Proximo Spirits Privacy Policy

Proximo Spirits, Inc. (“Proximo”, “we”, “our” or “us”) respects your personal privacy and takes it seriously.  We have issued this Privacy Policy to inform you of our procedures and policies regarding the collection, disclosure and use of Personal Information (as defined below) we receive or collect when you interact with our brands and with us. The term “Services”, as used in this Privacy Policy, refers to the Proximo website, as well as each of its websites, including the following list of brand websites (collectively, the “Sites”), and all Proximo products or services offered by Proximo online or offline:

  • Jose Cuervo
  • 1800
  • Bushmills
  • The Kraken
  • Pendleton

  • Maestro Dobel
  • Gran Centenario
  • Tincup
  • Three Olives
  • Hangar 1
  • Boodles
  • Stranahan’s
  • The Sexton
  • Old Camp
  • Wolf Moon
  • Black Dirt
  • Creyente
  • 400 Conejos
  • Owney’s
  • Matusalem
  • Agavero
  • Bentwing

Please note that this Privacy Policy is intended for United States (“U.S.”) consumers.  This Privacy Policy applies to information that you provide to us (or permit third party sites to provide to us) or that we collect through the Services.  This Privacy Policy may from time to time be updated in the future. We will notify you of any material changes by posting the new Privacy Policy through the Services and/or by providing alternative notice appropriate to the circumstances.  Proximo recommends that you consult this Privacy Policy periodically for any changes.

By using our Services you are consenting to our Processing (as defined below) of your information as described in this Privacy Policy now and as revised in the future by Proximo.  For purposes of this Privacy Policy, “Processing” means using cookies on a computer or using, reviewing or otherwise interacting with Personal Information in any way, including, storing, deleting, collecting, using, combining and disclosing Personal Information and transferring it to the United States government or other governments.  If you do not agree to the terms of this Privacy Policy, please do not use the Services.

What This Policy Contains

How We Collect and Use Your Personal Information

Information That You Provide or Authorize Us to Collect

As you use the Services, we may collect or you may provide information that identifies, relates to or directly or indirectly describes you or your household and devices (“Personal Information”).  Personal Information includes data such as your name and email address, but is not limited to this information.  For example, when you contact our customer support services, this may include a record of communication correspondence and associated contact information. 

Social Networking Details.  Where applicable, you may connect with us or sign up to receive information from us through third-party social networking sites (each, a “Social Networking Site”).  If you decide to interact with the Services via a Social Networking Site, we may extract the Personal Information you have provided to such Social Networking Site (such as your “real” name, email address and other information you choose to provide or make available via the Social Networking Site, such as phone number, age and transaction data); the information we extract may depend on the privacy settings you have with the Social Networking Site.

Purchase and Product Usage Details.  If you choose to purchase any goods through the Services, we or our third party service providers may collect Personal Information from you, including financial information related to your method of payment, to facilitate your payment for such goods, and information about your use and purchase of our products.

Information You Provide When You Communicate with Us and Otherwise Use Our Services.  We collect information that you provide when you use the Services, including when you sign up to receive marketing communications, communicate with us online or interact with us at events.  The Personal Information we may collect may include personal identifiers and contact information including your name, contact details, birthday and zip code, and details like your individual communication and privacy preferences. 

Device Information Collected with Your Consent.  With your permission, and only if you confirm that you are age 21 or older, we may access information from your device, such as device ID.

Certain information we collect may be Personal Information depending on how it is combined with other identifiers (for example, your Internet Protocol (“IP”) address when combined with other data that enables us to identify you or your household).  The same pieces of information may not be Personal Information when taken alone or combined only with non-identifying information.

Information Provided by Third Parties

We sometimes work with third parties who provide us with personal information, such as event organizers and event sponsors who collect and share Personal Information with us about event participants.  For example, if you attend a concert or festival hosted or sponsored by one of our partners, they may share data with us including contact details, other personal identifiers or device identifiers, product preferences and communications and privacy preferences.  We also work with vendors who provide services to help us manage coupons, rebates and similar offerings and receive personal information regarding individuals who voluntarily participate in those programs.

Information We Collect Automatically

Our Services may require additional information or permissions from your device or browser in order to function effectively.

