Effective Date: December 22, 2020
This Privacy Notice explains how Vesper Brewing Co. Ltd. (“Vesper” or “we,” “us,” or “our”) collects, uses, and discloses information about you when you visit, access, or use our websites, domains, applications, software, and other online products and services, including online portals and our network (collectively, the “Services”) or when you otherwise interact with us. By visiting https://vesper.finance or https://vesperdev.net each (the “Site”) or otherwise using our Services, you acknowledge the practices described in this Privacy Notice. We will occasionally change this Privacy Notice. When we do, we will notify you by revising the date at the top of this Privacy Notice and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Notice whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.
If you have any questions about this Privacy Notice, you may contact us via email at info@vesper.finance.
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Information You Provide to Us: We collect information you provide directly to us. For example, to use our Services we may ask you to provide us with certain information in order to create an account, which may include personal information that can be used to contact or identify you, such as your name, email address, billing address, phone number, username and/or password. If you request technical or product support, you may provide additional information on your usage of the Services, including your environment set up and log files.
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Information We Collect Automatically: When you access or use our Services, we automatically collect information about you, including:
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Log Information: This is information about your use of the Services, including the type of browser you use, access times, pages viewed, session IDs, your IP address, and the page you visited before navigating to our Services.
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Location Information: This is information about the location of your equipment, computers, devices, and/or hardware (collected in accordance with your device permissions).
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We use information to provide, analyze, administer, enhance, and personalize the Services and our marketing efforts, to process your account registration, and to communicate with you on these and other topics. Specifically, we may use information collected about you via the Services to:
- Deliver advertising, promotions, and other information regarding the Services to you;
- Analyze and understand our audience, improve the Services (including our user interface experiences), and optimize content selection and delivery;
- Email you regarding your account or notify you of updates to the Services;
- Compile aggregate data and analysis for internal business purposes;
- Perform other business activities as needed;
- Comply with and enforce legal requirements, agreements, and policies;
- Protect your and our rights; and
- Any other purpose that is disclosed to you at the time we collect the information that is related to a request made by you or for which you have given express permission or consent to us.
We may share information collected from or about you in the following ways:
- Service Providers: We may share your information with service providers and third parties that perform services for us on our behalf, including data collection, monitoring, and analysis; know-your-customer, identity validation, authorization, and eligibility services; email and/or content delivery; hosting services; customer service; and marketing access.
- By Law or to Protect Rights: If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection.
- Business Transfer or Fundraising: In connection with any reorganization, restructuring, merger or sale, other transfer of assets, or if we are otherwise involved in a change of control transaction or in connection with our fundraising activities, we may transfer information, including your Personal Data, to one or more third parties as part of the transaction, including the due diligence process. You acknowledge that such transfers may occur and that the transferee may decline to honor commitments we made in this Privacy Notice.
- Parties With Your Consent or When You Otherwise Choose to Share. In addition to the sharing described in this Privacy Notice, we may share any information from or about you with any party when we have your consent or when you otherwise choose to share such information.
While no one can guarantee your personal information is completely secure at all times, we use administrative, organizational, technical, and physical safeguards to protect the personal information we collect and process. Our security controls are designed to maintain data confidentiality and integrity, and to give us appropriate access to your data. Among other things, we use professional third party service providers and data centers to provide our website, and enter into confidentiality agreements with them where appropriate. Those service providers and data centers implement industry-standard measures to protect the security of the personal information we collect, such as SSL (Secure Socket Layers), firewalls, digital certificates, and encryption.
We keep your personal information in line with set periods of time calculated using the following criteria:
- How long it is reasonable to keep records to show we have met the obligations we have to you and by law;
- Any periods for keeping information which are set by law or recommended by regulators, professional bodies or associations; and
- Any relevant proceedings that apply. We keep Log Information and Cookie Information for 30/60/90/120 days.
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Account Information: You may update or correct information about you at any time by logging into your online account or emailing us at the contact email address below.
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Geolocation: We may have access to your geolocation to and enable the collection of location information. You can subsequently stop the collection of this information at any time by changing the preferences through your web browser or the Services, as applicable. If you do not allow us to collect your location information, certain features may no longer function or be available to you.
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Cookies: We use cookies to collect information (e.g., Log Information and Equipment Information discussed above) and to help improve our Services and your experience. Cookies are sent to your browser from a web site and stored on your computer’s hard drive or in device memory. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
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Opting Out: You may opt out of future contacts from us at any time. You can do so at any time by contacting us via the email address below or through the unsubscribe link in our emails. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.
