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PRIVACY
NOTICE

California residents have additional rights explained HERE

NEW PRIVACY POLICY

Effective Date: January 1, 2021.

To download and/or print this Privacy Policy (“Privacy Policy”), click here.

Privacy Policy Scope

Welcome to Winston Cigarettes’ Website (the “Website”), owned, operated, or controlled by ITG Brands, LLC (“ITGB,” “us,” “we,” or “our”). An overview of this ITGB Privacy Policy is provided below. To see the full text, click on the links. This Privacy Policy applies to your use of any online services (e.g., website and certain e-mails we send) that post a link to this Privacy Policy, regardless of how you access or use it. Click here to view our Terms of Use.

Your California Privacy Rights

California residents have certain rights regarding their Personal Information. View our California Consumer Privacy Notice here. To the extent that there is a conflict between this Privacy Policy and the California Consumer Privacy Notice, the California Consumer Privacy Notice will control as to California Consumers.

Quick Links

This Privacy Policy is posted in interactive format to ease your review, especially using smart phones and other devices with small screens. It is important that you read and understand the entire Privacy Policy before using the online services (the “Service”). You should read this entire Privacy Policy, but we have summarized some (but not all) of the main topics of this Privacy Policy below. The complete provisions, and not the headings or summaries govern.

· Your Choices and Your CA and NV Privacy Rights

You have certain choices regarding information collection and communications options explained here,

including:

-- California residents have certain privacy rights detailed here; here

-- Nevada residents have certain privacy rights detailed here; here

-- Although ITGB does not look for or respond to “do not track” signals, you can find information on tracking technologies here

-- About Ads and Tracking: Learn about certain options regarding Tracking Technologies, including certain sharing of activities for interest-based advertising here;

-- Your options regarding accessing and changing certain of your Personally Identifiable Information are available here;

-- Your options regarding promotional communications are explained here; and

· Collection of Information

-- ITGB may ask you to provide Personally Identifiable Information (e.g., name, address, e-mail, phone number, etc.), as well as other information (e.g., gender, interests, etc.), which may be required to access certain content, features, and functionality. More

-- ITGB and third parties may collect information from you automatically as you access the Service (e.g., information about the devices you use to access the Service and your usage activities). More

--This may include use of cookies and other technologies to keep track of your interactions with the Service, to serve you with ads on third-party services, and to offer you a more personalized and relevant experience. More

--The information ITGB receives via the Service may be combined with information ITGB receives from third parties and sources outside of the Service. More

-- ITGB’s policies and practices regarding Personally Identifiable Information of children are explained here.

· Use of Information

The information ITGB collects is used for a variety of purposes as detailed in this Privacy Policy. For example, your information helps ITGB provide and improve the Service, communicate with you, serve advertising and offers to you (including Winston Cigarettes coupons, Winston Cigarettes deals, sweepstakes entries, and Winston Cigarettes loyalty programs (e.g., the Winston Loyalty Program, or Winston Rewards, etc.), and operate ITGB’s business. More

· Sharing of Information

-- ITGB may share the information ITGB receives from or about you via the Service (or give others access to it), including your Personally Identifiable Information, for a variety of purposes, as detailed in this Privacy Policy. More These include, without limitation:

  • to deliver and improve ITGB’s services;
  • for marketing and other purposes;
  • in connection with corporate transactions (e.g., merger or sale);
  • to display your posts or send your messages (More);
  • in connection with your use of third-party services (More); and
  • in connection with sweepstakes, contests, coupons, and promotions (More).

-- ITGB obtains your consent (e.g., opt-out), however, before knowingly sharing Personally Identifiable Information with third parties (other than affiliates) for their own direct marketing purposes.

-- ITGB may share your non-Personally Identifiable Information, aggregate and/or de-identified information about you except as prohibited by applicable law.

· Questions and How to Contact ITGB

For more information about ITGB’s privacy practices regarding the Service, read the full Privacy Policy. You can also contact ITGB here if you have questions or concerns.

· Table of Contents

For a clickable table of contents that will help you find and navigate to all the sections of the full Privacy Policy click here. [Link to ToC navigation tool and add links back to the ToC at the end of each section.]

· Full Privacy Policy

To see and print our full Privacy Policy, click here. [Link]

Full Winston Cigarettes and ITGB Privacy Policy

Thank you for visiting Winston Cigarettes’ website (“Service” or “Website”) owned, operated, or controlled by by ITG Brands, LLC (“ITGB,” “we,” “us,” or “our”). This Privacy Policy describes our privacy practices with regard to how ITGB collects, uses, and shares information about you, including the choices ITGB offers with respect to that information, and applies to your use of any Service, regardless of how you access or use it. It does not apply to ITGB’s data collection activities offline or otherwise outside of the Service (unless otherwise stated below or at the time of collection). For certain Services, there may be additional notices about information practices and choices. Please read those additional privacy disclosures to understand how they apply to you. Please note that certain features or services discussed in this Privacy Policy may not be offered on the Website at any particular time.

