Effective Date: January 1, 2021.
Your California Privacy Rights
· Your Choices and Your CA and NV Privacy Rights
You have certain choices regarding information collection and communications options explained here,
-- 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
--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
· Sharing of Information
-- 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
· Table of Contents
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:
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.
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.
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.
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.
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.
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
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.
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.
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.
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.
Your California Privacy Rights. California residents can learn more about their privacy rights here.
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.