Privacy Policy

                                                        OTTO DISTILLING 

1. Your privacy is important to us. It is Otto’s policy to respect your privacy regarding any information we may collect from you across our Site, website www.ottodistilling.com, and other sites we own and operate.  This Privacy Policy applies to any and all information that we collect on any Site where this Privacy Policy is posted, as well as information that may be collected offline, which we may combine with online data. Your use of this Site is subject to this Privacy Policy. By interacting with this Site, you consent to our collection and use of your information as described in this Privacy Policy.  We may change, update, or add to this Privacy Policy to the extent allowed by applicable law from time to time, so we encourage you to review this Policy periodically. 

2. We collect personal information from you individually, either directly or indirectly, when you interact with us on our Site. “Personal Information” or “Personal Data” refers to any information relating to an identified or identifiable natural person or household.  The personal information we collect may include: (a) information that you provide to us; (b) information that we automatically collect/generate; and (c) information that we obtain from third parties. We collect personal information to better meet the needs of our customers and to improve our offerings to you. The types of personal information that we collect include:

• Name, username, password, any unique user ID, registration information, contact details, mailing address, email address, geographic location, or telephone number
• Your date of birth as it applies to legal purchase age confirmation, which could include photographic proof of age
• Shopping habits, transaction history, and payment and purchase information, such as bank account, credit card information or delivery address
• Marketing communications, cookie preferences, and data gathered by cookies
• Information posted online and usage information about how you interact with our website, newsletters, and other online content
• Details of your contact with us, including phone calls, posted stories, testimonials, or reviews that you have submitted to us through our Site.
• General details about your hobbies, lifestyle interests, and consumption preferences
• Photographs or videos posted to our Site by you or other users, as well as photographs or videos taken on Otto premises or at events
• Personal information about third parties if you have disclosed that information to us. By disclosing this information, you certify that you have the authority to do so and that we are permitted to use any of this information in accordance with our Privacy Policy.

Most often, you voluntarily provide us with your personal information. This happens when you interact with us through our Site. Some interactions may include your use of our Site and apps, your purchase of products or services on our online or physical stores; or when you register on our website, sign up for promotions or sweepstakes, ask us a question, opt in for messaging or e-mail, apply for employment with us, or submit content or comments to Otto sites and social media channels.  Please be aware that feedback provided to us on our Site via submitted reviews, message boards, blog posts or chats, or social media engagement may be posted in a public forum and viewed by other users and members of the public. Please do not include any information that should be kept confidential.  From time to time, we obtain additional information from third-party data suppliers who source data from commercially and/or publicly available sources, such as data aggregators, public databases, or third-party social media or consumer feedback platforms. These items may include things like demographic information, device information, purchase preference information, or such other information involving personal preferences that we may need to help us to understand our customers.  When interacting with us you may encounter links to external sites or other online services, including those embedded in third party advertisements or sponsor information, that we do not control. We are not responsible for their privacy practices and data collection policies for such third party services. You should consult the privacy statements of those third party services for details.

3. We primarily use your personal information to improve the efficiency of our Site and the ways in which we provide services to you; as well as any information, products, or services that you may request from us. We also use your personal information to enhance your user experience and display the most appropriate and relevant content to you on our Site and upon other media through which you interact with us. Your personal information may also be used to verify your identity to comply with legal obligations, and to assist us in maintaining the security and integrity of our Site and business.  Any time that you make a purchase, request a refund or process a return through any of our Site, we may use data that we have collected from you to verify your identity and prevent fraudulent transactions. We may also use your personal information to verify your identity and distribute prize(s) in the event you are a winner in any promotions or sweepstakes offered by us.

