Last updated 11/19/2021
Truman Vodka LLC, a Delaware limited liability company, operates the trumanvodka.com website. This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our website and the choices you have associated with that data.
What this policy covers
By using our websites, you signify your consent to the collection, use, storage, treatment, and disclosure of your personal information in accordance with this policy. If you do not agree with this policy, do not use our websites. For EU users, you may affirmatively opt-in to such collection, use, storage, treatment, or disclosure.
Children’s personal information
Our websites are not directed to children under the age of 21 We do not knowingly collect any personal information concerning or from children under the age of 21, except when consent is provided by a parent or guardian. If we learn that we have collected personal data from a child under 21 without parental consent, we will take steps to delete the information as soon as possible.
Non-personally identifiable information we collect
From time to time we automatically collect certain non-personally identifiable information when you visit any one of our websites, such as the time and date of your visit, the pages that you access, the website from which you linked to our website, the sections of the website you visit, and the number of times you return to the website. This information is not used to identify you, but is used in the aggregate for our internal marketing, system administration, website improvements and other similar purposes.
Examples of Cookies we use:
You may be able to disallow Cookies by modifying the settings in your browser. To learn more about Cookies, and how to disallow or manage them go to: http://www.allaboutcookies.org. If you choose not to accept Cookies, you may be unable to access certain parts or pages or our website. Your non-personally identifiable information may be disclosed to others and permanently archived for future use.
Personal information we collect
During your use of the websites, you may be asked to voluntarily provide certain personal information for purposes such as facilitating communications with you or for applying for access to certain special features or areas of the websites. This may include such information as name, address, telephone numbers, company name, job function, and email address.
We also automatically collect certain usage details, IP addresses, and Browser information. When you visit our website, we collect technical information such as the identity of your Internet Protocol (IP) address, your computer or device’s operating system and browser type, geo-location data, and the pages of our website that you visit. Most browsers transmit this type of information to websites automatically. We collect this information to administer and manage our website, to ensure that it functions properly and to review aggregate information.
Except as described above, we do not collect any personal information about you other than personal information which you expressly choose to submit to us directly or through our service providers.
How we use the information we collect
We use the information collected from us and/or our services providers (e.g., Amazon Web Services, WP Engine, and others)
We may also use information we collect to analyze user behavior as a measure of interest in, and use of our websites, and may disclose such analyses to advertisers or other third parties in the form of aggregate data, such as overall patterns or demographic reports that do not describe or identify any individual user.
We may disclose personal information about you to third parties: (i) if we have a good-faith belief that we are permitted or required to do so by law or legal process, (ii) to service providers who require access to such information for the carrying out of their mandate, (iii) to respond to legal claims, (iv) to protect our rights, property or safety or the rights, property or safety of others, or (v) to the resulting organization if we are involved in a merger or other reorganization. The disclosures referred to in this section may include transfers to entities located in other countries. Such transfers may include third parties located in other countries (such as Canada, Mexico, Caribbean, South America and EU countries). We have not confirmed that all such countries apply the same standards as required under the European General Data Privacy Regulations (“GDPR”); therefore, some risk exists regarding such transfers if the third parties are in countries where the European Commission has not made an adequacy determination nor adopted appropriate safeguards.
User-provided information and other parties
If you post information on our websites, or disclose it to any other party through any of our websites, you should be aware that your information may then be made available to others.
We may provide the information you provide us on a confidential basis with partners, contractors, vendors, or service providers for whom we provide services or that support our operations and our website, but only for those purposes. This may include, for instance, deploying marketing or informational emails and providing personalized web content.
We may also share your personal information with courts, law enforcement authorities, regulators, attorneys or other parties when it is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim, or for purposes of an alternative dispute resolution process; to comply with a subpoena or court order, legal process, or other legal requirement or when we believe in good faith that such disclosure is necessary to comply with the law, prevent imminent physical harm or material financial loss; to investigate, prevent or take action concerning illegal activities, suspected fraud, threats to us or our property; or as necessary in connection with an investigation of fraud, intellectual property infringement, piracy or other unlawful activity.
Links to Social Media and Third-Party Websites
We are not responsible for the privacy or security of any information you provide to a third-party website or the information practices used by any third-party site, including links to any third-party site from our website. We make no representations, express or implied, concerning the accuracy, privacy, safety, security or the information practices of any third-party site. The inclusion of a link to a third-party site on our website does not constitute any type of endorsement of the linked site by us. We are not responsible for any loss or damage you may sustain resulting from your use of any third-party website or any information you share with a third-party website.
Storing and securing your personal information
Your information may be subject to foreign laws and accessible to foreign governments, tribunals, law enforcement, and regulatory agencies. To help protect the confidentiality of your personal information, we employ security safeguards appropriate to the sensitivity of the information (including encryption in transit and at rest) and we limit access to your personal information solely to those employees, representatives and agents who require such information for the fulfillment of their functions and/or the carrying out of their mandates. We will keep such information only as long as necessary to fulfill the business purposes for which it was provided and to meet legal obligations. We will not use your personal information for making any automated decisions affecting your legal rights or for creating profiles other than as described in this Policy.
