CA Privacy Notice
ITG Brands California Privacy Notice
Effective Date: January 1, 2023
This ITG Brands, LLC (“ITGB,” “Company,” “us,” “we,” or “our”) California Privacy Notice (“Notice”) is provided pursuant to the California Consumer Privacy Act, as amended (the “CCPA”). This Notice supplements ITGB’s other privacy policies and notices, including our Privacy Policy. In the event of a conflict between any other Company policy, statement, or notice and this Notice, this Notice will prevail as to California consumers and their rights under the CCPA.
This Notice does not apply to job applicants or current and former employees/contractors. If you are an employee or current or former employee/contractor, a separate privacy notice will be provided to you in the course of your employment. If you are an applicant, please review our California applicant privacy notice If you have any questions, please contact us as provided below.
Unless otherwise noted, the disclosures herein cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices.
HOW AND WHY WE COLLECT, USE, AND DISCLOSE PERSONAL INFORMATION
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, aggregated, and the CCPA exempts certain additional categories of information from its purview, such as information subject to other laws and regulations. This Notice applies only to information governed by the CCPA
We may collect, use, and disclose Personal Information and sensitive Personal Information for valid business purposes or in connection with threatened or pending litigation consistent with applicable laws as identified below. Where we disclose applicable Personal Information or sensitive Personal Information to recipients, such as our service providers, we do so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us.
1. Identifiers
Example:
Real name, alias, account name, username, driver’s license number, signature, social security number, state identification number, postal address, unique personal identifier, online identifier, IP address, email address, or other similar identifiers
Purpose for Collection:
- To allow you to participate in the features we offer
- To maintain your accounts with us
- To communicate with you, including about our products, your orders, updates to our terms and policies, and to obtain your feedback
- To send you marketing materials and advertisements
- To recognize you when you use our services
- To show you relevant ads while you browse the internet or use social media
- To send you relevant coupons
- To allow you to participate in promotions, sweepstakes, contests, and rewards programs
- Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes
- To detect and prevent fraud against you and/or us
- For litigation and other legal and regulatory requirements
Categories of Recipients to Whom Personal Information is Disclosed for a Business Purpose:
- Service providers
- Affiliates
- Data analytics providers
- Legal counsel and/or in connection with threatened or pending litigation and regulatory matters
2. Personal Records Described in Cal. Civ. Code § 1798.80(e)
Example:
Name, address, telephone number, state identification card number, and bank account number, credit card number, debit card number, or other financial payment information
Some Personal Information included in this category may overlap with other categories
Purpose for Collection:
- To allow you to participate in the features we offer
- To maintain your accounts with us
- To communicate with you, including about our products, updates to our terms and policies, and to obtain your feedback
- To send you marketing materials and advertisements
- To recognize you when you use our services
- To show you relevant ads while you browse the internet or use social media
- To send you relevant coupons
- To allow you to participate in promotions, sweepstakes, contests, and rewards programs
- Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes
- To detect and prevent fraud against you and/or us
- For litigation and other legal and regulatory requirements
Categories of Recipients to Whom Personal Information is Disclosed for a Business Purpose:
- Service providers
- Affiliates
- Data analytics providers
- Legal counsel and/or in connection with threatened or pending litigation and regulatory matters
3. Characteristics of protected classification under California or federal law
Example:
Age and date of birth, gender, languages spoken, marital status, and racial or ethnic origin
Purpose for Collection:
- To allow you to participate in the features we offer
- To send you relevant marketing materials and advertisements
- To tailor our communications to you
- To improve our services, and our products, marketing and advertising
- Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes
- To detect and prevent fraud against you and/or us
- For litigation and other legal and regulatory requirements
Categories of Recipients to Whom Personal Information is Disclosed for a Business Purpose:
- Service providers
- Affiliates
- Data analytics providers
- Legal counsel and/or in connection with threatened or pending litigation and regulatory matters
4. Commercial Information
Example:
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Purpose for Collection:
- To allow you to participate in the features we offer
- To provide you with appropriate products and recommendations
- To help you find relevant products more quickly
- To tailor our communications to you
- To provide customer service and support
- To send you relevant coupons
- To allow you to participate in promotions, sweepstakes, contests, and rewards programs
- To improve the Service, and our products, marketing and advertising
- Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes
- To detect and prevent fraud against you and/or us
Categories of Recipients to Whom Personal Information is Disclosed for a Business Purpose:
- Service providers
- Affiliates
- Data analytics providers
5. Internet or other electronic network activity information
Example:
Internet or other similar activity, browsing history, search history, information on a consumer’s interaction with a website, application logs, device data and registration, social media account information or advertisement
Purpose for Collection:
- To allow you to participate in the features we offer
- To provide you with appropriate products and recommendations
- To help you find relevant products more quickly
- To tailor our communications to you
- To provide customer service and support
- To send you relevant coupons
- To allow you to participate in promotions, sweepstakes, contests, and rewards programs
- To improve our services, and our products, marketing and advertising
- Auditing, research and analysis, to maintain and improve the Service, and for any other internal business purposes
- To detect and prevent fraud against you and/or us
Categories of Recipients to Whom Personal Information is Disclosed for a Business Purpose:
- Service providers
- Affiliates
- Data analytics providers
6. Geolocation Data
Purpose for Collection:
- To allow you to participate in the features we offer
- To deliver coupons to you
- Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes
Categories of Recipients to Whom Personal Information is Disclosed for a Business Purpose:
- Service providers
- Affiliates
- Data analytics providers
7. Audio, electronic, visual, thermal, olfactory, or similar information
Example:
Audio recordings of customer care calls, video, or similar information
Purpose for Collection:
- To provide you with customer service
- To improve our products and the Service
- For litigation and other legal and regulatory requirements
Categories of Recipients to Whom Personal Information is Disclosed for a Business Purpose:
- Service providers
- Affiliates
- Data analytics providers
- Legal counsel and/or in connection with threatened or pending litigation and regulatory matters.
