Privacy Policy

Last Updated: May 27, 2022

 

I. Scope of this Privacy Policy

We believe in transparency, and we’re committed to being upfront about our privacy practices, including how we treat your personal information. This Privacy Policy describes the types of information we collect through: https://nextglass.co; https://untappd.com; https://oznr.com; https://beeradvocate.com; https://hopculture.com; and https://getollie.com; and various related websites, mobile device applications, and services (collectively, the “Site”), and how we collect, use, and share that information. This Privacy Policy does not govern our collection of information through any other website or other means, other than through the Site.

 

By using the Site and/or submitting or collecting any personal data via the Site, you accept and expressly consent and agree to our practices surrounding the collection, use, and sharing of personal information (referring to any information that relates to an identified or identifiable individual) and non-personal information(referring to information that does not identify you as a specific individual).provided by you in the manner described in this Privacy Policy. If you do not consent and agree with the terms of this Privacy Policy, you cannot, and we do not authorize you to, access, browse, or use the Site.

 

Our processing of personal information, such as your name, address, e-mail address, or telephone number, shall be undertaken consistent with the requirements of applicable privacy laws, including, but not limited to, the California Consumer Privacy Act (“CCPA”), the General Data Protection Regulation (“GDPR”), the UK General Data Protection Regulation (“UK GDPR”),the Canadian Personal Information Protection and Electronic Documents Act(“PIPEDA”), and British Columbia’s Personal Information Protection Act (“PIPA”).The purpose of this Privacy Policy is to provide to users and potential users of our Site information about the nature, scope, and purpose of the personal information we collect, use and process and to advise data subjects of their rights. Whether we serve as the data controller or processor, we have implemented numerous technical and organizational measures to ensure the protection of personal information processed through the Site. However, Internet-based data transmissions may in principle have security gaps, so please understand that absolute protection is not assured.

 

Accountability with respect to your personal information is important to us. In the event that you have any questions (including how your personal information is managed), complaints or concerns about this Privacy Policy, or if you have reason to believe that we may have failed to adhere to it, please contact us anytime at privacy@nextglass.co.

 

II. Personal Information

 

A. Personal Information You Give Us

Except for physical location information and tracking technologies (as described below), you do not have to give us any personal information to browse this Site. However, you may be asked to provide personal information to submit or request information from us, or to use the services offered through this Site. Once you provide us with your personal information, you are no longer anonymous to us. This information may include:

 

Registration and Account Setup Information: In order to use certain aspects of the Site, will need to register for an account and submit a username and valid email address. You may also provide your name and other personal information (such as birthday, gender, location) in connection with your account and activity. You can edit or remove this information through your account settings. The username associated with your account (which you may modify in your account settings) is publicly displayed and connected to your Site activity. Other members may see the date you joined; ratings, reviews and information relating to items you review, and related photos you post.

 

Communications: When you signup to receive communications and marketing materials from the Site you are also required to provide personal information such as your name and email address.

 

Additional Information: In addition, you may be asked to provide optional personal information during registration to enhance the Site experience. Additional personal information that you may provide to us includes personal information provided through feedback, pictures you upload, comments, ratings, reviews, messages, emails, posts to public discussion boards, event registrations, and/or answers to surveys or questionnaires that you may submit.

 

Payment Information: If you choose to purchase any of our products or services, you will be required to provide personal information such as your name, email address, address, phone number, and payment information.

 

B. Personal Information We Collect

 

Location Information. In order to access and use certain areas or features of the Site, you consent to our collection and use of your personal information about your physical location if you use the Site on a device that has location enabled (including GPS, cellular, and Wi-Fi networks) or from your browser.

 

Automated Information Collection. In order to access and use certain areas or features of the Site, you consent to our collection and use of certain non-personal information about your use of the Site through the use of tracking technologies or by other passive means. Your consent to our access and use of this “passively collected” personal information includes, but is not limited to, the domain name of the website that allowed you to navigate to the Site, search engines used, the internet protocol (IP) address used, the length of time spent on the Site, the pages you looked at on the Site, other webpages you visited before and after visiting the Site, the type of internet browser you have, the frequency of your visits to the Site, and other relevant statistics, including the following:

 

Log Information: When you access the Site, you also consent to our servers automatically recording information that your browser sends whenever you visit a website. These server logs may include information such as your web request, IP address, browser type, browser language, the date and time of your request, your computer operating system, mobile device and mobile operating system, mobile device identifier (i.e., IDFA or Google ID), name of your internet service provider or your mobile carrier, and one or more cookies (small text files containing a string of characters) that may uniquely identify your browser. Our servers also automatically record what you click on while visiting the Site.

