LAST UPDATED OCTOBER 25, 2019
Privacy is important. These documents may not be the most exciting thing in the world, but we take them seriously. Take a few minutes to look this over, and contact us if you have any concerns about our use of your Personal Data in connection with our services to you.
DrinkTV, LLC. (“DrinkTV”), and its affiliates and subsidiaries, really respects your privacy and are committed to protecting your Personal Data.
As an organization that cares about you, it is our desire and duty to comply with the various applicable regulations around the world that govern the collection and processing (using) of your Personal Data.
Protecting the personal rights and privacy of each individual that visits or uses our website and APPs is at the center of our concern in our relationship with you.
So we recognize the need for appropriate safeguards and management practices in relation to the collection and use of your Personal Data. We want to ensure that you understand what information we collect about you and how we use it.
Our website and our APPS are not intended for children and we do not knowingly collect data relating to children.
Please use the Definitions provided at the end of this Policy to help you understand the meaning of some of the terms we use here. If you have any questions regarding this Policy, contact us at: privacy@DrinkTV.com
Our full details are: Full name of legal entity: DrinkTV, LLC.
Address: 5757 W. Century Blvd., Suite 810, Los Angeles, CA 90045, USA
Email address: privacy@DrinkTV.com
“Personal Data” is defined as any information about an individual from which that person can be identified. It might include your name, mailing address, email address, telephone number, company, title, website or APP username or website or APP password. It does not include data where your identity has been removed (anonymous data).
We collect, store and process your Personal Data by different methods in connection with your use of our services, such data may include: account data, your personal profile data, your personal data that are provided in the course of the use of our services, information that you post for publication on our website or through our services, information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website or APPs, information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters, information contained in or relating to any communication that you send to us, and we may also process your shareholder data, if any. The shareholder data may include your name, address, date of birth, number of shares, date purchased and email address and other information as required by law. It may also include the above information for any joint or gift shareholders.
When you are using our website or APPs, which may include when you download content or contact us via our website or APPs, here is how we generally collect your data:
We collect, process or disclose your Personal Data for our legitimate business purposes including:
We rely on the following main grounds to process Personal Data of website and APP users, suppliers or other third parties:
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at: privacy@DrinkTV.com
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so or seek your consent, providing you with a clear, conspicuous and readily available mechanism for you to exercise your choice.
Please note that we may process your Personal Data without your knowledge or consent where this is required or permitted by law/
We will not sell or rent to anyone the Personal Data provided to us or obtained by us.
In certain circumstances we will share your Personal Data with other parties. We share your data with other entities within DrinkTV acting as joint controllers or processors. We do this to provide sales and marketing, IT, system administration services, product development and undertake internal reporting.
We will also share your Personal Data across DrinkTV entities to improve our customer service and to make our services more valuable to you.
We also share your Personal Data with the following third parties:
If you are located in the European Economic Area (EEA) this may involve transferring your Personal Data outside of the EEA. Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the Protection of Personal Data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model Contracts for the Transfer of Personal Data to Third Countries.
DrinkTV uses industry standard physical, technical, and administrative controls to protect your Personal Data by:
While we operate to the highest standards we are also aware that the transmission of information via the internet is not completely secure. We cannot guarantee the security of your data transmitted to our website or APPs and any transmission is at your own risk. Where we have given you (or where you have chosen) a password which enables you to access any of our online or electronic resources, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.
You should note that this website and our APPs may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their content or privacy statements. When you leave our website or Apps, we encourage you to read the privacy notice of every website you visit.
Where we collect your Personal Data, the length of time for which we retain it depends on the type of data, the purpose for which we use that data and our accounting, regulatory and legal data retention obligations. We do not retain Personal Data in an identifiable format for longer than is necessary.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
We will retain your Personal Data on our systems unless we have not had any meaningful contact with you (or, where appropriate, the company you are working for or with) for two years (or for such longer period as we believe in good faith that the law, statute or relevant regulators require us to preserve your data). After this period, it is likely your data will no longer be relevant for the purposes for which it was collected and we will delete or destroy it.
In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, by you have the right to:
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your Personal Data, or request that we transfer a copy of your personal information to another party, please contact us by email at: privacy@DrinkTV.com.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
To withdraw your consent, please send us an email at: privacy@DrinkTV.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, without undue delay, unless we have another legitimate legal basis for doing so.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is incomplete and we need to write to you for more information or is particularly complex or you have made several requests. In these cases, we will notify you and keep you updated.
In the EU, if you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your principle residence, your place of work or the place of the alleged infringement.
Please see “how to make a complaint” below.
Data privacy laws are constantly evolving and we endeavor to maintain best practices. However, we recognize that we may not always get it right and if you are not satisfied in the way we handle your Personal Data or you wish to discuss our processes then we would like to hear from you.
If you believe that there is something which we have not done correctly with your Personal Data then we would appreciate the chance to deal with your concerns before you approach a Supervisory Authority, so please contact us in the first instance at: privacy@DrinkTV.com.
Consent means your agreement which must be freely given, specific, informed and be an unambiguous indication of you, the Data Subject’s wishes, by which you, by a statement or by a clear positive action, signifies agreement to the Processing of Personal Data relating to you.
Data Controller means the person or organization that determines when, why and how to process your Personal Data. It is responsible for establishing practices and policies in line with the GDPR. For example, we are the Data Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes.
Data Subject means a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have various legal rights regarding their Personal Data.
EEA means the 28 countries in the EU, and Iceland, Liechtenstein and Norway.
Explicit Consent means consent which requires a very clear and specific statement (that is, not just action).
General Data Protection Regulation (GDPR) means the European Union General Data Protection Regulation ((EU) 2016/679). Applicable Personal Data is subject to the legal safeguards specified in the GDPR.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Personal Data means any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Special Category (Sensitive) Personal Data and pseudonymized Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal Data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behavior.
Processing or Process means any activity that involves the use of your Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.
Special Category or Sensitive Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and Personal Data relating to criminal offences and convictions.
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