Notice at Collection

We may collect or receive (and may have collected or received during the 12-month period prior to the Last Update date of this Notice) the categories of personal information, including sensitive personal information listed below.  Not all categories will be collected or received for every individual. 

• Identifiers and customer records personal information, such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (“IP”) address, email address, account name, Social Security number, driver’s license number, name, signature, telephone number, state identification card number, education, employment, employment history, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
• Characteristics of protected classifications and demographic information if voluntarily provided, such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, or veteran or military status.
• Commercial information, including information about your interests and consuming history or tendencies, such as products or services considered, purchased, obtained, or other purchasing or consuming histories or tendencies; transaction information when you request information, contact us, or purchase, return, request, or exchange a product or service, including payment card information or other financial information; information provided in response to surveys or other research conducted on our behalf; and information you provide in public forums.
• Internet or other electronic network activity information, including information regarding your interactions with us online, including browsing history, search history, and information on your interactions with our websites, applications, or advertisements, and information we obtain from third parties about the use of our applications on third-party platforms or devices.
• Geolocation data, including approximate location information provided by a mobile device or other device interacting with or detected by our websites or applications.
• Professional or employment-related information if voluntarily provided, such as current or past job history or performance evaluations. 
• Sensitive Personal Information: Government-issued identifiers (such as Social Security number, driver’s license, and state identification card), account access credentials, and financial information (such as payment card details).

We may obtain and combine personal information from different sources, as described in the How We Collect Your Information section of our Privacy Policy.  We collect this information so that we can best serve you, including to fulfill your requests and to share offers or information that we think you may be interested in.  As further described in the How We Use Your Information  section in our Privacy Policy, we generally collect and use the above-listed categories of personal information to provide and manage our Websites, products, and services, and for other business or commercial purposes, such as advertising, marketing, and to improve our products and services.

We use sensitive personal information for the following purposes: 

• Government-issued identifiers to: process your employment application, including to conduct background checks if we offer you a position of employment; and respond to law enforcement requests and as required by applicable law, court order, or government regulations.
• Financial information to: process your requests, purchases, transactions, and payments and prevent transactional fraud; provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses; and help maintain the safety, security, and integrity of our Website, Webstore, products and services, databases and other technology assets.

If you voluntarily provide other sensitive information, such as racial or ethnic origin, religious or philosophical beliefs, health information, and sex life or sexual orientation information, we do not use such information except, in limited circumstances to: 

• Process health insurance claims. 
• Investigate and process workers’ compensation claims. 
• Review and process religious reasonable accommodations requests.
• Conduct internal audits and investigate complaints, grievances, and suspected violations of our policies.
• Respond to law enforcement requests as required by applicable law, court order, or government regulations. 
• Exercise or defend our legal rights and the rights of our employees, customers, contractors, and agents.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Selling and Sharing of Personal Information

We may rent, sell, or use for targeted advertising, the personal information we collect.  We may disclose your personal information to our third-party service providers for a business purpose as described in the How We Share Your Information section in our Privacy Policy.  We do not knowingly sell or share the personal information of consumers under 16 years of age.  For more information about treatment of children’s personal information, see the Users Under the Age of 21 section of our Privacy Policy.

Data Retention

We retain each category of personal information that we collect for as long as necessary to fulfill the purposes described in our Privacy Policy, including to satisfy legal or reporting requirements.  What this means in practice will vary for different types of information, but the criteria assessed in the data retention analysis consider ongoing business or legal needs for the information, for example in relation to tax, health and safety, and potential or actual disputes or investigations.

Your California Privacy Rights 

If you are a California resident, you can make certain requests regarding your personal information.  Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies.  If we are unable to comply with your request in whole or in part, we will notify you with reasons for the denial.  Your rights include:  

• • Right to Know: You have the right to request that we disclose to you the categories of personal information we have collected about you, as well as the sources of such personal information, the purposes, and the categories of third parties with whom such personal information is shared.

• Right to Access: You have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, sell, and share.

• Right to Delete: You have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.

• Right to Correct: You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.

• Right to Opt-Out of Sale or Sharing of Personal Information: You have the right to opt out of the “sale” or “sharing” of your “personal information” to or with “third parties” (as those terms are defined by California Privacy Laws).

• Right Not to Receive Discriminatory Treatment.  You have the right not to receive discriminatory treatment for the exercise of your privacy rights.  If you choose to exercise any of these rights, you will not receive different prices or quality of services unless permitted by applicable law, including if those differences are reasonably related to your information.  For example, if you exercise your right to opt out of “sale” or “sharing” of your “personal information,” the ads you view may not be tailored to your interests.  We may offer you certain promotions, sweepstakes, or contests that qualify as “financial incentives” under California Privacy Laws.  Participation in these activities may result in different opportunities, benefits, or prizes.  The collection of your personal information in these instances, such as your name, email address, and/or phone number, will be governed by the applicable terms and conditions for each program, which will detail any financial incentives offered and how to opt in and participate.  Your participation in these promotions is voluntary and requires your prior opt-in consent, which you may revoke at any time.  For more information about our financial incentive programs, please see our Notice of Financial Incentives below.

Exercising Your California Privacy Rights

Making Requests to Know, Access, Delete, or Correct Your Personal Information, or Opt-Out of the Sale of Your Personal Information.  To exercise your rights to know, access, delete, or correct your personal information, or opt-out of the sale of your personal information, please submit a request by clicking on the Do Not Sell My Information on the bottom of our Website pages, emailing: privacy@gambrinus.com, or  calling: 1-800-596-6486.  Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information.  You may only submit a request to know twice within a 12-month period.  We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  We will only use personal information provided in a request to review and comply with the request.  We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.  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.  We will delete or de-identify personal information not subject to a legal exception from our records and will direct our service providers to take similar action.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. 

Instructions for Using an Authorized Agent to Make Requests: You may use an authorized agent to submit a request to know or an access, deletion, correction, or opt-out request on your behalf.  An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable law.  Before completing requests from authorized agents, we may contact you directly to confirm you’ve given your permission and/or to verify your identity.  Authorized agents may submit requests by clicking on the Do Not Sell My Information on the bottom of our Website pages, emailing: privacy@gambrinus.com, or calling: 1-800-596-6486.

Notice Of Financial Incentives

We may offer various sweepstakes, contests, or other promotional campaigns (“Programs”) that provide certain benefits to our users and customers.  In general, we collect personal information to support and fulfill the Programs, which could include identifiers, demographic information, commercial information, Internet or other electronic network activity information, and geolocation data.  For additional details on the types of information we may collect, please see Types of Information We Collect in our Privacy Policy .  Because we collect personal information, the Programs may be considered to be “financial incentives” or “price or service differences” under California Privacy Laws.

To the extent the Programs are reasonably related to the value of your personal information, the method for calculating this value would include the expenses related to our offer (such as the costs of providing discounts, free shipping, or other promotions, intellectual property or marketing costs, and other related expenses).  The value of your personal information that we collect will vary depending on your engagement.

To learn more about the details of our Programs, including the material terms, please review the specific terms of each Program.  If you have any questions or require assistance, please contact us by emailing: privacy@gambrinus.com, or calling: 1-800-596-6486.

Contact Information

If you have any questions or comments about this Notice, the ways in which we collect and use your information, our Privacy Policy, your choices and rights regarding such use, or wish to exercise Your California Privacy Rights, please do not hesitate to contact us by clicking on the Do Not Sell My Information on the bottom of our Website pages, emailing: privacy@gambrinus.com, or calling: 1-800-596-6486.