Privacy Policy - Havanna USA

How do we collect information about you?

We may collect identifying information (“Personal Information“) about you through automatic interactions with you, through submissions you make directly to us and through third parties.

Information we collect about you through your use of Sites

We use cookies and other tracking technology which collect certain kinds of information when you interact with our websites and apps, such as IP addresses, browsing preferences and pages you have viewed, as well as information about your navigation experience (time of the visit). You can read more about these policies below and in our Cookie Notice.

Information you provide to us

We collect Personal Information when you request information about us, purchase our products, register for a contest or use an application of our company.

Information we receive from third parties

We work closely with third parties (for example, business partners, affiliates of Havanna, advertising networks, payment processors, and analytics providers) and may obtain information about you from them. For example, we may obtain information about your shopping habits in order to better customize our products to you.

What type of information is collected about you?

We may collect the following Personal Information about you:

  • Name and contact data. Your first and last name, email address, home or business address and phone number.
  • Demographic data. Data about you such as your age, gender, country and preferred language.
  • Payment data. Payment card number and related information such as expiration date and any required codes.
  • Images and videos. Any images, videos and personal stories that you may provide as a result of your use of Sites.
  • Location data. Data about your location which can be precise or imprecise. For example, we collect location data about nearby cell towers and hotspots as well as zip code data which provides a less precise location.
  • Feedback and ratings. Any information that you provide to us about our Sites.
  • Credentials. Passwords, password hints, and other security information used for authentication.

How is information collected about you used?

We use Personal Information about you for the following purposes:

  • To provide you with our Sites, products or information you asked for;
  • To improve and develop our Sites and products;
  • To administer contests and promotions for which you signed up;
  • To personalize our products and Sites and make recommendations to you;
  • To allow you to participate in our loyalty program;
  • To address Sites integrity or security issues;
  • To send you updates about our Sites;
  • To facilitate and otherwise address certain inquiries or requests regarding the Sites, or respond to your questions or requests for information about or from Havanna;
  • To ensure compliance with any Havanna policies and any applicable law, regulation or order;
  • To protect the rights, property, or personal safety of another Havanna user, website visitor, other users of the Sites, or any member of the public;
  • To operate our Sites.

With whom do we share the information that we collect?

We share Personal Information about you with third parties, as needed, to administer our website and perform our Sites, and as described in this Privacy Notice. We may share Personal Information about you with affiliates, agents, service providers and distributors in order to administer our Sites.

We may also use and disclose certain aggregated, anonymized information, such as website usage data, to our trusted business partners. Such information may also be shared with third parties for advertising, informational, or comparison purposes. However, such information shall not be personally identifiable to any user.