By visiting or otherwise using the Service, you agree to the Service’s Terms of Use and consent to ITGB’s data collection, use, and disclosure practices, and other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Service. If you do not agree and consent, please discontinue use of the Service, and uninstall Service downloads and applications.

1. INFORMATION WINSTON CIGARETTES COLLECTS

  1. Active Information Collection.

    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.

    Information ITGB, its Service Providers and/or Third-Party Services may collect may include:
    (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, address, full payment account number, Instagram handle, driver’s license number, Social Security Number, passport or national identification card, tax ID and identifiers, precise location information we create (“Personally Identifiable Information” or “PII”); and (2) demographic information, such as your gender, age, zip code, product preferences, recent purchases, purchase channel (online or retail), communication channel preferences, satisfaction rate with our products and services, Winston Cigarettes coupon usage, and Winston Cigarettes loyalty program usage (“Demographic Information”). Except to the extent required by applicable law, Demographic Information is “non-Personally Identifiable Information” or “non-PII” (i.e., data that is not Personally Identifiable Information under this Privacy Policy). In addition, Personally Identifiable Information, including, without limitation, ITGB-Collected PII (defined below), once “De-identified” (i.e., by the removal or modification of the personally identifiable elements, or the extraction of non-personally identifiable elements including through anonymization, pseudonymization, and/or hashing) is also non-Personally Identifiable Information and may be used and shared without obligation to you, except as prohibited by applicable law. However, we do not make assurances that De-identified data is not capable of re-identification. To the extent any non-Personally Identifiable Information, or PII collected outside of the Service, is combined by or on behalf of ITGB with Personally Identifiable Information ITGB itself collects directly from you on the Service (“ITGB-Collected PII”), ITGB will treat the combined data as ITGB-Collected PII under this Privacy Policy. The definition of “personal information” under certain California laws differs from the definition of PII used in this Privacy Policy. California residents can learn more about Californians’ privacy rights here.

  2. Passive Information Collection.

    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

      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.

    • Location Information

      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.

    • Information Collected by Cookies and Other Tracking Technologies

      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.

      • Cookies

        A cookie is a small data file that is placed on a device when it is used to visit the Service, which may include session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features, and functionalities of the Service may not work. A Flash cookie (or locally shared object) is a data file which may be placed on a device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device. HTML5 cookies can be programmed through HTML5 local storage. Flash cookies and HTML5 cookies are locally stored on your device other than in the browser and browser settings won’t control them. To identify certain types of local shared objects on your device and adjust your settings, please visit here. The Service may associate some or all of these types of cookies with your devices.

      • Web Beacons (“Tracking Pixels”)

        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.

      • Embedded Scripts

        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.

      • Location-identifying Technologies

        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.

      • Device Recognition Technologies

        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”).

      • Device and Activity Monitoring

        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.

  3. Offline Collection from You. ITGB may also collect Personal Information from you through means other than the Website. This may include offline collection, such as when you submit a paper form to us. It may also include e-mails that you send to us separate from the Website. This Privacy Policy also applies to Personal Information that you provide to us through means other than the Website. However, to the extent we combine the Personal Information we collect from you outside of the Website with Personal Information that we collect through the Website, we will apply this Privacy Policy to the combined information, unless specifically disclosed otherwise.
  4. Information ITGB Collects from Other Sources. ITGB may also obtain information about you from other sources, including Service Providers and Third-Party Services, and combine that with ITGB-Collected PII. Notwithstanding anything to the contrary, except to the extent such data is combined by or on behalf of ITGB with ITGB-Collected PII, this Privacy Policy is not intended to limit ITGB’s activities regarding such third-party-sourced, or non-Service-sourced, information (including Personally Identifiable Information), and such data will only be treated as ITGB-Collected PII to the extent it is combined with ITGB-collected PII. ITGB is not responsible or liable for the accuracy of the information provided by third parties or for third-party policies or practices.
  5. EEOC / Affirmative Action Reporting. 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.
  6. Youth Access Prevention. 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.

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2. HOW WE USE THE INFORMATION WE OBTAIN.

