PRIVACY POLICY COJIMAR
This Privacy Policy describes how cojimar.com (the “Site” or “we”) collects, uses, and discloses your Personal Information when you visit the Site.
We strive every day to build trust with our users. The privacy rights of our users are an integral part of building that trust. This policy explains how we collect, use and share your personal information to better serve you and to improve our own business processes. By using our websites, facilities, services, mobile, telephonic, and other electronic and online applications (collectively, the "Services"), or by your use of any of our programs, content, materials, functionality (collectively, the “Content”), or by providing information to us in other ways, you agree to this policy.
AGE 21 AND OLDER
The Services offered by Cojimar Cigar are not directed to individuals under the age of twenty-one (21). If you are under twenty-one (21), you should not provide any personal information to us. We do not knowingly collect personal information directly from persons under the age of 21. Likewise, we do not knowingly collect information from children under 13. Visit the Federal Trade Commission website (www.ftc.gov) for more information about the Children’s Online Privacy Protection Act (COPPA).
CONTACT
After reviewing this policy, if you have additional questions, want more information about our privacy practices, or would like to make a complaint, please contact us by e-mail at Cojimarint@yahoo.com
PERSONAL INFORMATION WE COLLECT
See the list below for more information about what Personal Information we collect and why. Personal information we collect may include:
- Contact information, such as name, email address, postal address, phone number
- Demographic information, such as age
- Information about your interests and preferences
- Device identifiers and related information including internet protocol (IP) addresses, MAC addresses, browser and settings information, and information about how you interact with our website
- Information collected through cookies
- Information that may be accessible to us when you interact with us on social media sites, such as Facebook, Instagram, and Snapchat. Such information may include photos, lists of social media contacts, and similar information
- If you disclose any personal information relating to other people to us or our service providers, you represent that you have the authority to do so, and to permit us to use the information in accordance with this policy. Device information
- Purpose of collection: to load the Site accurately for you, and to perform analytics on Site usage to optimize our Site.
- Source of collection: Collected automatically when you access our Site using cookies, log files, web beacons, tags, or pixels.
- Disclosure for a business purpose: shared with our processor.
- Personal Information collected: version of web browser, IP address, time zone, cookie information, what sites or products you view, search terms, and how you interact with the Site.
INFORMATION YOU PROVIDE
When you sign up on our websites (the “sites”), communicate with us about a customer service issue, or to make other inquiries, we collect the content of those communications as well as any additional information about the method of communication such as phone, SMS, email, chat, or social media platforms. For example, if you email us, we will collect your email address, if you send us a text message, we will collect your phone number, and so on. Any such communication will be considered non-confidential and non-proprietary.
HOW YOUR PERSONAL INFORMATION MAY BE USED
We may use information we collect for various business purposes including:
- to deliver content (including advertising) correlating to your interests and browsing and usage history, both within Punch and other General Cigar websites and applications;
- to enable you to interact with us and other users through various means, such as through message boards, blogs and social media;
- to communicate about, and administer your participation in, special events, programs, surveys, sweepstakes, contests, and other offers or promotions;
- to evaluate and improve our business, including developing new products and services and analyzing the effectiveness of products, services, applications, and websites;
- to diagnose and address technical and service problems;
- to perform data analyses, including market and consumer research, trend analysis, demographic analysis, and financial analysis;
- to comply with applicable legal requirements and our policies; and
- to contact you via telephone, email, mail, or text. We will obtain your consent to contact you in the manner required by law.
COOKIES AND SIMILAR TECHNOLOGIES
When you use Cojimar cigars site, various technologies such as cookies, local shared objects, and web beacons (generally referred to as "Data Technologies"), are used to automatically collect information. "Cookies" are small identifiers sent from a web server that are stored on your device for the purpose of identifying your browser or storing information or settings in your browser. "Local shared objects," or "LSOs," sometimes known as Flash cookies, may be used to store your preferences or display content based upon what you have viewed on various websites to personalize your visit. A "web beacon" (e.g. Internet tag, pixel tag or clear pixel GIF), links web pages to web servers and their cookies, and may be used to identify you and monitor your activity on General Cigar sites. Anonymous advertising identifiers are increasingly being used on mobile devices in a manner similar to cookies. When we refer to Data Technologies, we are including all current and similar future technologies.
One or more Data Technologies may be used on Cojimar Cigar site and other websites and mobile applications (that may not be Cojimar Cigar site) used by us, by another party on our behalf, or by third parties in accordance with their privacy policies. Data Technologies may be used by us and others, on our behalf and on their own behalf, to collect information about you that may be added to your user profile and used to connect information about you from different sources, websites, devices, and mobile applications. This information may be used to more effectively market our products and services, and those of our affiliates and third parties, that may be of interest to you.
DO NOT TRACK
Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.
CHANGES
We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.
BEHAVIOURAL ADVERTISING
Advertising that is customized based on predictions generated over time from your visits across different websites, devices and mobile applications is sometimes called "online behavioral" or "interest-based" advertising. We may partner with advertising networks, which are companies that deliver targeted advertisements to consumers. They may provide customization, auditing, research and reporting for us, our affiliates and other advertisers. This data collection takes place both on Cojimar Cigar sites and on third-party’s websites and mobile applications, allowing Cojimar Cigar and our business partners to deliver targeted advertising, enhance marketing programs and help track the effectiveness of our targeting advertising. Our advertising networks also may use this information to determine or predict the characteristics and preferences of their respective advertising audiences and to measure the effectiveness of their advertising in accordance with their privacy policies.
