Last updated: September 2021
LEGAL AGE AND UNDERAGE PERSONAL DATA
You must be at least the legal age to purchase and consume alcohol in order to use or access these Websites. Please exit immediately if you are not at least the legal age for such activity in the territory from which you are accessing these Websites.
Upon visiting our Websites, you will be prompted by an age check. This age check does not store the date of birth you provide. We do not knowingly collect or solicit personal information from anyone under the legal drinking age. If, at a later date, it comes to our attention that an individual under the legal drinking age has provide us with their personal information, we will delete that information as expediently as possible.
Do not share, forward, or solicit access of this Website, or any of its contents, to anyone who is not at least the legal age to purchase and consume alcohol.
“MUJEN”, “we”, “our”, or “us” refer to Mujen Spirits, Inc. and its subsidiaries and affiliates.
“Services” refer to any and all of our Websites and online services.
“You” refers to the relevant individual who is the subject of the personal data described herein.
In this overview, we summarize the relevant personal information we collect and how we use it. The actual personal information we collect and how we use it may vary depending upon the nature of our relationship and interactions with you. Also, in some cases (e.g., where required by law), we may ask for your consent or give you certain choices prior to collecting or using certain personal information.
“Personal data” or “personal information” include any information relating to an identifiable living person and includes all information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.
Scope of Collection. Generally, we collect the following categories of personal information:
- Identity: name and date of birth;
- Contact: billing address, mailing address, email, and phone numbers;
- Transaction: bank account details, payment device details, and purchase history;
- Technical: cookies, internet protocol (IP) address, browser type, browser version, time zone, device location, plug-in details, mobile device IDs and mobile device advertising IDs (MAID), operating system (OS) and/or platform details, and other technology employed by devices used to access our Websites;
- Interaction: your use of our Website, products, assets, applications, and services;
- Promotion: your communication preferences in receiving promotional, informational, and/or marketing material, including feedback and complaints; and
- Public Posted Content: your user-generated content, including text, pictures, audio, video, posted by you on online platforms such as social media and e-commerce sites.
Purposes of Use. Generally, we use and disclose personal information for the following purposes:
- Support: providing support, our Services, and operating our Websites;
- Improvement: analyzing and improving our business;
- Personalization: customizing content and experiences;
- Promotion: advertising, marketing, and promotional purposes;
- Protection: securing and protecting our business, defending our legal rights;
- Compliance: auditing, reporting, corporate governance, internal operations, and complying with legal obligations.
Duration of Use. We may retain personal data processed and/or received by us for as long as is considered necessary for the purpose for which it was collected, including as required by applicable law or regulation and to satisfy any legal, accounting, or reporting requirements. When the data is no longer necessary for the purpose for which it was collected, we securely delete it or, in some cases, anonymize it.
HOW DATA IS COLLECTED
Indirect Collection. We may also collect information about you from other entities, including members of our corporate family, business partners, and third-party service providers, including, but not limited to, professional advisers, analytics providers, advertising networks, search information providers, fraud prevention and credit reference agencies, and providers of technical, payment and delivery services.
SPECIFIC PURPOSES AND USE
We may collect, use, disclose, and otherwise process your personal information for the purposes described in this section.
Legal Bases. Certain laws require that we inform you of the legal bases for our processing of your personal information. Pursuant to such laws, we may process personal information for the following legal bases:
- Contract performance: processing of your personal information which is required for us to perform obligations or exercise rights under contracts that you may have with us;
- Legal compliance: to comply with our legal obligations (e.g., maintaining information in accordance with tax, audit, or company law requirements, and responding to legal process);
- Legitimate business interests: in furtherance of our legitimate business interests, including: facilitating your use and access of our Websites; communicating with you; conducting data analysis, audits, fraud monitoring, and fraud prevention; protecting and defending our legal rights and interests, and those of third parties.
Use and Processing. We collect, use, and otherwise process your personal information for the below commercial or business purposes. While the purposes for which we may process personal information will vary depending upon the circumstances, in general we use personal information for the purposes set forth below. We have set forth the legal bases for such processing (see above for further explanation of our legal bases) in parenthesis.