Log Data.  When you use the Services online, for example, in accessing our Services through a Social Networking Site, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”).  This Log Data may include information such as:

  • your computer’s IP address;
  • the browser type or the website you were visiting before you came to the Service;
  • pages of the websites involved in the Service that you visit and the time spent on those pages;
  • information you search for on our Sites; and
  • other details about your interaction with our Services, such as access times and dates, your device’s operating system, software version and unique advertising identifier and other statistics.

We use this information to monitor and analyze use of the Services and for the Services’ technical administration, to increase the functionality and user-friendliness of our Services and to better tailor the Services to our visitors’ needs.  For example, some of this information is collected so that when you use our Services again, it will recognize you and serve advertisements and other information appropriate to your interests, as described in more detail below.  We also use this information to verify that visitors to the Services meet the criteria required to process their requests.  We may aggregate, analyze and evaluate Log Data, and such aggregate data is not treated as Personal Information.

Cookies and related technologies.  Like many websites and applications, our Services use “cookies” and mobile advertising identifiers to collect information.  For information regarding your rights and preferences regarding the use of cookies, see “Your Rights and Privacy Preferences” below. 

  1. What Are Cookies?

A cookie is a small file that a website can send to your browser, which may then store it on your system or your mobile device.  Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.  Cookies set by the website owner (in this case, Proximo) are called “first party cookies”.  Cookies set by parties other than the website owner are called “third party cookies”.  Third party cookies enable third party features or functionality to be provided on or through the website (e.g., advertising, videos and website analytics services).  The parties that set these third party cookies can recognize your devices (which can include computers, tablets, phones, smart TVs, etc.) both when they visit the Sites and when they visit certain other websites.

  1. How Long Do Cookies Last?

Cookies can remain on your device for different periods of time.  Some cookies, called “session cookies”, exist only while your website browser is open and are deleted automatically when you close your browser.  Other cookies are semi-permanent cookies or “persistent cookies” that survive after your browser is closed and can be used by websites to recognize your device when you later reopen your browser and browse the Internet again.

  1. How Does Proximo Use Cookies?

We use first party cookies to allow us to understand what areas of the Sites are of interest to you so we can better provide you with tailored information from the Sites.  We use first party cookies to collect data such as information about your web browser and operating system, the frequency of your visits, your actions on the Sites and, if you arrived at the Sites from a non-Proximo website, the URL of that website.  Third party web analytics providers may collect and analyze the data we obtain from our cookies to tell us how you use the Sites.

Proximo may also use first party cookies when you register for some parts of the Site, such as our web programs.  In this case, a cookie will store useful information, including your Personal Information, which enables the Site to remember you when you return to visit.  Only we can read the information we gather from the cookies we place on your system.

We use the below specific types of cookies served through the Sites:

  • Strictly Necessary – These cookies are essential to enable you to navigate our Sites and use related features.

  • Performance Cookies – Performance cookies collect information about how visitors use a website, such as the pages that visitors go to most often, and whether they get an error messages from our web pages.  We use this information so we can improve and enhance our Sites.  These cookies do not collect information that allows us to specifically identify you; they only provide aggregated information about our visitors.  Most performance cookies are persistent.

  • Functionality Cookies – These cookies are used to allow and enhance certain functionality, such as remembering your language preferences on our Sites or enabling your shopping cart to work if you use our brands’ online shops.

  • Targeting Cookies – These cookies are used to deliver relevant advertising and other tailored content, including by leveraging social media, and selecting advertisements based on your interests and interactions with the Sites.  Targeted cookies are also used to limit the number of times you see an advertisement, to help measure the effectiveness of a campaign and to enable you to share pages and content through third-party social networking sites.

  1. Related Technologies Proximo May Use

The Sites may also use “Web beacon” technologies.  When you access pages with a Web beacon, an anonymous notice of that visit is generated which may be processed by us or by our analytics vendors.  These Web beacons work in conjunction with cookies to let us know what portions of the Sites are of interest to you and to help us provide you with tailored information from the Sites.  If you choose not to accept cookies, Web beacon technologies will still detect anonymous visits, but the notices they generate cannot be associated with other information.

We will collect your IP address when you visit the Sites.  From this, we may be able to identify the approximate geographic location of the device from which you are visiting the Sites and the domain that it is using to access the Internet.  If you are visiting the Sites from a shared business IP address, we will use this information to identify the company from which you are visiting and to pre-populate the web-forms that you use on the Sites with information about your company and the country from which you are visiting the Sites.