 

Location Information: You consent to our receipt of location data passed to us from location-enabled devices or that you have enabled, from your browser, or from third-party services.

 

Links: The Site may include links in a format that enables us to keep track of the IP addresses from which these links have been followed. You further consent to our collection and use this information to improve the quality of our Site, product(s) and our business operations.

 

URLs: When you visit or access the Site, you consent to our receipt of the URL of the site from which you came and links you click on to leave the site. Additionally, advertisers receive the URL of the page you were on when you click on an ad on the Site.

 

Cookies: When you visit or access the Site, you consent to our use of one or more cookies(small text files containing a string of characters) to your computer that uniquely identifies your browser. We use cookies to improve the quality of the Site by storing user preferences, tracking user trends, and providing personalized content and ads. Most web browsers accept cookies automatically, but can be configured not to do so or to notify the user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. Please note that if you disable cookies, you may not be able to use some customized features available through the Site. For more information, including an opt-out, please visit our Cookie Policy.

 

Web Beacons: Our Site may contain electronic images known as web beacons (also called single-pixel gifs and transparent graphic images) that we use to help deliver cookies on our sites, count users who have visited those sites, deliver services, and analyze the effectiveness of our promotional campaigns, for example. We may also include web beacons in our marketing email messages or newsletters to determine whether an email is opened or if links are clicked. You consent to our use of web beacons to facilitate Site administration and navigation, to track the actions of users of the Site, to compile aggregate statistics about Site usage and response rates, and to provide an enhanced online experience for visitors to the Site.

 

Aggregate Information: We may compile and use certain personal information collected through the Site on an aggregate basis. However, such aggregate information does not identify you individually.

 

C.   How We Use Personal Information

 

We comply with our obligations under applicable privacy laws by: keeping personal information up to date where needed based on the purposes for which the personal information is being processed; by not collecting or retaining excessive amounts of data; by ensuring that appropriate technical measures are in place that are designed to protect personal information from loss, alteration, misuse, unauthorized access and disclosure as it is transmitted, stored, or otherwise processed, and by using appropriate measures to securely destroy personal information when it is no longer needed.

 

Personal information collected through the Site may be used by us and our affiliates for purposes of:

 

o   Responding to your questions and feedback;

o   Providing the services you select through this Site;

o   Tailoring and delivering targeted advertisements to you;

o   Contacting you, whether by email, postal mail, or telephone with information about this Site, our products, or our services;

o   Auditing, research, and analysis to maintain, protect, and improve this Site and our services;

o   Ensuring the technical functions of our network;

o   Improving and customizing the content and layout of the Site;

o   Developing new products and services;

o   Compiling personal information and other information collected through the Site on an aggregate basis; and

o   For such purposes as you may authorize at the time you submit the information.

 

Although the sections above describe our primary purpose in collecting your personal information, in many situations we have more than one purpose. For example, if you complete an online purchase we may collect your personal information to perform our contract with you, but we also collect your personal information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your order. As a result (and as permitted by applicable law), our collection and processing of your personal information is based in different contexts up on your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

 

D.  Personal Information We Share

 

We may share your personal information collected through the Site for any lawful purpose, including in the following ways:

 

In Connection with our Offerings. The Site involves the sharing of certain personal information collected through the Site with (i) other users of the Site, and(ii) as you otherwise provide your consent. Information which you upload, post, e-mail, submit or otherwise transmit in connection with the Site to a public message board, chat area or other public area of the Site will be made public to users of the Site, including certain metadata related to such activities(such as timestamps). You are solely responsible for any such personal information you choose to post on or through the Site. All information that is posted to a message board, chat area, or other public area of the Site may be shared by us with (i) other users of the Site, and (ii) as you otherwise provide your consent. Please be aware that anything you share publicly may be further shared by other users of the Site (for example, by emailing a screenshot of your post to non-users). We are not responsible for any such sharing of information you have shared publicly on the Site.

 

Subsidiaries and Affiliates. We may share personal information with our subsidiaries and affiliates for the purposes for which you provided the information or as reasonably necessary for our internal administrative and business purposes.

