The Stacey Group LLC, d/b/a Deanbury Vodka and its affiliated entities (collectively, the foregoing entities are referred to as “DEANBURY VODKA”, “we” or “us” in this Privacy Policy) and is committed to protecting your privacy. The purpose of this Privacy Policy is to inform you about the types of information we gather about you, how we may use and share that information, specific use controls, and how we safeguard your information. The Privacy Policy applies to information collected through our website, www.deanburyvodka.com and social media accounts (collectively, the “Site”). The DEANBURY VODKA Terms of Use is incorporated by reference into this Privacy Policy.


Information You Provide to Us:
We collect information about you directly from you and from third parties, as well as automatically through your use of our Site. DEANBURY VODKA has implemented technical and organizational measures with respect to processing Personal Information from European Union individuals for purposes of the EU General Data Protection Regulation (“GDPR”). Upon request, we will provide you with information as to whether and what Personal Information we store in relation to you. Should your Personal Information be incorrect, you may request to have it rectified. You may also revoke your consent to use your Personal Information in the future, in whole or in part, or request deletion of your Personal Information.


When you use the Site, we collect identifiable information, such as IP addresses (which identify your device info) and any other information that may be collected in accordance with the Terms of Use (“Personal Information”). In addition, we may collect the information you provide us through various social media services or joint promotions with partners.
In addition, we may also collect non-personally identifiable information such as, pages viewed, computer type, screen resolution, operating system version, Internet browser type and version, information collected through cookies, pixel tags, web beacons, and other technologies, and other data (“Non-Personal Information”).  Because Non-Personal Information does not personally identify you, we may collect, use and disclose Non-Personal Information for any purpose. Non-Personal Information will be retained only for so long as to fulfill a legitimate business need.


We may aggregate Personal Information so that the aggregated information does not personally identify you or anyone else, such as by using Personal Information to calculate the percentage of our customers who live in a particular area (“Aggregate Information”). In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your geographical location). If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined, and may aggregate any information collected in a manner which does not identify any individual.


Information from Other Sources:
We may use automated devices and applications, such as Google Analytics, to evaluate usage of our Site. We also may use other analytic means to evaluate our Site. We use these tools to help us improve our Site, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your Personal Information with these third parties.

Automatically Collected Information:
When you visit our Site, read our emails or interact with our Service Providers, we may collect certain types of technology-specific information from you. This information will help us optimize your visit and track the performance of our marketing efforts.


How We Share Your Information: 
We may share your information, including Personal Information, as follows:

Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
a.    In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
b.    To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Privacy Policy, or as evidence in litigation in which we are involved.
c.    Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, research or similar purposes.
We may also disclose information about you that is not Personal Information. For example, we may provide merchants, business partners, or other third parties with reports that contain aggregated and statistical data about our users.


Cookies: 
DEANBURY VODKA uses cookies and other tracking mechanisms to track information about your use of our Site. We may combine this information with other Personal Information we collect from you. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others allow us to track your activities on our Site.

WHAT ARE THE DIFFERENT TYPES OF COOKIES AND HOW DO WE USE THEM?
a)    Essential: These are cookies which are essential for the running of our Site. Without these cookies, parts of our Site would not function. These cookies do not track where you have been on the internet and do not gather information about you that could be used for marketing purposes.
Examples of how we may use essential Cookies include:
•    Setting unique identifiers for each unique visitor, so that user numbers can be analyzed.
b)    Third Party Cookies: You may notice on some pages of our Site that cookies have been set that are not related to us. When you visit a page with content embedded from these third-party service providers may set their own cookies on your  mobile device. We do not control the use of these third-party cookies and cannot access them due to the way that cookies work, as cookies can only be accessed by the party who originally set them. Please check the third-party websites or mobile applications for more information about these cookies.
c)    Disabling Cookies: Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to refuse, disable, or delete cookies, some of the functionality of our Site may no longer be available to you.  Without this information, we are not able to provide you with all the requested services, and any differences in services are related to your information.
•    Some browsers transmit “do-not-track” signals to websites. Because of differences in how browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

d)    Clear GIFs, pixel tags and other technologies: Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.


