Privacy Policy

Privacy Policy

Investinelegance.com is a website owned and operated by Elegance Spirits, Inc. and its affiliates (“Elegance Vodka”, “us”, or “we”). Your privacy is very important to us and in order to best protect your information, we have adopted this privacy policy (“Privacy Policy”), which applies to any and all information you submit to us in connection with your access to and/or use of the Website. It is important to note that this Privacy Policy only applies to information that we collect through investinelegance.com (the “Website”). Therefore, if you click any links on the Website that lead to websites owned or operated by third parties, or if you access any other website, this Privacy Policy no longer applies. You should review the privacy policies adopted by those third parties to ensure that you know what information is being collected and for what it is being used. While registration is not required in order to access the Website, certain features and areas of the Website require you to register, create an account and become a member of the Website (each, a “Member” and collectively, “Members”). Please read this Privacy Policy carefully prior to your registration for, access to, and/or use of the Website and/or Service. If you do not agree to abide by this Privacy Policy, please do not use the Website.

By using our Website or submitting information to Elegance Vodka, you consent to our collection and use of information as explained in this Privacy Policy and agree to be bound by our Terms of Use. This Privacy Policy is governed by the Terms of Use, which includes all disclaimers of warranties and limitations of liability. All capitalized terms not defined in this Privacy Policy will have the meanings set forth in the Terms of Use. A copy of the Terms of Use can be found on the Website.

Collection of Information

Some of the information we collect is Personally Identifiable Information (“PII”). PII, collected only with your consent, may include your email address, first and last name, date of birth, phone number, password, mailing address, taxpayer identification number, internet protocol (“IP”) address, net worth, income, and any other information that you provide to us that is linked to your identity. We will only collect PII that is relevant to the services that we provide and the maintenance of the Website. This may occur, for example, when you sign up for more information, start the investment process, create an account, register to become a Member of the Website, make an investment through the Website, sign up to receive newsletters, provide responses to survey questions, send us an email through the Website or make inquiries through our Website, and when you provide us with any other information. Remember that you always have the option not to provide information by choosing not to use the Website or by not using the particular feature of the Website for which the information is being collected.

We may also collect information using various technologies (some of which are described below), including, but not limited to, cookies, web beacons, web session variables, server log files, clear gifs, browser plug-ins or add-ons, or Javascript. “Cookies” are alphanumeric identifiers in the form of text files that are inserted and stored by your web browser on your hard drive or via mobile IDs. A “web beacon” is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a website or in an email which allows a website to record the simple actions of the User opening the page that contains the beacon. “Server logs” can be either a single log file or several log files automatically created and maintained by a server of activity performed by the server, which can include information about any transaction you conduct with the server. Elegance Vodka (and, potentially, third party advertisers or other partners) may set and access cookies on your computer or mobile device to track and store preferential information about you, for purposes such as (i) recognizing you when you return to the Website and use the Service, (ii) tailoring the Website and Service to your specific needs or preferences, and (iii) personalizing the content that you see in order to ensure you enjoy your visit, etc. We may also use Cookies to control the display of ads, to track your Website usage patterns, to record registration and personalization information, and to track the various Website items that you view. Elegance Vodka (and potentially third party advertisers) gathers anonymous information about users through Cookie technology on an aggregate level only. Such aggregated information is used within Elegance Vodka’s internal organization and is only shared with third party advertisers on an aggregated and non-personally identifiable basis. You can always tell your Internet browser that you don’t want to have any cookies downloaded to your computer. Check with the provider of your particular browser to find out how. Before you do however, note that deleting cookies or directing your browser to refuse them may limit your ability to use certain portions of our Website that require cookies to function. Lastly, third parties who partner with us to display advertising may also use cookies to collect or store data. Please note that your internet browser may enable you to send a message requesting that the Website not track your usage. As described, we do use this information in order to determine which pages of the Website you view and which links you click in order to tailor our content and advertising for you. Therefore, the Website currently does not follow these messages from your browser (but again, you may disable Cookies if you so wish).

The last form of information we may collect is non-personally identifying information but relates to your Website or Service usage or is necessary for the proper functioning of the Website or Service. Non-personally identifiable information may include, without limitation, Website pages viewed, websites visited before visiting the Website, frequency of visits, clickstream data, the mobile platform or service provider you use, browser type, operating system, your IP address, organization name, internet connection speed, presentations and videos viewed, time spent viewing pages of our Website or using certain features of our Website, demographic data such as server location, location services, cookies existing on your computer, search criteria used and results, date and time of access or visits to our Website, frequency of visits to our Website, connection speed, and other unique device identifiers or information which does not specifically identify you (“Other Information”). We may also compile this data to enable statistical analysis of our services that would be used internally or with external assistance to make improvements to our Website. We may also provide this information to third parties, including advertisers. Remember, though, that this information is not personally identifiable. If we ever associate Other Information with you as a specific and identifiable person, we treat it as PII.

