Last Revision Date: 8/1/23
Imbibe Media, Inc. and its affiliated website Negroni Week (“Imbibe,” “Company,” “us,” “our,” or “we”) respect your privacy and is committed to protecting it through our compliance with this policy.
Who We Are
Negroni Week by Imbibe Media, Inc. is a celebration of one of the world’s great cocktails and an effort to raise money for charitable causes around the world. Our primary office is located at 1001 SE Water Ave., Ste 285, Portland, OR 97214.
How to Contact Us
Attn: [Web Team]
1001 SE Water Ave., Ste 285
Portland, OR 97214.
You may also email negroniweek @ imbibemagazine.com
Scope of This Policy
- On or though this Website;
- In e-mail, text, and other electronic messages between you and this Website; and
- When you interact with third-party services operated on our behalf on the Website, such as commenting platforms or contact us forms.
Website Visitors Under the Age of 21
Our Website is not intended for people under 21 years of age. No one under age 21 may use or provide any Personal Data to or on the Website. We do not knowingly collect Personal Data from anyone under 21. If you are under 21, do not provide any information on this Website or on or through any of its features, register on the Website, make any purchases through the Website, make any donation through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, e-mail address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a person under 21, we will delete that information. If you believe we might have any information from or about a person under 21, please contact us at email@example.com.
Categories and Sources of Personal Data
The following describes the categories of data relating to identified or identifiable individuals and households (“Personal Data”) that we collect and how we collect it.
CATEGORIES OF PERSONAL DATA
We may collect several categories of Personal Data from and about users of our Website, including:
Contact Data: Identity Data that relates to information about how we can communicate with you, such as email, phone numbers, physical addresses, social media handles, and information you provide to us when you contact us by email or when you communicate with us via social media, including records and copies of your correspondence (including e-mail addresses), if you contact us.
Device/Network Data: Browsing history, search history, and information regarding your interaction with a web site, application, or advertisement (e.g. IP Address, MAC Address, SSIDs or other device identifiers or persistent identifiers), online user ID, device characteristics (such as browser/OS version), web server logs, application logs, browsing data, first party cookies, third party cookies, web beacons, clear gifs, embedded pixels, and pixel tags.
Identity Data: Information such as your name; address; email address; telephone number; account login details, including your user name and password; information you provide in connection with your application to register your venue; your identity, , and similar information.
Inference Data: Personal Data we infer about infer or create about you, e.g. preferences, characteristics, interests, marketing segments, likes, favorites and other data or analytics.
Sensitive Personal Data: Personal Data deemed “sensitive” under California or other laws, such as social security, driver’s license, state identification card, or passport number; account log-in and password, financial account, debit card, or credit card number; precise location data; racial or ethnic origin, religious or philosophical beliefs, etc. We collect the following category of Sensitive Personal Data: “Payment Data” Information, such as bank account details, payment card information, including similar data protected as Sensitive Data under applicable law, and relevant information in connection with a financial transaction.
Transaction Data: Data about transactions you carry out through our Website, including purchases made through our Website and the fulfillment of your donations.
User Content: Unstructured/free-form data that may include any category of Personal Data, e.g. Personal Data you provide when you complete forms on our Website or submit content. May also include your responses to surveys that we might ask you to complete for research purposes, or information you provide to enter a contest or promotion sponsored by us and when you report a problem with our Website.
SOURCES OF PERSONAL DATA
We collect Personal Data from various sources, including:
Data you provide us: We receive Personal Data you provide to us, such as when you create a customer account, make a donation, purchase our products, enter a search query on the Website, contact us, or when you join our mailing list.
Data we collect automatically: We collect Personal Data about or generated by any device you have used to access our Website. May include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies. May also include details of your visits to our Website, including traffic data, logs, and other communication data, and the resources that you access and use on the Website, as well as information about your online activities over time and across third-party websites or other online services (behavioral tracking).
Data we create and infer: We, certain partners, social media companies, and third parties operating on our behalf create and infer Personal Data such as Inference Data or Aggregate Data based on our observations or analysis of other Personal Data processed under this Policy, and we may correlate this data with other data we process about you. We may combine any Personal Data about you that we receive from you and from third parties.