8. Professional or employment related information
Example:
If you are a Company employee, please contact Human Resources for additional disclosures. Job applicants can find additional disclosures here.
Purpose for Collection:
- For litigation and other legal and regulatory requirements
Categories of Recipients to Whom Personal Information is Disclosed for a Business Purpose:
- Legal counsel and/or in connection with threatened or pending litigation and regulatory matters.
9. Non-public education information
Example:
School(s) attended and degree obtained.
Purpose for Collection:
- For litigation and other legal and regulatory requirements
Categories of Recipients to Whom Personal Information is Disclosed for a Business Purpose:
- Legal counsel and/or in connection with threatened or pending litigation and regulatory matters
10. Inferences used to create a profile.
Example:
School(s) attended and degree obtained.
Purpose for Collection:
- To provide you with appropriate products and recommendations
- To improve our services, and our products, marketing and advertising
- To provide you with a better website or app experience
- Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes
- To detect and prevent fraud against you and/or us
Categories of Recipients to Whom Personal Information is Disclosed for a Business Purpose:
- Service providers
- Affiliates
- Data analytics providers
11. Other Information
Example:
Information that does not directly fit within one of the categories defined by the CCPA, including the contents of communications you send to us by phone, email, text, online chat, etc.
Purpose for Collection:
- To communicate with you about our products and services, your orders, and to provide customer service and support
- To improve our websites, apps, products, and marketing
- To allow you to participate in our promotions, sweepstakes, contests, and loyalty programs
- To detect and prevent fraud against you and/or us
- For litigation and other legal and regulatory requirements
Categories of Recipients to Whom Personal Information is Disclosed for a Business Purpose:
- Service providers
- Affiliates
- Data analytics providers
- Legal counsel and/or in connection with threatened or pending litigation and regulatory matters
Sensitive Personal Information
We may collect, use, and disclose sensitive Personal Information for business purposes consistent with applicable laws, as identified below. Where we transfer applicable sensitive Personal Information to recipients, such as our service providers, we do so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us.
Personal Information that reveals a consumer’s social security, driver’s license, state identification card, or passport number
Business Purposes for Collection, Use, and Disclosure
- To allow you to participate in the features we offer
- To maintain your accounts with us
- To communicate with you, including about our products, updates to our terms and policies, and to obtain your feedback
- To send you marketing materials and advertisements
- To recognize you when you use our services
- To send you relevant coupons
- To allow you to participate in promotions, sweepstakes, contests, and rewards programs
- Auditing, research and analysis, to maintain and improve our services, and for any other internal business purposes
- To detect and prevent fraud against you and/or us
- For litigation and other legal and regulatory requirements
Categories of Recipients to Whom Sensitive Personal Information is Disclosed for a Business Purpose
- Service providers
- Affiliates
- Data analytics providers
- Legal counsel and/or in connection with threatened or pending litigation and regulatory matters
Personal Information that reveals a consumer’s race
Business Purposes for Collection, Use, and Disclosure:
- For product testing
- For litigation and other legal and regulatory requirements
Categories of Recipients to Whom Sensitive Personal Information is Disclosed for a Business Purpose
- Service providers
- Affiliates
- Legal counsel and/or in connection with threatened or pending litigation and regulatory matters
Personal Information collected and analyzed concerning a consumer’s health
Business Purposes for Collection, Use, and Disclosure:
- For litigation and other legal and regulatory requirements
Categories of Recipients to Whom Sensitive Personal Information is Disclosed for a Business Purpose:
- Legal counsel and/or in connection with threatened or pending litigation and regulatory matters
Disclosing Your Personal Information
We may disclose each of the categories of Personal Information and sensitive Personal Information identified above to the respectively identified categories of recipients for operational 6 or business purposes consistent with the purposes for collection or use designated, as is reasonably necessary and proportionate to achieve those purposes, or for another purpose that is compatible with the context in which the Personal Information or sensitive Personal Information was collected including, but not limited to:
- Auditing related to ads;
- Helping to ensure security and integrity;
- Debugging, repairing, and improving functionality;
- Short-term, transient use;
- Performing services on our behalf;
- Providing advertising and marketing services, as applicable;
- Internal research for technological development; and
- Verifying quality and/or safety.
