Four Walls Whiskey Privacy Notice
Last Updated: June 13, 2022
Welcome! This Privacy Notice explains how Brown, Brown & Brown, LLC dba Four Walls Whiskey (“Four Walls,” “we”, “our” or “us”) collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with our services, including when you visit our website https://fourwallswhiskey.com/(the “Site”), visit or talk to us on our targeted social media pages (“Social Media”), participate in a sweepstakes or contest (“Prize Promotions”), contact our customer service agents (“Customer Service”), open our ads, receive or open our e-mails or text messages, or otherwise interact or communicate with us related to any of these services, or when you interact or use one of our services that link to this Privacy Notice (all collectively referred to as the “Services”). The Services are intended for people who are 21 years of age or older.
What is Personal Information?
When we use the term “personal information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.
Our Collection of Personal Information
Personal Information Collected from Individuals
We may collect the following personal information submitted to us by individuals through the Services:
· Contact information, including first and last name, email address, and communication preferences.
· Inquiry and Communications Information, including information provided in custom messages sent through the forms, to one of our email addresses, to one of our social media accounts, or via phone. This also includes information provided in order to subscribe to any of our newsletters or waitlists (such as email address, name, zip code, and phone number ) or contact information provided on our Services. Please note that Four Walls Whiskey is not a retailer and does not collect any payment card information. All orders of our products and merchandise are completed through our third party business partners and are governed by their respective privacy notices. For more information, please see the Information From Third Party Sources section below.
· Prize Promotions Information, including information provided when you enter a contest or sweepstakes, such as your name, social media handle, address, e-mail address, phone number, image, photograph, voice, statements, and/or other information included as part of the Prize Promotion.
· Employment Applications Information, including your contact and demographic information, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment.
· SMS Text Messaging Program. If you join our promotional text messaging program, we will collect your mobile phone number. Only residents of the US are eligible to participate in promotional text messaging programs.
Personal Information Automatically Collected
As is true of most digital platforms, we and our third-party providers may also collect personal information from an individual’s device, browsing actions and website usage patterns automatically when visiting or interacting with our Services, which may include log data (such as internet protocol (IP) address, operating system, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Services and any errors that may occur during the visit to our Services), analytics data (such as the electronic path taken to our Services, through our Services and when exiting our Services, as well as usage and activity on our Services) and location data (such as general geographic location based on the log data we or our third-party providers collect).
When you access our Sites from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.
For more information on our and third-party partners’ data collection and online advertising practices, please see the Third Party Data Collection and Online Advertising section of this Privacy Notice.
Information from Third Party Sources
We also obtain personal information from third parties, which we often combine with personal information we collect either automatically or directly from an individual.
We may receive the same categories of personal information as described above from the following third parties:
Business Partners. We may receive your information from our business partners, such as marketing companies and online retailers that promote or sell our products. Please note that you provide your information directly to these companies, and they are lawfully permitted to process your information for their own business purposes and legal requirements.
Service Providers. Our service providers that perform services solely on our behalf, such as survey and marketing providers, collect personal information and often share some or all of this information with us.
Social Media. When an individual interacts with our Services through various social media networks, such as when someone follows us on Instagram, Twitter, or other social networks, we may receive some information about individuals that they permit the social network to share with third parties or any other information shared through our pages. The data we receive is often dependent upon an individual’s privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third parties. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
Information from Other Sources. We may obtain information from other sources, including through third-party information providers, our shareholders, customers, or through transactions such as mergers and acquisitions. We may combine this information with other information we collect from or about you. In these cases, our Privacy Notice governs the handling of the combined personal information. We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.
Our Use of Personal Information
We use personal information we collect to:
· Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services;
· Manage our business and its day-to-day operations;
· Communicate with individuals, including via email and social media;
· Request individuals to complete surveys about our company, companies we partner with, and the Services;
· For marketing and advertising purposes, including to market to you or offer you through email, direct mail, and updates on products or services we think that you may be interested in;
· Test, enhance, update and monitor the Services, or diagnose or fix technology problems;
· Facilitate customer benefits and services, including customer support through our command center services;
· Identify and analyze how individuals use our Services;
· Conduct research and analytics on our customer and user base and our Services;
· Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;
· Help maintain the safety, security and integrity of our property and Services, technology assets and business;
· Evaluate your candidacy for employment, to communicate with you during the application process and to facilitate the onboarding process, if you are applying for employment;
· To fulfill or enforce our legal or contractual obligations and requirements (including in relation to our Terms and Conditions), to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
· Prevent, investigate or provide notice of fraud or unlawful or criminal activity;
· For any other lawful purpose, or other purpose that you consent to or for which you provide your information.
Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy notice will govern how we may process the information provided at that time.
Our Disclosure of Personal Information
We disclose personal information in the following ways:
· Affiliates. We may share personal information with other companies owned or controlled by Four Walls Whiskey, and other companies owned by or under common ownership as Four Walls Whiskey, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.
· Contests, Sweepstakes, and Survey Providers: We share personal information with third parties who assist us in delivering our contests, sweepstakes, or survey offerings and processing the responses.
· Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
· Customer Service and Communication Providers: We share personal information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
· Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, employment application-related services, and administrative services.
· Business Partners: We may also disclose personal information with other business partners with whom we jointly offer products or services, or who partner with us to offer their products and services to you. Our business partners will use your information in accordance with their own privacy notices.
· Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see the section Third Party Data Collection and Online Advertising for more information.
· Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
· Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
· in connection with the establishment, exercise, or defense of legal claims;
· to comply with laws or to respond to lawful requests and legal process;
· to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
· to detect, suppress, or prevent fraud;
· to protect the health and safety of us and others; or
· as otherwise required by applicable law.
With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or service-related publications.
Third-Party Data Collection and Online Advertising
We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including clickstream information, browser type, time and date you visited the Sites, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.
Social Media Widgets and Advertising. Our Services may include social media features, such as the Facebook “Like” button, Pinterest, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.
We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Instagram, LinkedIn and other social media forums. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks.
Third Party Partners. We work with a variety of third-party partners to provide advertising services. For example, we use Google Analytics to recognize you and link the devices you use when you visit our Services on your browser or mobile device, log in to your account on our Services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Services and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s website, “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here: https://tools.google.com/dlpage/gaoptout/.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Services.
Please see Online Ads in the Control Over Your Information section below to learn how you can opt out of interest-based advertising
Control Over Your Information
You may control your information in the following ways:
Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
Push Notifications. You can stop receiving push notifications from us by changing your preferences in the iOS or Android notifications settings menu.
Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at email@example.com. We may not be able to modify or delete your information in all circumstances.
Online Ads: To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visitinghttp://youradchoices.com/appchoices and downloading the mobile AppChoices app. You may also control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences.
SMS Text Messages Preferences. If you opted-in to our SMS text messaging program, you may opt-out of receiving promotional text messages at any time. To unsubscribe from promotional SMS texts, please reply “STOP” to one of our marketing SMS texts. Note that if you unsubscribe from receiving promotional text messages, we may still send you transactional text messages about your account or any services you have requested or received from us (e.g., technical and security notices, responses to your communications). For more information, please see our Terms and Conditions.
Links to Third-Party Websites and Services
For your convenience, our Service may provide links to third-party websites or services that we do not own or operate. We are not responsible for the practices employed by any websites or services linked to or from the services, including the information or content contained within them. Your browsing and interaction on any other website or service are subject to the applicable third party’s rules and policies, not ours. If you are using a third-party website or service, you do so at your own risk. We encourage you to review the privacy policies of any website or service before providing any personal information.
Intended for 21+
Our services are not intended for persons under the age of 21. We do not knowingly solicit or collect personal information from individuals under the age of 21.
Transfers Outside the European Economic Area
If and when transferring your personal data outside the EEA (which consists of EU member states and Iceland, Lichtenstein and Norway), We will only do so using one of the following safeguards:
· the transfer is to a non-EEA country which has an adequacy decision by the EU Commission;
· the transfer is covered by a contractual agreement, which covers the GDPR requirements relating to transfers to countries outside the EEA;
· the transfer is to an organization which has Binding Corporate Rules approved by an EU data protection authority; or
· the transfer is to an organization in the US that is EU-US Privacy Shield certified.
You may request a copy of any relevant document in relation to transfers of your personal data outside the EEA by contacting us at firstname.lastname@example.org.
Cookies are small files which often include an anonymous unique identifier sent by web servers to web browsers and stored by the web browsers which enable the site or service provider’s systems to recognize your browser and capture and remember certain information. The information is then sent back to the server each time the browser requests a page from the server. This enables a web server to identify and track web browsers. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, and the time spent at our website. There are two main kinds of cookies: session cookies and persistent cookies. Session cookies are deleted from your computer when you close your browser, whereas persistent cookies remain stored on your computer until deleted, or until they reach their expiry date.
Our website requires you to enter your date of birth and cookies allow us to remember the data you have entered, so that we do not need to ask you to re-enter information every time you browse to a different page of the website. We also use Google Analytics type of cookies which, in conjunction with our web server’s log files, allow us to calculate the aggregate number of people visiting our website and which parts of our website are most popular. This helps us gather feedback so that we can improve our website and better serve our customers. We do not generally store any personal information that you provide to us in a cookie. Most of our cookies expire within 90 days although our analytics cookies may persist for two (2) to ten (10) years. If you delete cookies relating to the Site, we will not remember things about you and you will be treated as a first-time visitor the next time you visit the site.
The purpose of cookies, such as Google Analytics cookies, is storing information such as the time you visit the website, and whether you have visited it before.
We may also use “Social Media” cookies to personalize your interaction with third party social media platforms, such as Instagram and Facebook, where our website uses such features. Such cookies recognize users of these social media sites when you view social media content on our website. They also allow you to quickly share content across media, through the use of simple “sharing” buttons. We use the following Social Media cookies: Twitter, Facebook, Instagram, YouTube, LinkedIn, Pinterest, and Tumblr. For further information about those Social Media cookies please see here:
You may disallow receiving cookies at any time through your web browser. Although you may still use the site if you reject cookies, some functionality may be limited. Most browsers allow you to refuse to accept cookies:
In Internet Explorer, you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector.