- Support: including to provide our Services; to communicate with you about your access to and use of our Services; to respond to your inquiries; to provide troubleshooting, fulfill your orders and requests, process your payments and provide technical support; and for other customer service and support purposes. (Legal basis: performance of our contract with you; and our legitimate interests)
- Improvement: including to better understand how users access and use our Services, to evaluate and improve our Services and business operations, and to develop new Services; to conduct surveys and other evaluations (such as customer satisfaction surveys); and for other research and analytical purposes. (Legal basis: our legitimate business interests and/or with your consent)
- Personalization: including to tailor content we send or display on our Websites and other Services; to offer location customization and personalized help and instructions; and to otherwise personalize your experiences. (Legal basis: our legitimate business interests and/or with your consent)
- Promotion: including to reach you with more relevant ads and to evaluate, measure, and improve the effectiveness of our ad campaigns; to send you newsletters, offers, or other information we think may interest you; to contact you about our Services or information we think may interest you; and to administer promotions and contests. (Legal basis: our legitimate business interests and/or with your consent)
- Protection: including to protect and secure our business operations, assets, Services, network, and information and technology resources; to investigate, prevent, detect, and take action regarding fraud, unauthorized access, situations involving potential threats to the rights or safety of any person or third party, or other unauthorized activities or misconduct; to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend, or protect our rights or interests, including in the context of anticipated or actual litigation with third parties. (Legal basis: our legitimate business interests and/or compliance with laws)
- Compliance: including relating to financial, tax, and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping, and legal functions; related to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy, or restructuring of all or part of our business; and including to comply with the law, our legal obligations and legal process, such as warrants, subpoenas, court orders, and regulatory or law enforcement requests. (Legal basis: our legitimate business interests and/or compliance with laws)
Aggregate and De-identified Information. We may de-identify personal information and create anonymous and aggregated data sets and reports in order to assess, improve, and develop our business, products, and Services; prepare benchmarking reports on our industry; and for other research, marketing, and analytics purposes.
DISCLOSURE OF PERSONAL INFORMATION
We may disclose the personal information we collect as set forth in this section.
- Service providers: to third-party service providers to provide us with services such as sales services, website hosting, payment processing services, and postal services.
- Business partners: to our business partners in order to perform services you request or authorize, including as set forth in this policy, in accordance with our commercial practices.
- Corporate transactions and restructuring: in connection with planning, due diligence, negotiation, and implementation of an actual or potential corporate reorganization, merger, sale, joint venture, transfer, investment transaction, or other disposition of all or any of our business, including in connection with any bankruptcy or similar proceedings.
- Advertising and analytics partners: to third parties that provide advertising, campaign measurement, online and mobile analytics, and related services to us (with your consent, where required by applicable laws). They may use this information to help us better reach individuals with relevant ads and to measure and improve our ad campaigns, or to better understand how individuals interact with our Services. In addition, these third parties may combine the information collected from us and our Services with information collected about you from third-party sites, apps, and services, in order to make inferences about you and your interests, to better tailor advertising and content to you across multiple sites, apps, and services, and to collect associated metrics.
- With consent: to third parties for other purposes, with your consent.
Aggregate and De-identified Information. We may share aggregate or de-identified information, which does not identify and is not linked or linkable to a particular individual, with third parties for research, marketing, analytics, and other purposes.
COOKIES AND SIMILAR TECHNOLOGIES
Our Websites may use first party and third-party cookies, pixel tags, plugins, and other tools, which are used in order to operate, secure, and ensure the proper functionality of the Websites, and are otherwise necessary to the operation of the Website (“necessary cookies”). On some of our Websites, we may also use these tools to gather device, usage, and browsing information in order to personalize and improve your experience while using the Websites, to improve and measure our advertising campaigns, and to better reach users with relevant advertising both on our Websites and on third-party websites.
Cookies. A cookie is a small file that we transfer to your computer’s memory through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Website, while others are used to enable a faster log-in process or to allow us to track your activities while using our Website. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Some of the Services may not work properly if you disable cookies.
Pixel Tags. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some websites to, among other things, track the actions of users of the websites (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Websites and response rates. We and our service providers also use pixel tags in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Log Files. Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system (OS) version, and internet browser type and version. This information is gathered automatically and stored in log files.
Managing Your Cookie Preferences. You can manage your cookie preferences for our Websites and opt out of certain cookies as explained below.
- Browser controls: You may block or disable cookies for the device and browser you are using, through your browser settings; however, certain features on our Websites may not be available or function properly if you block or disable cookies.
RIGHTS AND CHOICES REGARDING PERSONAL INFORMATION
In this section we describe the choices individuals have regarding our collection, use, and handling of their personal information.