Data Processing Contexts/Notice at Collection
We process Personal Data in the contexts and for the purposes set forth below:
WHEN YOU CREATE A NEGRONI WEEK ACCOUNT OR REGISTER AS A PARTICIPATING VENUE
When you register for an account with us, or enroll as a venue participating in Negroni Week events, we generally process Identity Data, Device/Network Data and Contact Data. A full name and email address is required to register a customer or venue account. We process this Personal Data to open and maintain your account, provide you with information relevant to your account, and otherwise provide the features and services you request. We may use your Personal Data to respond to any emails or other communications you send to us, to advise you of any changes to our Website or any products or services we offer or provide though it, or to advise you of any problems with this Website. In addition, subject to applicable law, we may also enroll you in marketing communications, e.g. with information regarding services and events that we believe you may be interested in (see more below). You may opt-out of receiving marketing communications from this website by contacting us directly at firstname.lastname@example.org, or by following the “unsubscribe” process at the bottom of the promotional email.
We may also use this Identity Data, Contact Data, and Device/Network Data collected in this context for our Business Purposes. Please note, we may share venue name and non-Personal Data with our Sponsors and post participating Venue information publicly on our Website.
WHEN YOU MAKE A DONATION OR PURCHASE
We process any Personal Data we receive following these transactions as necessary to perform or initiate a contract with you, process your order and payment, and carry out fulfillment and delivery of the transaction. In addition, we or our service providers may collect Device Data and create Inference Data. Payment Data, together with other data we process in this context, is used as necessary in connection with our Business Purposes, as described below. In addition, we may share Personal Data collected through a donation transaction with the third party to which you have donated for the purposes of processing the donation, providing documentation of transactions, or as otherwise appropriate to complete your requests.
WHEN YOU ACCESS OR USE OUR WEBSITE
The Website may, with your consent, process Location Data. We use this data, together with Inference Data, and Device/Network Data in order to provide contextual information to you, such as estimated shipping costs, prices in your local currency, or to show you content related to your location (such as partner events or venues). We may also use this information in connection with our legitimate business interests, such as, creating aggregate information about users’ location and patterns, which we use to help improve our Website, and for our other Business Purposes.
We may process Identity Data, Device Data and Contact Data in connection with email or SMS marketing or promotional communications, which you might receive (subject to limitations of applicable law) if you register for an account, choose to receive marketing communications, or engage in a transaction allowing us to send you those marketing communications. Subject to your rights and choices, we use Identity Data and Contact Data as necessary to customize, deliver, and otherwise process marketing communications, in order to tailor certain communications to individuals’ preferences and requests, and for other appropriate Business Purposes.
We may also automatically collect Device Data and related Identity Data from devices receiving those marketing communications if you open or interact with those marketing communications, and we may create Inference Data derived from that data. We may process such Personal Data as part of our business interests in understanding whether our emails are opened or other aspects of engagement with such marketing communications.
WHEN YOU CONTACT US
We collect and process Identity Data, Contact Data, or User Content you provide as necessary to address your request, fulfill the purpose for which that information was provided, or for other related purposes. Where permitted by law, and relevant to your request, we may enroll you in marketing communications (described below). We may also use this Identity Data, Contact Data, and Device/Network Data collected in this context for our Business Purposes.
COOKIES AND OTHER TRACKING TECHNOLOGIES
- Strictly Necessary: for “essential” purposes, such as to enable certain features of our Website that cannot be turned off in our systems, and which are required for our Website to function (for example, a strictly necessary cookie may allow a customer to log in or complete a form on our Website).
- Functional: for enhanced functionality and personalization of our Website. Some of these may be set by us, and others may be set by third party service providers if we have added their services to our Website. Without these cookies, some features of our Website may not function properly.
- Analytics: for “analytics” purposes, such as to analyze the traffic to and usage of our Website for example, how many people have looked at a page, how visitors move around the Website, what website they visited prior to visiting ours, and use this information to understand user behaviors and improve the design and functionality of the Website); estimate our audience size and usage patterns; store information about your preferences, allowing us to customize our Website according to your individual interests; speed up your searches, or recognize your device when you return to our Website.
If you wish, you can manage/deny cookies (and certain technologies) using your browser’s settings menu. Some devices allow you to control this through your device settings. If you choose not to receive cookies at this time, websites may not function properly and certain services may not be provided.
Please, note that certain third parties may be able to identify you across sites and services using these cookies and similar tracking technologies. The use of third party technologies by third parties may be subject to their own privacy policies.
PURPOSES OF PROCESSING
We and our service providers process Personal Data we hold for numerous business purposes, depending on the context of collection, your rights and choices, and our legitimate business interests. For example, we generally process Personal Data in connection with the following “Business Purposes”:
Service Provision and Contractual Obligations
We process any Personal Data as is necessary to provide our Websites, to provide you with the products you purchase, to authenticate users, and as otherwise necessary to fulfill our contractual obligations to you. Failure to provide such information may result in our inability to complete the transaction or provide the service you request.