In addition to the other purposes for collection, use, and disclosure of Personal Information and sensitive Personal Information described in this Notice, we may collect, use, and disclose Personal Information and sensitive Personal Information as required by law, regulation, or court order; to respond to governmental and/or law enforcement requests; to identify, contact, or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a threatened or pending case or before any jurisdictional and/or administrative authority, arbitration, or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may disclose Personal Information and sensitive Personal Information to other parties in connection with the sale, assignment, merger, or reorganization.
Sources of Personal Information
We may collect Personal Information and sensitive Personal Information from the following sources:
- Directly from you. For example, when you sign up to receive information from us, when you place an order, or any other time you submit Personal Information to us voluntarily.
- Automatically when you use our website or mobile apps. For example, we may collect your usage history when you use our websites, systems, and applications.
- Other parties. For example, we may receive Personal Information from service providers who provide us with IT services, advertising services, or help facilitate our sales.
Tracking Technologies
We may use tracking technologies, such as cookies, including tracking technologies managed by vendors or external parties.
Tracking technologies can generally be categorized as follows:
- Necessary or essential. These tracking technologies are used for core functionality, for example for security and to enforce your privacy preferences. Without these cookies, some functionality on our websites and apps may fail.
- Functional or analytics. These tracking technologies help to improve our websites and apps by allowing us to understand how they are used and how they perform. We may also use location-aware technologies for purposes such as verifying your location and delivering or restricting content based on your location.
- Advertising. These tracking technologies help personalize ads that are shown to you on our websites and apps. If enabled, these tracking technologies will allow other parties to engage in advertising based on your use of online services.
We may use Google Analytics or other providers for analytics services. We may also implement Google Analytics Advertising Features such as remarketing with analytics and interest-based ads. We may use first-party cookies or other first-party identifiers as well as third-party cookies or other third-party identifiers to, e.g., deliver advertisements, measure your interests, and/or personalize content. For more information on how Google Analytics uses data collected through our services, visit http://www.google.com/policies/privacy/partners. To opt out of Google Analytics cookies, visit https://tools.google.com/dlpage/gaoptout or download the Google Analytics Opt-Out Browser Add-On.
Depending on your device settings, you may also opt out of certain interest-based advertising through the device’s “Limit Ad Tracking” or equivalent feature. Refer to your device for more information on what this opt out affects. For instance, you can adjust or reset the advertising identifiers on your mobile device in the device settings. iOS users can visit Settings > Privacy > Advertising > Reset Advertising Identifier. Android users can visit Google settings > Ads > Reset advertising ID.
How Long We Keep Your Personal Information
The chart below shows how long we retain the categories of Personal Information and sensitive Personal Information we collect and maintain in the ordinary course of business. For each category, our retention period is determined by the purposes for which we use the information and any legal obligations that require us to retain it.
We generally retain the categories of Personal Information and sensitive Personal Information described below for as long as one of the following apply:
- Retention is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the Personal Information or sensitive Personal Information;
- Retention is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information or sensitive Personal Information was collected;
- Retention is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
- We are otherwise required or permitted to keep your Personal Information or sensitive Personal Information by applicable laws or regulations.
Where Personal Information or sensitive Personal Information is used for more than one purpose, it will be retained at least as long as the latest period provides. If collected, we may maintain Personal Information or sensitive Personal Information indefinitely according to legal or regulatory requirements, including applicable legal holds, or for data backup or recovery purposes.
Identifiers
Our records retention schedule prescribes minimum retention periods of this information for business, legal, or operational requirements, including:
• active period plus six (6) years for records related to the purchasing of products or services;
• seven (7) years for records relating to accounting for money owed by customers;
• indefinite retention for record information related to customer incentive payments; and
• indefinite retention for applicable legal or regulatory holds.
