privacy policy

Zuzu Drinks Inc. (“we” “us” or “our”) respect your privacy and are committed to protecting it through our compliance with this policy. 

This Privacy Policy (this “Policy”) describes how your Personal Information (as defined in Section 1) is collected, used, and shared when you visit www.drinkzuzu.com (the “Site”). By accessing or using this Site, you are consenting to the collection of Personal Information and use practices described in this Policy, as modified from time to time by us in our sole discretion.

WHAT DO WE COLLECT?  WHAT DO WE DO WITH YOUR INFORMATION?

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, operating system, IP address, time zone, and some of the Cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”

We collect Device Information using the following technologies: 

  • “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. You may refuse to accept browser cookies by activating the appropriate setting on your browser. For more information about Cookies, and how to disable Cookies, visit http://www.allaboutcookies.org.
  • “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site), and to assess the success of our marketing and advertising campaigns.

The information we collect on or through our Site may also include information that you provide by filling in forms on our Site. This includes information provided at the time of subscribing to our services or contacting us, such as your name, address, email address and phone number. We refer to this information as “Contact Information.”

When we talk about “Personal Information” in this Privacy Policy, we are talking about both Device Information and Contact Information.

In addition to the uses set forth elsewhere in this Policy, we may use Personal Information about you for various purposes, including to:

  • Provide, maintain and improve the Site and our products;
  • Respond to your comments, questions and requests and provide customer service;
  • Communicate with you about the Site, products, offers, surveys, events and other news and information we think may be of interest to you;
  • Monitor and analyze trends, usage and activities in connection with the Site;
  • Detect, investigate and prevent illegal activities and protect our rights and property;
  • Personalize and improve the Site and provide advertisements, content and features that match your interests;
  • Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;
  • Link or combine with information we get from others to help understand your needs and provide you with a better experience; and
  • Carry out any other purpose for which the information was collected.

CONSENT

How do you get my consent?

You consent to our collection and use of Device Information by using or accessing the Site. 

How do I withdraw my consent?

You may withdraw your consent for us to contact you, or for the continued collection, use or disclosure of your information, at any time, by emailing us at help@drinkzuzu.com.If you decide you don’t want to receive marketing emails from us, you can opt out of marketing emails by clicking the “Unsubscribe” link in our emails, or emailing us at help@drinkzuzu.com

DISCLOSURE

Subject to the terms of this Policy, we shall never sell, rent, share or otherwise distribute or make available your Personal Information to third parties outside of our group of companies without your consent, except that we may access, use, preserve, and disclose your Personal Information to third parties if we believe in good faith that it is reasonably necessary to:

  • Comply with applicable laws, regulations, legal processes, and governmental requests;
  • Protect the safety of any person including to prevent death or imminent bodily harm;
  • Detect, prevent, and address fraud, security, or technical issues;
  • Further process your Personal Information in accordance with the purposes for which it was originally collected;
  • Enforce the Terms of Service; or
  • Protect our rights or property.
California Privacy Rights

California residents may have additional personal information rights and choices. This section applies only to California residents. It describes how we collect, use and share Personal Information (as hereinafter defined) of California residents in operating our business and Website, and their rights with respect to such Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA. To learn more about your California privacy rights under the CCPA, visit https://oag.ca.gov/privacy/ccpa.

How We Collect, Use, and Share your Personal Information

We may have collected the following statutory categories (as defined by CCPA) of Personal Information in the past twelve (12) months:

  • Identifiers (e.g., name, email address, billing and shipping address, phone number).
  • Online identifiers (e.g., device identifier, IP address, unique browser ID, cookies, beacons, account login, other unique identifiers).
  • Financial information (e.g., your financial account numbers or payment card information; please note that a third party payment processor is responsible for all collection, processing, and storage of your financial information and we do not have direct access to or possession of any payment card information).
  • Commercial information (e.g., purchase history, Website engagement).
  • Internet or network activity (e.g., browsing and search history, Website and advertisement interactions).
  • Geolocation data (e.g., physical location derived from GPS-enabled services).

We obtain the categories of Personal Information listed above both directly and indirectly from users of the Website. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Your California Privacy Rights

As a California resident, you have the rights listed below. Please note that in certain cases we may decline your request where we cannot verify your request (as described below), where an exception applies, or as otherwise permitted by law.

  • Right to Know. You can request the following information about how we have collected, used, disclosed, and, if applicable, "sold" your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected and used.
  • The categories of sources from which we collected Personal Information.
  • The business or commercial purpose(s) for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share Personal Information.
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third-party recipient.
  • If applicable, whether we’ve “sold” your Personal Information, and if so, the categories of Personal Information received by each category of third-party recipient. We do not sell your Personal Information to third-party recipients.
  • Right to Request Deletion.  You can ask us to delete the Personal Information that we have collected from you.
  • Opt-out of sales.  You can ask that we do not sell your Personal Information. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes, if applicable.
  • Opt-in.  We do not sell Personal Information to third-party recipients.
  • Non-Discrimination.  You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you goods or services; increasing the price/rate of goods or services; decreasing the quality of goods or services; or suggesting that you may receive a different price/rate of goods or services or a different level or quality of goods or services for exercising any of your CCPA rights.
How to Exercise your California Rights

California residents may exercise the CCPA rights described above as follows:

  • Rights to know and request deletion.  To request to exercise your right to know or right to request deletion, email us with your request at help@drinkzuzu.com.
  • Identity verification and response timing for CCPA rights to know and request deletion.  We reserve the right to confirm your California residency to process your requests to exercise your CCPA rights.

