Last updated: November 9, 2023
Effective: November 9, 2023
Brother Justus Whiskey Company (“we”, “our”, or “us”) understands the importance of privacy, and we respect and take responsibility for protecting personal and financial information. This Privacy Policy explains how we collect and process personal information of our website users, business contacts, and customers. We refer to our website and other publicly available information systems as our Services. This Privacy Policy does not cover our processing of personal information of employees, applicants for employment, former employees, or emergency contacts or benefits beneficiaries of such individuals.
We will update this notice from time to time, as our privacy practices change, to ensure it accurately describes how we use personal information. When we do so, we will update the dates above. We recommend that you review this Privacy Policy for the latest information. If we change our practices in a material way, we will provide appropriate notice to you, usually through an e-mail message or through a banner or pop-up on our Services.
1. How We Use and Share Personal Information
We use and share personal information (information relating to an identified or identifiable person or household) as described below. Please also refer to the content following the table for more information about certain terms used in the table.
All users of our Services. We collect Activity Information (see below), interest information, and the user’s report of whether they have attained age 2. We use this information for Service Analysis (see below), marketing, and to prevent use of our Services by those who have not attained the legal drinking age. We collect this information directly from the user and by observing users’ activities while they use our Services. We share this information with analytics providers and behavioral advertisers.
Users who use the store locator tool. We collect location information from individuals who use our store locator tool to identify nearby stores that carry our products and for other marketing purposes. We may collect this information directly from the user or indirectly from the user’s device or network information. We do not share this information with third parties, except as set forth in section 2, below.
Individuals who send us correspondence. We collect name and contact information (including email address) as well as the contents of the correspondence. We use this information to respond to the correspondence. We collect this information directly from the sender. We do not share this information with third parties, except as set forth in section 2, below.
Users who sign up for product updates. We collect these users’ email addresses to provide them updates as they have requested. We collect this information directly from the user. We do not share this information with third parties, except as set forth in section 2, below.
Individuals who participate in marketing events. From individuals that participate in marketing events and who have provided us with consent for us to use their name and likeness for our marketing purposes, we collect name and contact information and pictures (or videos) and use them for our marketing purposes. We collect this information directly from the individual and share the information publicly.
Our marketing business contacts. We maintain a database of marketing business contacts that includes each included individual’s name and business contact information. We use this data for marketing purposes. We collect it directly from the included individuals as well as from third parties that provide this kind of information. We do not share this information with third parties, except as set forth in section 2, below.
In the foregoing bullet points, the following terms have the meanings set forth below:
Activity Information. When you visit our Services, we collect information such as the IP address of the device you are using to connect to the Internet, the browser and version used, the type of operating system you have, pages and content viewed, time and duration of visits, and whether advertisements were clicked. This information helps us provide you with a more effective online experience. To facilitate the collection of this information we may use cookies, pixel tags, or other similar technologies.
Service Analysis. We use the term “Service Analysis” to refer to a variety of closely related purposes, including security purposes, to understand how individuals use our Services, to detect improper usage, to identify technical problems with the Services, to improve the Services’ design and functionality, to understand the demographics of our Services’ users, and to evaluate the effectiveness of the Services.
Please note that, in addition to using personal information as reflected in the table above, we may also use personal information to defend or assert legal claims with respect to which the personal information is relevant.
2. Personal Information Disclosure and Sharing
In addition to the sharing with the third parties described in the table above, we may also share your information with:
Service providers. We share your personal information with third parties that provide services to us. We engage these kinds of third parties with contracts that require them to use your personal information only to deliver the services for which we have engaged the third party (or as may be otherwise required or permitted by law). These kinds of third parties may provide business, professional, administrative, or technical support functions for us, such as payment processing, billing, data storage, quality assurance, and marketing.
Legal compliance recipients. We disclose personal information to the courts, the government, law enforcement agencies, litigants, and similar recipients to comply with applicable legal requirements.
Successors. We may disclose personal information associated with a part of our business to a buyer, potential buyer, or other successor to our business. Such disclosures enable the recipients to evaluate our business.
We also may disclose personal information to third parties with your consent or at your direction.
3. Personal Information Security and Location of Processing
Protecting your personal information is important to us. To protect your personal information, we have enacted physical, electronic, and procedural safeguards that meet applicable law. These measures include a wide variety of computer safeguards as well as secured files and buildings.
