Protecting Your Privacy
Who We Are
The Company behind flaviar.com is Flaviar, Inc.
with headquarters in New York, NY. The Company acts as Data Controller for all our services. You can reach us by sending email to [email protected]
How This Policy Applies
To perform our services and communicate with you, we need to collect some information about you. This Policy describes what information we collect, how we store it and share it with third parties, how we use that information and the legal basis for doing so. It also explains how collected information may be used and your rights regarding information you provide to us.
What Information We Collect and Receive
When you use our Website, App or communicate with us regarding our services, we may collect personal information from you.
Visiting flaviar.com or using Flaviar Mobile App
We record information how you use and interact with our Website and Mobile App, such as your IP Address, type of device or browser you use.
Engaging in Speakeasy Club
If you decide to apply for joining Flaviar Speakeasy Club, we collect your email address and phone number that allows us to communicate with you regarding the Club and other offers from Flaviar.
When you join the club, we also collect your billing information such as your name, email, billing and shipping address and credit card details. To tailor our services for you, we collect your interests on specific drinks and drink types, your ratings of specific drinks and your reviews of specific drinks.
When you sign up to our newsletter, we collect your personal data such as your email address, IP address, open ratio and time of opening, click ratio including time stamp regarding visited URLs in our newsletters. Your email address will be added to the list of subscribers only with your explicit consent.
Shopping on flaviar.com
If you shop on flaviar.com, we collect your billing and shipping information such as your name, email, billing and shipping address and credit card details.
We maintain a record of products you have ordered to be able to fulfil the orders. We keep the record of all your orders for accounting purposes. We also maintain a record of products that are out of stock, but you expressed interest in using “+ Add to Wishlist” feature that allows us to inform you when the product is back in stock.
How We Use this Information
We need this information to:
- Learn about how you use our Website and Mobile App and decide about changes, we want to implement to make your experience better,
- Communicate with you as Speakeasy Club Member to communicate about benefits you have as a member,
- Communicate with you regarding our latest offers,
- Process your orders to deliver fine spirits you ordered on our Website or through our Mobile App.
What is the Legal Background for us to Collect this Information
We collect and retain Personal Information on several legal bases:
- Contractual obligation: if you gave us your personal information in connection with the order you placed with us, we need this information to deliver the Goods or Services to you.
- Legal obligation: in some cases, it is required by the law to collect and store your Personal Information. For example, tax laws require that we keep all the sales records and, in some cases, share it with local tax authorities.
- Legitimate interest: for some data, we have good and fair reason to use it in such ways that do not hurt your interests and rights. Example of that would be that we use your information like location, browser information, IP address, billing and shipping address, email address, to prevent fraud and abuse of our Services.
How Long Do We Keep this Information
Your information will be stored as long as your account is active to provide you with the Services you expect from us and/or for as long as we have your permission to keep it. Some of your personal information, like your shipping and billing addresses, will be stored with our partners or us as long as required by different laws that we need to comply with (for example tax laws).
We also collect and maintain aggregated, anonymised or pseudonymized information which we may retain indefinitely to protect the safety and security of our Site, improve our Services or comply with legal obligations. For instance, we are required to retain records related to previous sales for financial reporting and compliance purposes. We may retain and use Information to, among other purposes, comply with our legal obligations, preserve our rights, resolve disputes and enforce our agreements.
You can always request deletion of your Personal Information by sending a request to [email protected]
How Do We Share this Information with our Partners
We don’t publish any information about our users publicly.
If you choose to review products on our Website or in Mobile App, we will add your First Name (as set in your Profile) together with the review. Comments you voluntarily post on public forums such as our blog will be displayed publicly along with the name you submit and the time at which you submitted the comment. Although we reserve the right to monitor and delete any activity at our discretion, all Information posted is unprotected and can be seen by anyone.
We share some information with our trusted third-party services that help us provide, improve, promote or protect our Services (Data Processors). Those third-party services include payment processors, fulfilment partners, services that help us manage our ads and similar.
Third-party services are authorised to use your personal information only in connection with services they provide for Flaviar, and we require to use the same security and privacy standards as we do. When possible, we anonymise and aggregate the information we share with third-party services so that they are not able to identify you as an individual.
In addition, we may disclose your personal data with competent authorities, to law enforcement authorities as it is required by law or is strictly necessary for the prevention, detection or prosecution of criminal acts or fraud or if we are otherwise legally obliged to do so. We may need to further share personal data to competent authorities to protect and defend our rights or the rights of our business partners.
How can you Manage your Privacy Settings
You can always see, update and delete your Personal information we store from your Account Settings page.
