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:
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.
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:
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.
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.
Otto Distilling Co.
1713R McKean Street Philadelphia PA 19145
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