Personal Information described
in Cal. Civ. Code § 1798.80(e)
Our records retention schedule prescribes minimum retention periods of this information for business, legal, or operational requirements, including:
• active period plus six (6) years for records related to the purchasing of products or services;
• seven (7) years for records relating to accounting for money owed by customers;
• indefinite retention for record information related to customer incentive payments; and
• indefinite retention for applicable legal or regulatory holds.
Characteristics of protected classifications
Our records retention schedule prescribes retention periods of this information for business, legal, or operational requirements, including:
• indefinite retention for record information related to consumer demographics; and
• indefinite retention for applicable legal or regulatory holds.
Commercial information
Our records retention schedule prescribes minimum retention periods of this information for business, legal, or operational requirements, including:
• active period plus six (6) years for records related to the purchasing of products or services;
• seven (7) years for records relating to accounting for money owed by customers; and
• indefinite retention for record information related to customer incentive payments.
Internet or other electronic network activity information
We do not generally maintain this type of Personal Information, and our record retention schedule does not prescribe a retention period for it.
Geolocation Data
Our records retention schedule prescribes minimum retention periods of this information for business, legal, or operational requirements, including:
• seven (7) years for records relating to accounting for money owed by customers; and
• indefinite retention for information related to select marketing material.
Audio, electronic, visual, thermal,
olfactory, or similar information
Our records retention schedule prescribes retention periods of this information for business, legal, or operational requirements, including:
• indefinite retention for record information related to consumer marketing activity; and
• indefinite retention for applicable legal or regulatory holds.
Professional or employment related information
Our records retention schedule prescribes retention periods of this information for business, legal, or operational requirements, including:
• indefinite retention for record information related to consumer survey reports; and
• indefinite retention for applicable legal or regulatory holds.
Non-Public education information
We do not generally maintain this type of Personal Information, and our records retention schedule does not prescribe a retention period for it.
Inferences
We do not generally maintain this type of Personal Information, and our records retention schedule does not prescribe a retention period for it.
Other Information
Our records retention schedule prescribes retention periods of this information for business, legal, or operational requirements, including:
• indefinite retention for record information related to customer sales; and
• indefinite retention for applicable legal or regulatory holds.
Sensitive Personal Information
Social security, driver’s license, state identification card, or passport number
Our records retention schedule prescribes minimum retention periods of this information for business, legal, or operational requirements, including:
• active period plus six (6) years for records related to the purchasing of products or services;
• seven (7) years for records relating to accounting for money owed by customers; and indefinite retention for record information related to consumer demographics; and
• indefinite retention for applicable legal or regulatory holds.
Personal Information that reveals a consumer’s race
Our records retention schedule prescribes retention periods of this information for business, legal, or operational requirements, including:
• indefinite retention for record information related to consumer survey reports; and
• indefinite retention for applicable legal or regulatory holds.
Personal Information collected and analyzed concerning a consumer’s health
Our records retention schedule prescribes retention periods of this information for business, legal, or operational requirements, including:
• indefinite retention for record information related to consumer survey reports; and
• indefinite retention for applicable legal or regulatory holds.
Sharing and Selling Personal Information
We may sell or share the following categories of Personal Information with third parties for the purposes of cross-context behavioral advertising:
- Identifiers
- Internet or other electronic network activity
- Geolocation data
We sell and/or share this Personal Information with third parties for advertising purposes. The third parties to whom this Personal Information was sold and/or shared are advertisers and analytics vendors. When we use the terms sell, sold, or sale, we mean for valuable consideration and not monetary value. We offer you the ability to opt out of sales and sharing of your Personal Information as set forth in the “Right to Opt-Out of Sales and Sharing of Personal Information” section below.
We do not have actual knowledge that we sell or share the Personal Information of consumers under twenty-one (21) years of age.
Submitting Requests Relating to Your Personal Information
If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To submit a request, please use our Consumer Rights Request form or call (888) 342-6567. Please note that, if you submit a request to know, request to delete or request to correct, you will be asked to provide two-to-three (2-3) pieces of Personal Information that we will match against our records to verify your identity. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed. To submit a request as an authorized agent, please click here.
Right to Know. You have the right to know what Personal Information we have collected about you, which includes:
- The categories of Personal Information we have collected about you, including:a. The categories of sources from which the Personal Information was collected;
b. Our business purposes or commercial for collecting, selling, or sharing Personal Information;
c. The categories of recipients to which we disclose Personal Information;
d. The categories of Personal Information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information; and
e. The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information. - The specific pieces of Personal Information we have collected about you.
Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions.
Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.
Right to Opt Out of Sales and Sharing of Personal Information. You have the right to opt out of the sale of your Personal Information, and to request that we do not share your Personal Information for cross-context behavioral advertising. To opt-out, please click here.
If you choose to use the Global Privacy Control (“GPC”) browser signal, you will only be opted out of online sales or sharing of Personal Information, and will need to turn it on for each browser you use. To submit a request to opt out of offline sales and sharing which would not otherwise be controlled by GPC, please use our webform.
Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive by us.
CALIFORNIA PRIVACY RIGHTS
California residents have the right to submit certain requests relating to their Personal Information as described below. Please note that when submitting a request, you may be asked to provide information to verify your identity before action is taken. You may designate an authorized agent to make the requests below on your behalf. An authorized agent must submit proof to us that he or she has been authorized by you to act on your behalf, and you will still need to verify your identity directly with us before we can process the request.
To submit a request, please use our Consumer Rights Request form or call (888) 342-6567.
A. THE RIGHT TO KNOW
If you are a California resident, you have the right to request more information regarding the following, to the extent applicable:
1. The categories of Personal Information we have collected about you
2. The categories of sources from which the Personal Information was collected
3. Our business or commercial purposes for collecting (or selling—if applicable) your Personal Information
4. The categories of third parties with which we shared your Personal Information
5. The categories of Personal Information about you that we sold in the preceding 12 months, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information
6. The categories of Personal Information that we disclosed for a business purpose in the preceding 12 months, and for each category identified, the categories of third parties to which we disclosed that particular category of Personal Information
7. The specific pieces of Personal Information we have collected about you
You may submit a request for this information as described above. In connection with submission of your request, we will need to take steps to verify your identity before action is taken.
B. RIGHT TO OPT OUT OF “SALES” OF PERSONAL INFORMATION
Although we do not sell your Personal Information in exchange for money, some of the ways in which we share your Personal Information for advertising or marketing may be considered a “sale” under California law. If you are a California resident and would like to opt out of our use of your information for these purposes, you may do so by submitting a request through our webform or by downloading and using a browser supporting the Global Privacy Control (GPC) browser signal. If you choose to use the GPC signal, you will need to turn it on for each browser you use.
C. RIGHT TO DELETE
You may request that we delete your Personal Information that we have collected directly from you and are maintaining. Following receipt of a request to delete, we will let you know what Personal Information we can delete from our records, and we will direct any of our service providers that may have processed your Personal Information on our behalf to delete your Personal Information from their records. There may be circumstances where we cannot delete your Personal Information or direct service providers to delete your Personal Information from their records. For example, if we need to: (1) retain your Personal Information to complete a transaction or provide services to you; (2) keep you enrolled in our rewards program; (3) for purposes of a product warranty or recall; (4) detect security incidents; (5) protect against unlawful activities; (6) identify, debug or repair errors; or (7) comply with a legal obligation. You may submit a request to delete as described at the beginning of Section 4. In connection with submission of your request, we will need to take steps to verify your identity before action is taken.
D. NON-DISCRIMINATION
You have the right to not receive discriminatory treatment for exercising your CCPA privacy rights. We do not use the fact that you have exercised or requested to exercise any CCPA rights for any purpose other than facilitating a response to your request.
E. NOTICE OF FINANCIAL INCENTIVE
ITGB offers rewards programs through its Blu and Winston brands (the bluNation Rewards Program (“bluNation”) and the Winston Rewards Program (“Winston Rewards”, and together with BluNation, the “Programs”)). A financial incentive notice covering the Programs follows below. We may add or change Programs and/or their terms by posting notice on the program descriptions, so check them regularly.
(1) Summary of Financial Incentives
Program: bluNation
Incentive Offered:
Members earn points on eligible purchases of blu products and for completing other qualifying activities, such as completing polls. Points can be redeemed for discounts on future purchases of blu products except where prohibited by law.
Material Terms:
bluNation is available to smokers who are 21 years of age or older and points accumulated can only be redeemed for discounts at blu.com or participating retailers. bluNation collects Personal Information to facilitate its operations and provide you with Program benefits including:
- Identifiers, such as name, alias, postal address, online identifier, date of birth, or other similar identifiers.
- Personal Records, such as signature, telephone number, credit card number and other financial, medical, or health information.
- Protected classification characteristics under California or federal law, such as age, birth date, and gender.
- Commercial Information, such as records of products or services purchased, obtained, or considered and coupon or loyalty program usage.
- Internet Activity Information, such as browsing history, search history, and information regarding your interaction with an Internet Website, application, or advertisement.