How We Use Your Personal Information

We may use the Personal Information described above to provide Services and to support our business functions. For example, we may use this information for the following purposes:

Provide, Improve and Develop the Services.

  • Provide the Services to you.
  • Store information about your use of the Services and recognize you when you return to our Services.
  • Provide customer service.
  • Operate, protect, improve and optimize the Services and the user experience, such as by performing analytics and conducting research.
  • Communicate with you and send you information by email, postal mail, telephone, text message or other means about our products, services, contests, support messages, updates, security alerts and account notifications.  If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or update your user preferences information (see “Your Rights and Privacy Preferences” below).
  • Make your user experience easier, more personalized, more enjoyable and more efficient.
  • Address problems with and improve our products, brands, services and technologies, and develop new products and services.
  • Enable certain features of the Services in order to better understand how you interact with the Services and monitor aggregate usage. 
  • Enable you to share information to social media.
  • Administer and fulfill our contests and other promotions.
  • Help us learn more about your product preferences.
  • Fulfill your purchase requests and process refunds.
  • Fulfill any contract we have with you.
  • Operate, protect, improve and optimize the Services and experience, and personalize and customize your experience.  We draw inferences from your interactions with the Services in order to help us tailor our advertising to your interests.

We process this information due to our legitimate interest in improving the Services and our users’ experience, and, where necessary, for the adequate performance of any contract with you.

Create and Maintain a Trusted and Safe Environment.

  • Prevent, detect, mitigate and investigate fraud, security breaches and activities that are or potentially may be prohibited or illegal.
  • Conduct security investigations and risk assessments.
  • Verify or authenticate information.
  • As we believe to be required or appropriate to protect the rights, property, safety and security of Proximo and our employees, customers and others.
  • As we believe to be required or appropriate under applicable law to respond to requests from government authorities and to comply with legal process, investigations or regulatory or governmental inquiries or for other legal or regulatory purposes.
  • Comply with our legal obligations.
  • Resolve any disputes with any of our users or customers, and enforce our agreements with third parties.
  • Enforce our Terms of Service or other policies.

We process this information given our legitimate interest in protecting the Services, to measure the adequate performance of any contract with you, and to comply with applicable laws.

Provide, Personalize, Measure and Improve our Advertising and Marketing.

  • Send you promotional messages we believe may be of interest to you, including marketing, advertising and other information that may be of interest to you based on your preferences (including information about Proximo or its authorized third party campaigns and services) (for information about how to change your communications preferences, please see the “Your Rights” section below).
  • Personalize, measure and improve our advertising.
  • Administer referral programs, rewards, surveys, sweepstakes, contests or other promotional activities or events sponsored or managed by Proximo or its authorized third parties.
  • Analyze your characteristics and preferences (based on the information you provide to us, your interactions with the Services, information obtained from third parties and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.

We will process your Personal Information for the purposes listed in this section due to our legitimate interest in undertaking marketing activities to offer products or services that may be of interest to you. 

Other Purposes.

  • When you consent to it.
  • When it is necessary to protect your vital interests or that of another person.
  • When it is necessary to carry out your instructions.
  • When it is necessary for the performance of a task carried out in the public interest.
  • When it is in our legitimate interests.  Legitimate interests are our business or commercial reasons for using your data, such as: (i) keeping our records up-to-date; (ii) providing the Services to you; (iii) maintaining or administering the Services; (iv) performing business analyses or for other internal purposes to improve the quality of our business and the Services we offer; (v) prevention of fraud and financial crime to protect the public; (vi) communicating with you concerning programs or services consistent with our obligations to provide those programs or services or otherwise; and (vii) participating in litigation, investigations, regulatory or governmental enquiries or for other legal or regulatory purposes involving our customers who use or have used our Services or other third parties. 

Legal Basis for Use of Your Personal Information

Other than as described above, the legal basis for using your Personal Information as set out in this Privacy Policy are as follows:

  1. when our use of your Personal Information is necessary to perform our obligations under any contract with you (for example, to comply with the Terms of Service);
  2. when you have provided us with your consent to do so, including with respect to the advertising and marketing materials delivered via our Services that are tailored to you and your preferences; or
  3. where (a) and (b) do not apply, but our use of your Personal Information is necessary for our legitimate interests or the legitimate interests of others.  Our legitimate interests are to:
  1. develop and improve our business, including funding our business by use of advertising revenues;
  2. operate, maintain and improve the Services and our marketing optimization efforts;
  3. understand the way in which the Services are used; and
  4. for internal administrative purposes.