In Firefox, you can adjust your cookies settings by clicking “Tools”, “Options” and “Privacy”.
In Google Chrome, you can adjust your cookies settings by clicking the “Chrome Menu” on the browser tool bar, “Settings”, “Show Advanced Settings”, “Privacy”, “Cookies” and select your preferred setting.
Changes to Privacy Notice
We reserve the right to change this Privacy Notice from time to time in our sole discretion. We will notify you about material changes in the way we treat personal data by sending a notice to the primary email address specified in your Four Walls Whiskey account and/or by placing a prominent notice on our Site. It is your responsibility to review this Privacy Notice periodically. When we do change the Privacy Notice, we will also revise the “last updated” date.
Your California Privacy Rights
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To opt-out of having your information shared in this manner, please email us at email@example.com.
For additional inquiries about this Privacy Notice, please send us an email at or contact us at:
Four Walls Whiskey
540 Court st.
Brooklyn NY 11231
1. Notice of Collection and Use of Personal Information
We may collect or process the following categories of personal information as specified in the CCPA:
· Commercial Information: commercial information, including products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
· Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, IP address, email address, account name, and other similar identifiers. Social Security number, driver’s license number and passport information may be obtained in limited instances for identity and age verification and tax purposes.
· Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements.
· Geolocation Data
· Sensory Information: audio, electronic, visual, olfactory, and similar information.
· Employment Information: professional or employment-related information.
· Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, and credit or debit card number.
· Protected Classifications: certain characteristics of protected classifications under California or U.S. federal law, such as age, sex, gender, disability, and military and veteran status.
· Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We may use the categories of personal information listed above for the purposes described in our Privacy and Cookie Notice and for certain business purposes specified under the CCPA, as described below.
· Short-Term Use, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
· Performing Services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services.
· Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.
· Detecting Security Incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
· Debugging to identify and repair errors that impair existing intended functionality.
· Safety, including undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.
2. Our Prior Collection, Use and Disclosure of Personal Information
We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this CCPR Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, and (c) the categories of personal information we may have sold.
a. Categories of Sources of Personal Information
We may have obtained personal information about you from various sources, including:
· Directly from you (such as when you visit our website, enter a competition, take advantage of a promotion, redeem a coupon or offer, fill in a questionnaire or survey, purchase products or services from us, contact us with an inquiry, register on or post a comment on our website or app, attend our events, forward an item to a friend, communicate with us via social media or third-party apps and/or inform us of your marketing preferences)
· From your devices, such as when you browse or use our website or apps
· Your family or friends (such as when they contact us on your behalf, or refer you for one of our contests, sweepstakes or other participatory events)
· Our subsidiaries, affiliates, and parent companies, and any of their related businesses
· Vendors who provide services on our behalf
· Business partners (such as distributors and joint marketing partners)
· Social media platforms and other third-party websites with whom we have partnered
· Online advertising technologies companies
· Government entities
· Consumer data resellers
· Publicly-available sources, such as public databases and data aggregators
b. Sale of Personal Information
We do not sell your personal information in exchange for monetary compensation. We may allow certain third parties (such as certain advertising partners) to collect your personal information via automated technologies on our websites in an effort to serve you content and advertisements that may be of interest to you. The categories of personal information that may have been disclosed in this manner include: Identifiers, Protected Classifications, Commercial Information, Online Activity, Geolocation Data, and Inferences. We share these categories of personal information for online advertising purposes as described in our Privacy and Cookie Notice. You have the right to opt out of interest- based advertising, as detailed below and in the “Marketing Cookies” section of our Privacy and Cookie Notice.
3. California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
· Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months. To submit an access request, you may contact us here: firstname.lastname@example.org
· Deletion: You have the right to request that we delete certain personal information we have collected from you. To submit a deletion request, you may contact us here: email@example.com
· Opt-Out of Sale: You have the right to opt out of the sale of your personal information. For information about how to manage cookies and opt out of online interest-based advertising, please see the “Cookies” section of our Privacy and Cookie Notice. Your opt-out will be specific to the web browser or device you use at the time you exercise your opt-out rights; if you use multiple web browsers or devices, you will need to opt-out from each browser and device. Opting out of the sale of your information for interest-based advertising purposes does not mean you will stop seeing ads, including interest-based ads, and your information that was collected prior to 90 days before your opt-out request may be further used for interest-based advertising purposes. Please understand that we will still share your information in ways that are not a “sale,” such as with our service providers, for our own online advertising purposes.
To submit a request as an authorized agent on behalf of a consumer, contact us at firstname.lastname@example.org
Verifying Requests. To help protect your privacy and maintain security, if you request access to or deletion of your personal information, we will take steps and may require you to provide certain information to verify your identity before granting you access to your personal information or complying with your request. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make a request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described above).
Shine the Light Requests: California Civil Code Section 1798.83 permits you to opt out of the disclosure of your personal information by Four Walls Whiskey to third parties for the third parties’ direct marketing purposes. To make an opt-out request of such disclosures, please send an email to email@example.com.
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.