Last Modified and Effective Date: January 1, 2020
Root Drinks LLC
- ACCESS RESTRICTED TO INDIVIDUALS OF LEGAL DRINKING AGE
- COLLECTION, USE & DISCLOSURE OF INFORMATION
- TRACKING TECHNOLOGIES
- SHARING YOUR INFORMATION/DISCLOSURE TO THIRD-PARTIES
- CHOICES AND OPT-OUT
- SECURITY AND STORAGE OF INFORMATION
- THIRD PARTY APPLICATIONS/WEBSITES
- PRIVACY INQUIRIES AND CORRECTING YOUR INFORMATION
- INFORMATION FOR EU RESIDENTS
- INFORMATION FOR CALIFORNIA RESIDENTS
ACCESS RESTRICTED TO INDIVIDUALS OF LEGAL DRINKING AGE
Root Drinks LLC SITES AND ADVERTISING ARE INTENDED ONLY FOR PERSONS OF LEGAL DRINKING AGE BASED ON THE JURISDICTION WHERE SUCH CONTENT IS BEING ACCESSED OR VIEWED. YOU WILL BE REQUIRED TO VERIFY YOUR DATE OF BIRTH PRIOR TO ENTERING OR INTERACTING WITH A SITE. AGE VERIFICATION PROMPTS MAY ALSO BE LOCATED WITHIN THE SITES.
It does not apply to information we obtain in our capacity as an employer. For information on how Root Drinks LLC will process your information where you apply for a job with us, please see our separate fair processing notice which can be found when you apply for a job.
COLLECTION, USE, AND DISCLOSURE OF INFORMATION
Root Drinks LLC collects personal information relating to you in a variety of ways depending on how you interact with us. The following represents a non-exhaustive list of common activities with examples of the type of information that we collect from and about you, and how we use that information (collectively, “Information”):
Context Type of Information Primary Purpose for Collection & Use Contact customer service, make inquiries, or otherwise communicate with us
Contact information (e.g., name, home or physical address, email address, telephone number, and mobile phone number).
Some of our Sites utilize live or automated conversation systems, or “chat bots,” that allow us to interact with customer, help customers buy goods and services, and answer a wide variety of questions. When you communicate with our chat bots, we collect the content that you send to us in order to reply. For more information about our use of chat bots, please go to Terms & Conditions.
We have a legitimate interest in receiving, and responding to your inquiries and acting upon your feedback or issues. Opt in to receive promotional communications Contact information (e.g., name, home or physical address, email address, telephone number, and mobile phone number); We share information about new products, events, and promotions with individuals that have opted in to receive such information. We also have a legitimate interest in sharing information about our products or services. Order merchandise
Contact information (e.g., name, home or physical address, email address, telephone number, and mobile phone number);
Billing and shipping information (e.g., credit/debit card number, expiration date, CVV code, billing and shipping addresses and contact information).
We use your information to perform our contract to fulfill your order and process your transactions/payments. Register for an account
Contact information (e.g., name, home or physical address, email address, telephone number, and mobile phone number);
Username and passwords used to access Sites, including verification through social media platforms.
We have a legitimate interest in administering your account and providing account related functionalities. Accounts can be used for easy checkout and to save your preferences and transaction history. Interact with us on social media Social media account information (e.g., user name and passwords, profile images, and other images that you make available such as user-generated content).
We have a legitimate interest providing customers with a means for interacting with us on social media.
We also have a legitimate interest in understanding customer perception of our brands and products, creating content tailored to our followers, understanding industry trends, improving customer experience, and developing products that would be of interest to our followers.
Enter a promotion, sweepstakes, contest, or other special offer
Government identification numbers (which may include, if you are resident in the US, Social Security Number (in limited circumstances, for example if you win a sweepstakes or receive compensation that must be reported on government tax forms)).
We have a legitimate interest in operating the sweepstakes, contests, and special offers, including notifying you if you are selected. In some contexts we are also required by law to collect information about those that enter into our sweepstakes, and we have a legitimate interest in complying with those laws. Complete a survey or voluntarily provide information about yourself
Demographic information including date of birth, gender, interests, state, zip/postal code, time zone, country, and language;
Preferences, shopping habits, and other lifestyle information, including product wish lists, order history, marketing preferences, and cell phone carrier.
We have a legitimate interest in understanding our users and providing tailored services.
We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.
Interact with our Site, emails, and/or online advertisements
Search queries, Application usage data;
Server log file location, internet service provider, mobile or other device identifier (e.g., UDID and MEID), user agents, or IP address;
Information collected through cookies, tags, pixels, clear pixels, beacons, and other similar technologies;
Referring and exiting websites/URLs (including click through URL and pixel tags);
Browser and device information (including platform and version);
Geo-location information such as your precise or approximate location.
