privacy policy

VNGR BEVERAGE, LLC PRIVACY POLICY

1. WHO WE ARE

“We”, “us” or “our” means VNGR Beverage d/b/a Poppi, a Texas limited liability corporation with its principal place of business located at 31 Navasota Street Suite 270 Austin, TX 78702. We act as controller for the personal data we gather through your use of our website.

2. WHAT THIS IS

Your privacy is important to us, so we’ve developed this Privacy Policy (the “Privacy Policy” or “Policy”), which sets out how we collect, disclose, transfer and otherwise use (collectively, “Process”) the personal data that you share with us. Please take a moment to read through this Policy in its entirety.

If you have any questions, concerns or complaints regarding this Privacy Policy or our processing of your personal data or you wish to submit a request to exercise your rights as set out in Section 5, you can do so by contacting us via e-mail: info@drinkpoppi.com.

This Privacy Policy was created on March 5, 2021.

3. HOW WE USE AND COLLECT YOUR PERSONAL DATA

Personal data is defined as any information relating to an identified or identifiable natural person. Identifiable refers to identifiers (such as name, identification number, location data, etc.), that can be used to directly or indirectly identify a natural person.

The personal data we collect, is collected and used for the purposes as listed hereunder:

  • In the event you use the contact form on our website, we will use your personal data in order to reply to your query, via e-mail or telephone.
  • In the event you create a profile on our website or you provide us with transaction data, we collect your personal information in order to save such information, to provide you with our services and permit us to receive your information or to contact you.
  • In the event you register for our newsletter, your e-mail address will be used in order to send you our newsletters, which may include invites to events, seminars, etc. organized by us.
  • We Process your personal data for the purpose of supporting the website, mobile applications, advertising experience, and enhancing your user experience, which includes ensuring the security, availability, performance, capacity and health of these systems.
  • We Process your personal data to enforce or exercise any rights that are available to us based on the applicable law, such as use for the establishment, exercise or defense of legal claims.
  • We may also use your personal data to fulfil our obligations as set out by the applicable law.

The following categories of personal data can be distinguished:

  • Contact data: in the event you make use of the contact form, you will be asked to provide the following information: name, address, e-mail address, phone number, and any personal data that you choose to put in the designated blank field (please do not provide us with any sensitive information, such as health information, information pertaining to criminal convictions, or credit card/account numbers). This is information that is provided directly by you.
  • Profile data: If you create an account on our website, we collect the following data: name, telephone number, e-mail address, address, country, company name, job title, industry. This is information that is provided directly by you.
  • Newsletter: If you register for our newsletter, you will be asked to provide your e-mail address. This is information provided directly by you.

 

  • Transaction data: We collect personal data relating to transactions that you make through the website, including your “contact data”, payment information and the goods and/or services purchased. This is personal data provided directly by you.
  • Identifiers such as name, resources, sales inquiry, partner inquiry, subscription to our newsletter: name, telephone number, e-mail address, address, country. This is personal data provided directly by you.
  •  We collect personal data relating to your access request to VNGR Beverage, LLC Customer Records Information such as credit/debit card number used to pay for goods.
  • Characteristics of Protected Classifications such as age to determine permitted use of our services.
  • Commercial Information such as your purchase history.
  • Internet or other Electronic Network activity information such as your Usage Data: We collect personal data regarding your activities on our website: IP address, device ID and type, referral source, language settings, browser type, operating system, geographical location, length of visit, page views, or information about the timing, frequency and pattern of your service use. This information may be aggregated and used to help us provide more useful information regarding the use of our website. In the event the usage data is completely anonymized (and can therefore not be traced back to you as an individual), this will not be considered personal data for the purpose of this Privacy Policy. This is personal data that is automatically collected through your use of the website.
  • Geolocation data such as to determine the applicability of regional legislation permitting the purchase of certain products based on your device’s location.
  • Professional or employment-related information such as employer or workplace to determine any logistical requirements for shipping or delivery.
  • Inferences such as product flavor or fragrance preference.

We will only collect and Process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g., to deliver the Services you have requested) and “legitimate interests”.

Data categories disclosed for business purposes:

  • Identifiers such as name, shipping address, or billing address. For example, if we use a 3rd party carrier to deliver your order.
  • Customer Records Information such as credit/debit card number used to pay for goods. For example, if we use a 3rd party payment processor.
  • Characteristics of Protected Classifications such as age. For example, in some cases, your age may be required to determine permitted use of our services.
  • Commercial Information. For example, your order detail will be required for a 3rd party logistics provider to fulfill your order.
  • Internet or other Electronic Network activity information such as your use of our website in terms of browsing and search history. For example, 3rd party monitoring services may be used to ensure operational effectiveness of our services.
  • Geolocation data such. For example, location data may be used to determine the applicability of regional legislation.
  • Professional or employment-related information. For example, if you place an subscription order for your work, office, etc, we may use employment-related information such as work address for delivery and logistics.

Inferences such as product flavor or fragrance preference.

Where we rely on your consent to Process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you reside in the designated countries and have any questions about the lawful basis upon which we collect and use your personal data, please contact info@drinkpoppi.com with specific attention to Data Protection Officer.

Your personal data will solely be used for the purposes as set out in this section.