Our Services, including the Site, may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects their information, including personally identifiable information.
If you are in the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your Personal Data (as defined under the General Data Protection Regulation).
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Legal Basis for Processing. If you are in the EEA, when we process your Personal Data we will only do so in the following situations:
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We need to use your Personal Data to perform our responsibilities under our contract with you (e.g., providing the Services you have requested).
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We have a legitimate interest in processing your Personal Data. For example, we may process your Personal Data to send you marketing communications, to communicate with you about changes to our Services, and to provide, secure, and improve our Services.
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We have your consent to process your Personal Data. For example, when you provide us with consent to send emails to you containing information about our products and services, our affiliated or partner entities, or other industry or business news.
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We have a legal obligation to process your Personal Data. For example, we may need to retain certain transactional data to comply with our legal obligations. We may also be required to retain information about our interactions with you when you make certain requests for information to comply with our regulatory obligations.
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Data Subject Requests and Rights.
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If you are in the EEA, you have the right to access or modify Personal Data we hold about you and to ask that your Personal Data be corrected, erased, or transferred. The right to transfer your Personal Data or the right to data portability means that you can request that we provide certain Personal Data about you that we process in a machine-readable format. The right to erasure means that you can request deletion or removal of certain Personal Data we process about you.
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You also have the right to know whether, and for what purposes, we process Personal Data about you, the right to be informed about the Personal Data we collect and/or process about you, the right to know with whom we have shared Personal Data about you, for what purposes, and what Personal Data has been shared (including whether Personal Data was disclosed to third parties for their own direct marketing purposes), and where processing of Personal Data about you is based on consent, the right to withdraw your consent to such processing. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us at our contact email address shown below and include in the subject line the nature of your request.
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Note that we may need to request additional information from you to validate a request relating to the exercise of any of the rights above.
- How We Store Your Personal Data
Your information is securely stored in the United States. You understand and agree that we may transfer your information to the United States or our offices in other countries. We endeavor to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with us and the practices described in this Privacy Notice.
- Questions or Complaints.
If you are in the EEA and have a concern about our processing of Personal Data that we are not able to resolve, you have the right to lodge a complaint with a data privacy authority. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
If you are a California resident, please note that we do not share information that identifies you personally with non-affiliated third parties for their own marketing use without your permission. Under the California Consumer Privacy Act (“CCPA”), California residents have the right to know and request access to their Personal Information (as defined under the CCPA) collected and shared within the past 12 months, the right to delete their Personal Information in accordance with the CCPA, the right opt out of selling, and the right not to be discriminated against if invoking these rights granted by the CCPA.
- Submitting CCPA Requests
If you are a California resident and a consumer of the website and our services, you can submit a request by contacting us at the following email address: info@vesper.finance. For requests that require identity verification, we will take commercially reasonable steps to verify your identity, including asking you to provide us with information to confirm your identity using the information we have on file. If you wish to designate an authorized agent to make a request on your behalf, please indicate that when submitting your request. We will make good faith efforts to respond to your request. There may be circumstances under the CCPA in which we cannot, or need not, respond to your request. Any requests that can be processed by us will be done so in no more than 45 days from the date we receive your request, unless the law requires a faster response or we notify you that an extension is required. In case of an extended completion period, we will process your request in no more than 90 days from the date of your original request. Consumers are limited to two requests to know/access their personal information within a 12-month period.
- Personal Information Collected, Used and Disclosed within the Past 12 Months
| Category of data collected from consumers within the past 12 months: | Source of this data | Business or commercial purpose |
|---|---|---|
| Identifiers such as a name, online identifier, Internet Protocol address, and email address | You | Provide our Site/Services |
| Commercial information such as Services purchased or obtained and account history | You, service providers, and automatically through use of service | Provide our Site/Services |
| Internet or other electronic network activity information, including, but not limited to, information regarding a consumer’s interaction with our Site/Services | You, service providers | Provide our Site/Services Analytics |
| Geolocation data | You | Provide our Site/Services Analytics |
Because our services are intended for adults, we do not knowingly collect personal information from children or minors under the age of 16, nor do we knowingly share any such personal information with third parties.
Residents of Nevada have a right to submit a request to opt-out of sale of personal information, referred to under Nevada law as “covered information.” Please note, however, that we have not “sold” covered information as that term is defined by Nevada law, nor do we intend to “sell” any such information.