4.  We may work with third-party advertising companies to deliver targeted ads on other websites and social media channels. This enables us to present you with advertising that we think you are most interested in viewing. These companies might also perform reporting and tracking functions on other websites and may place cookies on your device as you browse targeted advertisements. Third-party companies do not collect your personal information at our request, nor do we give or sell them your information as part of this interaction. Their processes are covered under their own respective privacy policies. The mere inclusion of a link on our Site does not imply any Otto’s endorsement of the linked services or sites.  As with all websites and apps, when you browse, click on advertisements, or use the tools on the Site, some information about your visit is automatically recorded using cookies and other similar information collection technology. This includes your IP address, your device operating system and browser type, the pages you viewed, and the date/time of your visit. We may also collect information using cookies.

5. We also collect information, via cookies, web beacons, pixels, tags or other tracking technologies, such as your Internet Service Provider and IP address, the date and time you access our website or mobile app, the pages you accessed while visiting our website or mobile app, and the Internet address from which you accessed our website or mobile app. Some cookies exist only during a single session and some are persistent over multiple sessions over time. We and our partners use these technologies to ensure basic functionality of our website and mobile app, to remember user preferences (including regarding your preferences regarding tracking technologies), maximize the performance of our website, mobile app, and services, provide you with offers that may be of interest to you, measure the effectiveness of our website, mobile app, and email campaigns and to personalize online content. These cookies and other technologies may be used to track you over time and across devices. When required by law, we only use these tracking technologies, when you have given us your consent to do so.  We may create a unique ID for your device or browser that may assist us in identifying it when it browses our site. This identification allows us to tailor content to you based upon your use of our Site and aids us in preventing fraud and other misuse of our Sites. The use of Cookies is subject to this Privacy Policy and all applicable regulations.  To the extent that any personal information is collected by or through these cookies, the contents of this Privacy Policy shall apply.

• To provide you with a more relevant and interesting experience, we may work with third party companies to display ads or customize the content on our website or mobile app. These companies may use cookies and similar tracking technologies as described in this Notice to gather information about your visits to the website or mobile app, as well as your visits elsewhere on the Internet. These companies also may use this information to provide you with more relevant advertising known as interest-based advertising. For more information about third-party advertisers and how to prevent them from using your information, please visit https://www.networkadvertising.org/choices/.  This is a site offered by the Network Advertising Initiative ("NAI") that includes information on how consumers can opt-out from receiving interest-based advertising from some or all of NAI's members. The Digital Advertising Alliance (“DAA”) also offers a choice mechanism with respect to certain types of data collection and use by third parties available at www.aboutads.info. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives. Similarly, asking our mobile apps not to track you/not agreeing or rejecting tracking technologies in our cookie banner/preference center/mobile app selection screen will only opt you out of those technologies, but not all advertising. Some browsers have incorporated Do Not Track (“DNT”) preferences. Most of these features, when turned on, send signals to the website you are visiting that you do not wish to have information about your online searching and browsing activities collected and used. As there is not yet a common agreement about how to interpret DNT signals, we do not honor DNT signals from website browsers at this time. However, you may not accept to/refuse or delete cookies. If you do not accept/refuse or delete cookies, some of our website functionality may be impaired or some of the advertising served to you may not be relevant for you anymore. If you change computers, devices, or browsers, or use multiple computers, devices, or browsers, and delete your cookies, you may need to repeat this process for each computer, device, or browser. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies. You can also find more information on managing cookies at All About Cookies - Manage Cookies at https://allaboutcookies.org/how-to-manage-cookies. 
• Our Site may make use of Google Analytics. This is a web analytics service which may use Cookies to gather and analyze data related to your use of our Site, as well as other sites, services and apps. Google may also transfer the personal information that it collects to third parties.  Google Analytics cookies collect your IP address; however, because IP anonymization is used on this website, your IP address will be shortened (and therefore anonymized) as soon as technically possible and before it is stored or otherwise used in connection with Google Analytics. The anonymization process takes place within the European Union or the European Economic Area, except in exceptional cases, where your full IP address may be sent to a Google server in the United States and shortened there. We use the information collected by Google Analytics cookies to find out about how visitors use our website, to throttle request speed and for advertising tracking. Google will not combine the IP address sent by your browser in connection with Google Analytics with other data. You can prevent Google Analytics cookies from being stored by setting your browser software accordingly or opting-out of Google Analytics by downloading and installing the browser plug-in available here: https://tools.google.com/dlpage/gaoptout. You can also change settings regarding which cookies and tracking technologies placed on your device you allow us and our partners to read, in our cookie preference center. Changing these settings will not delete these cookies, but we will no longer be able to utilize them for the purposes you decided to turn off.