ITGB may use information about you, including ITGB-Collected PII and other Personally Identifiable Information, for any purposes not inconsistent with ITGB’s statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law, including, without limitation, the following:

  • Allow you to participate in the features we offer on the Service;
  • Facilitate, manage, personalize, and improve your online experience;
  • Process your registration, manage your account and/or upload your User Generated Content (“UGC”). (For more information on how UGC is treated under the Service’s Terms of Use click here. For more on the public nature of UGC, see Section 5;
  • Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices;
  • Contact you, whether by email, postal mail, or telephone with information about this Service, our products, or our services, including exclusive Winston Cigarettes special offers and information about sales, promotions, coupons, new releases, and other relevant information (e.g., Winston Cigarettes coupons, Winston Cigarettes deals, sweepstakes entries, Winston Cigarettes loyalty programs – including the Winston Loyalty Program, or Winston Rewards, etc.);
  • Auditing, research, and analysis to maintain and improve the Service and for any other internal business purposes;
  • Tailor our content, advertisements, and Winston Cigarettes offers;
  • Develop new products and services;
  • Fulfill other purposes disclosed at the time you provide Personally Identifiable Information or otherwise where we are legally permitted or are required to do so;
  • Determine your location and manage digital content rights (g., territory restrictions); and
  • Prevent and address fraud, breach of policies or terms, and threats or harm.

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3. INFORMATION WE SHARE WITH THIRD PARTIES.

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:

  • Marketing: Subject to your communications choices explained in Section 11.D, and the rights of California residents explained here, we may use your Personally Identifiable Information to send you marketing communications. Absent your consent (which may be by means of opt-in, your election not to opt-out, or a third-party interaction described in the next bullet point), however, we will not share your ITGB-Collected PII with third parties (other than our affiliates) for their own direct marketing purposes, except in connection with Corporate Transactions (defined below).
  • Your Disclosure or Consent: As more fully described in Section 5(Information You Disclose Publicly or to Others) and Section 6(Third-Party Content, Third-Party Services, Social Features, Advertising, and Analytics), your activities on the Service may, by their nature, result in the sharing of your ITGB-collected Personally Identifiable Information (as well as your other Personally Identifiable Information and your non-Personally Identifiable Information) with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties. Such third-party data receipt and collection is subject to the privacy and business practices of that third party, not ITGB.

ITGB may also share any information about you (including, without limitation, ITGB-Collected PII) for any purposes not inconsistent with this Privacy Policy, or our written statements at the point of collection, and otherwise not prohibited by applicable law, including, without limitation:

  • ITGB’s agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive, or be given access to, your information, including, without limitation, Personally Identifiable Information, Demographic Information, and Usage Information, in connection with their work on ITGB’s behalf, provided however, ITGB does not authorize its Service Providers to use ITGB-Collected PII provided by ITGB to the Service Providers to send you direct marketing messages other than related to ITGB and ITGB Affiliates absent your consent. For more information on choices Service Providers may offer you click Section 11.
  • To comply with the law, law enforcement or other legal process, and, where permitted, in response to a government request; and
  • If ITGB believes your actions are inconsistent with ITGB’s terms of use, user agreements, applicable terms or policies, or to protect the rights, property, life, health, security and safety of ITGB, the Service or its users, or any third party.

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”).

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4. SWEEPSTAKES, CONTESTS, AND PROMOTIONS.

ITGB may offer sweepstakes, contests, and other promotions (each, a “Promotion”), including Promotions jointly sponsored or offered by third parties, which may require submitting Personally Identifiable Information. If you voluntarily choose to enter a Promotion, your information, including Personally Identifiable Information, may be disclosed to ITGB, co-sponsors, Service Providers, and other third parties, including for administrative purposes and as required by law (e.g., on a winners list). By entering, you are agreeing to the official rules that govern that Promotion and Additional Terms, which may include consent to additional or differing data practices from those contained in this Privacy Policy. Please review those rules carefully.

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5. INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS.

The Service may permit you to post or submit UGC including, without limitation, written content, user profiles, computer graphics, pictures, data, or other content, including Personally Identifiable Information (“PII”). If you choose to submit UGC to any public area of the Service, your UGC will be considered “public” and will be accessible by anyone, including ITGB. Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Personally Identifiable Information included in UGC is not subject to ITGB’s usage or sharing limitations, or other obligations, regarding ITGB-Collected PII or other Personally Identifiable Information under this Privacy Policy or otherwise, and may be used and shared by ITGB and third parties to the fullest extent not prohibited by applicable law. ITGB encourages you to exercise caution when making decisions about what you disclose in such public areas. For more information on how UGC is treated under the Service’s Terms of Use click here. If you believe any material on the site infringes on a copyright, click here for more information about sending us a notice pursuant to the Digital Millennium Copyright Act (“DMCA”). California minors should see Section 9 regarding potential removal of certain UGC they have posted on the Service.