 

Service Providers. We work with third parties that provide services on our behalf. Among other things, business partners may help us to administer and host our Site, assist or support our business operations, conduct surveys, provide technical support, conduct research and analysis, provide marketing services, process payments, and assist in the fulfillment of orders.. We may share personal information and non-personal with these service providers, vendors, sales brokers, and retail partners (and their service providers) for the purpose of enabling them to provide these services.

 

Partner Promotion. We may offer contests, sweepstakes, or other promotions with third party partners. If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third party partner, the personal information that you provide will be disclosed to such third party partners, and their use of your personal information is not governed by this Privacy Policy.

 

Marketing. We may disclose, sell, rent, loan, transfer, and/or trade your personal information to unaffiliated third parties for any of the purposes specified in this Privacy Policy, including for such third parties to use your personal information for their own marketing purposes, to send marketing solicitations to offer products or services, and to use the personal information for data validation, data enhancement, data information authentication/verification, and/or data suppression services. For example, we may sell personal information to third party advertising service providers to help facilitate their data marketplace offerings with data buyers, and to third party data analytics service providers to help facilitate their data matching offerings with data authentication customers.

 

Required by Law. We may disclose personal information or any information collected through this Site if we are required to do so by law or pursuant to legal process, in response to a request from government officials or law enforcement authorities, or as necessary or appropriate in connection with an investigation of illegal activity.

 

Certain Transactions. We may disclose or transfer personal information or any information collected through this Site to third parties who acquire all or a portion of our business, whether such acquisition is by way of merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.

 

Interest-Based Advertising. We participate in Interest-based advertising. This means that you may see advertising on the Site tailored to how you engage or browse, or you may see advertising for us on other websites, applications and social media based on your behavior across websites, applications and social media. We may target ads based on data we have collected, or data provided by third parties alone or in combination with the data we collect ourselves. If you choose to interact with specific third parties who advertise through the Site, the information you provide to them is subject to the conditions of their specific privacy policies. By using the Site you agree to usage tracking and targeted interest-based advertising. If you do not wish to have cookies track your usage for these purposes, please visit each website’s respective Cookie Policy page for information regarding how to refuse all or some browser cookies, or do not use the Site.

 

Consent. We may share personal information in accordance with any consent you provide.

 

III. Non-Personal Information

We may compile non-personal information and de-identify and use personal information collected through the Site on an aggregate basis. This information may include, without limitation, the number of users who have registered for the Site and demographic information about users and usage of the Site. Such aggregate non-personal information does not identify you individually.

 

We may sell, rent, loan, transfer, and/or trade such non-personal information to third parties for any of the purposes specified in this Privacy Policy, and for any other lawful purpose. For example, we may sell non-personal information to third party advertising service providers to help facilitate their data marketplace offerings with data buyers. We may also provide our third party customers in the beverage industry with non-personal information that they use for their own measurement, communications and marketing purposes. For example, certain of our customers use this non-personal information to update their menus, select products to stock in their stores, and communicate available products to their customers.

 

IV. Your Choices

 

A.        Information You Provide You can always choose whether or not to provide personal information on the Site. However, if you choose not to disclose certain personal information, you maynot be able to register as a user of the Site, which may limit your access to certain portions of the Site. However, we will not discriminate against you for exercising any of your rights, including otherwise denying you goods or services, providing you with a different level or quality of services, or charging you different prices or rates for services.

 

B.        Privacy Settings By default, certain types of information you choose to submit will be made public to users of the Site. This includes your account username, profile picture, and any comments or posts you make to public posts or discussion boards. You can control whether other profile and activity information as described in Section II will be shared publicly with all users of the Site, or limited to users that you have friended.

 

C.        Communications From Us If at anytime you decide that you no longer wish to receive notices from us regarding the Site, you may indicate this preference by contacting us at privacy@nextglass.co

 

D.        Do Not Track As described in more in our Cookie Policy located at each website’s respective Cookie Policy page, you can configure your browser not to accept cookies or to notify you when a cookie is being sent.

 

E.        Your Rights and Your Personal Data under the GDPR, UK GDPR, PIPEDA and PIPA Unless subject to an exemption, if your personal data is subject to the GDPR, UK GDPR, PIPEDA or PIPA you have the following rights with respect to your personal data:

 

o   The right to request a copy of your personal data which we hold about you;

o   The right to request that we correct any personal data if it is found to be inaccurate or out of date;

o   The right to request your personal data be erased where it is no longer necessary for us to retain such data;

o   The right to withdraw your consent at any time to the processing of personal data to which you provided consent for processing;

o   The right to request that we provide you with a copy of your personal data and where possible, to transmit that data directly to another data controller (known as the right to data portability);

o   The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction be placed on further processing;

o   The right to object to the processing of personal data (where applicable); and

o   The right to lodge a complaint with a data supervisory authority.

