PRIVAcy POLICY

 

Effective Date: December 1, 2021

This Privacy Policy describes how Manifest Distilling, LLC d/b/a Flying Cloud and our subsidiaries and affiliates (collectively “Flying Cloud” “we“, “us” or “our“) collects, uses, and shares your personal information if you use our websites or digital properties that link to this Privacy Policy (collectively, the “Site” or the “Service”). 

This Privacy Policy is part of our online Terms of Service, which governs your use of the Site. By visiting this Site, you are accepting the practices described in this Privacy Policy and agree to receive future revisions to our Privacy Policy through our Site. This Privacy Policy is applicable only to visitors and users of the Site, and it may not be applicable to transactions or information gathered outside the Site. This Site is not directed to or intended for individuals under the age of 21. 

In the case of an online transaction, which is processed by Seelbach’s Spirits LLC, a different privacy policy will apply in accordance with its terms. 

We provide important information for California residents below.

PERSONAL INFORMATION WE COLLECT

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

  • Contact data, such as your first and last name, e-mail and mailing addresses, residence, postal code, and phone number.

  • Profile data, such as your username and password if you establish an online account with us, age, gender, biographical details, links to your profiles on various third-party sites including social networks, interests, preferences, and information that may be related to a service, account, or an event you register for.

  • Communications that we exchange, including when you contact us with questions, feedback, or otherwise.

  • Payment and transactional data, such as the information needed to complete your orders on or through the Service (including name, credit card information, bank account number, billing, and shipping information), and information about our products that you have purchased.

  • Marketing data, such as your preferences for receiving communications about our products, services, activities, events, and publications, and details about how you engage with our communications.

  • Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may obtain personal information from other sources, such as:

  • Data providers, such as information services and data licensors.

  • Public sources, such as social media platforms.

  • Business partners, such as joint marketing partners and event co-sponsors.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on our sites and other sites and online services, such as:

  • Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, IP address, unique identifiers, the website you visited before browsing to our website, and general location information such as city, state, or geographic area.

  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

  • Precise geolocation data, such as when you authorize our mobile application to access your location.

Cookies and similar technologies. Like many online services, we use the following technologies:

  • Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.

  • Flash cookies, or locally-stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data.

  • Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or e-mail was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.

Information about others. Users of the Service may have the opportunity to refer friends or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.

Minors. We follow the federal rules, restrictions, and guidelines of the Children’s Online Privacy Protection Act, under which parents can control what information is gathered online about their children. We do not knowingly collect, maintain, or use personally identifiable information about persons under the age of 21. 

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for the following purposes or as otherwise described at the time we collect it:

Service delivery. We use your personal information to:

  • provide, operate and improve the Service and our business;

  • establish and maintain your user profile on the Service;

  • fulfill your orders for products that you purchase;

  • process the rebates and other redemptions you submit;

  • enable security features of the Service, such as by sending you security codes via e-mail or SMS, and remembering devices from which you have previously logged in;

  • communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;

  • understand your needs and interests, and personalize your experience with the Service and our communications; and

  • provide support for the Service, respond to your requests, questions, and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing and advertising. We and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

  • Direct marketing. We may send you Flying Cloud-related or other direct marketing communications as permitted by law, including by e-mail and mail. You may opt-out of our marketing communications as described in the “Opt-out of marketing communications” section below.

  • Interest-based advertising. We may contract with third-party advertising companies and social media companies to display ads on our Service and other sites. These companies may use cookies and similar technologies to collect information about you (including the device data, online activity data and/or geolocation data described above) over time across our Service and other sites and services or your interaction with our e-mails, and use that information to serve ads that they think will interest you. You can learn more about your choices for limiting interest-based advertising, in the “Advertising choices” section below.

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

  • audit our internal processes for compliance with legal and contractual requirements and internal policies;

  • enforce the terms and conditions that govern the Service; and

  • prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection: 

Affiliates. Our corporate parents, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as IT, hosting, customer relationship management and support, print and mail fulfillment, data management, event registration, e-mail delivery, marketing, website analytics, event management services, order fulfillment, running promotional activities such as sweepstakes, rebates, and surveys).

Advertising partners. Third-party advertising companies that collect information about your activity on the Site and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.