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.

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6. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS.

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 may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on third-party services. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the Internet, which may include use of precise location and/or Cross-Device Data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on a Third-Party Service after you have left the Service (i.e., “retargeting”). We may target ads based on data we have collected, or data provided by third parties alone or in combination with the data we collect ourselves. We may participate in online advertising networks and exchanges that display Interest-based Ads to you on Third Party Services. These entities may use cookies and other Tracking Technologies to automatically collect information about you and your activities, such as registering a unique identifier for your device and tying that to your online activities on and off of the Website.

ITGB may use Google Analytics and other Service Providers for analytics services. These analytics services may use cookies and other Tracking Technologies to help ITGB analyze Service users and how they use the Service. Information generated by these services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere), and these Service Providers may use this information for purposes such as evaluating your use of the Service, compiling statistical reports on the Service’s activity, and providing other services relating to Service activity and other Internet usage. ITGB only retains aggregated data from Service Providers for analytics services.

ITGB is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Service, and encourages you to familiarize yourself with and consult their privacy policies and terms of use. See Section 11 for more on certain choices offered by some third parties regarding their data collection and use, including regarding Interest-based Advertising and analytics.

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7. DATA SECURITY AND MONITORING.

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.

To help protect you and others, ITGB and its Service Providers may (but make no commitment to) monitor use of the Service, and may collect and use related information including ITGB-Collected PII and other Personally Identifiable Information for all purposes not prohibited by applicable law or inconsistent with this Privacy Policy, including, without limitation, to identify fraudulent activities and transactions; prevent abuse of, and investigate and/or seek prosecution for, any potential threats to or misuse of the Service; ensure compliance with the Terms of Use and this Privacy Policy; investigate violations of or enforce these documents; improve the Services and your Services experiences, and to protect the rights and property of ITGB, third parties, and other users. Monitoring may result in the collection, recording, and analysis of online activity or communications through our Service. If you do not consent to these conditions, you must discontinue your use of the Service.

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8. INTERNATIONAL TRANSFER.

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.

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9. AGE RESTRICTIONS.

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.

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10. ACCESSING AND CHANGING INFORMATION.

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

  • as required by applicable law; and
  • for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.

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11. CHOICES, TRACKING AND COMMUNICATIONS OPTIONS AND STATE NOTICES.

  1. Tracking Technologies Generally. Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website. On our consumer-facing websites we also offer a cookie preference tool that gives you the ability to make certain choices regarding cookies. Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.

    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.

  2. Analytics and Advertising Tracking Technologies. You may exercise choices regarding the use of cookies from Google Analytics by going here or downloading the Google Analytics Opt-out Browser Add-on. You may exercise choices regarding the use of cookies from Adobe Analytics by visiting here under the section labeled “Tell our customers not to measure your use of their web sites or tailor their online ads for you.”

  3. Communications. You can opt out of receiving certain promotional communications (emails or text messaging) from ITGB at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account; and (ii) for text messages, following the instructions provided in text messages from ITGB to text the word, “STOP”. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, ITGB may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or ITGB’s ongoing business relations.

  4. Cross-Device Data. To learn more about how you can exercise certain choices regarding Cross-device data for Interest-based Advertising, see the prior section regarding the DAA’s Interest-based Advertising choices.

  5. Nevada Residents. Nevada law allows customers to “opt out” of the sale of certain personal information, called “covered information.” At ITGB, we do not sell covered information as defined in the law and we have no plans to change that practice. If you want to be notified if we do change that practice, you may contact us here and provide your name, Nevada resident address, and email address. We’ll contact you if there are any changes and you can complete your opt out at that time. If your contact information changes at any point, contact us in the same manner to update your contact information. For more information about our data collection and sharing practices, please review this Privacy Policy. We may share your data as explained in this Privacy Policy for different purposes, such as to make your experience and our services better, and those activities are separate from the opt out request.

  6. Connecticut Privacy Notice. Connecticut law requires any person or entity that collects Social Security numbers from Connecticut residents in the course of business to create a privacy protection policy and to publish or display it publicly. It is our policy to protect the confidentiality of any Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information in order to perform their job functions.

  7. Your California Privacy Rights. California residents can learn more about their privacy rights here.

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12. INFORMATION STORAGE AND SECURITY.

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 thorugh 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.

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13. CHANGES TO THIS PRIVACY POLICY.

We reserve the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not treat your previously collected ITGB-Collected PII, to the extent it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

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14. CONTACT ITGB.

If you have any questions about this Privacy Policy, please contact ITGB here or by mail at 714 Green Valley Road, Greensboro, NC 27408-7018 (Attn: Legal Department).

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