Privacy Policy

Protecting Your Privacy

When you use our Website, you are providing some personal information about who you are and how you use our services. We collect, store and analyse this information to monitor technical performance of our services, discover the bugs and offer better services for the next visitors. By visiting our Website, you consent to the practices described in this Privacy Policy. We are committed to protecting the security of your personal information we collect and protect your privacy. Please, read on if you want to learn more.

Who We Are

The Company behind frerotcognac.com is Supermassive Beverage Company, LLC, with headquarters in New York, NY (244 Fifth Avenue, Suite F247, New York, NY 10001). The Company acts as Data Controller for all our services. You can reach us by sending an email to [email protected].

How This Policy Applies

To perform our services, we need to collect some information about you. This Policy describes what information we collect, how we store it and share it with third parties, how we use that information and the legal basis for doing so. It also explains how collected information may be used and your rights regarding information you provide to us.

What Information We Collect and Receive

When you use our Website, or communicate with us regarding our services, we may collect personal information from you. We record information on how you use and interact with our Website, such as your IP Address, type of device or browser you use.

We may collect your email address and phone number that allows us to communicate with you regarding our Services and other offers, billing information such as your name, email, billing and shipping address and credit card details.

To tailor our services for you, we analyse your use of our website via the use of cookies software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. We may collect your interests on specific drinks and drink types, your ratings of specific drinks and your reviews of specific drinks.

If you submit any personal information relating to other people to our service providers or to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

How We Use this Information

We need this information to:

  • Learn about how you use our Website and decide about changes, we want to implement to make your experience better,
  • To provide and operate the Services;
  • To provide our Users with ongoing customer assistance and technical support;
  • To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;
  • To comply with any applicable laws and regulations.

What is the legal background for us to collect this Information

We collect and retain Personal Information on several legal bases:

  • Contractual obligation: if you gave us your personal information in connection with the Services you bought from us, we need this information to deliver Services to you.
  • Legal obligation: in some cases, it is required by the law to collect and store your Personal Information. For example, tax laws require that we keep all the sales records and, in some cases, share it with local tax authorities.
  • Legitimate interest: for some data, we have good and fair reasons to use it in such ways that do not hurt your interests and rights. Examples of that would be that we use your information like location, browser information, IP address, billing and shipping address, email address, to prevent fraud and abuse of our Services.
  • Consent: when you deliberately enter your information, like your email address on our Website, and give consent, you should expect that this information will be stored and used by our systems according to this Privacy Policy.

How long do we keep this Information

Your information will be stored as long as it is necessary to provide you with the Services you expect from us and/or for as long as we have your permission to keep it. Some of your personal information will be stored with our partners or us as long as required by different laws that we need to comply with (for example tax laws).

We also collect and maintain aggregated, anonymised or pseudonymized information which we may retain indefinitely to protect the safety and security of our Site, improve our Services or comply with legal obligations. For instance, we are required to retain records related to previous sales for financial reporting and compliance purposes. We may retain and use information to, among other purposes, comply with our legal obligations, preserve our rights, resolve disputes and enforce our agreements.

You can always request deletion of your Personal Information by sending a request to [email protected].

How do we share this Information with our partners (disclosure to third parties)

We don’t publish any information about our users publicly.

If you choose to review products on our Website (if this feature is active), we will add your First Name together with the review.

We share some information with our trusted third-party services that help us provide, improve, promote or protect our Services (Data Processors). Those third-party services include payment processors, fulfilment partners, services that help us manage our ads and similar.

Third-party services are authorised to use your personal information only in connection with services they provide for us, and we require to use the same security and privacy standards as we do. When possible, we anonymise and aggregate the information we share with third-party services so that they are not able to identify you as an individual.

What are your »data rights«?

Certain privacy laws around the world, including the European General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), provide users with rights related to their personal information. Consistent with those laws, we give you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you (If you wish to exercise any of the rights you may at any time, contact our Data Protection Officer).

The exercise of these rights is free of charge, except if your request is »manifestly unfounded or excessive« (for example, if you make repetitive requests). In this case a fee may be charged to cover our administrative costs in responding.

  • Right to Access & Portability: You can request a copy of your personal information in an easily accessible format and information explaining how that information is used, free of charge.
  • Right to Correction: You have the right to request that we rectify inaccurate information about you.
  • Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.
  • Right to Deletion: In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and our integrity.
  • Right to Object: If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can object using the unsubscribe link in such communications or changing your account email settings.
  • Right to avoid automated decision-making.
  • Right to Withdraw Consent: Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link.

The CCPA provides California residents with the following additional rights (to get more information about your rights under CCPA, please check California Consumer Privacy Act below):

  • Right to Know: California residents may request disclosure of the specific pieces and/or categories of personal information that the business has collected about them, the categories of sources for that personal information, the business or commercial purposes for collecting the information, the categories of personal information that we have disclosed, and the categories of third parties with which the information was shared.
  • Right to Opt-Out: To the extent that we “sell” personal information (as that term is defined under the CCPA), California residents are entitled to opt-out of the “sale” of data at any time.
  • Right to Nondiscrimination – we shall not discriminate against California residents (nor anyone else) on the basis of their exercising their CCPA rights (they have a right “not to receive discriminatory treatment” for exercising their CCPA rights).