 

Please note that we may verify your identity before we are able to process any of the requests described in this Section, and in our discretion, deny your request if we are unable to verify your identity. As a part of this process, government or other identification may be required.

If your personal data is subject to the GDPR or UK GDPR, we will transfer personal data from the European Economic Area (EEA) to a location outside the EEA only when there has been a documented adequacy determination, or where we have confirmed adequate privacy protections. If we transfer personal data to a third party acting as our agent, we will also obligate the third party to have adequate privacy protections in place. If your personal data is subject to PIPEDA, we will transfer personal data from Canada to locations outside of Canada only where we have confirmed adequate privacy protections. If we transfer personal data to a third party acting as our agent, we will also obligate the third party to have adequate privacy protections in place. We may transfer personal data to and on behalf of clients and third parties with whom we have an existing service agreement or as part of our legal obligations, each of which shall be subject to our policies, and only to the extent necessary for purposes of legitimate interests pursued by the data controller (or by a third party).

We do not engage in automated decision making.

If your personal data is subject to PIPA, the Next Glass Privacy Officer is James Smith and can be contacted at trace@nextglass.co.

The data controller for provisions related to data protection is Next Glass, Inc., Attn: privacy@nextglass.co

 K. California Privacy Rights

In the preceding twelve (12) months, we have collected and disclosed for a business purpose the following categories of personal information about California consumers:

Category Examples Collected? Categories of Recipients

Identifiers Name, address, e-mail address, IP address Yes ·     IT service management providers

·     Email marketing website vendors

·     Data analytics providers

·     Security vendors

·     Background check vendors

·     Employment agencies or recruiting vendor

Personal information categories listed in the California Customer Records statute Name, professional-related information; and employment-related information

Yes ·     IT service management providers

·     Email marketing website vendors

·     Data analytics providers

·     Security vendors

·     Background check vendors

·     Employment agencies or recruiting vendors

Protected classification characteristics under California or federal law Name, age, citizenship, nationality, ancestry, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, proof of eligibility to work

No n/a

Commercial Information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Yes ·     IT service management providers

·     Email marketing website vendors

·     Data analytics providers

·     Business partners

·     Product fulfillment partners

Internet or other similar network activity Browsing history, search history, information on a consumer’s interaction with the Website

Yes ·     IT service management providers

·     Email marketing website vendors

·     Data analytics providers

Geolocation data IP address data Yes ·     IT service management providers

·     Email marketing website vendors

·     Data analytics providers

·     Business partners

Professional or employment-related information Proof of eligibility to work, resumé, other professional-related information and employment-related information

No n/a

Biometric information Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. No n/a

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. No n/a

Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Yes ·     IT service management providers

·     Email marketing website vendors

·     Data analytics providers

·     Business partners

Purposes for Collection, Use, and Sharing. We may sell, use and disclose the personal information we collect for our commercial purposes, as further described in this Privacy Policy, including for our business purposes with our partners and service providers as follows:

• Auditing related to our interactions with you;

• Legal compliance;

• Advertising and marketing;

• To provide content

• To provide goods or services that have been purchased by you, for you, or on your behalf;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and exercising our related rights;

• Debugging;

• Performing services (for us or our service provider);

• Internal research for technological improvement;

• Internal operations;

• Activities to maintain and improve our services; and

• Other one-time or short-term uses.

Sales of Personal Information. In the preceding twelve (12) months, we have sold the following categories of personal information:

• Geolocation data

• Commercial Information

• Inferences drawn from other personal information

• Protected classification characteristics under California or federal law

We sell your personal information to our business partners solely for the purposes of fulfilling your product orders and advertising.

Your Rights. Where applicable, if you are a California resident you may have the following rights under the CCPA in relation to personal information we have collected about you, to the extent required by the CCPA and subject to verification and any applicable exceptions:

Right to Know/Access: You have the right to request that we disclose certain information to you about our collection and use of certain personal information about you as described below:

• The specific pieces of personal information collected;

• The categories of personal information collected;

• The categories of sources from whom the personal information is collected;

• The purpose for collecting the personal information; and

• The categories of third parties with whom we have shared the personal information.

Right to Delete: You have the right to request that we delete your personal information.