In accordance with California law, we take reasonable precautions to verify the identities of those California residents submitting CCPA requests, or to learn more about how their Personal Information is processed.  Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may make a verifiable consumer request for access or data portability twice within a twelve (12)-month period. The verifiable consumer request must:

  1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or such person’s authorized representative.
  2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with your Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of receipt. If we require more time (up to forty-five (45) days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the twelve (12)-month period immediately preceding our receipt of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

RETENTION OF PERSONAL INFORMATION

We will only retain your Personal Information for as long as necessary to fulfil the purpose we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We retain Personal Information for the duration of any actively engaged user of our Site and services and for a period after this time as necessary and relevant to our legitimate operations and in accordance with applicable law obligations. This may include retention necessary to identify, issue or resolve legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

INTERNATIONAL USERS

Our Site is based in the United States. We provide this Site for use only by persons located in the United States. We make no claims that the Site or any of its content is accessible or appropriate outside of the United States. Access to the Site may not be legal by certain persons or in certain countries. If you access the Site from outside the United States, you do so on your own initiative and are responsible for compliance with local laws.

THIRD-PARTY SERVICES

We employ other companies and individuals to perform functions on our behalf. Examples include agencies providing marketing assistance, providing conference administration assistance, processing credit card payments, and providing user service. They have access to personal information needed to perform their functions but may not use it for other purposes.

Certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies with respect to the information we are required to provide to them for your purchase-related transactions.

For those providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by those providers.

We direct users to an independent, third-party company, Thirstie, Inc. (“Thirstie”), for any transactions related to alcohol products. When you visit the “Shop” portion of our services, you will be directed to a subdomain operated by Thirstie. Thirstie’s Privacy Policy, Terms of Use, e-commerce and payment terms, and any other terms and conditions set forth by Thirstie apply to any purchase you make via Thirstie and are between you and Thirstie.

Once you leave our website or are redirected to a third-party website or application, including without limitation, Thirstie, you are no longer governed by this Policy or our Site’s Terms of Service.

SECURITY

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

Although we have tried to create secure, reliable and trustworthy websites for our visitors, please be aware that the Internet is generally not regarded as a completely secure environment, and that therefore the confidentiality of your Personal Information provided or transmitted via our Site or by e-mail cannot be guaranteed by us. Thus, we are not responsible or liable for the security of your Personal Information whilst in transit via the Internet to us.

By using the Site or providing information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending a message. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at help@drinkzuzu.com.

COOKIES

By using or accessing the Site, you are consenting to our use of Cookies as follows:

We, and third-party vendors (such as Google), use Cookies to analyze user activity in order to improve the Site. For example, by using Cookies we can look at aggregate patterns, like the average number of products that users browse. We can use such analysis to gain insights about how to improve the functionality and experience for all users, as well as serve ads based on past site activity.

Google Analytics & Interest-Based Online Advertising

As you navigate through and interact with our Site, we may utilize automatic data collection technologies (such as Google Analytics) to collect anonymized information about your Site visit. We do this to help us estimate the size of our audience and their usage patterns in order to improve the user experience for everyone.

Data collected may include, but is not limited to, demographic information like age and gender, system details like your browser version and operating system, your mobile device type if accessing the Site on your phone or tablet, onsite behavior like which pages on our Site that you visited and how long you stayed, and whether or not you completed any actions like signing up for our mailing list. Nothing collected is personally identifiable.

We may allow others to serve advertisements on our behalf, on other sites across the internet, based on you visiting our Site in the past. These entities may use Cookies, web beacons, or other technologies to function properly and identify the effectiveness of those efforts.

You have the right to update, correct, or modify information we may have about you at any time by emailing us at help@drinkzuzu.com.

You may also adjust your ad personalization settings directly with Google in their “Ad Personalization Settings” link: https://adssettings.google.com/authenticated page.

Opt-Out Options

Users who wish to not have their data collected with Google Analytics can install the opt-out browser add-on, which prohibits information from being sent to Google Analytics.

To opt out, visit the Google Analytics opt-out page link: https://tools.google.com/dlpage/gaoptout and install the add-on for your browser.

Another option is by visiting the Network Advertising Initiative Opt-Out link: http://optout.networkadvertising.org/?c=1#!%2Fpage.

AGE OF CONSENT

Our Site is designed to appeal to adults only. We do not knowingly solicit any information from children or people under the legal drinking age, nor do we knowingly market or otherwise target our websites or our products or services to children or people under the legal drinking age.
If we become aware that a visitor to our websites is a child or under the legal drinking age in the country or other territory in which he or she is located at the relevant time and has registered without verifiable parental consent, we will remove his or her personal information from our files. By using this Site, you represent that you are at least the legal drinking age in the United States.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Site. If we make material changes to this Policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.  Your use of the Site signifies your acceptance of this Policy.  If you do not agree to the terms of this Policy, please do not use the Site.  

If the ownership of all or substantially all of our business changes, or we otherwise transfer assets relating to our business or any of the services to a third party (such as by merger, acquisition, bankruptcy proceeding, or other change of control transaction), we may transfer or sell your information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to this Policy unless we notify you otherwise.

TRADEMARK RIGHTS

We and our affiliates, licensors and content providers are the owners of all the trademarks used on the Site. Third parties are not allowed to use and apply any of the trademarks, logos and identifying marks without our express written consent.

QUESTIONS AND CONTACT INFORMATION

If you would like to: access, correct, amend or delete any Personal Information we have about you, register a complaint, or simply want more information, contact our team via email at help@drinkzuzu.com.

We urge you to also carefully read our “Terms of Service” for more information on the use of our Site.

Effective Date: November 20, 2020

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