Email and SMS Settings
If you are receiving SMS and/or emails from Flaviar and would like to unsubscribe you can respond to any messages received with STOP or directly unsubscribe by clicking the link at the bottom of any of the emails you have received, and you will no longer receive our messages.
We may retain specific information as required by law or as necessary for our legitimate business purposes.
What are your »Data Rights«?
Certain privacy laws around the world, including the European General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), provide users with rights related to their personal information. Consistent with those laws, Flaviar gives you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you. If you wish to exercise any of the rights you may at any time, contact our Data Protection Officer.
The exercise of these rights is free of charge, except if your request is »manifestly unfounded or excessive« (for example, if you make repetitive requests). In this case a fee may be charged to cover our administrative costs in responding.
- Right to Access & Portability: You can access certain personal information associated with your account by visiting your account privacy settings. You can request a copy of your personal information in an easily accessible format and information explaining how that information is used, free of charge.
- Right to Correction: You have the right to request that we rectify inaccurate information about you. By visiting your account settings, you can correct and change certain personal information associated with your account.
- Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.
- Right to Deletion: In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of Flaviar.
- Right to Object: If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can object using the unsubscribe link in such communications or changing your account email settings.
- Right to avoid automated decision-making.
- Right to Withdraw Consent: Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link. This is without prejudice to your right to generally permanently close your account and delete your personal information.
The CCPA provides California residents with the following additional rights:
- Right to Know: California residents may request disclosure of the specific pieces and/or categories of personal information that the business has collected about them, the categories of sources for that personal information, the business or commercial purposes for collecting the information, the categories of personal information that we have disclosed, and the categories of third parties with which the information was shared.
- Right to Opt-Out: To the extent that Flaviar “sells” personal information (as that term is defined under the CCPA), California residents are entitled to opt-out of the “sale” of data at any time (you can learn more about CCPA rights here).
- Right to Nondiscrimination: Flaviar shall not discriminate against California residents on the basis of their exercising their CCPA rights (they have a right “not to receive discriminatory treatment” for exercising their CCPA rights).
We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different from, and potentially not as protective as, the laws of your own country. Therefore, Flaviar may be unable to provide the same level of security as provided under the regulation of the EU and its Member States.
As part of the services offered to you through our website, the information you give to us may be transferred to the countries outside the European Union (applies to EU customers only).
Flaviar provides a voluntary service; you can choose whether or not to use the Services. As we operate in different countries and use technical infrastructure in the U.S. to deliver the Services to you, in accordance with the contract between us (our Terms & Conditions), we need to transfer your personal information to the U.S. and to other jurisdictions as necessary to provide the Services. Simply put, we can’t provide you with the Services and perform our contract with you without moving your personal information around the world.
We understand that security of your personal information is especially important. We protect the collected data according to the industry-standard practices and continuously improve security protocols. However, we understand that no electronic storage of the data or transmission over the internet is entirely secure and we can not guarantee absolute security. Therefore we encourage all users to be careful whenever they store or post any personal information online.
In the event that personal information is compromised as a result of a breach of security, we will promptly notify those persons whose personal information has been compromised, in accordance with California Consumer Privacy Act and the EU Regulation GDPR or as otherwise required by applicable law.
As we develop our business, we may buy or sell assets or business offerings. Customer and visitor information is generally one of the transferred business assets in these types of transactions. We may also transfer such information in the course of corporate divestitures, mergers, or dissolution.
We do not rent or sell your personal data to others.
We do not knowingly collect Information about or from minors, nor do we or any of our third parties direct any solicitations or advertisements to minors. If you are not 21 or older (or of legal drinking age in your respective country), you are not authorized to use the website. Parents should be aware that there are parental control tools available online that you can use to prevent your children from submitting information online without parental permission or from accessing material that is harmful to minors. If we learn that we collected Information about a minor, we will immediately act to remove that Information.
California Consumer Privacy Act
If you are a California resident, you can learn more about the data processing in light of California Consumer Privacy Act here.
If you have any concerns or questions about how your data is being used or stored or any information that is related to security of your or other user’s data on Flaviar, or you wish to request disclosure or deletion, please reach out to our Data Protection Officer by email to [email protected] or by post to our current registered office (244 Fifth Avenue, Suite F247, New York, NY 10001), marked for the attention of “The Legal Department”.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily you can also contact our:
- EU Representative by email to [email protected] or by post to Likozarjeva ulica 1, 1000 Ljubljana, Slovenia.
- UK Representative by email to [email protected] or by post to 4th Floor, Silverstream House, 45 Fitzroy Street, Fitzrovia, London, W1T 6EB, UK.
Changes to How We Protect your Privacy
We kindly recommend that you check this page regularly to keep up-to-date.