market in which we operate. When requested by the applicable laws, your consent. Please see our Cookie Policy, too.
Security. This will also include controls we might perform to confirm your credit worthiness and to prevent criminal/fraudulent activities.	Our Legitimate interest to assure a safe environment in which to operate, and to prevent crimes and frauds. The legal obligations we are subject to. Our contractual obligations. When requested by the applicable laws, your consent.
Profiling. Analyze your preferences, purchase history and tracked behavior, even on third parties’ websites and applications, and connect this information with the one you provided to us to enrich your profile, predict your interests and personalize the content of our websites, applications, or our marketing and advertising messages.	Your consent. Please see our Cookie Policy, too.
Marketing and advertising. Promote our products, services and events on our own or on third party’s websites, social media pages, or other media, by letter, email or other forms of electronic communication, with generic or personalized messages, and assess the success of our campaigns.	Our legitimate interest when we have an established relationship with you. When requested by the applicable laws, your consent. Please see our Cookie Policy, too.
Management reporting; building of a legal defense.	Our legitimate interest in keeping our organization and management informed, and to defend us in case of litigations.
Maintaining appropriate business records, and complying with lawful requests by public authorities and with applicable laws and regulations.	The legal obligations we are subject to.
Receive products or services from you, and manage our relationship.	The performance of a contract. The legal obligations we are subject to.
Use your image (film or photos) at events to support our communication and promotional campaign.	Our legitimate interest to document events where we promoted our goods and services. When requested by the applicable laws, your consent.

We may use technologies that are considered automated decision-making or profiling. We will not make any automated decisions that would significantly affect you unless such a decision is necessary for entering into, or the performance of, a contract with you, if we have obtained your consent, or we are required by applicable laws to use such technology.

2. HOW WE HANDLE PERSONAL INFORMATION

We may share or disclose your Personal Information for purposes consistent with this Privacy Policy in the following situations:

Within our group of companies. For instance, to combine the Personal Information collected about you.
With our service providers. We may share your Personal Information with companies we have hired to provide services for us, such as: perform marketing campaigns, publish our advertisement on websites and social media on our behalf, provide IT services (e.g. platform providers, hosting services, maintenance and support), perform researches and surveys, provide consumer-care services, organize competitions, sweepstakes and contests, manage events. We will ensure that any service provider engaged by us is bound to comply with data protection obligations, process your Personal Information only on documented instructions from us and do not use it for their own purposes. The following table lists the categories of Personal Information disclosed for a business purpose and the categories of recipients who have received this Personal information. Please note that not every one of the following categories may apply to your Personal Information.

Category of Personal Information Disclosed for a Business Purpose

Categories of Recipients

Identifiers
Personal information
Commercial information
Internet or other electronic network activity information
Geolocation
Sensory information
Inferences drawn from personal information

Miami Cocktail Co group affiliates
Service providers
Law enforcement or government bodies
Partners

Where your Personal Information may be transferred along with other business assets. In such cases, Personal Information may also be shared during any assessment process, subject to confidentiality and non-disclosure requirements.
Where we have received your consent to the disclosure of your Personal Information.
To fulfill a service to you.
To comply with the law or respond to legal process or lawful requests, including from law enforcement and government agencies.
To investigate complaints or possible breaches of law, to protect the integrity of our assets, or to cooperate in any legal investigation.
To protect our rights or property, including enforcing the terms governing your use of our services.

When we need to share your personal information with third parties in order to sell or deliver our products to you, or because required by the law, the parties receiving your Personal Information will process it independently and will be fully liable for complying with applicable data protection laws.

Our websites and applications may, from time to time, contain links to and from the websites of third parties, or you might interact with us on various social media forums. These websites and social media have their own privacy notices or policies. Please check them before you submit any Personal Information. We are not responsible for the practices employed by third party websites linked to/from our sites nor for the information contained therein.

We may sometimes offer you a service or application in co-operation with partners (for example, co-sponsors or licensors, licensees or distributors, advertising partners and social media platforms). We may therefore disclose your personal information to those partners. This disclosure will happen, depending on its purpose and characteristics, and the applicable legal requirements, based your consent, or our legitimate interest. An example of this type of disclosure is our collaboration with The Trade Desk; operating as joint-controllers, we may submit to them your email address, to create consistent unique identifiers called EUIDs. EUIDs allow us, and other participants in the EUID advertising initiative, to ensure that the ads you see online are relevant and measure the effectiveness of our advertising. You can read more about how EUID works, your rights, and how to contact The Trade Desk.

If you are located in California, please note that, with your consent where applicable, we use vendors, such as analytics providers, that use identifiers and internet information in such a way to create a “sale” as defined under California law, meaning "to exchange Personal Information for monetary or non-monetary value".Further, we “share” the same categories of information as that term is generally defined to refer to targeted advertising.

We protect your Personal Information through technical and organizational security measures to minimize risks associated with its loss, misuse, unauthorized access or disclosure and alteration.

We are a multinational company, and our affiliates, partners and service providers are located all around the world; for this reason, your Personal Information may travel internationally. Whenever this happens, we implement appropriate measures to assure the original level of protection is maintained. You may request a copy of any relevant documents in relation to the transfers of your Personal Information.

3. YOUR RIGHTS

Subject to possible restrictions under national law, you are entitled to certain rights, such as the right to:

know or access to your Personal Information,
rectification, completion or erasure of your Personal Information,
restrict or object to the processing of your Personal Information,
portability of your Personal Information,
opt-out of profiling and automated individual decision-making, or of sale and sharing of your Personal Information, or of targeted advertising,
consent and/or limit the use of your Sensitive Personal Information to that which is necessary to perform services (if you are a United States resident)
non-discrimination
lodge a complaint with a supervisory authority.

If you gave us your consent to use your Personal Information for certain purposes, you can withdraw your consent at any time. You will be able to withdraw your consent to our digital marketing communication by simply clicking on the “opt-out” link at the bottom of our emails. Check our Cookie Policy to learn how to update your Cookies preferences and consent.

Please note, the satisfaction of your requests is subject to our ability to reasonably verify your identity in light of your request and of relevant privacy laws requirements, limitations, and regulations.

If you would like to exercise your rights, contact us using the contact details mentioned in the section "Contact us".

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn't an industry or legal standard for recognizing or honoring DNT signals, we don't respond to them at this time.

4. RETENTION PERIOD

We will keep and process your Personal Information only for as long as is necessary for the purposes for which it was collected in connection with your relationship with us, unless we have a legal right or obligation to retain it for a longer period, or the data is necessary for the establishment, exercise or defense of legal claims.

5. CHILDREN

Our website, applications and services are designed to appeal to adults only. We do not knowingly solicit any information from children or people under the legal drinking age, nor do we knowingly market or otherwise target our websites or its products or services to children or people under the legal drinking age.

If we become aware that a visitor to our websites is a child or under the Legal Drinking Age in the country or other territory in which he or she is located at the relevant time we will remove their Personal Information from our files.