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CBT Group LLC – Data Privacy Policy
Last Updated and Effective: December 1st, 2020
This Privacy Policy (“Policy”) describes the privacy practices of CBT Group, LLC and its affiliates, subsidiaries, and franchisees (“Company”, “we”, and “our”) with respect to data that we collect through websites operated by us (“Websites”), through our social media pages (such as https://www.facebook.com/citybrewtours/, https://www.instagram.com/citybrewtours/, and others , through email messages we send to you that link to this Policy, and through other services (“Services”) provided by us both online and offline. “You” or “user” refers to any individual who visits or otherwise uses the Websites, social media pages, or Services, or purchases a product or service from us.
Privacy laws and guidelines are part of a constantly changing environment. We reserve the right, at our discretion, to change, modify, add, or remove portions of this Policy at any time. All changes will be effective immediately upon posting to the Websites. Material changes will be conspicuously posted on the Websites or otherwise communicated to you.
WHAT PERSONAL INFORMATION DO WE COLLECT?
Personal Information You Provide Us
You can visit our Websites without submitting personal information. If you elect to provide data that personally identifies you (“Personal Information”) such as your first and last name, email address, birth date, mailing address, phone number, credit card information, or other details to help you with your experience, we will collect, use, and share such Personal Information pursuant to this Policy and applicable law.
Franchise Information. If you submit a Franchise Inquiry Form, we will collect your name, proposed city/location, phone number, e-mail address, certain financial information, and employment/industry experience information.
Order & Payment Data. When you make a purchase online, we use a PCI-compliant payment processor vendor to help us facilitate payment. We have contracted with our vendor to collect your personal information to process your payment. You can obtain more information on their data privacy and security practices at https://squareup.com/us/en/legal/general/privacy. Company does not receive your credit card, debit card or other financial information when you make a payment- such information is provided directly to our payment processor vendor. However, Company does receive information about your purchase and your contact information (e.g. name, email address, mailing address, phone number) and will keep a record of your purchases,
Marketing Communications; Email Opt-Out. If you provide your email address to us or subscribe to our newsletters, you understand that we may send you emails, including marketing emails. We may use third-party providers to deliver communications to you. You may opt-out of marketing emails by using the unsubscribe link in the email or contacting us at [email protected] with “Unsubscribe” in the subject line. Opting out of marketing communications does not opt you out of communications about your transactions with us.
Text Messaging In addition to the methods mentioned above, we may also use text messaging as a means of communication with you. If you provide us with your mobile phone number, you understand and consent that we may send text messages to that number for various purposes, including but not limited to order updates, marketing promotions, and customer service notifications. Standard messaging rates or other charges may apply depending on your mobile carrier plan. You can opt-out of receiving text messages at any time by replying “STOP” to the message or by contacting us directly at [email protected]. Please note that opting out of text messages does not opt you out of other communications, such as emails or phone calls, regarding your transactions with us.
Applying to Work with Company. To submit job application materials online to work with Company, you may be redirected from our Site to a website operated by Indeed. You may be required to create an account with Indeed. We encourage you to review the terms and privacy policy posted on Indeed’s website since this Policy does not govern your use of that website. If you send us your job application materials directly, we will only use and share those job application materials to evaluate your qualifications to work with Company and its affiliates.
Feedback. When you provide comments or feedback about our products, Services, or the content on the Websites or Social Media Pages (“Feedback”), we will not treat that Feedback as confidential and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.
Data Automatically Collected
Cookies & Other Tracking Technologies.
What types of online tracking mechanisms do we use? We may use cookies, web beacons, pixel tags and other tracking technologies (collectively “Cookies“) on our Websites.
What are cookies and web beacons / pixel tags? A cookie is a small text file that our Websites save onto your computer or device when you use the Websites that provides us certain information about your activities. Cookies allow the Websites to remember your actions and preferences and recognize you or your browser, along with some information you provided. Web beacons / pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.
Why do we collect Cookies? We use Cookies to:
Websites and to help us improve our Websites; and
What type of information do Cookies collect? The Cookies on our Websites may collect information such as:
We may combine information from Cookies with other Personal Information.
How long do Cookies last? A Cookie can either be a “session” Cookie or a “persistent” Cookie. Session Cookies exist only for so long as you are visiting the applicable website and are typically deleted when you exit your web browser. Persistent Cookies exist for a set period of time, for example, up to several months or years. Each time you visit a website that has implemented a persistent Cookie, the persistent Cookie is renewed and that Cookie will remain active until its predetermined expiration date. You can manually delete persistent Cookies through your browser settings.
First and Third-party Cookies. Cookies may either be “first-party” or “third-party” Cookies. A first-party Cookie allows your web browser to talk to the actual website that you are visiting (i.e. our Websites). A third-party Cookie allows your web browser to talk to a third-party website, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. We may not have control over how a third-party uses information collected through third-party Cookies.
How do you manage Cookies or opt-out? Most browsers automatically accept cookies. You can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Websites. Not all features or functions of the Websites may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Websites.
CALIFORNIA’S “DO-NOT-TRACK” REQUIREMENT. WE CURRENTLY DO NOT HONOR “DO NOT TRACK” REQUESTS.
Google Analytics. We use Google Analytics to collect and process information about your use of the Websites. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Websites.
We may also implement additional add-on services to Google Analytics, such as Demographics and Interest Reporting and Remarketing with Google Analytics. Demographics and Interest Reporting uses cookies to collect data about our Site traffic by tracking users across websites and across time to provide us with analytics on our user base. Remarketing with Analytics uses Google Analytics cookies to serve advertisements to you across the Internet based on your visits to the Website.