Types of Personal Data CollectedSource of the Personal DataPurpose for CollectionInformation Disclosed for a Business or Commercial Purpose? (Yes/No)Categories of Third Parties (Which Does Not Include Service Providers) with whom the Personal Data is Shared
Identifiers (e.g., name, e-mail, postal address, and phone number)Information directly submitted by a consumer online or offline (such as through a survey); information collected pursuant to a transaction; information collected through communications with our customer service department; and information collected from business partners and analytics service providers
  • To deliver, improve, and provide our products and related services
  • Internal record keeping and operations, including legal compliance
  • To provide customer support
  • For marketing activity such as to administer our loyalty program and administer contests
YesBusiness partners, affiliates and distributors
Demographic informationInformation directly submitted by a consumer online or offline (such as through a survey); information collected pursuant to a transaction; information collected through communications with our customer service department; and information collected from business partners and analytics service providers
  • To deliver, improve, and provide our products and related services
  • To analyze business and consumer trends
  • Internal record keeping and operations, including legal compliance
  • For marketing activity such as to administer our loyalty program and administer contests
YesBusiness partners, affiliates and distributors
Professional or Employment InformationInformation directly submitted by a consumer online or offline (such as through a survey); information collected pursuant to a transaction; information collected through communications with our customer service department; and information collected from business partners and analytics service providers
  • To deliver, improve, and provide our products and related services
  • To analyze business and consumer trends
  • Internal record keeping and operations, including legal compliance
  • To provide customer support
  • For marketing activity such as to administer our loyalty program and administer contests
YesBusiness partners, affiliates and distributors
Commercial Information (e.g., purchase histories)Information directly submitted by a consumer online or offline (such as through a survey); information collected pursuant to a transaction; information collected through communications with our customer service department; and information collected from business partners and analytics providers
  • To deliver, improve, and provide our products and related services
  • To maintain and secure our Sites and related media
  • To analyze business and consumer trends
  • Internal record keeping and operations, including legal compliance
  • To provide customer support
  • For marketing activity such as to administer our loyalty program and administer contests
YesBusiness partners, affiliates and distributors
Financial Account InformationInformation directly submitted by a consumer online or offline (such as through a survey); information collected pursuant to a transaction; information collected through communications with our customer service department; and information collected from business partners and analytics providers
  • To deliver, improve, and provide our products and related services
  • To maintain and secure our Sites and related media
  • To analyze business and consumer trends
  • Internal record keeping and operations, including legal compliance
  • To provide customer support
  • For marketing activity such as to administer our loyalty program and administer contests
YesBusiness partners, affiliates and distributors
Geolocation DataInformation directly submitted by a consumer online or offline (such as through a survey); information collected pursuant to a transaction; information collected through communications with our customer service department; and information collected from business partners and analytics providers
  • To deliver, improve, and provide our products and related services
  • To maintain and secure our Sites and related media
  • To analyze business and consumer trends
  • Internal record keeping and operations, including legal compliance
  • To provide customer support
  • For marketing activity such as to administer our loyalty program and administer contests
YesBusiness partners, affiliates and distributors
Consumer Preferences such as feedbackInformation directly submitted by a consumer online or offline (such as through a survey); information collected pursuant to a transaction; information collected through communications with our customer service department; and information collected from business partners and analytics providers
  • To deliver, improve, and provide our products and related services
  • To maintain and secure our Sites and related media
  • To analyze business and consumer trends
  • Internal record keeping and operations, including legal compliance
  • To provide customer support
  • For marketing activity such as to administer our loyalty program and administer contests
YesBusiness partners, affiliates and distributors
Website Browsing ActivityWeb tracking technology such as browser cookies, flash cookies and web beacons
  • Website functionality, customization and security
  • Advertising and marketing
YesThird party web tracking providers

What are your choices about the Personal Information collected?

When submitting information and interacting with our Sites, you choose which information you wish to share. Please take care to share only such information as is needed or that you believe is appropriate. Any promotional email we send to you will contain a link which will allow you to opt out of receiving any further correspondence. If you have created an online account, you may also change your correspondence preferences by logging into your account.

You may also opt out at any time from marketing communications by contacting us via our Contact Us form. You may disable your online account access at any time; however, this will not necessarily result in the deletion of any Personal Information.

You can also limit the use of tracking technologies, such as cookie collection which can be modified in browser settings on your device.

Use of cookies, web beacons and Google Analytics

Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. We use cookies and similar technologies for storing and honoring your preferences and settings, enabling you to sign in, providing interest based advertising, combating fraud, analyzing how our products perform and fulfilling other legitimate purposes.

We also use “web beacons” to help deliver cookies and gather usage and performance data. Our websites may include web beacons, cookies or similar technologies from third party service providers.

Our Sites may use Google Analytics, a web analysis service provided by Google, in order to better understand your use of our Sites and how we can improve them. Google Analytics collects information such as how often users visit our Sites, what pages you visit when you do so, and what other websites you used prior to coming to the Sites. Google Analytics collects only the IP address assigned to you on the date you visit the Sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with your personal information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our Sites, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Sites is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. Google utilizes the data collected to track and examine the use of the Sites, to prepare reports on its activities and share them with other Google Sites. Google may use the data collected on the Sites to contextualize and personalize the ads of its own advertising network. To more fully understand how Google may use the data it collects on the Sites, please review How Google Uses Information From Sites Or Apps That Use Our Sites.