- Geolocation data, your location inferred from your IP address.
- Sensory Data, such as audio recordings of customer care calls, video, or similar information.
- Inferences from Other PI, such as creating a profile about a Member reflecting preferences, characteristics, behavior, and attitudes.
How to Opt-In:
Participating in bluNation is entirely optional but is subject to additional Program Terms and Conditions. You must opt-in by signing up for a bluNation account, here. Additional information about bluNation is available in the FAQs.
Program: Winston Rewards
Incentive Offered:
Members earn points on eligible purchases of Winston products and for completing other qualifying activities, such as completing an online profile. Points can be redeemed for items listed in the Rewards catalogue on the Program website, including discounts on future purchases of Winston products except where prohibited by law.
Material Terms:
Winston Rewards is available to smokers who are 21 years of age or older and points accumulated can only be redeemed for rewards listed on the Program website, which are subject to change and availability. Winston Rewards collects Personal Information to facilitate its operations and provide you with Program benefits including:
- Identifiers, such as name, alias, postal address, online identifier, date of birth, or other similar identifiers.
- Personal Records, such as signature, telephone number, credit card number and other financial, medical, or health information.
- Protected classification characteristics under California or federal law, such as age, birth date, and gender.
- Commercial Information, such as records of products or services purchased, obtained, or considered and coupon or loyalty program usage.
- Internet Activity Information, such as browsing history, search history, and information regarding your interaction with an Internet Website, application, or advertisement.
- Geolocation data, your location inferred from your IP address.
- Sensory Data, such as audio recordings of customer care calls, video, or similar information. Inferences from Other PI, such as creating a profile about a Member reflecting preferences, characteristics, behavior, and attitudes.
How to Opt-In:
Participating in Winston Rewards is entirely optional but is subject to additional Program Terms and Conditions. You must opt-in by signing up for a Winston Rewards account, here.
(2) Value of the Consumer’s Data
The financial incentive we offer to adult consumers through each Program is reasonably related to the value of the adult consumer’s data. ITGB has made a good faith estimate of the value of adult consumers’ data based on relevant expenses related to the collection and retention of adult consumers’ Personal Information as part of each Program.
(3) Withdrawing from our Loyalty Programs
California consumers may make a personal information deletion request under the CCPA. The consumer will then be sent an email requesting that they confirm that they want to delete their respective Program data.
You may, however, terminate Program participation at any time, as explained in the Programs’ terms or by calling us at (888) 342-6567. Upon a termination request, some Program data associated with the terminated account may be retained for recordkeeping, tax reporting, and other legally permissible purposes. You can opt-out of non-Program marketing emails or delete your Personal Information from our active marketing lists and retain your Program account and benefits.
CALIFORNIA APPLICANT PRIVACY NOTICE
Effective Date: January 1, 2023
The purpose of this California Privacy Notice (“Notice“) is to inform job applicants of ITG Brands, LLC (“ITGB,” “we,” or “us“) who are residents of the State of California (“Applicants” or “you“) of the categories of Personal Information we may collect about them and how we may use or disclose their Personal Information. This Notice is provided pursuant to the California Consumer Privacy Act, as amended (the “CCPA“), and should be read in conjunction with all other policies that govern your relationship with us.
As used in this Notice, the term “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with Applicants. Personal Information does not include information that is publicly available, de-identified, or aggregated, and the CCPA exempts certain additional categories of information from its purview, such as information subject to other laws and regulations. This Notice applies only to information governed by the CCPA.
Unless otherwise noted, the disclosures herein cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices
I. Collection, Use, and Disclosure of Personal Information
ITGB may collect, use, and disclose Personal Information for valid business purposes consistent with applicable laws as identified below. Where we transfer applicable Personal Information to recipients, such as our service providers, we do so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us.
Category of Personal Information
Identifiers including name, alias, postal address, IP address, email address, or other similar identifiers
Personal Information described in Cal. Civ. Code § 1798.80(e), including your name, address, telephone number, education, employment, and employment history
Characteristics of protected classifications under California or federal law, including age, race, gender, military or veteran status, medical condition, or disability status
Professional or employment-related information, including: Skills, qualifications, work experience, references, recommendations, and other information included in a resume, CV, application form, or cover letter;
Answers to behavioral or other screening questions in an interview;
Information contained in any personal webpages or documents you choose to share with us;
Information relating to professional licenses, training, disciplinary actions, and membership in professional organizations;
Information relating to membership in civic organizations you may provide to us.