Other Websites: 
Our Site may contain links to other websites not maintained by DEANBURY VODKA. Other websites may also reference or link to our Site. The inclusion of a link on the Site does not imply endorsement of the linked site by us. We are not responsible for the privacy practices of websites operated by third parties that are linked to or integrated with our Site, or for the privacy practices of third-party Internet advertising companies. We encourage you to be aware when you leave our Site, or surf the Internet, and to read the privacy statements of each and every website that you visit.


Information Security:
To protect your Personal Information, we take reasonable precautions and follow industry standard SSL/TLS end-to-end encryption of data in transit to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. If you provide us with your financial or any other Personal Information, the information is encrypted using industry standard protections in our database. No payment information is ever stored on our Site or internal database, as it is solely processed through third parties and is only temporarily stored during the processing of payment. No Personal Information is ever stored in our database.

Although we have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, please be aware that despite our best efforts, no data security measures can guarantee 100% security. 

Privacy of Minors:
We do not intentionally collect or maintain information from persons under the age of 21. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 21, we will make reasonable efforts to delete such information from our records.


California Privacy Rights:
The California Consumer Privacy Act (CCPA) provides consumers who are residents of the State of California with specific rights related to their Personal Information, subject to certain exceptions.  It also requires us to disclose the information we collect, the purposes for which we collect it, and what we share and disclose. 

California Civil Code § 1798.83, also known as the "Shine the Light" law, provides California residents with the right to request, once per year, without charge, information from website operators and owners regarding the Personal Information that they collect online and offline, if any, and the third parties, including affiliates, with which they have shared this information during the preceding calendar year, for the direct marketing purposes of the third party. If such information is collected and shared with third parties for their direct marketing purposes, the website operator or owner is required, upon request, to provide the list of categories of Personal Information they collect, if any, and the names and addresses of all third parties with which it has shared such information for direct marketing purposes.
A website operator or owner may meet its obligations, and be exempt from such disclosures, under the Shine the Light law, if it provides California residents the right to opt-out of, and thereby prohibit, the website operator or owner from sharing such Personal Information with third parties including its affiliates, for the direct marketing purposes of the third party.
In accordance with California Civil Code section 1798.83(c)(2), DEANBURY VODKA complies with California's "Shine the Light" law by providing all of its users, including its California users, with a cost-free method to opt-out of the sharing of Personal Information with all third parties for the direct marketing of those third parties, by not disclosing to third parties, for their direct marketing purposes the Personal Information of any customer if the customer has exercised the option to prevent such disclosure, and by disclosing these policies in its Privacy Policy. Consequently, DEANBURY VODKA is not obligated under Shine the Light to provide California users, who have requested such information, a list of the categories of the Personal Information disclosed by DEANBURY VODKA to third parties for their direct marketing purposes or the names and addresses of the third parties to which DEANBURY VODKA has shared such Personal Information for their direct marketing purposes during the preceding calendar year.
California residents may have further rights related to the handling of their Personal Information under the California Consumer Privacy Act. While DEANBURY VODKA does not "sell" your Personal Information in the traditional sense, it may share your information with third parties.  California residents may have certain rights related to this information, including the right to ask that we "Do Not Sell Your Personal Information," the right to ask that we Delete your Personal Information, or the right to request access to the categories or specific pieces of Personal Information we have collected about you.  California residents also have the right to not be treated differently by DEANBURY VODKA in response to your decision to exercise any of these rights. 


To learn more about these rights, to opt-out of our sharing of your Personal Information, and to exercise other rights that apply, please contact DEANBURY VODKA by emailing us at hello@deanburyvodka.com. As part of your request, we may ask for certain information including your name and account information, or the manner in which you have previously interacted with DEANBURY VODKA.  We will use this information only to contact you about your request and to verify your request.  You may also designate an authorized agent to submit a request on your behalf. 

Changes to this Privacy Policy:
DEANBURY VODKA reserves the right to change this Privacy Policy from time to time as it sees fit and your continued use of the Site will signify your acceptance of any adjustment to this Privacy Policy. If there are any changes to our Privacy Policy, we will announce that these changes have been made on our home page and on other key pages on our Site. If there are any changes in how we use our customers’ Personal Information, notification by e-mail will be made to those affected by this change. Any changes to our Privacy Policy will be posted on our Site 30 days prior to these changes taking place. You are therefore advised to re-read this statement on a regular basis.


Effective Date:
This Privacy Policy is effective as of August 5, 2021.