6.  You have rights to control how your personal information is used. These include the right to withdraw previous consent and the right to limit communications from us. You have the right to access your personal information and the ability to update, amend, suppress, port or remove it from our records.  If we possess personal information belonging to you that is incorrect, you have the right to inform us that such information is incorrect and ask us to fix any errors. We will do this consistent with applicable law and within a reasonable amount of time. You may also exercise your rights and choices as they relate to interest-based ads from third-party and social media providers.  You may request to access, update, or remove your personal information. In some cases, we may need further information to verify your identity, or to identify your information within our system. We will respond to your requests consistent with applicable law. Please allow a reasonable period of time for your request to be processed.  Please contact us via the contact section on our website. 

7.  Interactions with us are intended for individuals 21 years of age and older. Our interactions are not directed at, marketed to, nor intended for, children under 21 or 16 years of age. We do not knowingly collect any information, including Personal Information, from children under 16 years of age. If you believe that we have inadvertently collected Personal Information from a child under the age of 16, please contact us at the address below and we will use reasonable efforts to delete the child’s information from our databases.  

8.  We maintain reasonable security procedures and technical and organizational measures to protect your Personal Information against accidental or unlawful destruction, loss, disclosure, alteration, or use.  Your Personal Information will be retained as long as necessary to fulfill the purposes we have outlined in Section 3. of this Notice, unless we are required to do so by applicable law.  This includes retaining your data to provide you with the services requested and interact with you; maintain business relationship with you/your company; determine eligibility of candidates, prepare for future contract establishment and keep data to account for future job offers; to manage relationship with our drivers; to improve our business over time; to ensure ongoing legality, safety and security of our services and relationships or otherwise in accordance with our internal retention procedures. Once you / your company has terminated the contractual relationship with us or otherwise ended your relationship with us, we may retain your Personal Information in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts, or for other legitimate business purposes, such as in order to enable easier future user onboarding, in order to evidence our business practices and contractual obligations, or to provide you with information about our products and services in case interest.  If you would like to know more about retention periods applicable to your particular circumstance, you can contact us.

9.  YOUR CALIFORNIA PRIVACY RIGHTS.  This section applies to certain California residents and supplements the rest of our Notice above. This section does not apply to the following information:

• Information about individuals who are not California residents;
• Information about our own employees, contractors, agents, and job applicants. Such information is subject to a separate privacy notice that we will make available to individuals.
• Information we collect from individuals with whom we engage in solely business-to-business communications and transactions, such as information about the employees of our business partners and customers;

Pursuant to the California Consumer Privacy Act of 2018, below is a summary of the Personal Information we collected from consumers, the sources from which we collected the Personal Information, the business or commercial purpose for which the Personal Information was collected and the categories of third parties with whom we share consumer Personal Information. The section references relate to the sections above in this notice.

• Source of Your Personal Information.  The categories of sources of personal information are detailed in Section 2 above and are summarized as follows: (a) directly from you, (b) through automated technologies or interactions, (c) public sources, and (d) from third parties.
• Uses of Your Personal Information.  The business and commercial purposes for which we collect personal information are detailed in Section 3 above and include purposes, such as : (a) performing services, (b) auditing, (c) legal and compliance, (d) quality assurance, (e) security, (f) debugging, (g) short term, transient use, (h) internal research, (i) corporate transactions, and (j) marketing.
• Sharing Personal Information.  Our data sharing practices are detailed in the chart below and align with the information provided above in Section 3 (Personal Information), Section 5 (Sharing), and Section 6 (How We Use Cookies and Automatic Data Collection Tools).