Freedom from Discrimination: You have the right to be free from unlawful discrimination for exercising any of the rights above.

Opt Out of Sale: You have the right to opt out of sale of your personal information to a third party.  Please note that this does not stop us from distributing this information within our organization across business units.  Additionally, your right to opt out does not stop all transfers to third parties as we can continue to provide your personal information to our service providers pursuant to a written contract that meets requirements within the CCPA.  Furthermore, we can continue to provide data that does not meet the definition of personal information. This right to opt out applies to all California consumers ages 16 or older and may be exercised at any time. We will honor all such requests unless you subsequently decide to opt in to the sale of your personal information.

The sale of personal information does not include if you direct us to interact with a third party, any third party alerts that you have opted out of, the sharing of information is necessary to perform a business purpose and meets the other conditions specified, or the information is transferred as part of an asset in a merger, acquisition, bankruptcy or other change of control event.

If you wish to exercise your right to opt out, please contact us using the information in Section X below.  We will honor your request for twelve (12) months before we ask you to opt in to the sale of your personal information.

To make a request in relation to the above rights, please contact us using the information in Section X below.  To fulfil your request, we will need to verify your identity.

Only you, or someone legally authorized to act on your behalf, may make a request related to personal information collected about you. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.

 

V. Information Storage and Security

 

We employ commercially reasonable safeguards and security precautions to help protect against the loss, misuse, and alteration of personal information provided on or through the Site. These safeguards and security measures include: storing passwords in hashed form, anti cross-site-request forgery measures, SSL encryption of CMS communications, and a monitoring system to actively screen for unwanted behaviors. However, no method of transmitting or storing data is completely secure. As a result, although we strive to protect personal information about you, we cannot guarantee the security of any information you transmit to us through or in connection with the Site. If you have reason to believe that personal information is no longer secure, please notify us immediately by contacting us in accordance with the last section below.

 

VI. Special Notes about Children and Certain Privacy Rights

 

Individuals under the age of 18 may not use the Site or not submit any personal information to us. If you are a minor, you can use the Site only in conjunction with your parents or guardians.

 

If you are a California resident, the CCPA provides you with certain rights over your personal information (defined under the CCPA as information which 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). In addition, the term “sale” is defined broadly under the CCPA. To the extent that “sale" under the CCPA is interpreted to include interest based advertising or other data uses described in this Privacy Policy, we will comply with applicable law as to those activities. You can read more about your rights and choices with respect to your personal information that is held by us under the CCPA at each Site’s respective CCPA Notice page.

 

If you are a Nevada resident, you have the right to opt-out of the sale of your personal information collected by us through the Site.

 

VII. External Links

 

The Site may contain links to various websites that we do not control. When you click on one of these links, you will no longer be transacting business through the Site. Third party websites maintain their own privacy policies, and we do not exercise any control over any of the third party websites that may be linked to the Site. If you visit a website that is linked to the Site, you should consult that website’s privacy policy before providing any personal information. Please be aware that we are not responsible for the privacy practices of such other websites, and we are not liable for their misuse of personal information about you.

 

VIII. Special Admonitions for International Use

 

The Site is hosted in the United States. All matters relating to the Site are governed exclusively by the laws of the State of Delaware in the United States of America and not the jurisdiction in which you are located. If you are located outside of the United States of America and you contact us, please be advised that any information you provide to us will be transferred to the United States of America and that by submitting information, you explicitly authorize such transfer.

 

IX. Updates to this Privacy Policy

 

We may change or update the Site or any of our policies and procedures without prior notice, except that if any changes are likely to have an adverse impact on your rights under data protection law, we will use reasonable efforts to notify you of the changes in advance in writing or by post mail, and, where required, obtain your consent to our activities. We will post a notice on this Site to advise you of any significant changes to this Privacy Policy and indicate via the “Last Updated” legend in this Privacy Policy when it was most recently updated. Except to the extent that your express consent to any change or update is required under data protection law, your continued use of the Site signifies your continued assent to the terms of this Privacy Policy, as updated or amended at that time.

 

X. Questions Regarding this Privacy Policy

Any individual may, at any time, contact us directly with any questions and suggestions concerning data protection. We encourage individuals to raise any concerns about the collection, use, or processing of your personal data using the contact information provided above. In the event of a privacy related issue or complaint, we will investigate and attempt to promptly resolve any complaints and disputes regarding use and disclosure.

If you have any questions or comments regarding this Privacy Policy, please send us an emailat privacy@nextglass.co