Professional advisors. Professional advisors, such as lawyers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and operations purposes described above.

Business transferees. Relevant participants in business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, Flying Cloud or our subsidiaries or affiliates (including, in connection with a bankruptcy or similar proceedings). 

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties on our Service, that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.

YOUR CHOICES

You have the following choices with respect to your personal information.

Access or update your information. If you have registered for an account with us, you may review and update certain account information by logging into the account.

Opt-out of marketing communications. You may opt out of marketing-related e-mails by following the opt-out or unsubscribe instructions at the bottom of the e-mail, or by contacting us. You may continue to receive service-related and other non-marketing e-mails. If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message.

Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Service and our Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. We use Google Analytics to help us understand user activity and patters on the Site. You can learn more about Google Analytics cookies at https://developers.google.com/analytics/resources/concepts/gaConceptsCookies and about how Google protects your data at http://www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing a browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.

Privacy settings and location data. Users of our App can disable our access to their device’s precise geolocation in their mobile device settings.

Interest-based advertising. Some of our advertising partners are members of the Network Advertising Initiative (NAI) and are subject to the Self-Regulatory Principles for Online Behavioral Advertising published by the Digital Advertising Alliance (DAA). You can obtain more information about these companies’ information collection practices and opt-out of receiving interest-based advertising from participating NAI and DAA members at http://www.networkadvertising.org/managing/opt_out.asp and/or the DAA’s website at optout.aboutads.info. Mobile app users may opt out of receiving interest-based advertising in mobile apps provided by participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available at https://www.youradchoices.com/appchoices. You can also limit collection of your information for interest-based ads by blocking third-party cookies in your browser settings or using privacy plug-ins or ad blocking software that help you block third-party cookies. In addition, your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for targeted online advertising purposes. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Some of the third-party advertising companies we work with offer their own opt-out options that you can use to limit their use of your information for interest-based advertising:

Google

Info: https://policies.google.com/technologies/adsOpt-out: https://adssettings.google.com/authenticated

Facebook

Info: https://www.facebook.com/privacy/explanationOpt-out: https://www.facebook.com/about/ads

Trade Desk

Info: https://www.thetradedesk.com/general/privacy-policyOpt-out: https://www.adsrvr.org/

Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above. Even after using these opt-out mechanisms, you may receive interest-based advertising from other companies.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.

Third-party platforms. If you choose to connect to the Service through your social media account, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

OTHER SITES AND SERVICES

The Service may contain links to websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or other online services that are not associated with us. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions.

SECURITY

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

INTERNATIONAL DATA TRANSFER

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

CHILDREN

The Service is not intended for use by children under 21 years of age. If we learn that we have collected personal information from a child under 21 without the consent of the child’s parent or guardian as required by law, we will delete it.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail or another manner through the Service. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

HOW TO CONTACT US

You can reach us in the following ways:

IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS

Scope. This section applies only to California residents. It describes how we collect, use, and share Personal Information of California residents when we act as a “business” as defined under the California Consumer Privacy Act of 2018 (“CCPA”), and their rights with respect to their Personal Information. For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA or information we collect from you in the course of providing services to you or receiving services from you where you are an employee, controlling owner, director, officer or contractor of a company, partnership, sole proprietorship, non-profit or government agency. In some cases, we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.

Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

  • Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:

    • The categories of Personal Information that we have collected.

    • The categories of sources from which we collected Personal Information.

    • The business or commercial purpose for collecting and/or selling Personal Information.

    • The categories of third parties with whom we share Personal Information.

    • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information disclosed to each category of third-party recipient.

    • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third-party recipient.

  • Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.

  • Deletion. You can ask us to delete the Personal Information that we have collected from you.

    • Opt-out of sales. If we sell your Personal Information, you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.

    • Opt-in. If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.

    • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.