Information Sharing and Disclosure

Third-Party Advertisers.

Aggregate Information and Other Data Shared with Advertisers to Provide you with Personalized Advertisements.  We may share aggregated information that does not include Personal Information with third parties.  We may also disclose device identifiers, advertising identifiers and Log Data to third parties.  This information is used for industry analysis, demographic research and other purposes.

In particular, we share device and advertising identifiers and Log Data and aggregated information with third party advertising and technology companies.  The data we share with them includes data about your device, location and use of our Services, including IP address, device identifiers and information, and purchase data.  Such information may be used to send you personalized advertisements for products and services that are relevant to your interests. 

In some cases, these third parties will also use the data that they collect for their own purposes, such as aggregating your data with other data they hold in order to inform advertising related services provided to other clients.  These third parties may place a cookie on your browser, or use a web beacon, to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests.  That advertising may appear across the Services, or on other websites, apps and services. 

You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.  On mobile devices you can reset your settings by taking the following steps (for iOS: https://support.apple.com/en-us/HT202074 and for Android: https://support.google.com/ads/answer/2662922?hl=en).  If you do not accept cookies, however, you may not be able to use all portions of the website or all functionality of our Services, and advertising will no longer be personalized based on your interests.

For example, we may collect and share the advertising identifier associated with your device (such as the Apple IDFA and Android Advertising ID) with advertisers.  An advertising identifier is an alphanumeric string that can be used to identify your device so that advertisers can serve relevant ads to you.  We use the Apple IDFA only as permitted by Apple, and we use the Android Advertising ID only as permitted by Google.  An advertising identifier is assigned, and ad tracking is turned on, by default on your mobile device.  You may limit the use of or reset your advertising device ID using the privacy settings on your mobile device; in some instances, you may need to reset the operating system to reset the advertising device ID.  We do not associate any of your personal information with your advertising device ID without your consent.

Service Providers.  We may employ third party companies and individuals to support the Services, to help us provide the Services or to provide the Services on our behalf (e.g., without limitation, analytics and reporting services, database and hosting services, distribution platforms and other web or app service providers) or to assist us in analyzing how our Services are used.  These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Social Networking Sites.  We may share the Personal Information you provide to us with Social Networking Sites and other advertising vendors to provide you with enhanced services, including relevant advertising. 

Proximo Brands.  We may share your Personal Information with our group of brands where it is in our legitimate interests to do so to enable them to provide customer support to you or for internal administrative and management purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development, and quality assurance).

Compliance with Laws and Law Enforcement. Proximo cooperates with government and law enforcement officials and private parties to enforce and comply with the law.  We will disclose your Personal Information to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including, subpoenas), to protect the property and rights of Proximo or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.

Business Transfers.  Proximo may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Other Disclosures.  We may share your Personal Information with our legal, regulatory, audit and other professional advisors.  Those advisors may use your Personal Information to assist us in our operations consistent with our legitimate business interests.  We also may share information about you as described at the point of collection or otherwise pursuant to your consent or where Proximo has a legitimate interest in doing so. This may include, without limitation, sharing information with third parties to provide you with special offers, promotions and co-branded products or services. Once this information is shared with a third party, the information is subject to the terms and conditions of the respective third party’s privacy policy.

Online Advertising and Usage Analytics

We use third-party advertising services to serve ads when you visit some of our Sites and other websites and online services, third-party email services to send informational and marketing emails, and third-party analytics services to help us understand and improve the usage of the Sites and emails.  These services will collect your personal identifiers (such as IP address, device ID and cookie information), device characteristics (such as browser version) and website browsing activity from you when you visit the Sites by placing cookies and using other similar technology.  They use that information to provide advertisements to you on our Sites and other non-affiliated websites and/or to provide analytical information for our Sites.  These third-party companies also may collect and combine information about your online activities over time, on other devices and on other websites or online services, if those websites and online services also use the same companies.