We have a legitimate interest in understanding our users and providing tailored services. In some contexts our use is also based upon your consent, such as when we obtain your consent for the deployment of cookies on our Sites.
We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful.
We have a legitimate interest in monitoring our networks and the visitors to our Sites. We also have a legitimate interest in detecting and preventing fraud.
Although the above chart describes examples of information we collect and our primary purpose in collecting such information, in many situations we have more than one legitimate purpose. For example, if you complete an online order we collect your payment and shipping information to perform our contract with you (e.g., to process and fulfill your order), but we also collect your information because we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your order. As a result, our collection and processing of your information is based in different contexts upon: (i) your consent (e.g., to place cookies or for marketing), (ii) the performance of our contract with you (e.g., to provide you with products and services you have requested); (iii) compliance with legal obligations (e.g., where we are required to disclose information to a court or tax authority); and/or (iv) our legitimate interests in conducting our business.
To the extent that any Information is considered “personal information” by local law, we treat this information as such and ensure that our handling of this information complies with all applicable data privacy and protection laws. To the extent permitted by applicable law, any Information you provide to us directly may be combined with other Information that you provide to us through other channels, that is publicly available, or that we may otherwise obtain, including from third parties.
How We May Collect Information: Root Drinks LLC may collect Information from the following:
- From You (e.g., information, such as date of birth, gender, hobbies and interests, consumption habits, zip/postal code and your preferred means of communication when you voluntarily provide it);
- Our Sites and Applications (e.g., when you purchase a product on an e-commerce Site or opt-in to receive promotional emails);
- Offline (e.g., customer service inquiries, sweepstakes);
- Online tracking technologies, including cross-device tracking (e.g., service file logs, IP address, cookies, tags, pixels, clear pixels, gifs, bugs, beacons, and other similar technologies, some of which may enable Root Drinks LLC or our service providers to identify you and collect information about you across devices and Sites);
- Mobile usage ((i.e., information learned from our mobile application, such as your device’s latitude and longitude or your device’s location capabilities (e.g., GPS, Wi-Fi, Bluetooth signal, beacons, LED light chips or other similar technologies)) and 3rd party mobile pay applications or services;
- Through your browser or device (e.g., certain information, including your computer type, operating system name and version, IP address, Media Access Control (“MAC”) address, language, Internet browser type and version, and service provider that is often automatically collected by most browsers);
- Through website analytics and advertising features (e.g., Google Analytics, Google Analytics Demographics, Interest Reporting, Adobe Flash technologies including but not limited to Adobe Flash Local Stored Objects, Quantcast);
- Other Sources (e.g., public databases; joint marketing partners, social media platforms, from people with whom you are connected on social media platforms, public forums, and from other third parties).
How We May Use Information: To the extent permitted by applicable law, Root Drinks LLC may use your Information to:
- Identify you when you visit our Sites;
- Send administrative information to you, for example, information regarding the Sites and changes to our terms, conditions, and policies.
- Administer your account on any of our Sites, including rewards programs, sweepstakes, and contests for which you enter, including notifying you of the results.
- Please note that some promotions have additional rules, which could contain additional information about the use and disclosure of your Information;
- Send you marketing communications and updates about Root Drinks LLC for which you have opted in (e.g., emails, push notifications, SMS and MMS messages);
- Deliver customized or targeted advertisements to you;
- Send you transactional emails about purchases made on our Sites, including order confirmation and abandoned cart emails;
- Fulfill your order and process transactions/payments;
- Provide customer support and respond to your inquiries and fulfill requests;
- Allow you to send messages to a friend (legal drinking age only) through the Sites. By using this functionality, you are telling us that you are entitled to use and provide us with your friend’s contact information;
- Conduct marketing research and analysis;
- Personalize your experience on our Sites, including displaying content based upon your location, past purchases, interests, as well as Information collected across devices and Sites;
- Diagnose, enhance and improve our products, services, Sites, content, advertising, and promotions;
- Comply with or enforce applicable legal requirements, including complying with laws outside of your country of residence;
- Respond to requests from governmental authorities, including those outside of the country of residence;
- Use your Information for other purposes on an anonymized or aggregate basis; or
- As otherwise required by law.
- How We May Collect Information: Root Drinks LLC may collect Information from the following:
Cookies and Tracking Technologies. Root Drinks LLC utilizes “cookies”, “tags”, “pixels”, “clear gifs” and other similar tracking technologies on our Sites. A cookie is a text file that is placed on your computer or other mobile device when you access the Sites or the Internet. These technologies allow us to collect Information about your interaction with our Sites and advertisements. Examples of such Information may include, but are not limited to: demographic Information, browser type, IP address, pages viewed, activity conducted, and timing of your visit.
