Spirit of 21, Inc. (Spirit of 21) considers personal information to be information that can be traced directly back to and identifies a specific individual or household, such as name, address, email address, birthday, gender and/or phone number. We do not consider personal information to include information that alone does not allow a third party to easily identify a specific individual or household.

  1. HIGHLIGHTS OF WHAT YOU ARE CONSENTING TO

By using the Services, you are consenting to:

We collect your information when you:

register to use the Services;

link email and other accounts to the services;

log in with social networking credentials;

use the Services; and

communicate with us.

We also collect information such as anonymous usage statistics, by using cookies, server logs, and other similar technology as you use the Site.

the collection, use, and processing of information collected from the online accounts you connect to the Service, such as geo-location;

the use of Cookies and Related Technologies;

the sharing of anonymous transaction information with third parties;

the sharing of personal information, including transaction information, with service providers and vendors;

the collection, use, sharing and other processing of your information as otherwise described in this Privacy Policy.

III. THE INFORMATION WE COLLECT

Registration and Customer Support.

Spirit of 21 collects personal information when you register, such as your name, age, gender and email address. We may also collect personal information from you in other ways, such as through contacts you may make with our customer support team.

Tasting Profile.

Through the use of the Service, Spirit of 21 will collect information on the winery, brewery, or distillery and/or product tasting preferences and location of the tasting.

Email and Other Accounts.

You may also provide information necessary to use the Services, such as the login credentials for your email, social networking, or other Internet accounts that you link to the Services. By linking the Services to your email or other Internet accounts, you authorize us to gather, parse, and retain information, including personal information related to your online shopping and purchasing (“transaction information”).

Social Sign-On.

We receive and retain basic information about you when you use a social media website (such as Facebook) to log into the Services. This information generally includes your name, email, website ID and public profile with the service. We may receive and retain demographic information about you through a social sign-on.

From Others.

We may collect information from vendors and suppliers and combine it with information that we have about you.

Cookies and Related Technologies.

Spirit of 21 uses “cookies” and similar technologies to collect and store information that is generated automatically as you use the Services, including your preferences and usage statistics. Most browsers allow you to manage cookies including blocking and deleting them. If you block or delete our cookies, the Services may not work as well or at all for you. Spirit of 21 also records information on our server logs that is collected from your browser, including your IP address, Spirit of 21 cookie information, and the pages you request, and relates it to the personal information you provide.

Mobile Device Information.

Spirit of 21 uses tools, including third party analytical software, to automatically collect certain anonymous data about your device that does not directly identify you, such as: (i) device properties, including, but not limited to unique or other device identifier; (ii) device software platform and firmware; (iii) mobile phone carrier; (iv) geographical data such as country or region; (v) other similar data as reasonably required by Spirit of 21 to enhance the Services and other Spirit of 21 products and services.

Usage Information.

When you use our Services, we will automatically collect information about how you use our Services.

  1. INFORMATION THAT WE DO NOT COLLECT

Specifically, Spirit of 21 does not collect credit card numbers, expiration dates or CCD codes. All payment data is through a 3rd party portal. The 3rd party processor is responsible for the security of the data.

  1. HOW WE MAY USE YOUR INFORMATION

We will use the information we collect, including your personal information and transaction information: (i) for internal and service-related purposes, such as to provide, improve, and personalize our Services, and to develop new ones; (ii) to communicate with you in order to provide you with information we think may be useful or relevant to you; (iii) to promote the Services; (iv) to analyze information in order to offer anonymized data products to third parties; (v) to facilitate the sharing of anonymized information, including transaction data, as set forth below; (vi) to enforce this Privacy Policy, the Terms of Service, and to protect the rights, property, or safety of Spirit of 21 or its users; and (vii) as otherwise stated in this Privacy Policy.

We use your information to:

facilitate and improve our services;

build anonymous market research products and services with partners; and

communicate with you.

We may use anonymous information for any purpose, including for marketing purposes.

  1. HOW WE SHARE YOUR INFORMATION

Service Providers.

Spirit of 21 may disclose your information, including personal information and transaction information, to service providers for the purposes of managing, providing, and improving the Services, analyzing usage of the Services, and for marketing purposes.

Vendors and Suppliers.

We may share information, including personal and transaction information, with vendors and suppliers to collect additional information about you from them, or to help us provide anonymized data to others.

Anonymous Use and Sharing.

We may share with others anonymized transaction information. Such information will not include personal information, but may include unique identifiers such as device identifiers or “hashes” of email addresses.

We may share your information:

with our vendors, suppliers, and service providers;

with others when it is anonymized;

to comply with legal obligations;

to protect and defend our rights and property.

We do not rent, sell, or share personal information with other people or non-affiliated companies for their direct marketing purposes.

Legal sharing for protection of us, you, and others.

We may access, preserve, and disclose collected information, if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; or protect your, our, or others’ rights, property, or safety.

Merger or sale.

If all or a portion of Spirit of 21 or its assets are sold or transferred, personal information and other information we have collected may be treated as an asset and transferred in accordance with this Policy.

Your Permission.

We may also disclose your personal information with your permission.

VII. HOW WE SECURE YOUR PERSONAL INFORMATION

Spirit of 21 limits access to your personal information.

We have physical, electronic, and administrative procedures in place to protect and help prevent unauthorized access and use of personal information.

No data transmissions through the Internet or via mobile devices, or even the physical transfer of information, can be guaranteed to be completely secure. We cannot eliminate fully all security risks associated with personal information. We do not ensure or warrant the security of any data or information you transmit to us and you do so at your own risk.

You agree that we may communicate with you electronically regarding security, privacy, and administrative issues, such as security breaches. We may post a notice on our website if a security breach occurs. We may also send an email to you at the email address you have provided to us.

VIII. INTERNATIONAL VISITORS

Spirit of 21 is hosted in and intended for use in the United States by U.S. residents. We may transfer your personal information within Spirit of 21 and in accordance with this policy. Spirit of 21 may also subcontract processing to, or share your information with, third parties located in countries other than your home country.

By using the Services, you will transfer data to the United States.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information to the United States to Spirit of 21. By providing your personal information you consent to any transfer and processing in accordance with this Policy.

  1. HOW TO CONTACT US

If you have questions or suggestions, please email Spirit of 21 at zeva@Spiritof21.com.

  1. HOW TO REVIEW OR CORRECT YOUR PERSONAL INFORMATION, OR CLOSE YOUR ACCOUNT.

Upon request, we will provide an individual with access to personal information that we have collected about them (provided that they have given proof of identity). Personal information can be requested and corrected by contacting us using the contact information above.

You may choose to deactivate your Spirit of 21 account through your account settings. If you do, we will disassociate your personal information from your purchase data.

  1. HOW WE MAY UPDATE OUR PRIVACY POLICY

From time to time, we may use personal information for new, unanticipated uses not previously disclosed in our Privacy Policy. If our information practices change, we will immediately post any adjustments to our Privacy Policy on this website. The revised version will be effective at the time we post it, unless the revised version includes a change that would be materially less restrictive on our use of your personal information. In such case, we will provide you with 30 days’ prior notice on this website. You may bookmark this page and check it periodically for updates.