Effective Date: January 1, 2021.
You have certain choices regarding information collection and communications options explained here, including:
ITGB, and/or its Service Providers (defined below), may collect information you provide directly to ITGB and/or its Service Providers via the Service. For example, ITGB collects information when you use or register for the Service, fill out and submit forms, subscribe to notifications, post on the Service, participate in promotional activities (e.g., Winston Cigarettes coupons, Winston Cigarettes deals, sweepstakes entries, Winston Cigarettes loyalty programs – including the Winston Loyalty Program, or Winston Rewards, etc.), or communicate or transact through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties. For more information on Third-Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here.
We strive to maintain accurate information on the adult consumers on our Marketing List through consumer surveys, adult consumer-initiated contacts, and responses to our marketing programs (online and offline), as well as through address update services.
ITGB, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include IP address (“Unique Identifier”), device identifier, browser type, operating system, information about your use of the Service, data regarding network connected hardware (e.g., computer or mobile device), the domain name of the website that allowed you to navigate to the Service, search engines used, the length of time spent on the Service, the pages you looked at on the Service, the address (or “URL”) of the websites you visited before and after visiting the Service, the frequency of your visits to the Service, and certain other available information. An IP address is a number that is automatically assigned to your computer wherever you access the Internet, which our web servers use to identify where to send the information about your computer requests. When you request pages from the Website, our servers log your IP address as well as information about your activities on those pages. Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of ITGB with ITGB-Collected PII, ITGB does not consider Usage Information (including, without limitation, unique device identifiers) to be Personally Identifiable Information or ITGB-Collected PII. For more information on Third-Party Services’ data collection and practices click here. For more information on Service Provider data collection and practices click here. For information on choices some of these third parties may offer you regarding automated data collection click here.
To collect this Usage Information, the Service and any e-mails sent to you by the Service may utilize the following:
Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, mobile device and mobile operating system, mobile carrier, cookies that identify your browser, and related data, and may be stored in log files.
The Service may include links in a format that enables us to keep track of the IP addresses from which these links have been followed. You further consent to our collection and use this information to improve the quality of our Services, product(s), coupons, promotional offers, and business operations.
Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, device recognition technologies, device and activity monitoring and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior.
Web beacons are small graphic images or other web programming (also known as “1x1 GIFs” or “clear GIFs,” “Pixel Tags,” or “Web Bugs”) may also be included in our Website’s pages and messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from ITGB’s web server, or from a third party with which ITGB works and is active only while you are connected to the Service and deleted or deactivated thereafter.
Geo-filtering and other location-aware technologies locate you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content, including third-party ads, based on your location. Our store finder feature may access and use information about your device location (such as based on IP address or GPS, as applicable), or your account information, to suggest appropriate store locations. Our Service content may be personalized based on various information we may have about you to try to provide you with more location-relevant content.
Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use, which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).
Technologies that monitor, and may record, certain of your interactions with the Service, and/or collect and analyze information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes such as identification, security, fraud prevention, troubleshooting, tracking and/or improving the Services and customizing or optimizing your experience on the Services.
Some information about your use of the Service and certain third-party services may be collected using Tracking Technologies across time and services and used by ITGB and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Service and certain third-party services. See Section 11 regarding certain choices regarding these activities.
ITGB is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 11 so that your consent to encountering them is meaningfully informed.
In conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission (“EEOC”), the Office of Federal Contract Compliance Programs (“OFCCP”) and similar state and local regulatory agencies, we may ask you to provide us with self-identifying information (such as veteran status, gender, and ethnicity). Providing such self-identifying information is voluntary, but if you do provide us with such information, we may submit that information to the EEOC, the OFCCP and similar state and local regulatory agencies or otherwise use or disclose it for business-related purposes, including, without limitation, responding to information requests, fulfilling regulatory reporting requirements and defending against employment related complaints.
We are a general audience service, restricted to adults twenty-one (21) years of age or older. Please see Section 9 below for more information regarding Age Restrictions and data collection.