Internal Processing and Service Improvement
We may use Personal Data for our legitimate interests in/business purposes related to improving our Websites, understanding how our Websites are used, for customer service purposes, in connection with logs and metadata relating to service use, and for debugging, and similar purposes. Additionally, we may use Personal Data as necessary to as necessary to understand the performance of our Services, what products our customers view or purchase, for internal purposes such as auditing or data analysis, Website usage and performance improvement, or for troubleshooting.
Security and Incident Detection
We may process Personal Data legitimate interests in/business purposes related to improving the security of our Websites, identifying and preventing crime or fraud, and detecting potential personal data breaches or incidents. We may analyze network traffic, device patterns and characteristics, maintain and analyze logs and process similar Personal Data in connection with our information security and anti-fraud activities.
We process Personal Data about our customers and users for our legitimate interests in/business purposes related to identifying trends and use of our Service, e.g. to create aggregated or anonymized data about buying and spending habits, the use of our Websites, and other similar information (“Aggregated Data”). For example, we may process Aggregate Data to determine audience responses to various content or media, and other aspects of our Websites. We may also retain and use this information in connection with the development of products or Websites. We may pass Aggregated Data to certain third parties to give them a better understanding of our business and to improve our Websites. Aggregated Data will not contain information from which you may be personally identified.
We process certain Personal Data as appropriate in connection with our legitimate interests in/business purposes related to the personalization of our Services. For example, aspects of the Services may be customized to you so that it displays your name or reflects your preferences, to display content or features that you have interacted with in the past, or to display material that we think may be of interest to you based on your interactions with our Services. This processing may involve the creation and use of Inference Data relating to your preferences.
We process certain Personal Data as appropriate in connection with our legitimate interests in/business purposes related to communicating with users about our service. For example, we may reach out to you about your transactions or account, provide other relevant notifications or information, or request information or feedback. Similarly, we may use your Personal Data to send important notices, such as communications about purchases and changes to our terms, conditions, and policies, or other information that relating to the products you have purchased or your use of our Service.
We process certain Personal Data as appropriate in connection with our legitimate interests in/business purposes related to corporate operations/activity. For example, we may process Personal Data as necessary to carry out actual or prospective corporate transactions, e.g. as part of corporate restructuring, mergers, acquisitions, and other similar administrative purposes, including related due diligence.
Compliance Safety, and Public Interest
We may also process any Personal Data as necessary to comply with our legal obligations, such as where you exercise your rights under data protection law and make requests, to ensure content or advertising is directed to users eligible to participate in advertised Websites or view such content/advertisements, for the establishment and defense of legal claims, or where we must comply with our legal obligations, lawful requests from government or law enforcement officials, and as may be required to meet national security or law enforcement requirements or prevent illegal activity. We may also process data to protect the vital interests of individuals, or on certain public interest grounds, each to the extent allowed under applicable law.
How We Share Personal Data
Affiliates: We may share Personal Data internally with our current and future subsidiaries and affiliates.
Service Providers & Agents: In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests and business purposes, we may share your Personal Data with service providers, contractors, and other third-parties who provide certain services or process data on our behalf. For example, we use third parties to host our Website and email server, provide cloud storage, send certain emails, process credit card payments, deliver packages. These companies only have access to personal information needed to perform their functions, but may not use it for other purposes. If you make a donation, we also share with our associated charities to fulfill the donation and so that they can deliver your donation receipts to you.
Partners: We may offer you the opportunity to use services operated by third parties (such as our event partners or sponsors.), and if you choose to use these services, we will disclose the Personal Data that you direct us to provide to them or as is appropriate to fulfill your requests.
Corporate Events: Your Personal Data may be shared with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Imbibe’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Imbibe about our Website users is among the assets transferred.
Legal Disclosures: In limited circumstances, we may, without notice or your consent, access and disclose your Personal Data and any other information that we may have about you to the extent we believe such disclosure is legally required, to prevent or respond to a crime, to investigate violations of our Terms and Conditions or a customer agreement, or to protect the rights, property, or safety of Imbibe, our customers, or others. We may, in our sole discretion (but without any obligation), object to the disclosure of your Personal Data to such parties.
