PRIVACY POLICY

Last Updated on January 25, 2023.

At CAOcigars.com and General Cigar Co., Inc., 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 General 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).

PERSONAL INFORMATION WE COLLECT

 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. 

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 TO CONTROL YOUR PERSONAL INFORMATION

You have the right to make certain requests regarding your personal information. On CAOcigars.com under the heading “Login/Register”, you have the option to create an account using a username and password and subscribe to a General Cigar email list that is used to provide updates, promotions and news. Of course, you may unsubscribe after receiving emails. 

In addition, you can: 

• Ask us to review, update or correct your personal information
• Opt-out of sharing your personal information with third parties for some purposes
• Make choices about receiving marketing communications 

Note, if you ask us to delete or stop using your personal information, we may not always be able to honor that request if some or all of the information is required to comply with commercial, regulatory or legal requirements.

HOW YOUR PERSONAL INFORMATION MAY BE USED

We may use information we collect for various business purposes including: 

1. to deliver content (including advertising) correlating to your interests and browsing and usage history, both within Punch and other General Cigar websites and applications;
2. to enable you to interact with us and other users through various means, such as through message boards, blogs and social media;
3. to communicate about, and administer your participation in, special events, programs, surveys, sweepstakes, contests, and other offers or promotions;
4. to evaluate and improve our business, including developing new products and services and analyzing the effectiveness of products, services, applications, and websites; 
5. to diagnose and address technical and service problems;
6. to perform data analyses, including market and consumer research, trend analysis, demographic analysis, and financial analysis; 
7. to comply with applicable legal requirements and our policies; and 
8. 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 General Cigar sites, 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 General Cigar sites and other websites and mobile applications (that may not be General Cigar sites) 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.

ADVERTISING NETWORKS

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 General Cigar sites and on third-party’s websites and mobile applications, allowing General 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.

We do not provide information that is directly associated with a specific person (such as name and address) to an advertising network when you interact with or view a customized advertisement. However, when you view or interact with an advertisement, the advertiser may assume that you are interested in the subject matter of the advertisement.    

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.

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 https://www.caocigars.com/contact/.

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 General Cigar Co., Inc. 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.

YOUR CALIFORNIA PRIVACY RIGHTS

This PRIVACY NOTICE supplements the information contained in the above policy and applies solely to California residents who have business relationships with us. We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA"), the California Privacy Rights Act of 2020 (“CPRA”), the California “Shine the Light” law, and other California privacy laws. Any terms defined under California law shall have the same meaning when used in this PRIVACY NOTICE under “Your California Privacy Rights”.

Under California’s “Shine the Light” law, if you are a California resident who provides personal information in obtaining products or services for personal use, you may choose to opt out of any sharing of that personal information with third parties by one of our brands or affiliates with whom you have provided that personal information. If you are a California resident and (1) you wish to opt out; or (2) you wish to request information concerning whether one of our brands or affiliates has disclosed any of your personal information to any third parties for direct marketing purposes, you may contact us as specified in the “Contact for More Information” section below.

Information We Collect

We collect and retain the following categories of personal information and, in some cases, sensitive personal information from consumers for the business purpose of complying with federal, state and local laws, and regulations governing our business, and to help us determine what products and services might be of greatest interest to you.                          

We collect at least one item from each of the below categories of personal information identified in the CCPA. 

Category

1. Your real name, alias, date of birth, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, or other similar identifiers.
2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, driver's license or state identification card number, bank account number, or other financial information. Some personal information included in this category may overlap with other categories.
3. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
4. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
5. Geolocation data. Physical location or movements.

We obtain the categories of personal information and sensitive personal information listed above from the following categories of sources: 

• Directly from our customers or their agents. For example, from documents that our customers provide to us related to the products or services for which they engage us.
• Indirectly from our customers or their agents. For example, through information we collect from our customers in the course of providing products or services to them.
• Directly and indirectly from activity on any General Cigar sites. For example, from submissions through our website portal or website usage details collected automatically.
• From third parties that interact with us in connection with the services we or they perform.

Sharing Personal Information

We may disclose your personal information to our corporate affiliates and to third parties with whom we have joint marketing agreements for the purpose of offering complementary products and services. When we disclose personal information to our affiliates, service providers, and/or third parties, we do so under a contract that describes the business purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except for performing the services provided under the contract.