Non-public education information, including school(s) attended, grades, transcripts, records of attendance, disciplinary records, and other information relating to your secondary and post-secondary education
Inferences used to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
Other Categories of Personal Information, including national identification information (citizenship, immigration, visa status, and work authorization information), criminal records information (such as results of background checks), languages spoken, and drug screening results
Purposes for Collection, Use, or Disclosure
Identifiers
• To process job applications and maintain records
• To assess qualifications for a particular job or task
• To complete activities related to recruiting, onboarding, and employment referrals
• To enable you to register an account with us
• To recommend potential jobs for you
• To verify your identity and stated credentials
• To undertake activities to verify or maintain the quality or safety of our systems and services, and to improve, upgrade, or enhance our systems and services
Personal Information described in Cal. Civ. Code § 1798.80(e)
• To process job applications and maintain records
• To assess qualifications for a particular job or task
• To complete activities related to recruiting, onboarding, and employment referrals
• To enable you to register an account with us
• To recommend potential jobs for you
• To verify your identity and stated credentials
• To undertake activities to verify or maintain the quality or safety of our systems and services, and to improve, upgrade, or enhance our systems and services
Characteristics of protected classifications
• To process job applications and maintain records
• To complete activities related to recruiting and onboarding
• To verify your identity and stated credentials
• To comply with applicable laws and regulations
Professional or employment-related information
• To open and maintain your application records
• To assess your eligibility for employment
• To assess qualifications for a particular job or task
• To comply with applicable laws and regulations
• To manage the workplace safety and security
• To verify your identity and stated credentials
Non-public education information
• To open and maintain your application records
• To assess your eligibility for employment
• To assess qualifications for a particular job or task
• To comply with applicable laws and regulations
• To manage workplace safety and security
• To verify your identity and stated credentials
Inferences
• We will only use this information for recruitment efforts and will not impact your current application or future employment with us.
Other Categories of Personal Information
• To open and maintain your application records
• To assess your eligibility for employment
• To assess qualifications for a particular job or task
• To comply with applicable laws and regulations
• To manage the workplace safety and security
• To verify your identity and stated credentials
Categories of Recipients to whom Personal Information is Disclosed for a Business Purpose
Identifiers
• Data analytics providers
• Background check vendors
• Information technology vendors
• Service providers
Personal Information described in Cal. Civ. Code § 1798.80(e)
• Data analytics providers
• Background check vendors
• Information technology vendors
• Service providers
Characteristics of protected classifications
• Service providers
• Data analytics providers
• Background check vendors
• Information technology vendors
Professional or employment-related information
• Background check providers
• Service providers
• Information technology vendors
Non-public education information
• Background check providers
• Information technology vendors
Inferences
• Service providers
Other Categories of Personal Information
• Background check providers
• State or federal government agencies’ related to confirmation of national identification information and criminal records information
II. Sensitive Personal Information
ITGB may collect, use, and disclose sensitive Personal Information for valid business purposes consistent with applicable laws as identified below. Where ITGB transfers applicable sensitive Personal Information to recipients, such as our service providers, it does so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us.
Category of Sensitive Personal Information
1. Social security, driver’s license, state identification card, or passport number(s)
2. Personal Information that reveals an Applicant’s racial or ethnic origin.
3. Personal Information collected and analyzed concerning an Applicant’s health
Purposes for Collection, Use, or Disclosure
1. Social security, driver’s license, state identification card, or passport number(s)
• To assess your eligibility for employment
• To comply with applicable laws and regulations
2. Personal Information that reveals an Applicant’s racial or ethnic origin.
• To process job applications and maintain records
• To complete activities related to recruiting and onboarding
• To verify your identity and stated credentials
• To comply with applicable laws and regulations
3. Personal Information collected and analyzed concerning an Applicant’s health
• To assess your eligibility for employment
• To comply with applicable laws and regulations
Categories of Recipients to whom Personal Information is Disclosed for a Business Purpose
1. Social security, driver’s license, state identification card, or passport number(s)
• Background check providers
• State or federal government agencies’ related to confirmation of national identification information and criminal records information
2. Personal Information that reveals an Applicant’s racial or ethnic origin.
• Government agencies
• Service providers
• Data analytics providers
• Background check vendors
3. Personal Information collected and analyzed concerning an Applicant’s health
• Service providers
III. Disclosing Your Personal Information
We may disclose each of the categories of Personal Information identified above to the respectively identified categories of recipients for operational or business purposes consistent with the purposes for collection or use designated, as is reasonably necessary and proportionate to achieve those purposes, or for another purpose that is compatible with the context in which the Personal Information was collected including, but not limited to:
• Helping to ensure security and integrity;
• Debugging, repairing, and improving functionality;
• Short-term, transient use;
• Performing services on our behalf;
• Internal research for technological development; and
• Verifying quality and/or safety.