We may share this Personal Information with third-party groups, which may include: our affiliates, data processors, service providers (which includes those who help manage our Site and deliver our communications); business partners, third party advertising and analytics companies, third-party contest and promotions partners, successors-in-interest, or other such third-parties or affiliates to whom you have agreed or requested that we share your information.

Otto also reserves the right to share this Personal Information with our advisors, auditors, service professionals, government authorities or regulators, entities who may acquire your information as a result of merger, acquisition, or other ownership transaction in whole or in part; or other government agencies as required by international, federal, state, or local law.

The CCPA provides a right to California residents to request to opt-out of the sale of Personal Information. While we will not “sell” your information for money or other valuable consideration, we may allow third-party advertising companies to collect data from visitors to our Sites to better serve you more relevant advertisements. This may potentially be considered “sales” under CCPA under certain circumstances. You may submit a written request to us to mark your Personal Information as “Do Not Sell” by contacting us through the contact us link on the website. 

You have the right to request information about the categories of Personal Information we have collected about you, the categories of sources from which we collected the Personal Information, the purposes for collecting the Personal Information, the categories of third parties with whom we have shared your Personal Information, and the purpose for which we shared your Personal Information (“Categories Report”). You may also request information about the specific pieces of Personal Information we have collected about you (“Specific Pieces Report”).  You have the right to request that we delete Personal Information that we have collected from you.  You have the right to opt out of the sale of your Personal Information.  We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights.

In order to exercise your rights, we will need to obtain information to locate you in our records or verify your identity depending on the nature of the request. If you are submitting a request on behalf of a household, we will need to verify each member of the household in the manner set forth above. For a Specific Pieces Report, we will request your name, email, and phone number to verify your identity and seek a signed declaration, under penalty of perjury, that you are who you say you are. For a Categories Report, we will request name, email, and phone number to verify your identity. For a Right to Delete request, we will request your name, email, and phone number to verify your identity.  Authorized agents may exercise rights on behalf of consumers, but we reserve the right to also verify the consumer directly as described above. Authorized agents must upload documentation demonstrating the agent has authority to exercise rights on the consumer’s behalf. At a minimum, we will require evidence of the agent’s identity, proof of registration with the California Secretary of State, and at least one of the following evidencing proof of your legal authority to act on the behalf of the individual consumer:  Written authorization signed by the Consumer; or  Certified copy of a Power of Attorney granted under Probate Code.  We will address Requests to Opt-out within 15 business days. We will respond to Requests to Delete and Requests to Know within 45 calendar days, unless we need more time in which case we will notify you and may take up to 90 calendar days total to respond to your request. If you are a California resident, you may also opt out of sharing your Personal Information with third parties for the third parties’ direct marketing purposes. Please contact us if you would like to do so.

10. Privacy Information for Users Located in the European Union.  It is the intention of this Privacy Policy to be fully compliant with the General Data Protection Regulation of the European Union (GDPR). We aim to protect and keep the data of all citizens from the European Union (EU) safe from unauthorized access through this Privacy Policy statement. Please note that we use software from third party partners to ensure our compliance with all GDPR regulations.  For those individuals who are visiting our Sites from the EU, please be aware that your personal information may be stored and processed in the United States, which may have different data protection rules than your country of residence. By using these Sites, you give us your consent to store, process and transfer your information. If you object to such information being transferred, stored, or used in this or any way, please do not use our Site.  For those individuals visiting our Sites from the EU, please know that you may also file a complaint or allege an infringement of an applicable data protection law with a data protection authority in your country or region.  If you are a user visiting from the EU and would like to make a request to us to access, correct, delete, or port your personal information, or to file an objection to our processing of your personal information, please use the contact us form on the website.