WEBSITE PRIVACY POLICY

Figlia, Inc. (hereinafter referred to as “Figlia,” “us,” “we,” “our,” or “Company”) has created this Privacy Policy to apply to all users of this website (drinkfiglia.com) including our mobile site, contained, or offered therein (collectively, our “Services”).  This Privacy Policy describes, among other things, the types of information we collect from users when you use our Services, how we use it, and how you can access your information.

This Privacy Policy does not apply to information collected or obtained by any third party, including through any application or content that may link to or be accessible from or on the Services.  This Privacy Policy is integrated into our Terms & Conditions of Use (“Terms & Conditions”).  

By using the Services and providing us with your personal Information (defined below), you agree to the practices described in this Privacy Policy and Terms & Conditions referenced below and to the updates to these policies posted here from time to time.  By using our Services, you consent to these policies.  

This Website Privacy Policy does not apply to information collected through other means, including but not limited to, by telephone or in person.  The Services are intended for a United States audience only.  Any information you provide, including any personal information (as defined in Section II below), will be transferred to and processed by a computer server located within the United States.

I. INFORMATION WE COLLECT ABOUT YOU

We may collect the following types of information about you which are described in more detail below: (A) information you provide to us, (B) information we may automatically collect, and (C) information we may receive from third parties.  All of the information listed in (A)-(C) above, are detailed below, and hereinafter referred to as “Information.” 

A. Information You Provide to Us:

-In using our Services, you may provide us with Information, including, without limitation:

-Contact information such as name, email address, postal address, and telephone number(s);

-Online account information and log in credentials, including unique identifiers such as username and password;

-Demographic data such as age range and geographic location; and

-Additional information as otherwise described to you at the point of collection or pursuant to your consent.

B. Information We May Automatically Collect About You:

Our Services may automatically collect certain Information about you.  This Information is used by Figlia for the operation of the Services, to maintain quality of the Services, and to provide general statistics regarding use of the Services.  This Information may include:

-IP address, which is the number associated with the service through which you access the Internet, like your ISP (Internet service provider);

-Date and time of your visit or use of our Services;

-Domain server from which you are using our Services;

-Type of computer, web browsers, search engine used, operating system, or platform you use;

-Data identifying the web pages you visited prior to and after visiting our website or use of our Services;

-Your movement and activity within the website, which is aggregated with other information; and

-Mobile device information, including the type of device you use, operating system version, and the device identifier (or “UDID”).

C. Cookies & Technologies Used to Collect Information About You

We collect the above Information directly and through the use of third parties.  We collect this Information by using certain technologies, such as cookies, web beacons, and other technologies.  Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons.

Cookies (or browser cookies).  A cookie is a small file placed on the hard drive of your computer.  You may refuse to accept browser cookies by activating the appropriate setting on your browser.  However, if you select this setting you may be unable to access certain parts of our Services.  Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.

Flash Cookies.  We may use local shared objects, also known as Flash cookies, to store your preferences such as volume control or display content based upon what you view on our site to personalize your visit.  Third parties, with whom we partner to provide certain features or to display advertising based upon your browsing activity, use Flash cookies to collect and store information.  Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.  Cookie management tools provided by your browser will not remove Flash cookies.

Web Beacons.  Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).  We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Services.  These technical methods may involve the transmission of Information either directly to us or to a third party authorized by us to collect Information on our behalf.  Our Services use retargeting pixels from Google, Facebook, and other ad networks.  We also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.

Analytics. Analytics are tools we may use, such as Google Analytics, to help provide us with information about traffic to our website and use of our Services, which Google may share with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network.  You can view Google’s Privacy Practices here: Privacy Policy – Privacy & Terms – Google.

Mobile Application Technologies.  If you access our website and Services through a mobile device, we may automatically collect Information about your device, your phone number, and your physical location. 

D. Information We May Receive from Third Parties

We may collect additional Information about you from third-party websites, social media platforms, such as, but not limited, to Facebook, Instagram, LinkedIn (“Social Media Platforms”), and/or sources providing publicly-available information (e.g., from the U.S. postal service) to help us provide services to you, help prevent fraud, and for marketing and advertising purposes. 

This Privacy Policy only applies to Information collected by our Services.  We are not responsible for the privacy and security practices of those other websites or Social Media Platforms or the Information they may collect (which may include IP address).  You should contact such third parties directly to determine their respective privacy policies.  Links to any other website’s or content do not constitute or imply an endorsement or recommendation by us of the linked website, Social Media Platform, and/or content.

II. HOW WE USE YOUR INFORMATION

A. Use and Purpose of Processing Your Information

We use and process your Information for things that may include, but are not limited to, the following:

-To provide you with the services and information you request;   

-To process your profile to open your Account;

-To process your request to be added to our newsletter listserv;

-To respond to your comments, inquiries and questions and provide customer service;

-For general or targeted marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties, provided that you have not already opted-out of receiving such communications;

-To fulfill contracts we have with you;

-To manage, improve and foster relationships with third-party service providers, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners;

-Maintain, improve, customize, or administer the Services, perform business analyses, or other internal purposes to improve the quality of our business, the Services, resolve technical problems, or improve security or develop other products and services;

-Comply with our Terms & Conditions;

-Analytics for business purposes and business intelligence;

-Comply with any applicable laws and regulations and respond to lawful requests; and/or

-For any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent.