To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on “How Google uses data when you use our partners’ sites or apps.” You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit Google Analytics Cookie Usage on Websites.
Online Behavioral Advertising. We use third parties and/or service providers to provide interest-based advertising services. These services may serve advertisements on our behalf that are customized based on predictions about your interests generated from your visits to websites (including our Websites) over time and across different websites. The data collected may be associated with your Personal Information. These advertisements may appear on the Websites and on other websites, and may be sent to you via email.
We use Google Ads to serve ads across various websites. Google uses Cookies to collect data about your visits to the Websites to generate targeted advertisements to you on other websites that you visit. To opt-out of this type of advertising by Google, to customize your ad preferences, or to limit Google’s collection or use of such data, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructions. Opting out will not affect your use of the Websites.
To change your preferences with respect to certain online ads or to obtain more information about ad networks and online behavioral advertising, visit National Advertising Initiative Consumer opt-out page or the Digital Advertising Alliance Self-Regulatory Program. Changing your settings with individual browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads. Opting-out of targeted advertising does not opt you out of all ads, just those targeted to you.
Social Media.
We are active on social media, including Facebook, Twitter, and Instagram. Anything you post on social media is public information and will not be treated confidentially. We may post (or re-post) on the Websites and our social media pages any comments or content that you post on our social media pages.
We may use advertising networks and services offered by social media platforms to deliver advertising content. Use of these services requires social media platforms to implement cookies or pixel tags to deliver ads to you while you access the Websites and sharing information to the social media platforms. If you have social media accounts but you do not want a social media platform to collect or receive data about you, you can visit the social media platform privacy policies to review your options regarding data collection with the social media platform itself.
Your use of social media pages is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We may use the information we collect from you in the following ways:
○ To verify that your age allows you to obtain Services from us.
○ To personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
○ To evaluate and improve our business, including developing new products and services and analyzing the effectiveness of products, Services and Websites. Through email communications, telephone calls, and/or focus groups. For our everyday business purposes, such as establishing and managing your customer account, responding to your inquiries, providing products and/or services you request, processing and collecting payments and providing customer support.
○ To administer a contest, promotion, survey or other site feature.
○ To quickly process your transactions.
○ To send periodic emails regarding your order or other products and Services.
○ To comply with legal recommendations, applicable legal requirements and our policies and practices.
○ To protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Websites, or to other users of the Websites.
○ To seek business, financial or legal advice, and to respond to other legal requests.
UPDATING OR DELETING YOUR PERSONAL INFORMATION
If you would like us to update or delete your Personal Information, you can email the following information to [email protected]:
○ First Name
○ Last Name
○ Email Address (if different from email address sent from)
○ Phone Number
We will respond back to you within 60 days, unless otherwise required by applicable law.
RETENTION OF PERSONAL INFORMATION
We will keep Personal Information for the period necessary to fulfil the purposes described in this Policy, unless a longer retention period is permitted or required by law.
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. If a breach of your Personal Information occurs, we will notify you of the breach if required under applicable law.
YOU UNDERSTAND THAT NO DATA TRANSMISSION OVER THE INTERNET OR DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION AND YOU PROVIDE PERSONAL INFORMATION AT YOUR OWN RISK.
THIRD PARTY DISCLOSURE
We do not sell, rent, or lease Personal Information to any third party. We may share Personal Information with the following parties, in compliance with applicable laws:
Employees, franchisees, and affiliates. We may share Personal Information with our employees, franchisees, and affiliates who have a need to know the information for business purposes. If we so do, their use and disclosure of your personal information will be subject to this Policy.
Third-Parties and/or Service Providers. We may share Personal Information with third parties and/or service providers that provide services for us. For example, we may share Personal Information with vendors to help us host and manage the Websites; provide targeted advertising and other marketing; improve the content and functionality of the Websites; perform data analysis and statistical analysis; troubleshoot problems with the Websites; provide payment processing services and online storefronts; and provide support or provide the security of the Websites.
Professional Advisors. We may share Personal Information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to us.
Change in Ownership. In the event Company is the subject of a change of control or in the event the Websites or Social Media Pages change ownership, in whole or in part, or in the event of a bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent owner(s).
Other. We may share Personal Information with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
USE AND DISCLOSURE OF NON-PERSONAL INFORMATION
Company may collect, use, share, transfer and otherwise process de-identified and aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. Company is the sole and exclusive owner of such de-identified and aggregated information, including if Company de-identifies Personal Information so that it no longer considered Personal Information under applicable data protection laws.
ACCESS FROM OUTSIDE THE UNITED STATES
If you access the Websites from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by the in other jurisdictions.
THIRD PARTY WEBSITES
The Websites may link to, or be linked to, websites not controlled by us. We are not responsible for third-parties’ privacy policies or practices. This Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.
CALIFORNIA RESIDENTS
Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to obtain: (a) a list of all third parties to whom we may have disclosed your Personal Information within the past year for direct marketing purposes, and (b) a description of the categories of Personal Information disclosed, by emailing us at [email protected].
CHILDREN’S INFORMATION
We sell age restricted products and therefore do not knowingly collect, use, or share Personal Information from children under 13. If a parent or legal guardian learns that their child provided us with Personal Information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Information.
CONTACT US
If you have any questions or concerns regarding this Policy, contact us at by email at [email protected], by phone at (888) 623-8687, or by post mail at 675 VFW Pkwy, PMB 257, Chestnut Hills, MA 02467.