We do not share your Personal Information with third parties (other than our affiliates) for such third parties’ own direct marketing purposes without your consent. ITGB may share non-Personally Identifiable Information, and Personally Identifiable Information that is not deemed ITGB-Collected PII hereunder (provided that ITGB is aware of no restrictions on ITGB’s use, if any), with third parties or for any purpose. Without limiting the generality of the foregoing, we and third parties may convert your Personally Identifiable Information, including ITGB-Collected PII, to non-Personally Identifiable Information, including without limitation through hashing it or substituting a unique identifier for the Personally Identifiable Information and we and third parties may use and share that data as permitted by applicable law, including to match data attributes to and from other sources. Any such third-party activities are subject to their privacy policies and practices. ITGB’s sharing of ITGB-Collected PII is, however, subject to the following:
In addition, ITGB may share your ITGB-Collected Personally Identifiable Information (as well as your other Personally Identifiable Information and your non-Personally Identifiable Information), in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of ITGB assets, or transfer of all or a portion of ITGB’s business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding (“Corporate Transactions”).
Additionally, the Service may offer you the option to send a communication to a friend or other contact. If so, ITGB relies on you to only send to people that have given you permission to do so. The recipient’s Personally Identifiable Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by ITGB for any other marketing purpose unless ITGB obtains consent from that person. Your contact information and message may be included in the communication.
The Service may include hyperlinks to, or include on or in connection with, the Service (e.g., plug-ins, application programming interfaces (“API(s)”), and software development kits (“SDK(s)”)), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personally Identifiable Information from you.
Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third-party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” ITGB’s content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see Section 5) or by the Third-Party Service that you use. Similarly, if you post information on a Third-Party Service that references the Service (e.g., by using a hashtag associated with ITGB in a tweet or status update), your post may be used on or in connection with the Service or otherwise by ITGB and ITGB Parties / Affiliates. Also, both ITGB and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.
ITGB takes reasonable measures to protect ITGB-Collected PII (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and ITGB does not guarantee the security of your information collected through the Service.
ITGB is based in the U.S. and the information ITGB and its Service Providers collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personally Identifiable Information, in the U.S., as well as for processing outside of the U.S.
The Service is intended for adults not less than twenty-one (21) years of age. If you are under twenty-one (21) years of age, you are not permitted to use the Website and should not send any information about yourself to us through the Website, except to the extent that access to the Website based on age verification. ITGB does not intend to collect or knowingly collect personal information as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA, and would collect such information, if at all, only in associated with ITGB’s age-related access restrictions. If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will dispose of that information, or otherwise treat it, in accordance with COPPA and other applicable laws and regulations. If you are a parent or guardian and you believe that your child under the age of thirteen (13) has provided us with personal information, please contact us here.
ITGB may provide web pages or other mechanisms allowing you to delete, correct, or update some of the ITGB-Collected PII, and potentially certain other information about you (e.g., profile and account information). ITGB will make good faith efforts to make requested changes in ITGB’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from ITGB’s databases (California minors see Section 9) and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, ITGB currently does not alter ITGB’s practices when ITGB receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but ITGB is not responsible for the completeness or accuracy of this third-party information. Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our web site is to add the free Ghostery plug-in to your browser (https://www.ghostery.com/), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. ITGB is not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms. For specific information on some of the choice options offered by third-party analytics and advertising providers, see the next section.
You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit http://www.aboutads.info/choices/ and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. ITGB supports the ad industry’s Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks ITGB directly engages to serve you Interest-based Advertising will do so as well, though ITGB cannot guarantee their compliance. ITGB is not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
We employ reasonable security precautions to help protect against the loss, misuse, and alteration of personal information provided on or through the Website. When you enter sensitive information (such as a credit card number and/or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). To learn more about SSL, follow this link: Verisign.
We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of online transmission or electronic storage is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. As a result, although we strive to protect personal information about you, we cannot guarantee the security of any information you transmit to us through or in connection with the Website. If you have reason to believe that personal information is no longer secure, please notify us immediately by contacting us in accordance with the last section below.
© ITG Brands, LLC, January 1, 2021. All Rights Reserved.