Different types of cookies may be used for different purposes on our Sites. These are known as: required cookies, functional cookies, and advertising cookies. Some cookies may be provided by an external third party to provide additional functionality to our Sites and these are included below. You may at any time "opt out" of certain tracking mechanisms. However, disabling such cookies may prevent you from using certain features or taking full advantage of all our offerings on our Site.
These cookies are necessary to enable the basic features of this site to function, such as providing secure log-in or remembering how far you are through an order. If you do not agree to the Required Cookies, then you will not be able to use the Sites.
These cookies allow us to analyze your use of the site to evaluate and improve our performance. They may also be used to provide a better customer experience on this site. For example, remembering your log-in details, saving what is in your shopping cart, or providing us information about how our site is used.
These cookies are used to show you ads that are more relevant to you. We may share this information with advertisers or use it to better understand your interests. For example, Advertising Cookies may be used to share data with advertisers so that the ads you see are more relevant to you, allow you to share certain pages with social networks, or allow you to post comments on our site.
- Required Cookies
Cookies on Your Browser. Subject to applicable privacy laws, we will automatically collect cookies and other information when you visit our Sites. We currently participate in third party ad networks and use third party cookies as discussed above to track your visits across websites.
Additionally, you may at any time "opt out" of certain tracking mechanisms through your browser settings. However, disabling such features may prevent you from using certain features or taking full advantage of all our offerings on our Site. Please refer to your browser Help instructions to learn more about cookies and other tracking devices and how to manage their use. If you use another computer or change browsers, you will need to repeat the process of refusing or deleting cookies. For more information about cookies including how to set your internet browser to reject cookies please go to www.allaboutcookies.org.
Ad Tracking. Certain devices may allow you to Limit Ad Tracking. Please refer to the settings on your computer or device for information on how to disable Ad Tracking.
Do Not Track Requests. While some browsers have a “do not track” feature, because these features are not yet uniform we do not currently recognize browser based “do not track” requests.
SHARING YOUR INFORMATION/DISCLOSURE TO THIRD-PARTIES
- Affiliates. We share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies and brands under common control).
- Marketing Partners. We share information with service vendors/providers that help us to evaluate and improve our marketing and promotional efforts, content, products and services, to better understand customer interests and preferences, to provide you relevant information, and to conduct joint marketing programs.
- Service Vendors/Providers. We share information with service vendors/providers that help us with certain business activities, including but not limited to processing credit card transactions, administering promotions, fulfilling and shipping your order, assisting us in Site operations, providing customer service (e.g., telephone, online, or via chat bots), and delivering email communications.
- Corporate Change. We may share information in connection with a corporate change including a merger, acquisition, or sale of assets, including during the planning and negotiation stages.
- Certain Other Disclosures Without Your Consent. We may disclose information as required by law, such as in conjunction with a government inquiry or to comply with a subpoena, warrant, court order, or similar legal process. We may also share your information when we believe in good faith that disclosure is necessary to protect our rights, to defend against a legal claim, to protect your safety or the safety of others, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, or a violation of our policies.
CHOICES AND OPT-OUT
- Emails. We may use your email address to send emails, newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions included in emails you receive from us, or by contacting us using the details below.
- Mobile Marketing (SMS and MMS) Updates. We may send you text messages relating to our brands, promotions, and other legitimate purposes. If you choose to join a mobile marketing list or participate in any text message program with us, there are typically message and data costs associated with receiving SMS (text) or MMS (multimedia) messages. These will vary based on your wireless carrier and plan. Check with your mobile carrier to determine what charges may apply. If you would like to stop receiving messages from us on your mobile device, reply to the message with “STOP” (or other message as instructed). You may also contact your mobile carrier for additional information on receiving or stopping mobile messages.
- Location Services. If you have previously enabled location sharing on your computer or mobile device, you may be able to opt out from further sharing by changing the settings on your computer or mobile device or by uninstalling the Application. We will not use any precise location data without your prior consent, which may be obtained directly by us or through our service providers or media partners.
- Push Notifications. If you wish to disable push notifications on your mobile device, refer to Settings on your mobile device.
Third Party Analytics.
- Google Analytics: For more information on how to opt out of our use of Google Analytics and our use of its Advertising Features visit https://tools.google.com/dlpage/gaoptout and http://www.google.com/safetycenter/tools/#manage-your-ads-preferences.
- Quantcast: For more information on or to opt-out of Quantcast, visit their site at https://www.quantcast.com/opt-out.
- DAA Opt-Out Page: Users can opt out of additional tracking and targeted advertising, including Google Analytics and Quantcast, via the Digital Advertising Alliance’s (“DAA”) opt-out page and the Networking Advertising Initiatives’ (“NAI”) opt-out page at http://www.aboutads.info/choices/ and http://www.networkadvertising.org/choices/, respectively.