We use commercially reasonable measures to secure your personal information against accidental loss and unauthorized access, use, alteration, and disclosure. Information you provide to us is stored on secure servers behind firewalls, and payment transactions are encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
International Transfers of Personal Data
How We Retain Your Personal Data
Retention periods established under applicable law;
Industry best practices;
Whether the purpose of processing is reasonably likely to justify further processing;
Risks to individual privacy in continued processing;
Applicable data protection impact assessments;
IT systems design considerations/limitations; and
The costs associated continued processing, retention, and deletion.
We will review retention periods periodically and may pseudonymize or anonymize data held for longer periods.
Your Right and Choices
Data Rights Overview
You may have certain rights and choices regarding the Personal Data we process. Please note, these rights may vary based on the country or state where you reside, and our obligations under applicable law. See the following sections for more information regarding your rights/choices in specific regions:
To submit a request to exercise your rights in your Personal Data, please contact us at email@example.com.
There may be situations where we cannot grant your request, e.g. if we are legally obligated to keep Personal Data to comply with applicable law. We may also decline to grant a request where our legitimate use of the data outweighs individual privacy concerns, e.g. in relation to anti-fraud and security purposes, or a request for deletion of an account that is being investigated for security concerns. We may also deny your privacy request if it jeopardizes the privacy of others, is frivolous or vexatious, and where applicable law allows the denial.
Verification of Rights Requests
If you decide to exercise your rights, to help protect the security of your Personal Data, you will be asked to verify your identity to ensure that you have the right to make that request, to reduce fraud, and to ensure the security of Personal Data. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.
We may require that you match personal information we have on file in order to adequately verify your identity. If you have an account, we may require that you log into the account to submit the request as part of the verification process. We may not grant access to certain Personal Data to you if prohibited by law.
Choices About How We Use and Disclose Your Peronal Data
We strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with the following control over your information. Additional rights and disclosures for residents of the California, Nevada, and other jurisdictions are described further below.
If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an e-mail stating your request to firstname.lastname@example.org. If we have sent you a promotional e-mail, you may send us a return e-mail asking to be omitted from future e-mail distributions, or simply click the “unsubscribe” link in at the end of the email. This opt out does not apply to information provided to the Company as a result of a product purchase, donation, warranty registration, product service experience, or other transactions.
Withdrawing Your Consent/Opt-Out
Where we are processing your Personal Data based on your consent, you may change your mind and withdraw your consent at any time. The consequence of you withdrawing consent might be that we cannot perform certain services or make features or content available to you.
Cookies and Similar Technologies
Do Not Track
Our Services Do Not Respond to Your Browser's Do Not Track Request.
Addtional Rights and Disclosures: EU/UK/Switzerland
The controller of Personal Data relating to residents of the EEA/UK/Switzerland is: Imbibe Magazine, 1001 SE Water Ave., Ste 285, Portland, OR 97214.
Legal Bases for Processing Your Information (For Users in EEA/UK/Switzerland)
Performance of a contract: The use of your Personal Data may be necessary to perform the agreement you have with us to provide products and services, e.g. to open and maintain your user accounts, to ship a product you have purchased, or process your request.
Legitimate interests: We may use your Personal Data as necessary for our legitimate interests. For example, we rely on our legitimate interest to administer, analyze and improve our Websites and related content, to operate our business including through the use of service providers and subcontractors, to send you notifications about our Websites or products you have purchase, for archiving, recordkeeping, statistical and analytical purposes, and to use your Personal Data for administrative, fraud detection, audit, training, security, or legal purposes. See the Business Purposes of Processing section above for more information regarding processing performed on the basis of our legitimate interests.
Consent: You are free to withdraw any consent you may have provided, at any time, subject to the Your Rights and Choices section and Legal Bases for Processing Your Information in this Section. Withdrawal of consent does not affect the lawfulness of processing undertaken prior to withdrawal.
Compliance with legal obligations: We may use your Personal Data to comply with legal obligations to which we are subject, including to comply with legal process. See the Business Purposes of Processing section above for more information regarding processing performed for compliance purposes.
Performance of a task carried out in the public interest: We may use your Personal Data to perform a task in the public interest or that is in the vital interests of an individual. See the Business Purposes of Processing section above for more information regarding processing performed for such purposes.
EEA/UK/Switzerland Privacy Rights
Under the GDPR and analogous legislation, you may have the following rights, subject to your submission of an appropriately verified request, as described above in the Your Rights section:
Access: You may have a right to know what Personal Data we collect, use, disclose, or otherwise process, and you may have the right to receive a list of that Personal Data and a list of the third parties (or categories of third parties) with whom we have received or shared Personal Data, to the extent required and permitted by law. You may be able to access some of the Personal Data we hold about you directly through the account settings menu.