No method of data storage or data transmission can be guaranteed to be completely secure. Your use of our website, and any personal information you transmit to us, is at your own risk.
We may use third-party Service Providers to monitor and analyze the use of our website. Certain applications may also access personal information as well.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our website. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on (https://tools.google.com/dlpage/gaoptout) for your web browser.
Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Updating, Correcting or Withdrawing Your Personal Information
It is important that the personal information we have about you is accurate. If any of the personal information you provide us should ever change, for instance if you change your email address or phone number, or should you wish to change your preferences, to stop receiving announcements from us, to correct any inaccurate personal information about you, or to delete any personal information that you provided through your visits to our website, please let us know by sending an email to firstname.lastname@example.org. We are not responsible for any losses that could arise from any inaccurate, deficient, or incomplete personal information that you provide us.
For security reasons, we may need to request specific information from you to help us confirm your identity, before we correct, update or delete any personal information you provide us.
Right to access and/or correct personal information
At any time after we collect your personal information, you will have a right to access and/or to correct it. You may make such a request by sending a written request by email to email@example.com.
Right to withdraw consent
At any time after we collect your personal information, you will have an opportunity to withdraw your consent to its use or disclosure. You may make such a request by sending an email to firstname.lastname@example.org, or by calling us at (888) 363-7997.
If you contact us by e-mail, you should be aware that e-mail transmissions might not be secure. Information you send by e-mail could be viewed in transit by a third party. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during transmission.
The California Consumer Privacy Act (“CCPA” or “Act”), where applicable, grants residents of the State of California certain privacy rights in their personal information. However, CCPA’s requirements apply only to those entities that meet its definition of “business.” We do not meet that definition, and therefore we are not a “business” as defined by the CCPA. Nonetheless, we will endeavor to act in accordance with the CCPA to the extent that it is reasonable for us to do so. Because CCPA does not apply to us, all of the provisions below are subject to our sole discretion.
The CCPA defines personal information as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
Personal information under the CCPA, however, does not include the following:
Other information is excluded from the scope of the CCPA:
The categories of personal information collected and the purposes for which personal information may be used are described above in the sections entitled “Personal information we collect,” “How we use the information we collect,” and “User-provided information and other parties.”
Your CCPA Privacy Rights
The CCPA, where applicable, provides California residents with the right to request for disclosure of:
Requests to delete Personal Information
CCPA, where applicable, provides a right to request that deletion of any of your personal information collected from you. This must be made in a verifiable request. Once we receive and confirm your request, we will delete the information from our records unless an exception applies. CCPA, where applicable, provides that we are not required to comply with a request to delete personal information if the information is necessary to:
How to exercise your Privacy Rights
You can exercise these rights in several ways. You can make a request by calling (888) 363-7997, by submitting a request via email at email@example.com, by submitting a request on our website, www.trumanvodka.com or by sending a written request to Truman Vodka LLC, 100 South Biscayne Boulevard, Suite 3117, Miami, Florida 33131, Attention: Privacy Department. Additionally, regarding sale of personal information as defined in CCPA, you may make that request at our “Do Not Sell My Personal Information” form at www.trumanvodka.com/do-not-sell-my-data. At this time, however, Truman Vodka has no intent to sell any personal data in collects.
You may make the request on your own behalf or on behalf of your minor child. Another person who is legally authorized to act on your behalf may also submit a request for you. Please describe your request in sufficient detail to allow us to understand the nature of the request, evaluate and respond to it. Because CCPA allows certain disclosures and actions only upon receipt of a “verifiable consumer request,” please provide sufficient information with you request to allow us to verify that you are the person, or an authorized representative of that person, about whom we collected personal information.
How we will verify and respond
Before we respond to any request involving personal information, CCPA, where applicable, requires that we confirm the identity of the person making the request, and if the request is made on behalf of another person, his or her authority to make the request on the other person’s behalf. Accordingly, we reserve the right to deny any request where we are unable to satisfactorily confirm the identity or the right of the person to make the request. We will attempt to verify your identity by matching any information provided in the request against the personal information already in our possession. If you have authorized someone else to make a request on your behalf, we will attempt to verify the identity of that person and that you have authorized that person to submit a request on your behalf, which may include requesting a copy of any written authorization or power of attorney applicable to the request.
The amount of information we may require in our verification process will depend on a variety of factors including the nature of the request, the type, sensitivity, and value of the personal information in our possession, the potential risk of harm that could result from unauthorized access or deletion of your personal information, the likelihood that fraudulent or malicious actors would seek your information, and whether the information provided to us is sufficient to protect against fraudulent requests or being fabricated or spoofed. For example, we may require more points of confirmation if the request is to disclose specific pieces of information rather than only categories of information in our possession.