You may exercise your California privacy rights described above as follows:

  • Right to information, access, and deletion. You may exercise your right to information, access, or deletion by:

  • Right to opt-out of the “sale” of your Personal Information. Like many companies, we use services that help deliver interest-based ads to you. Our use of some of these services may be classified under California law as a “sale” of your Personal Information to the companies that provide the services because they collect information from our users (e.g., device data and online activity data) to help them serve ads more likely to interest you. You can request to opt-out out of this “sale” of your personal information here: http://www.flyingcloudrum.com/opt-out

We reserve the right to confirm your California residency to process your requests and will need to confirm your identity to process your requests to exercise your information, access, or deletion rights. Government identification may be required. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Personal information that we collect, use, and disclose. The chart below describes the Personal Information we collect by reference to the categories specified in the CCPA and describes our practices during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. Each category is used for the business/commercial purposes described in the section above entitled “How We Use Your Personal Information,” and disclosed to the categories of third parties described in the section above entitled “How We Share Your Personal Information.”

We describe:

  • the sources from which we collect this information in the section above entitled “Personal Information We Collect”; and

  • the business and commercial purposes for which we collect this information in the section above entitled “How We Use Your Personal Information.”

  • the categories of third parties to whom we disclose this information in the section above entitled “How We Share Your Personal Information.”

COOKIE NOTICE

This Cookie Notice explains how Manifest Distilling, LLC d/b/a Flying Cloud (“Flying Cloud”, “we”, “us” or “our”) uses cookies and similar technologies in connection with the www.flyingcloudrum.com website and any other website that we own or control and to which this Cookie Policy is posted (collectively, the “Site”). 

What are cookies? Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies serve different purposes, like helping us understand how a site is being used, letting you navigate between pages efficiently, remembering your preferences, and generally improving your browsing experience. Our Site may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them).

We use two broad categories of cookies: (1) first-party cookies, served directly by us, which we use to recognize your computer or mobile device when it revisits our Site; and (2) third-party cookies, which are served by service providers or business partners on our Site, and can be used by these parties to recognize your computer or mobile device when it visits other websites. Third-party cookies can be used for a variety of purposes, including site analytics, advertising, and social media features.

What types of cookies and similar tracking technologies does Flying Cloud use on the Site? On the Site, we use cookies and other tracking technologies in the following categories described in the table below.

Type: Advertising

Description: These cookies are used by advertising companies to collect information about how you use our Site and other websites over time. These companies use this information to show you ads they believe will be relevant to you within our Service and elsewhere, and to measure how the ads perform.

Who Serves the Cookies: Google Doubleclick, Facebook, Bing

How to Control Them: You can opt-out of Google Doubleclick cookies here. You can opt-out of Facebook cookies here. See ‘your choices’ below.

Type: Analytics

Description: These cookies help us understand how our Service is performing and being used. These cookies may work with web beacons included in e-mails we send to track which e-mails are opened and which links are clicked by recipients.

Who Serves the Cookies: Google Analytics

How to Control Them: You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing a browser plugin available here.

Type: Essential

Description: These cookies are necessary to allow the proper technical operation of our site.

How to Control Them: See ‘your choices’ below.

Type: Functional / Performance

Description: These cookies enhance the performance and functionality of our service.

How to Control Them: See ‘your choices’ below.

Other technologies. In addition to cookies, our Site and e-mails may use other technologies to collect information. For example, we may use web beacons (which are also known as pixel tags and clear GIFs) on our Site and in our HTML formatted e-mails to track the actions of users on our Site and whether recipients of our marketing e-mails open or click links within them. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted e-mails. Pixel tags are used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our e-mails (e.g., they may tell us whether you have opened an e-mail, and/or forwarded it on to someone else) and to compile statistics about usage of the Site, so that we can manage our content more effectively.

Your choices. Your options for controlling what information cookies and similar technologies collect about you include:

  • Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Site may not work properly. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Site.

  • Third-party opt-outs. Use the third-party-provided opt-out options described in the chart above.

  • Industry association opt-outs. You may opt out of receiving targeted online advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. You may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms linked above.

  • Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

California privacy rights

California law may classify our use of the third-party advertising cookies listed above as a “sale” of your personal information. See the your choices section above for information about how to opt-out of data collection by these third parties on the Site or our mobile applications. For more information about how we collect, use and share your information, see our Privacy Policy.

Changes. Information about the cookies we use may be updated from time to time, so please check back on a regular basis for any changes.

Questions. If you have any questions about this Cookie Notice, please contact us by e-mail at info@flyingcloudrum.com.