We may use analytics programs and service providers, such as Google Analytics, which can use first party cookies to report on your interactions with the Website. Google Analytics collects information including, but not limited to, the time of each of your visits to the Website, whether you have visited the Website before, what website referred you to the Website, and what pages you viewed on the Website.

This Privacy Policy does not cover the collection of information by cookies or other methods by such Third Party Services or other third parties, such as our business partners. We do not control how these Third Party Services or third parties collect information or by what means such Third Party Services or third parties may use their own cookies to collect information about you.

Use of Information

We may use the information we collect for a number of purposes. For instance, we may use it to enforce the Terms of Use, respond to your inquiries and otherwise correspond with you, to market or deliver email messages to you such as special offers, updates, newsletters, customer service, and service announcements, to process transactions that you request, to maintain your Member account (if you have one), to comply with and meet any regulatory requirements for the offer or sale of securities required by law, rules or regulations to our affiliates or members, to customize the content you see on the Website, to maintain the security and integrity of our Website and services, to conduct market research or surveys, to enable our vendors and contractors to provide and assist us in the marketing, operation, troubleshooting and analysis of our Website and other services, and for the administration, review and/or the improvement of the content of our Website and services. We may also use your information to communicate with you about services that we think may interest you or may aggregate your information for market research, project planning, troubleshooting problems, and detecting and protecting against error or fraud, or as otherwise described to you at the time of collection.

You agree that Elegance Vodka may use information collected about you to analyze Website usage, improve or customize the Service, customize the Content, respond to your requests, questions and comments, managing your Member account, facilitate communications between users, and as otherwise set forth in this Privacy Policy or as Elegance Vodka believes necessary to protect its rights and the rights of others, including by enforcing the Terms of Use. You also agree that Elegance Vodka may use your information to contact you. Unless you specifically opt out, you agree that Elegance Vodka may use your information to deliver information to you that is relevant to your use of the Website or Service such as administrative notices, product enhancements or Service “newsletters”, or that, in some cases, is targeted to your interests, such as targeted advertisements that Elegance Vodka believes you may be interested in learning more about. By accepting the Terms of Use and this Privacy Policy, you expressly agree to receive this information, unless you specifically opt out in applicable circumstances.

Elegance Vodka may employ or contract other third parties, companies, or individuals to perform certain functions or services on its behalf. Examples of these services from such third parties, companies, or individuals, may include ID verification, electronic document signing, payment storing and processing, sending postal mail and email, escrow services, disbursement of funds, analyzing data, providing marketing assistance, and providing customer service. As such, these third parties, companies, or individuals may have access to your information, including Non-Personally Identifiable Information or Personally Identifiable Information, needed to perform their functions or services, and may not use it for other purposes.

Elegance Vodka maintains a strict “no-spam” policy. If you sign up to invest, sign up for more information, start the process of becoming a shareholder, create an account, or register for the Website and Service, you may receive newsletters, notices and/or special offers via email or text message, unless you have requested otherwise at the time of sign up or registration or as set forth below.

You may unsubscribe from these electronic newsletters, notices and/or special offers at any time by following the instructions contained at the very end of every such email or text message or elsewhere as directed by Elegance Vodka. If a third party vendor provides such newsletters, you may unsubscribe in accordance with the instructions provided by such third party. If you are having problems unsubscribing please contact us at shares@elegancevodka.com (forwarding the newsletter, if applicable, and including in the Subject line the words “Unsubscribe”), and we will use reasonable efforts to remove you within seven (7) business days. Please note that Elegance Vodka will not process any unsubscribe requests submitted as direct replies to any newsletter.

Disclosure of Information

Except as expressly provided herein, absent your prior consent, we do not share your PII with any unrelated third parties. In the event that we decide in the future to incorporate products or Services that require payment information from you, we may engage a third party service provider to handle billing for such products or Services on our behalf, and we will ensure that your payment information is not shared with anyone else; provided, that if any third party directly handles payment (such as a mobile service provider, application platform or PayPal), the terms of use and privacy policies of any such third party payment provider will prevail. Further, we may use third parties to outsource one or more aspects of our business (such as email or customer service providers, data processing, and security execution and clearing services), in which case, we would have to disclose to such third parties (who would be required by us to comply with this Privacy Policy and any other obligation of we have with respect to any information provided by you in connection with the Website and/or Service, to the same extent as our obligations) the PII necessary for such third parties to provide such services.

We also reserve the right, and you hereby authorize us, to share or disclose your PII, including, without limitation, any content, records or electronic communications of any kind, when we determine, in our sole discretion, that the disclosure of such information is necessary to identify, contact, or bring legal action against you if:

you are or may be violating the Terms of Use or this Privacy Policy;
you are interfering with Elegance Vodka’s or a third party’s rights or property;
you are violating any applicable law, rule or regulation;
necessary or required by any applicable law, rule or regulation; and/or
requested by governmental authorities in the event of any investigation, act of terrorism or instance of local, regional or national emergency.