4. RETENTION OF YOUR DATA AND DELETION

Your personal information will not be kept for longer than is necessary for a specific purpose. However, considering it is not possible for us to specify a period in advance, the period of retention will be determined as follows:

  • To provide you with information, products or services that you request from us or which we feel may interest you;
  • To carry out our obligations arising from any contracts entered into between you and us, including for billing and collection;
  • If you pay for Services or Goods using a credit card, we will transmit your credit card data to the appropriate credit card company and/or credit card payment processing company;
  • To allow you to participate in interactive features of our Services and Goods, when you choose to do so;
  • To contact you about our Services and Goods;
  • In any other way we may describe when you provide the information or when we prompt you regarding a new use of information about you; and
  • To present content from our Services and Goods in an effective manner for you and for your computer or mobile device.

In the event you withdraw your consent or you object to our use of your personal data, and such objection is successful, we will remove your personal data from our databases. Please note that we will retain the personal data necessary to ensure your preferences are respected in the future.

The foregoing will, however, not prevent us from retaining any personal data if this is necessary to comply with our legal obligations, in order to file a legal claim or defend ourselves against a legal claim, or for evidential purposes.

5. YOUR RIGHTS

This section lists your principal rights under data protection law. We have tried to summarize them for you in a clear and legible way.

To exercise any of your rights, please send us a written request in accordance with Section 1 of this Privacy Policy. We will respond to your request without undue delay, but in any event within one month of the receipt of the request. In the event of an extension of the term to respond or in the event we do not take action on your request, we will notify you.

The right to access

You have the right to confirmation as to whether or not we Process your personal data and, in the event we do so, you have the right to access such personal data, together with certain additional information that you also find listed in this Privacy Policy.

You have the right to receive from us a copy of your personal data we have in our possession, provided that this does not adversely affect the rights and freedoms of others. The first copy will be provided free of charge, but we reserve the right to charge a reasonable fee if you request further copies.

The right to rectification

If the personal data we hold about you is inaccurate or incomplete, you have the right to have this information rectified or, taking into account the purposes of the processing, completed.

The right to erasure (right to be forgotten)

In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include:

  • The personal data are no longer needed in relation to the purposes for which they were collected or otherwise processed;
  • You withdraw your consent, and no other lawful ground exists;
  • The processing is for direct marketing purposes;
  • The personal data have been unlawfully processed; or,
  • Erasure is necessary for compliance with EU or California law.

There are certain exclusions to the right to erasure.

Those exclusions include where processing is necessary,

  • for exercising the right of freedom of expression and information;
  • for compliance with a legal obligation; or,
  • for the establishment, exercise or defense of legal claims.

The right to restrict processing

You have the right to restrict the processing of your personal data (meaning that the personal data may only be stored by us and may only be used for limited purposes), if:

  • You contest the accuracy of the personal data (and only for as long as it takes to verify that accuracy);
  • The processing is unlawful and you request restriction (as opposed to exercising the right to erasure);
  • We no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; or,
  • You have objected to processing, pending the verification of that objection.
  • In addition to our right to store your personal data, we may still otherwise Process it but only:
    undefinedundefinedundefined

We will inform you before we lift the restriction of processing.

The right to data portability

To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

You also have the right to have your personal data transferred directly to another company, if this is technically possible, and/or to store your personal data for further personal use on a private device.

The right to object to processing

You have the right to object to the processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:

  • The performance of a task carried out in the public interest or in the exercise of any official authority vested in us;
  • The purposes of the legitimate interests pursued by us or by a third party.

If you make such an objection, we will cease to Process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to Process your personal data for this purpose.

The right to Non-Discrimination

Poppi will not discriminate against for exercising any of these rights.

The right to complain to a supervisory authority

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. 

6. PROVIDING YOUR PERSONAL DATA TO OTHERS

In order to provide you with our website, we work with service providers to process and store your personal information. We use the following categories of service providers:

  • Google cloud as website hoster: https://policies.google.com/privacy

We may also disclose your personal data in the event such disclosure is required or necessary in order to fulfil a legal obligation. We may also disclose personal data in order to protect your vital interests or the vital interest of another natural person.

As such, we do not disclose your personal data to our social media partners. We do, however, make use of social media plugins to direct you to our social media channels and to allow you to interact with our content. These social media channels are (Facebook, Instagram, LinkedIn, Twitter, Google+, Vimeo, TikTok, and Pinterest). In the event you click such link, such social media service provider may collect personal data about you and may link this information to your existing profile on such social media.

We are not responsible for the use of your personal data by such social media service provider. In such case, the social media service provider will act as controller. For your information only, we have included the relevant links (these may be changed from time to time by the relevant service provider):

We have never, nor will we ever, sell your personal information.

7. INTERNATIONAL TRANSFERS

We will ensure that any transfer of personal data to countries outside of the United States will take place pursuant to the appropriate safeguards.

8. COOKIES

Our website makes use of cookies. For further information relating to our use of cookies, we refer you to our Cookie Policy:

On the website of our company we only use cookies for the website itself (a smoother navigation, end …). If you prefer to waive the benefits of these cookies, you can read in the help function of your browser how to adjust the browser settings to avoid those cookies, to accept new cookies or to delete existing cookies. You will also learn how to block all cookies or to set up notifications for new cookies.

9. AMENDMENTS TO THE PRIVACY POLICY

From time to time, we have the right to modify this Privacy Policy. You will always be able to consult the most recent version of the Privacy Policy on the website.