In addition to the other purposes for collection, use, and disclosure of Personal Information described in this Notice, we may collect, use, and disclose Personal Information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a threatened or pending case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may use and disclose Personal Information to other parties in connection with the sale, assignment, merger, or reorganization of the company or its affiliates.
IV. Sources of Personal Information
We may collect the Personal Information and Sensitive Personal Information identified above from the following sources:
• Directly from you. For example, during the application process and throughout your interactions with us, including through our IT systems, company forms, and other processes where you submit information to us.
• Automatically when using our electronic systems. For example, we may collect your usage history when you use our websites, systems, and applications.
• Automatically when you visit our facilities. For example, security camera footage.
• Service providers. For example, from third-party human resources and information technology vendors, background check agencies, and other service providers.
V. Selling or Sharing of Your Personal Information
We do not sell Applicant Personal Information or share it for cross-context behavioral advertising.
VI. How Long We Keep Your Personal Information
The information below shows how long we retain Personal Information. For each category of Personal Information, our retention period is determined by the purposes for which we use the information and any legal obligations that require or authorize us to retain it.
Personal Information
Identifiers
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Personal Information described in Cal. Civ. Code § 1798.80(e)
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Characteristics of protected classifications
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Internet or other electronic network activity information
Short-term, transitory use only
Professional or employment-related information
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Non-public education information
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Inferences
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Other categories of information
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Sensitive Personal Information
Social security, driver’s license, state identification card, or passport number
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Personal Information that reveals an Applicant’s racial or ethnic origin
Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Personal Information collected and analyzed concerning an Applicant’s health Our Records Retention Schedule prescribes minimum retention periods for this information pursuant to business, legal, or operational requirements, including:
• four (4) years for records documenting hiring activities for individuals who were not hired.
Where information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention policies, please contact us using the contact details below.
VII. California Privacy Rights
If you are a resident of California, you have the right to submit certain requests relating to your Personal Information as described below. To exercise any of these rights, please submit a request by emailing us at privacy@ITGBrands.com, or calling us at (888) 342-6567.
If you make a privacy request, we may take steps to verify your identity before responding to your request. You may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission to act on your behalf. As permitted by law, we may take steps to verify your own identity in response to a request even if you choose to use an agent.
Right to Opt-Out of the Sale and Sharing of Your Personal Information. We do not sell Applicant Personal Information or share it for cross-context behavioral advertising.
Right to Limit Use and Disclosure of Your Sensitive Personal Information. We do not use or disclose sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.
Right to Know. You have the right to know what Personal Information we have collected about you, which includes:
(1) The categories of Personal Information we have collected about you, including:
a. The categories of sources from which the Personal Information was collected;
b. Our business purposes for collecting or disclosing Personal Information;
c. The categories of recipients to which we disclose Personal Information;
d. The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information.
(2) The specific pieces of Personal Information we have collected about you.
Right to Delete Your Personal Information. You have the right to request that we delete Personal Information we collected from you, subject to certain exceptions.
Right to Correct Inaccurate Information. If you believe that Personal Information we maintain about you is inaccurate, you have the right to request that we correct that information.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of your privacy rights under the CCPA, you also have the right not to receive discriminatory treatment by us.
VIII. How to Contact Us
If you have any questions about how ITGB handles your Personal Information or if you need to access this notice in an alternative format or language, please contact us at:
Phone: (888) 342-6567
Email: privacy@ITGBrands.com
CALIFORNIA “SHINE THE LIGHT”
Separate from your CCPA rights, you may obtain a list of the recipients to which we have disclosed Personal Information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding calendar year for direct marketing purposes, if applicable. To submit a request, please email us at privacy@itgbrands.com or send a letter to us at 714 Green Valley Road, Greensboro, NC 27408-7018 (Attn: Legal Department). Requests must include “California Privacy Rights Request” in the first line of the description, and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided email address or mail address. Because these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.
HOW TO CONTACT US
For more information on your California privacy rights, please contact us here, by mail to 714 Green Valley Road, Greensboro, NC 27408-7018 (Attn: Legal Department), or by phone at 1 (888) 342-6567.
THIRD-PARTY MARKETING
Separate from your CCPA rights, you may obtain a list of the third parties to which we have disclosed Personal Information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding calendar year for third-party direct marketing purposes. To submit a request, please email us at privacy@itgbrands.com or send a letter to us at 714 Green Valley Road, Greensboro, NC 27408-7018 (Attn: Legal Department). Requests must include “California Privacy Rights Request” in the first line of the description, and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the provided email address or mail address. Because these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.