We currently use Google Analytics to collect and process certain usage data on our Sites.  To learn more about Google Analytics and how to opt out, please visit https://policies.google.com/technologies/partner-sites.  You may learn more about advertising networks and opt out of receiving personalized advertisements on this browser or device from advertisers who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out options of each of those organizations.  Links to those sites are here:

Network Advertising Initiative: http://www.networkadvertising.org/choices/

Digital Advertising Alliance: http://www.aboutads.info/choices/

When you opt out of personalized advertising, you may continue to see online advertising on the Sites and/or our ads on other websites and online services.

How Long We Store Your Information

We keep your Personal Information for no longer than necessary for the purposes for which the Personal Information is processed.  The length of time for which we retain Personal Information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

Your Rights and Privacy Preferences

Users of the Services have the right to review, verify, correct and request erasure of the Personal Information that we hold about you under certain circumstances.  You also have the right to limit, restrict or object to the Processing of your Personal Information under certain circumstances.  You may also have the right to request that we transfer your Personal Information to another party to the extent provided for under applicable data privacy laws. 

If you want to review, verify, correct or request erasure of your Personal Information; limit, restrict or object to the Processing of your Personal Information; or request a transfer of your Personal Information to another party, please contact us at [email protected] or write to us at:

Proximo Spirits, Inc.
3 Second Street, Suite 1101
Attention: Legal Department
Jersey City, NJ 07302

To protect your privacy and security, we also will take reasonable steps to verify your identity before granting access, making corrections or following such a request to correct or delete your data.

When you contact us, we will respond as soon as possible and, where possible, within one month.  If your request is more complicated, it may take longer to respond to you, but we will respond within two months of your request.  There is no charge for most requests, but if you ask us to provide a significant amount of data, for example, we may ask you to pay a reasonable administrative fee where permitted by law. 

Controlling Cookies and Similar Technologies 

Most browsers have optional settings that allow you to be notified when you receive a cookie, giving you the chance to decide whether to accept it.  You can also set or amend your web browser controls to accept or refuse cookies.  Please refer to your browser instructions or help screen for information about how to do this.  You may also delete cookies.  However, this will mean that any information you have entered onto the Sites may be lost.  For example, the Sites will not recognize you on your next visit and you will have to re-enter any personal details.

You can find out more about cookies, including how to delete them, at: http://www.allaboutcookies.org/ and http://www.cookiecentral.com/.

To restrict which cookies may be set for advertising purposes, please visit: http://www.aboutads.info/choices/, and/or http://www.networkadvertising.org/managing/opt_out.asp.

Promotional Communications

We may send you promotional communications regarding the Services.  We have a legitimate interest in Processing your Personal Information for our promotional purposes, which means we may not always need your consent.  Where consent is needed, we will ask for it separately and clearly. 

You may opt out of receiving promotional communications at any time by:

  • Contacting us at [email protected], and/or
  • Using the unsubscribe instructions provided in any of our communications.

Your California Privacy Rights 

California Civil Code Section 1798.83 permits customers of Proximo who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please write to us at the following address:

Proximo Spirits, Inc.
Attn:  California Privacy Rights
3 Second Street, Suite 1101
Attention:  Legal Department
Jersey City, NJ 07302

Do Not Track is a privacy preference that users can set in their web browsers.  When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Do Not Track browser settings or signals.  For information about Do Not Track, please visit: www.allaboutdnt.org.

Under the California Consumer Privacy Act (“CCPA”), California residents have the right to request:

  • the deletion of the personal data we have about them;
  • additional information about whether and how we have collected, used, disclosed and sold personal data about them;
  • the specific pieces of personal data we have about them; and
  • that we opt them out of the “sale” of their Personal Information (the “Right to Opt Out”), which can be done at the below “Do Not Sell My Personal Information” Opt Out.

California residents also have the right not to receive discriminatory treatment if they exercise the rights listed above.

When you make a request, we may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it.  The verification steps we take may differ depending on the request you make.  We will match the information that you provide in your request to information we already have on file to verify your identity.  If we are able to verify your request, we will process it.  If we cannot verify your request, we may ask you for additional information to help us verify your request.

California residents will be required to submit data so that we can verify the request.  Please provide as much of the requested information as possible to help us verify the request.  We will use the information received in a request only for the purposes of responding to the request.