Rectification: You may correct any Personal Data that we hold about you to the extent required and permitted by law. You may be able to make changes to much of the information you provided to us using the account settings menu.
Delete: To the extent required by applicable law, you may request that we delete your Personal Data from our systems. We may delete your Personal Data entirely, or we may anonymize or aggregate your information such that it no longer reasonably identifies you. Contact us as part of your request to determine how your Personal Data will be erased in connection with your request.
Data Export: To the extent required by applicable law, we will send you a copy of your Personal Data in a common portable format of our choice.
Restriction: You may request that we restrict the processing of personal data to what is necessary for a lawful basis.
Regulator Contact:: You may have the right to contact or file a complaint with regulators or supervisory authorities about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority.
Submission of Requests (For Users in EEA/UK/Switzerland)
You may submit requests as follows (please review our verification requirements section):
Contact us via email to our privacy team at email@example.com.
You may send postal mail to our physical address with your email address, phone number and address we have on file, along with your request.
Additional Rights and Disclosures: U.S. States & California
Under the California Consumer Privacy Act (“CCPA”) and other state privacy laws, residents of certain US states may have the following rights, subject to your submission of an appropriately verified request, regional requirements, exceptions, and limitations:
Right to Confirm: You have the right to confirm whether we process your Personal Data.
Right to Know: You may request any of following, for the 12 month period preceding your request: (1) the categories of Personal Data we have collected about you, or that we have sold, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Data was collected; (3) the business or commercial purpose for which we collected or sold your Personal Data; (4) the categories of third parties to whom we have sold your Personal Data, or disclosed it for a business purpose; and (5) the specific pieces of Personal Data we have collected about you.
Right to Portability: You have the right to request that we provide certain Personal Data in a common, portable format.
Right to Delete: You have the right to delete certain Personal Data that we hold about you, subject to exceptions under applicable law.
Right to Correct: You have the right to correct certain Personal Data that we hold about you, subject to exceptions under applicable law.
Right to Non-Discrimination: You have the right to not to receive discriminatory treatment as a result of your exercise of rights conferred by the CCPA.
Direct Marketing: You may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year.
Opt-Out of Sale, Sharing, Targeted Advertising, Profiling: You have the right to opt-out of the following:
If we engage in sales of data (as defined by applicable law), you may direct us to stop selling Personal Data.
If we engage in Targeted Advertising (aka “sharing” of personal data or cross-context behavioral advertising,) you may opt-out of such processing.
If we engage in certain forms of “profiling” (e.g. profiling that has legal or similarly significant effects), you may opt-out of such processing.
Opt-out or Limit Use and Disclosure of Sensitive Personal Data: You have the right to opt-out of the processing of certain Sensitive Data, or request that we limit certain uses of Sensitive Personal Data. This right does not apply in cases where we only use Sensitive Personal Data where necessary, or for certain business purposes authorized by applicable law.
Submission of Requests (for U.S. State and California Users); Appeals
You may submit any of the above requests by submitting a request as follows (please our review verification requirements section above). If you have any questions or wish to appeal any refusal to take action in response to a rights request, contact us at firstname.lastname@example.org. We will respond to any request to appeal within the period required by law.
Contact us via email to our privacy team at email@example.com.
You may send postal mail to our physical address with your email address, phone number and address we have on file, along with your request. The e-mail subject line or mailing envelope and the content of your request must include the phrase “Your State Privacy Rights,” and include your name and e-mail address (if you wish to receive a response via e-mail) or street address, city, state, and zip code (if you wish to receive a response via postal mail).
Categories of Personal Data Disclosed for Business Purposes
For purposes of the CCPA, we have disclosed for “business purposes” the following categories of Personal Data, to the following categories of recipients:
|Category of Personal Data||Category of Recipients|
|Affiliates; Service Providers & Agents; Corporate Events; Partners; Lawful Recipients|
|Device/ Network Data
|Affiliates; Service Providers & Agents; Corporate Events; Lawful Recipients|
Categories of Personal Data Sold or Shared
For purposes of the CCPA, we have not “sold” or “shared” your Personal Data the preceding 12 months.
Categories of Sensitive Personal Data Used or Disclosed
For purposes of CCPA, we may use or disclose the following category of Sensitive Personal Data: Payment Data. However, we do not sell or share Sensitive Personal Data, or use it for purposes other than those listed in CCPA section 7027(m).