Please be aware that we are based in the United States and process personal information on systems within the United States.
4. Retention of Personal Information
We retain personal information for as long as is necessary for the purposes set out in this Privacy Policy, or as required by law. What is necessary depends on the context and purpose of processing. We generally consider the following factors when we determine how long to retain personal information:
Retention periods established under applicable law
Industry best practices
Whether the purpose of processing is reasonably likely to justify further processing
Risks to individual privacy in continued processing
Applicable data protection impact assessment
IT systems design considerations/limitations
The costs associated with continued processing, retention, and deletion
5. Children’s Privacy
Our Services are not intended for individuals who are under the age of 21, and should not be used by them. Please do not access or use our Services if you are under 21 years of age.
6. Your Privacy Rights
A. Outside the UK/EEA
For individuals who do not reside in the United Kingdom or European Economic Area: you may have rights relating to your personal information under the law of the jurisdiction in which you live. These may include rights such as: (1) the right to access your personal information; (2) the right to correct inaccuracies in your personal information; (3) the right to request deletion of your personal information; and (4) the right to obtain a portable copy of your personal information. To exercise your state-law rights, please submit a request by contacting us through any of the means outlined below.
Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. We will verify that any requests from persons other than you have your legal authorization. You may also make a request on behalf of your child.
Your request must:
Include your first and last name, e-mail address, telephone number, and a description of your request;
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Please note that you may also delete your account on the Services from within our mobile and web applications. This will also eliminate your personal information from our Services.
We do not take in action in response “do not track” or “global privacy control” signals transmitted by web browsers.
Appeal process. You may appeal our decision with respect to your request to exercise your legal rights with regard to your personal information. To submit such an appeal, you may contact us using the contact information below. You must include sufficient information to allow us to reasonably verify your identify, reference the date and time of your previous request to exercise your legal rights, and explain why you believe our decision was insufficient or improper. We will ordinarily respond to your appeal in accord with the timelines set forth in the applicable state’s law.
B. Inside the UK/EEA
If you live in the European Economic Area or the United Kingdom, you may have the following rights regarding your personal data:
Access/Data Export. You may have a right to access the personal data we process and to request it in a common portable format of our choice.
Rectification. You may request that we correct any personal data that you believe is inaccurate.
Deletion. You may request that we delete your personal data. We may delete your data entirely, or we may anonymize or aggregate your information such that it no longer reasonably identifies you.
Restriction of Further Processing. You may request that we restrict the processing of personal data under certain circumstances. For example, you may make this request if you withdraw consent you gave us previously and we have no other legal basis for us to retain it, or where you object to our use of your personal data for particular legitimate business interests.
Objection. You may have the right under applicable law to object to any processing of personal data based on our legitimate interests. We may not be required to cease or limit processing based solely on that objection, and we may continue processing where our interests in processing are appropriately balanced against individuals’ privacy interests. You also have the right to lodge a complaint with a supervisory authority. In addition to the general objection right, you may have the right to object to processing:
▪ for profiling purposes;
▪ for direct marketing purposes (we will cease processing upon your objection); and
▪ involving automated decision-making with legal or similarly significant effects (if any).
7. Consumer Health Data Privacy Policy
This section provides information about our processing of consumer health data.
A. Our Consumer Health Data Processing
We collect and process consumer health data as described in the table below:
Please note that we do not share consumer health data with any affiliates.
B. Your Consumer Health Data Rights
Depending on the jurisdiction where you live, you may have certain rights with regard to your consumer health data. These include the right to withdraw your consent to processing, to request the deletion of your consumer health data, and to confirm whether we collect, share, or sell your consumer health data. To exercise these rights, you can contact us as set forth in Section 8, below. When you contact us, please identify yourself and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Only you may make a request related to your consumer health data. We will verify your identity before processing any request.
You may also appeal the action we take in response to your request and may do so using the contact information below. When you contact us to appeal, please tell us why you believe our response to your request was insufficient or improper. We will respond to your appeal in accord with the timelines set forth in applicable law.
8. Contacting Us
To exercise your rights, submit an appeal, or for privacy-related inquiries, you may contact us via our website at https://brotherjustus.com/contact, by email at guestservices@brotherjustus.com, by telephone at 612-886-1658, or via postal mail at:
Brother Justus Whiskey Company
3300 5th Street Northeast
Minneapolis, MN 55418