Access, amendment, and deletion. You may request to review, make amendments, have deleted, or otherwise exercise your rights, under applicable privacy laws, over your personal information that we hold, subject to certain limitations under applicable law. You may submit a request to us related to your personal information by emailing us at [email protected] Please note that we may maintain copies of information that you have updated, modified, or deleted, in our business records and in the normal course of our business operations, as permitted or required by applicable law. Your access to or correction of your personal information is subject to applicable legal restrictions and the availability of such information. Further, we may take reasonable steps to verify your identity before granting such access or making corrections.
We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality that we owe to others, if we are legally entitled to deal with the request in a different way, or if relevant exemptions apply to some or all of the personal information subject to the request.
LINKS TO OTHER WEBSITES
We have implemented security measures to protect the personal information we collect from unauthorized access or disclosure, including technical and organizational security measures to safeguard and secure the personal information we collect. Despite this, data security cannot always be guaranteed. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us at [email protected]
CONTACT AND COMMENTS
European Union / United Kingdom Privacy Addendum
DATA CONTROLLER AND CONTACT INFORMATION
MUJEN is the data controller in respect of the personal data which we hold about you. As data controller, we are responsible for determining the purposes for which we use the information we hold about you.
Pursuant to the GDPR or equivalent local legislation, you may have the following rights, where applicable:
Subject Access. You can ask us to provide you with a copy of the personal data that we hold about you and a description of how we use your information.
Rectification. If you believe any information we hold about you may be inaccurate or incomplete, you can ask us to rectify these inaccuracies.
Erasure/To Be Forgotten. You can ask us to erase your information in certain circumstances: (i) the personal data is no longer necessary in relation to the purposes for which it was collected and processed; (ii) our legal grounds for processing is consent, you withdraw consent, and we have no other lawful basis for the processing; (iii) our legal grounds for processing is that the processing is necessary for legitimate interests pursued by us or a third party, you object to our processing, and we do not have overriding legitimate grounds; (iv) you object to our processing for direct marketing purposes; (v) your personal data has been unlawfully processed; or (vi) your personal data must be erased to comply with a legal obligation to which we are subject. Please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Data Portability. Where we process your information using automated means of processing based on your consent or for the purposes of performing a contract with you, you can ask us to supply such information to another party in a machine-readable format.
Restriction of Processing. You can ask us to restrict or suspend our processing of your information in certain limited circumstances: (i) for a period enabling us to verify the accuracy of your personal data where you have contested the accuracy of the personal data; (ii) your personal data has been unlawfully processed and you request restriction of processing instead of deletion; (iii) your personal data is no longer necessary in relation to the purposes for which it was collected and processed but the personal data is required by you to establish, exercise, or defend legal claims; or (iv) for a period enabling us to verify whether the legitimate grounds relied on by us override your interests where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us.
Objection to Procession. Where we process your information on the lawful basis of our legitimate interests, you have the right to object to us processing your information in certain circumstances: (i) our legal grounds for processing is that the processing is necessary for a legitimate interest pursued by us or a third party; or (ii) our processing is for direct marketing purposes. If you object, your personal data will subsequently no longer be used for direct advertising purposes (see Art. 21 (2) EU GDPR; see also Art. 18 UK GDPR) but will be retained on a suppression list.
Withdrawal of Consent. If we process personal data based on your express consent, you have the right to withdraw this consent at any time. We do not generally process personal data based on express consent (as we can usually rely on another legal basis). However, please note that this will not affect the lawfulness of any processing of your information carried out before you withdraw your consent. The consents obtained are independent from each other; therefore, you can often revoke one, without affecting the others. Revoking your consent may mean that we are no longer able to provide you with the same services.
Lodging of Complaint with Supervisory Authority. If you wish to submit a complaint or express any concerns about our use of your information, please contact us in the first instance. We will do our best to resolve your concerns to your satisfaction. However, if you feel that we have not addressed your concerns, please note that you have the right to make a complaint at any time to your local governmental or supervisory authority for data protection issues.
Individuals in the European Union or the United Kingdom may exercise any of these rights, free of charge, by emailing to [email protected] We will aim to respond to you within a month but this may be extended if the request is complex or we have received a number of requests from the same individual. If we have doubts about the identity of the requester, we may ask for more information to confirm your identity before responding to the request.