SECURITY AND STORAGE OF INFORMATION
We will store your Information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this notice. In some circumstances, we may store your Information for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements.
THIRD PARTY APPLICATIONS/WEBSITES
Social Networks/Online Communities
On certain Sites, we may enable you to access online communities for sharing information such as messages, photos, and videos. We may also enable you to post content from some Sites to your profile on other social networks. We cannot control any policies or terms of such third party social networks. For example, sharing such information with Facebook may require us to implement cookies and/or APIs in order to facilitate the communication between our Sites and Facebook. That information, shared through cookies and/or APIs, then becomes subject to Facebook’s Data Policy, located at https://www.facebook.com/full_data_use_policy. As a result, we cannot be responsible for any use of your information or content by a third party social network, which you use at your own risk.
Widgets and Interactive Applications
- Social Networks/Online Communities
PRIVACY INQUIRIES AND CORRECTING YOUR INFORMATION
Los Angeles, CA
Please note that email communications are not always secure; so please do not include any sensitive information, including credit card information, in your emails to us.
For further information on how we ensure compliance with applicable EU data privacy and protection legislation, please see the “Information for EU Residents” section below.
INFORMATION FOR EU RESIDENTS
Legal Basis for Processing. All processing (i.e., collection and use) of your Information is based on one of a number of legal conditions. Generally, these include:
- Your consent (for example, to place cookies which process Information, or to receive marketing communications from us);
- The performance of our contract with you (e.g., to process your payment or shipping information in order to fulfil your order);
- Compliance with a legal obligation (e.g., where we are required to disclose information to a court or a tax authority); and
- Our legitimate interests, provided these do not override your fundamental rights and freedoms (e.g., where we carry out research and analysis to improve our Site, products and services).
Rights of EU Residents. Subject to applicable law, as a resident of the EU, you may have certain rights with respect to your Information. These rights may include some of the following:
- To obtain a copy of your Information together with information about how and on what basis that Information is processed;
- To rectify inaccurate Information (including the right to have incomplete Information completed);
- To erase your Information (in limited circumstances, where it is no longer necessary in relation to the purposes for which it was collected or processed);
- To restrict processing of your Information where:
- The accuracy of the Information is contested;
- The processing is unlawful but you object to the erasure of the Information;
- We no longer require the Information but it is still required for the establishment, exercise or defense of a legal claim;
- To challenge processing which we have justified based on a legitimate interest (as opposed to your consent, or to perform a contract with you);
- To prevent us from sending you direct marketing;
- To withdraw your consent to our processing of your Information (where that processing is based on your consent);
- To object to decisions which are based solely on automated processing or profiling; and
- To obtain, or see a copy of the appropriate safeguards under which your Information is transferred to a third country or international organization.
In addition to the above, you have the right to lodge a complaint with your local supervisory authority (for example, the ICO in the United Kingdom).
Please contact us using the details above to exercise your rights. As noted above, we will request proof of identity, and verify such identity. Additionally, we reserve the right to charge a fee where permitted by law, including for example, if your request is manifestly excessive or unfounded. Lastly, we will respond to your requests within the applicable timeframes and consistent with applicable regulations.
International Transfers for EU Residents
You should be aware that Root Drinks LLC is headquartered in the United States with corporate offices abroad. Your Information may be transferred to and stored in the United States for processing. By submitting your Information to us you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States.
In relation to both internal transfers and the use of affiliates, service providers or suppliers, for information that is transferred outside the European Economic Area ("EEA"), we enter into data transfer agreements, use the EU Commission approved Standard Contractual Clauses, or rely on certification schemes such as the EU - US Privacy Shield. You may have a right to request additional details about the mechanisms under which your data is transferred outside the EEA. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information above.
- Legal Basis for Processing. All processing (i.e., collection and use) of your Information is based on one of a number of legal conditions. Generally, these include:
INFORMATION FOR CALIFORNIA RESIDENTS
- California Information Sharing Disclosure. California law indicates that organizations should disclose whether certain categories of information are collected, transferred for “valuable consideration,” or transferred for an organization’s “business purpose” as those terms are defined under California law. You can find a list of the categories of information that we collect and share in the chart below. Please note that because this list is comprehensive it may refer to types of information that we collect and share about people other than you.
Rights of California Residents. Subject to applicable law, as a resident of California, you may have certain rights with respect to your personal information. These rights may include the following:
- To request access to the personal information that we hold about you. Additionally, if you would like to obtain a list of any Information Root Drinks LLC has disclosed about you to third parties for direct marketing purposes during the preceding calendar year, please send a written, signed request to Root Drinks LLC by mail at the address above.
- To request that Root Drinks LLC deletes your Information (in limited circumstances).