In the event that Elegance Vodka is acquired by or merged with a third party entity, or sells all or substantially all of its assets, we reserve the right, in any of these circumstances, to transfer or assign the information and content we have received and collected from our users as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your PII is treated, transferred, or used.

Security

Elegance Vodka takes a range of security measures designed to protect your information and keep it confidential (unless it is non-confidential by nature, for example, publicly-available information) and free from any unauthorized alteration. However, the internet by its nature is not a secure environment and the nature of security risks is constantly evolving, as are the technical and organizational industry standards relating to the management of those risks. While we strive to keep current our security technology and will review, refine and upgrade our security technology as we deem appropriate based on new tools that may become available in the future, the complete security of any information collected, stored or used by us cannot therefore be guaranteed. We have security standards and procedures in place designed to prevent unauthorized access to your Member account and information. A key part of this process helps ensure that all the information we have about you is accurate and up-to-date. In the unlikely event that an unauthorized third party compromises Elegance Vodka’s security measures, Elegance Vodka will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use or disseminate such information. If you ever discover inaccuracies in our data or if your PII, we urge you to notify us immediately.

You hereby acknowledge that Elegance Vodka shall not be responsible or liable for any dissemination of your information that results from your disclosure of such information to any third party.

Links to Third Parties

The Website may include links to third party websites, apps or services, including payment providers. Such links are not an endorsement by Elegance Vodka of those websites, apps and/or the products or services they offer. Third parties have different privacy policies, and Elegance Vodka is not responsible for the privacy practices of such third parties. If you click on a link to a third party website, app or service, Elegance Vodka encourages you to check the applicable privacy policy, as it may differ substantially from that of this Privacy Policy. Elegance Vodka makes no representations or warranties nor is Elegance Vodka responsible for the privacy policies of any third party. If you decide to access any third party links appearing on the Website, you do so at your own risk.

Children’s Privacy

The privacy of children is of the utmost importance and we are committed to complying with the Children’s Online Privacy Protection Act (COPPA). This Website does not knowingly collect, use, or disclose PII from children under the age of 13. If we ever discover that we have inadvertently collected PII from children under the age of 13, we will delete it as soon as possible. If you are a parent or legal guardian and believe that we have collected PII from your child under the age of 13, please email us at shares@elegancevodka.com, and we will take steps to delete this PII as soon as possible.

Access to Your Information

We will provide you with access to PII you provide us for as long as we maintain that information in a readily accessible format. We will also work with you to correct any errors in your PII. If you wish to access or correct any PII that you have submitted through our Website, or to have us completely remove your PII from our systems, please send an email with your specific request to shares@elegancevodka.com.

Changes to This Privacy Policy

We reserve the right, in our sole discretion, to change, modify, add, or remove portions of this Privacy Policy at any time.  Any changes or updates will be effective immediately upon posting to our Website. You should review this Privacy Policy regularly for changes, and can determine if changes have been made by checking the Effective Date below. Your continued use of our Website following the posting of any changes to this Privacy Policy means you accept such changes.

Applicable Law and Jurisdiction

The Website is maintained in the United States of America. By accessing the Website, you consent to and authorize the export of information collected by us, including PII, to the United States of America, or any other country in which we or our agents maintain facilities, and its storage and use as specified in this Privacy Policy. By using the Website and Service, you consent to any such transfer of information outside of your country, where data protection laws may be different. Elegance Vodka makes no representation or warranty with respect to any duty to permanently store any information you may provide. By using the Website or Service and providing us with information, you waive any claims that may arise under your own or any other local or national laws, rules or regulations or international treaties. We may from time to time transfer or merge your information collected off-line to our online databases or store off-line information in an electronic format. We may also combine information we collect online with information available from other sources, including information received from our advertisers and promotional partners. This Privacy Policy applies to your information for as long as your information is in our possession, even if you terminate or discontinue your use of the Website and Service.

This Privacy Policy shall be governed by, construed and entered in accordance with the laws of the State of California applicable to contracts deemed to be made within such state, without regard to choice of law or conflict of law provisions thereof. All disputes with respect to this Privacy Policy shall be brought and heard either in the California state courts located in Los Angeles, California, or the federal district court of California located in Los Angeles County, California. You consent to the in personam jurisdiction and venue of such courts. YOU HEREBY WAIVE YOUR RIGHT TO A TRIAL BY JURY WITH RESPECT TO ANY CLAIM, ACTION OR PROCEEDING, DIRECTLY OR INDIRECTLY, ARISING OUT OF, OR RELATING TO, THIS AGREEMENT TO THE FULLEST EXTENT PERMITTED BY LAW.

Effective Date

This Privacy Policy was last updated on June 19, 2019.