During our verification process, we may request additional information from you. Any such additional information will be used only for purposes of verification of the request.
We will endeavor to respond within forty-five (45) days of receipt of a verifiable consumer request. If, however, we are unable to respond within that time, we will notify you of the reason and the additional time needed to make our response. CCPA permits us to extend the time of our response by up to an additional 45 days.
If we deny a request in whole or in part, we will explain the reasons for our denial.
CCPA’s Limitations on Disclosures
We are not obligated under CCPA to respond to any request where compliance or disclosure would violate an evidentiary privilege under California law or conflict with federal or state law.
CCPA does no require that we provide personal information to a consumer more than twice in a twelve month period. Any disclosures we make in response to a request will cover only the twelve month period preceding the request.
We will not charge a fee to process or respond to your request and will provide the information free of charge. Where a person’s requests are repetitive, manifestly unfounded, or excessive, CCPA authorizes us to either charge a reasonable fee that takes into account our administrative costs, or refuse to act on the request and notify the person making the request the reason for our refusal. If we determine that a request warrants a fee, we will explain our decision and will endeavor to provide a cost estimate.
Regulations proposed by the California Attorney General prohibit us from disclosing specific pieces of personal information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of that information or the security of our systems or networks. The proposed regulations further prohibit us from disclosing in response to a consumer’s request a Social Security Number, driver’s license number, other government identification number, financial account numbers, health insurance or medical identification numbers, account passwords, or security questions and answers.
We will not discriminate against you for exercising any of your CCPA rights. This means, for instance, that we will not deny you services or charge you a different price, including a discount or other benefit, or impose a penalty for the exercise of your CCPA rights.
Other California Privacy Rights
The California Civil Code permits California Residents with whom we have an established business relationship to request that we provide you with a list of certain categories of personal information that we have disclosed to third-parties for their direct marketing purposes during the preceding calendar year. To make such a request please send an email to firstname.lastname@example.org. Please mention that you are making a “California Shine the Light” inquiry.
Visitors from Outside the United States
If you are visiting our website from outside the United States (“U.S.”), any information you voluntarily provide via our website and any technical information from the browser of your computer, tablet, or mobile device will be transferred out of your country and into the U.S. where we are located. The protections available to the privacy of your personal information in the U.S. may significantly differ from the protections available in your country. If you do not want any personal information to be transferred to the U.S., please do not provide that information to us via our websites.
Visitors from the European Union
On May 25, 2018 the General Data Protection Regulation (“GDPR”) went into effect in the European Union (“EU”). The GDPR extends certain rights to natural persons in the EU involving the privacy of their personal information.
We are the data controller for any personal information provided to us from persons in the EU. We do not have a representative in the EU. As noted earlier, we may transfer your personal data to another country or international organization as needed.
We will retain any personal information that you provide us for as long as necessary to fulfill the business purposes for which it was provided and to meet legal obligations, unless you request that information be deleted at an earlier date. If that information is subject to a litigation hold, or is required to assert or defend a legal claim, then we will hold that information until the claim or action is finally resolved.
The GDPR grants EU residents with the right to request that we update, correct, or complete his or her personal information, and to delete or erase any of that personal information from our records. It grants EU residents with the right to object to processing of personal information in certain instances, such as for direct marketing purposes. The GDPR also grants EU residents with the right to restrict the processing of personal information when you believe the information in our possession is inaccurate, that our processing is unlawful, that we no longer need the information for purposes of the processing, or where you have objected to that processing. You may withdraw your consent at any time to our possession or processing of your personal information. EU residents also have a right to request access to their personal information, and to request certain information about its processing. The GDPR also grants EU residents with the right to obtain a copy of any personal information that is processed by automated means which you voluntarily provided to us in a commonly used, structured, machine-readable format, or to have that information transferred to another controller when it is technically feasible. An EU resident can exercise any of these rights by sending an email to email@example.com.
You also have the right to lodge a complaint with the competent supervisory authority of an EU member state.
We will review any requests we receive from EU residents and will endeavor to respond in a timely manner. For security reasons, we may request specific information from you to help us confirm your identity before taking action on any request, and to ensure your right of access and the exercise of any GDPR right does not adversely affect the rights of others.
We reserve the right to refuse to act on a request, or to charge a reasonable administrative fee when a request is either manifestly unfounded or excessive because of its repetitive character, and to charge a reasonable administrative fee to requests for further or additional copies
Changes to this policy
We reserve the right to change or update this policy, or any other policies or practices, at any time, at our sole discretion, and without notice or liability to you or any other person. Any changes or updates will be effective immediately upon posting to any of the websites. The collection, use, and disclosure of your personal information by us will be governed by the version of this policy in effect at that time. New versions of this policy will be posted here. Your continued use of the websites will signify that you consent to the collection, use, and disclosure of your personal information in accordance with the changed policy. Accordingly, we recommend that you periodically review this policy to ensure that you are familiar with its most current version.