California law permits California residents to use an authorized agent to make privacy rights requests.  We require the authorized agent to provide proof of the California resident’s written permission that shows the authorized agent has the authority to submit a request for the California resident.  An authorized agent must follow the process described below to make a request, and we will additionally require the authorized agent to verify his/her own identity.

You may submit a privacy rights request to us by:

  • Visiting HERE; and/or
  • Calling us at 1-866-I-OPT-OUT (1-866-4-678-688), Service Code: 1095.

Within the meaning of the CCPA, we disclose for a business purpose or “sell” to third parties the categories of Personal Information described above under “Information Sharing and Disclosure” and “Online Advertising and Usage Analytics”.  We do not knowingly disclose for a business purpose or “sell” the Personal Information of anyone under the age of 16.  To exercise the Right to Opt Out, in addition to contacting us using the above information, you may use the following link:

“DO NOT SELL MY PERSONAL INFORMATION.”

Your Nevada Privacy Rights 

We do not sell consumers’ covered information for monetary consideration (as defined in Chapter 603A of the Nevada Revised Statutes).  However, if you are a Nevada resident, you have the right to submit a request directing us not to sell certain information about you.  To submit such a request, please contact us at:

Proximo Spirits, Inc.
Attn: Nevada Privacy Rights 
3 Second Street, Suite 1101
Attention: Legal Department
Jersey City, NJ 07302

Security

Proximo is concerned with safeguarding your information. We employ reasonable administrative, physical and electronic measures designed to help protect your Personal Information from unauthorized access.  No security, however, can eliminate the possibility that your Personal Information may be accessed by an unauthorized third party and we cannot guarantee that your Personal Information will remain secure in all situations.

Where required by law, we will make any legally required disclosures of any breach of the security, confidentiality or integrity of your data to you via email, mail, telephone or conspicuous posting on our website in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement and (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.  Where permitted by law, we reserve the right to choose which method we use to contact you about such an event.

International Transfer

You are giving us the following particular express, voluntary and informed consent to a few activities relating to your Personal Information that is disclosed in providing goods and services to you, or for a purpose directly related to such purpose:

Consent to International Transfer and Disclosure of Personal Information:  The Services are intended for U.S. audiences, only.  Proximo is located in the U.S. and is subject to the applicable laws of the U.S. (where data privacy laws are generally less stringent than in the European Union (“E.U.”) and certain other jurisdictions).  We will store and process information we receive about you, as described in this Privacy Policy, in the U.S.

We may be involved in business activities in a variety of countries.  You agree that Proximo and those with whom we share your Personal Information (“Recipients”) may disclose, transfer, process and store your Personal Information outside of your country of origin to our affiliates, sponsors and agencies, and any other third party service providers, for the purposes described in this Privacy Policy. 

Some of the Recipients of Personal Information as specified above may be located in countries that do not provide a level of data protection equivalent to that set forth by the E.U. and some other jurisdictions.  If you submit any Personal Information or choose to access or use the Services offered by Proximo, such as through our Sites, you consent to such disclosure, transfer, process and storage of information in accordance with this Privacy Policy and subject to such applicable laws, which may include access by law enforcement and other government entities, including courts and tribunals.

Visitors to Our Sites Must Be 21 or Older

The Sites are not directed to, and we do not knowingly collect or store Personal Information from, persons under the age of 21.  ANY PERSON WHO VISITS ANY PORTION OF THE SITES REPRESENTS TO US THAT HE OR SHE IS 21 YEARS OF AGE OR OLDER AND MUST IMMEDIATELY LEAVE THE SITES IF UNDER THE AGE OF 21.  If we become aware that someone under the legal purchase age has provided us with Personal Information, we will take steps to delete that information.

Links to Other Sites

The Sites may contain links to sites operated, controlled and maintained by independent third parties.  We do not control the use of information you may provide to such third parties.  If you access other websites using links provided on our Site, the operators of the third-party sites may collect information from you that will then be used by them in accordance with their own privacy policies, not ours.

Complaints

If you have any complaints concerning our Processing of your Personal Information, please email us at [email protected] or write to us at:

Proximo Spirits, Inc.
Attn: Legal Department – California Privacy Rights
3 Second Street, Suite 1101
Jersey City, NJ 07302

Contacting Us

If you have any questions about this Privacy Policy, please contact us at [email protected] or write to us at:

Proximo Spirits, Inc.
3 Second Street, Suite 1101
Jersey City, NJ 07302