You can learn more about our use of cookies by reviewing our Cookie Notice.

How do you keep Personal Information secure?

Havanna takes commercially reasonable measures to secure and protect information transmitted via our Sites. Our Sites are scanned regularly for security holes and known vulnerabilities in order to make your use of our Sites as safe as possible.

Nevertheless, because no Sites are impenetrable, we cannot guarantee that information that users of the Sites may transmit or otherwise supply will be totally secure.

How long do you keep Personal Information?

We hold onto different types of data as necessary to provide the products and fulfill the transactions you requested, or for another legitimate purpose such as complying with legal obligations. Because the needs vary based on different data types, retention periods may vary significantly.

For example, we may keep information about you and how you use our Sites as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm as described in the How We Use Information section.

Links to third party websites

For your convenience, some hyperlinks may be posted on our Sites that link to other websites not under our control. We are not responsible for, and this Privacy Notice does not apply to, the privacy practices of those sites or of any companies that we do not own or control.

Changes to this Privacy Notice

We may change this Privacy Notice from time to time. You should visit our website’s privacy policy for the most up to date version of the Notice. If we make material changes to this Notice, we will provide you with a more prominent notice ahead of the Effective Date.

CALIFORNIA PRIVACY RIGHTS

Data Subject Rights — California Residents

This portion of our Privacy Policy advises California residents of rights provided in the California Consumer Privacy Act (“CCPA”) and how to effectuate those rights by communicating with us. Please note, we will seek to verify your identity when we receive an individual rights request from you in order to ensure the security of your Personal Information.

Please direct any rights requests (as further described below) or additional questions you may have regarding this Privacy Policy via email or postal mail to:

legal@havannausa.com
ATTN: Legal Department
Havannausa (USA)
15531 Sheridan Street, Forida

If you do, we will need to collect Personal Information and other information such as your name, email or transaction history in order to verify your identity. You may also authorize an agent to make a request on your behalf, who will need to provide similar information for verification.

Right to Deletion of Personal Information
California residents have the right to request the deletion of Personal Information as prescribed in Section 1798.105(a) of the CCPA. Havanna may not delete some or all requested Personal Information as required or allowed by applicable law.

Right of Access: Right to Request Disclosure of Data Collection and Sharing Practices

You may request to receive details about how we collect, use, and share your Personal Information. Specifically, you may request to receive the specific pieces of Personal Information that we have collected about you.

You may also request to receive:

  • the categories of Personal Information that we have collected about you,
  • the categories of Personal Information that we have disclosed for a business purpose,
  • the categories of sources from which we collected the Personal Information,
  • our purposes for collecting that Personal Information, and
  • the categories of parties with whom we share your Personal Information.

Right to Opt-Out of Sale
You have a right to direct us not to sell your Personal Information. If you would like to exercise that right, please click [Do not Sell]. Alternatively, you may direct us to not to sell your Personal Information by contacting us as provided above.

Right to not be Discriminated Against for Exercising CCPA Rights
We do not discriminate against you for exercising any CCPA rights, such as the access and deletion rights described above. If we choose to offer a product enhancement or financial incentive that is contingent on you sharing personal information, we will ensure that the value provided to us by that collection is reasonably related to the value of the product enhancement or financial incentive.

Do Not Track Requests

Certain states such as California and Delaware require that we indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. We do not monitor or follow any Do Not Track browser requests.

Are Children allowed to use the Sites?

Our Sites are intended for a general audience and is not intended for use or view by children under 13 years of age without parental consent, and we do not knowingly collect information about children or sell products to children. Consistent with the Children’s Online Privacy Protection Act, we will not knowingly collect any information from children under the age of 13.

Contact us

If you have questions about this Privacy Notice or the way in which Havanna uses Personal Information about you, you can contact us via our Contact Us page.

Alternately, you may also contact us at:

Havanna USA
15531 Sheridan Street, Forida

Updated: March 2020.