We may have disclosed or sold the following categories of personal information:  

• Category A: Identifiers
• Category B: California Customer Records personal information categories
• Category C: Commercial Information
• Category D: Internet or other similar network activity
• Category E: Geolocation data
• Category F: Inferences drawn from other personal information

Accessing, Correcting, or Deleting Personal Information

If you are a California resident, upon our receipt of a verifiable request from you, you can obtain access to the personal information about you which we have in our files, or which we have used or shared with third parties. This section describes your CCPA and CPRA rights and explains how to exercise those rights.

Requests to Know and/or Correct

You have the right to request that we disclose certain information to you about our collection and use of your personal information, including: the categories and specific pieces of personal information we have collected about you. You also have a right to correct any such personal information you believe to be inaccurate.

Requests to Delete

You have the right to request that we delete any of your personal information that we have collected and retained, subject to certain exceptions in the CCPA/CPRA. Once we receive and confirm your verifiable consumer request, we will delete your requested personal information from our records, unless an exception applies, and we will direct our service providers to similarly delete your personal information from their records.

Exercising Your Request to Know, Correct or Delete Rights

In order to submit a verifiable consumer request to know what personal information we may have collected or shared, or to correct or request the deletion of any of your personal information, you may: use one of these two Communication Methods:

• Use our online request form or
• Call our toll-free number at 1-888-914-9661 (PIN#: 780907).

Upon receipt of a request by one of the above methods concerning your personal information, we will attempt to verify your identity (or authority to make the request) by:

• requesting that you provide personally identifying information, including your first name, middle name, last name, email address, shipping address and telephone number. 
• requesting that you provide additional evidence proving your identity such as your unique customer identification number or details of a recent transaction.

You may make a verifiable consumer request up to two times within any 12-month period. We will not be able to respond to more frequent verifiable consumer requests.

Right to Non-Discrimination for the Exercise of Consumer’s Privacy Rights

You have a right not to receive discriminatory treatment from us for the exercise of any of your privacy rights conferred by the CCPA. 

Your Right to Opt-Out

As a California resident, you have the right to limit the personal information that we share with or sell to our affiliates or third parties. You also have a right to limit the sensitive personal information that we may collect to that necessary to perform the service or to provide the goods that we offer for sale. To request that your personal information not be shared or sold, or to limit the sensitive personal information that we may collect, please follow this hyperlink: online request form.  In addition, customers who are California residents may request certain information regarding our disclosure of personal information to third parties for direct marketing purposes. To make such a request, please contact us at either our toll-free number or https://www.caocigars.com/contact/. to make your specific request. Finally, California consumers have the right to opt out of behavioral advertising or targeted marketing based on past online commercial activity. Even if you opt out of the disclosures described in this section, we may still disclose information to affiliates and non-affiliated third parties as permitted by law.  

Online Tracking Policy for California Residents

As of the effective date of this policy, there is no commonly accepted response for Do Not Track signals initiated by browsers and, therefore, we do not respond to them.

Authorized Agent

As a California consumer, you can designate an authorized agent to make a request under the CCPA on your behalf. To do so, please write to us at the address provided below, providing your full name and address, the name and address of your authorized agent, the agent’s contact information, specify your relationship with the authorized agent, and the purpose for which you are designating the authorized agent. You may revoke the authority of that agent at any time by contacting us in writing at the address below.

Sensitive Personal Information

Unless we request it, we ask that you not send or disclose to us any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through our services or otherwise.

Sale or transfer of CAOcigars.com or General Cigar Co., Inc.

In the event of any potential or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings), your personal information may be shared with third parties such as the acquiring entity and its advisors.

If you are a registered user of any General Cigar site, you may make changes or updates to certain information by logging into your password-protected account within the websites.

Disputes

If you choose to visit any General Cigar site, your visit and any dispute regarding privacy is subject to this policy and our Terms of Use.

CHANGES TO THIS POLICY

We reserve the right to change, add or remove portions of this policy at any time. You should check this policy periodically to see if any recent changes to this policy have occurred. If we make changes, we will revise the date at the top of this policy. Such modifications shall become effective immediately upon posting. By continuing to engage with us after this policy has been updated, you agree to the updated terms of this policy.

CONTACT FOR MORE INFORMATION 

If you have questions or want more information about our privacy policy or your dealings with this site, please contact us at https://www.caocigars.com/contact/.