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example:
- We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
- We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).
As noted above, you can set your device or browser to accept or reject most cookies, or at least notify you in most situations where the technology is offered. In addition, the advertising companies we engage may participate in one of the following self-regulatory programs for online behavioral advertising, which provide the associated user opt-outs:
- Network Advertising Initiative (https://www.networkadvertising.org/choices) (US Only)
- Digital Advertising Alliance (https://www.aboutads.info/choices/) (US Only)
You may set a Do Not Track preference in your Web browser. Please note that even if you reject such technology, you may continue to receive advertisements, but they will not be tailored to your specific interests.
For more information about how targeted advertising works, you can visit the Network Advertising Initiative's (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
- FACEBOOK - https://www.facebook.com/settings/?tab=ads
- GOOGLE - https://www.google.com/settings/ads/anonymous
- BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
- Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance's opt-out portal at: https://optout.aboutads.info/
LAWFUL BASIS
Pursuant to the General Data Protection Regulation (“GDPR”), if you are a resident of the European Economic Area (“EEA”), we process your personal information under the following lawful bases:
- Your consent;
- The performance of the contract between you and the Site;
- Compliance with our legal obligations;
- To protect your vital interests;
- To perform a task carried out in the public interest;
- For our legitimate interests, which do not override your fundamental rights and freedoms.
RETENTION
When you place an order through the Site, we will retain your Personal Information for our records unless and until you ask us to erase this information. For more information on your right of erasure, please see the ‘Your rights’ section below.
HOW WE STORE AND SECURE YOUR INFORMATION
The security of your personal information is important to us. We use commercially reasonable administrative, technical, personnel, and physical security measures designed to safeguard information about you in our possession against loss, theft and unauthorized use, disclosure, or modification. Of course, despite these measures, we cannot guarantee perfect security of networks, servers, and databases we operate or that are operated on our behalf. Please note that we will never email you asking for account information like your username, date of birth, credit card information, or other personal information. Finally, we will never email you with attachments that can be opened. If you received a suspicious email that appears to be from us, please contact us at Cojimarint@yahoo.com
Most if not all the personal information is stored in the United States. By providing us with any personal information, you understand that your information may be transferred, processed, or stored outside of your country of residence, including the United States, which may have a different data protection regime from the country in which you reside. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal information.
We will retain your personal information for as long as “reasonably necessary” for the specific purposes we have disclosed to you, such as to provide services to you (for example, as long as you maintain an online account with us) or as needed to fulfill our own obligations, such as preventing fraud, meeting regulatory requirements, resolving disputes, improving our services or maintaining security, and in each case, as consistent with applicable law. We may retain non-personal information that has been sufficiently aggregated or anonymized for a longer period.
HOW PERSONAL INFORMATION IS SHARED
Except with your consent or as described in this policy, we do not sell, rent of share your personal information with third parties. We may share your personal information with our affiliated companies and brands. We also may share your personal information with certain third parties that provide services to you or us, with promotional partners, with social media companies, or with other third parties as needed to carry out our business, or to comply with a legal obligation. We also may share information about you if necessary or appropriate, in our good faith judgment, to comply with laws or regulations, or in response to a valid subpoena, order, or government request, or to protect the operations, privacy, safety, property or rights of Cojimar Cigards or others.
Service providers
We use third parties to provide certain services to you or us. These services include: operating or hosting the website; managing customer information; fulfilling promotions; sending marketing communications; conducting surveys; analyzing data; or providing network security, accounting, auditing, and other services. These service providers are not authorized to use or disclose personal information you provide to us for any purpose other than to perform the services designated by us.
Public posting and social sharing
When you post public comments on our site or on public forums like social media sites, your comments are accessible by other members of the public.
Social media logins and other integrations
When you log into your customer account using your social media account credentials, or use other social media services with us, your personal information will be disclosed to the social media account provider in connection with your login. By doing so, you authorize us to facilitate this sharing of information, and you understand that this sharing is governed by the social media site’s privacy policy that you used to log into your account.
AUTOMATIC DECISION-MAKING
If you are a resident of the EEA, you have the right to object to processing based solely on automated decision-making (which includes profiling), when that decision-making has a legal effect on you or otherwise significantly affects you.
We [DO/DO NOT] engage in fully automated decision-making that has a legal or otherwise significant effect using customer data.
Services that include elements of automated decision-making include:
- Temporary blacklist of IP addresses associated with repeated failed transactions. This blacklist persists for a small number of hours.
- Temporary blacklist of credit cards associated with blacklisted IP addresses. This blacklist persists for a small number of days.
GDPR
If you are a resident of the EEA, you have the right to access the Personal Information we hold about you, to port it to a new service, and to ask that your Personal Information be corrected, updated, or erased. If you would like to exercise these rights, please contact us through the contact information above. [OR INSERT ALTERNATIVE INSTRUCTIONS FOR SENDING ACCESS, ERASURE, CORRECTION, AND PORTABILITY REQUESTS]
Your Personal Information will be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States.
COMPLAINTS
As noted above, if you would like to make a complaint, please contact us by e-mail or by mail using the details provided under "Contact" above.
If you are not satisfied with our response to your complaint, you have the right to lodge your complaint with the relevant data protection authority. You can contact your local data protection authority, or our supervisory authority here: [Add contact information or website for the data protection authority in your jurisdiction. For example: https://ico.org.uk/make-a-complaint/]