We may also use Information that has been de-identified and/or aggregated for purposes not otherwise listed above.

B. Sharing Your Information

We may share your Information as set forth in the Privacy Policy and in the following circumstances:

Third-Party Service Providers.  We may share your Information with third-party service providers that perform certain functions or services on our behalf (such as to host the Services, manage databases, perform analyses, process credit card payments, provide customer service, or send communications for us).  These third-party service providers are authorized to use your Information only as necessary to provide these services to us.  In some instances, we may aggregate Information we collect so third parties do not have access to your identifiable Information to identify you individually.

Disclosure of Information for Legal and Administrative Reasons.  We may disclose your Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Information); (iv) to protect and defend the rights, property or safety of us, our subsidiaries and affiliates and any of their officers, directors, employees, attorneys, agents, contractors and partners, and the website Service users; (v) to enforce or apply our Terms & Conditions; and (vi) to verify the identity of the user of our Services.

Business Transfers.  Your Information may be transferred, sold, or otherwise conveyed (“Conveyed”) to a third party where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganize.  You agree to any and all such Conveyances of your Information.

Online Communications.  Any information you submit in a public forum (e.g., a blog, a chat room, Social Media Platform or network, or if you voluntarily choose to leave a rating or review) may be read, collected, or used by us and other participants, and could be used to personalize your experience.  You are responsible for the information you choose to submit in these instances.

De-Identified or Aggregated Data.  We may share your Information on an aggregated basis for any purpose in which your specific personal Information is blinded, masked or otherwise not identifiable. 

With Your Consent.  We may share Information consistent with this Privacy Policy with your consent.

Except as provided in this Privacy Policy, we will not sell, exchange, trade, or disclose your Information we have collected without your consent.

III. LINKS TO OTHER WEBSITES

Our Services may contain links to other websites or services that are not owned or controlled by us, including links to Social Media Platforms such as Facebook, Instagram or YouTube, or may redirect you off our website away from our Services.  

This Privacy Policy only applies to Information collected by our Services.  We are not responsible for the privacy and security practices of those other websites or Social Media Platforms or the Information they may collect (which may include IP address).  You should contact such third parties directly to determine their respective privacy policies.  Links to any other website’s or content do not constitute or imply an endorsement or recommendation by us of the linked website, Social Media Platform, and/or content.

IV. INFORMATION SECURITY

We use commercially reasonable measures to provide our Services.  However, you should assume that no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure.  Therefore, we do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private or secure.  We do not guarantee that your Information will not be misused by third parties.  We are not responsible for the circumvention of any privacy settings or security features.  You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Information.

If you believe that your Information has been accessed or acquired by an unauthorized person, you should promptly How to Contact Us so that necessary measures can quickly be taken.

V. DATA RETENTION

We will retain your Information for as long as needed to provide you Services.  If you wish to request that we no longer use your Information to provide you Services, please contact us at privacy@drinkfiglia.com.  We will retain and use your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.  In accordance with our routine record keeping, we may delete certain records that contain Information you have submitted to us.  We are under no obligation to store such Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Information.

VI. YOUR CHOICES

Marketing Communications.  If you do not want to receive marketing and promotional emails from us, you may click on the “unsubscribe” link in the email to unsubscribe and opt-out of marketing email communications or see How to Contact Us below for more information. 

Location Choices.  You can change the privacy settings of your device at any time to turn off the sharing of location information with our Services.  If you choose to turn off location services, this could affect certain features or services of our Services.  If you have specific questions about the privacy settings of your device, we suggest you contact the manufacturer of your device or your mobile service provider for help.

Opting Out of Direct Marketing by Third Parties.  To exercise choices regarding the marketing information you receive, you may also review the following links: 

-You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.

-You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info.

-You can opt-out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

VII. ACCESSING, CORRECTION, OR DELETING YOUR INFORMATION

To the extent certain state laws provide users with data subject rights, such as the right to opt out, access or delete their personal information, those rights may be honored by the Company following proper authentication and verification.  Please see the How to Contact Us section below for more information.

VIII. GEOGRAPHIC LOCATION OF DATA STORAGE AND PROCESSING

Our Services are targeted to individuals located in the United States.  As such, the Services collect Information and process and store that Information in databases located in the United States.  If you are visiting the Services from a country outside the United States, you should be aware that you may transfer personally identifiable information about yourself to the United States, and that the data protection laws of the United States may not be as comprehensive as those in your own country.  By visiting the Services and submitting any personally identifiable information you consent to the transfer of such personally identifiable information to the United States.

IX. CHILDREN’S INFORMATION

The Services are intended only for users over the age of eighteen (18).  If we become aware that a user is under thirteen (13) (or a higher age threshold where applicable) and has provided us with Information, we will take steps to comply with any applicable legal requirement to remove such Information.  Contact us if you believe that we have mistakenly or unintentionally collected Information from a child under the age of thirteen (13).

X. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change, modify or amend this Privacy Policy at any time to reflect changes in our products and service offerings, accommodate new technologies, regulatory requirements, or other purposes.  If we modify our Privacy Policy, we will update the “Effective Date” and such changes will be effective upon posting.  It is your obligation to check our current Privacy Policy for any changes.

XI. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Information we have collected about you, please contact us at the following:

Email us: privacy@drinkfiglia.com

Call us: 212-365-5629

Write us: Figlia, 93 4th Ave #259, New York NY 10003

Effective Date: March 1, 2021