Data Transfers

We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different from, and potentially not as protective as, the laws of your own country. Therefore, we may be unable to provide the same level of security as provided under the regulation of the EU and its Member States.

The information you give to us may be transferred to the countries outside the European Union (applies to EU customers only).

We provide a voluntary service; you can choose whether or not to use the Services. As we operate in different countries and use technical infrastructure in the U.S. to deliver the Services to you, in accordance with the contract between us, we need to transfer your personal information to the U.S. and to other jurisdictions as necessary to provide the Services. Simply put, we can’t provide you with the Services and perform our contract with you without moving your personal information around the world.

Security

We understand that the security of your personal information is especially important. We protect the collected data according to the industry-standard practices and continuously improve security protocols. However, we understand that no electronic storage of the data or transmission over the internet is entirely secure and we can not guarantee absolute security. Therefore we encourage all users to be careful whenever they store or post any personal information online.

In the event that personal information is compromised as a result of a breach of security, we will promptly notify those persons whose personal information has been compromised, in accordance with California Consumer Privacy Act and the EU Regulation GDPR or as otherwise required by applicable law.

As we develop our business, we may buy or sell assets or business offerings. Customer and visitor information is generally one of the transferred business assets in these types of transactions. We may also transfer such information in the course of corporate divestitures, mergers, or dissolution.

We do not rent or sell your personal data to others.

Minors

We do not knowingly collect Information about or from minors, nor do we or any of our third parties direct any solicitations or advertisements to minors. If you are not 21 or older (or of legal drinking age in your respective country), you are not authorized to use the website. Parents should be aware that there are parental control tools available online that you can use to prevent your children from submitting information online without parental permission or from accessing material that is harmful to minors. If we learn that we collected Information about a minor, we will immediately act to remove that Information.

Cookie Policy

When you visit our website, we analyse your use of our website via the use of cookies and similar technologies. You can set your browser to (partly) disable or refuse cookies. Please read our Cookie Policy for more information about the use of cookies.

California Consumer Privacy Act

If you are a California resident, you should review the information in this section carefully. If you are not a California resident, you may disregard the information in this section as it does not apply to you.

Notice of Collection
In addition to the ‘data rights’ described above, the CCPA requires disclosure of the categories of personal information collected over the past 12 months. While this information is provided in greater detail in the "What Information We Collect and Receive" Section above, the categories of personal information that we have collected – as described by the CCPA – are:

  • Identifiers such as name, address, date of birth, telephone number and email address
  • Categories of personal information described in subdivision (e) of Section 1798.80
  • Commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
  • Internet and other electronic network activity information such as your interaction with our website and applications
  • Geolocation data
  • Inferences drawn from the information identified above reflecting the consumer's preference
  • Identifiers such as name, address, date of birth, telephone number and email address

The Purposes for Our Collection
We collect and use these categories of personal information for our business and commercial purposes described in the “How We Use this Information” Section above, including providing and improving the Services, maintaining the safety and security of the Services, processing purchase and sale transactions, and for advertising and marketing services.

Third Party Marketing and Advertising and Your Rights (Opt-Out of “Sale”)
We do not sell personal information to third parties for monetary value. However, the term “sale” is defined broadly under the California Consumer Privacy Act. To the extent that “sale” under the CCPA is interpreted to include interest based advertising or other data uses, we will comply with applicable law as to those activities. You can read more in our Cookie Policy. To opt-out of receiving interest based advertising, you can exercise your choice by changing your privacy settings in Cookie Policy. The right to opt-out of interest based advertising is available to all our users.

Shine the Light
California law entitles residents to ask for a notice describing what categories of personal information we share with third parties for their own direct marketing purposes. Unless you request us to or consent to it, we do not share any personal information to third parties for their own direct marketing purposes. If you have questions about these practices, you can contact us through one of the channels listed in the “Contact” Section below. For information on interest based advertising and how your information is used for marketing, see our Cookie Policy.

Accessibility
If you have a disability and would like to access this policy in an alternative format, please contact us using one of the channels listed in the “Contact” section below.

Contact

If you have any concerns or questions about how your data is being used or stored or any information that is related to security of your or other user’s data on our Website, or you wish to request disclosure or deletion, please reach out to our Data Protection Officer by email to [email protected]. or by post to our current registered office (244 Fifth Avenue, Suite F247, New York, NY 10001), marked for the attention of “The Legal Department”.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily you can also contact our:

  • EU Representative by email to [email protected] or by post to Likozarjeva ulica 1, 1000 Ljubljana, Slovenia.
  • UK Representative by email to [email protected] or by post to 4th Floor, Silverstream House, 45 Fitzroy Street, Fitzrovia, London, W1T 6EB, UK.

Changes to how we Protect Your Privacy

We may update this Policy from time to time, to reflect how we are processing your data. If we make significant changes, we will make that clear on this page and let you know about it, so you will be able to review the changes before you continue to use our services.

If any non-significant changes to this Privacy Policy are unacceptable to you, you must contact us immediately and until the issue is resolved, stop using our website or any services we provide.

We kindly recommend that you check this page regularly to keep up-to-date.

This Privacy Policy was last updated in May 2021.