Privacy Policy

Last updated: February 23, 2018

Secret Spirits Ltd. ("us", "we", or "our") operates the

http://www.secretspirits.com/

http://www.secretspirits.com/secret-spirits-circle website (the

"Service").

Personal Information Collect, Use,

Disclosure and Consent

Personal Information may include your name, email address, age,

home address, phone number, marital status, income, credit history,

medical information, education, employment information and social

registration numbers.

We are committed to providing our clients, customers, members

("you", "your" or "them") with exceptional service. Providing

exceptional service may involve the collection, use and, at times, the

disclosure of your Personal Information. Protecting your Personal

Information is one of our highest priorities. While we have always

respected your privacy and safeguarded all Personal Information, we

have strengthened our commitment to this goal. This is to continue to

provide exceptional service to you and to comply with all laws

regarding the collection, use and disclosure of Personal Information.

We will inform you of why and how we collect, use and disclose

Personal Information; obtain your consent, as required; and handle

Personal Information according to applicable law. Our privacy

commitment includes ensuring the accuracy, confidentiality, and

security of your Personal Information and allowing you to request

access to, and correction of, your personal information.

This page informs you of our policies regarding the collection, use and

disclosure of Personal Information when you use our Service.

We will not use or share your information with anyone except as

described in this Privacy Policy.

We will only collect Personal Information that is necessary to fulfill the

following purposes:

To verify identity;
To identify your preferences;
To open and manage an account;
To ensure you receive a high standard of service;
To meet regulatory requirements;
Other legal reasons as apply to the goods and services requested.

We will obtain your consent to collect, use or disclose Personal

Information. In some cases, we can do so without your consent (see

below). You can provide consent orally, in writing, electronically or

through an authorized representative.

You provide implied consent where our purpose for collecting using or

disclosing your Personal Information would be considered obvious or

reasonable in the circumstances. Consent may also be implied where

you have notice and a reasonable opportunity to opt-out of having

your Personal Information used for mail-outs, marketing or fundraising

and you do not opt-out.

We may collect, use or disclose Personal Information without the

consent:

When permitted or required by law;
In an emergency that threatens an individual's life, health, or
personal security;
When the Personal Information is available from a public source;
When we require legal advice from a lawyer;
For the purposes of collecting a debt or protection from fraud;
Other legally established reasons.

We will not sell your Personal Information to other parties unless

consent has been provided or implied. We retain your Personal

Information for the time necessary to fulfill the identified purposes or a

legal or business purpose. We will make reasonable efforts to ensure

that your Personal Information is accurate and complete. You may

request correction to your Personal Information to ensure its accuracy

and completeness. A request must be in writing and provide sufficient

detail to identify your Personal Information and the correction being

sought.

We are committed to ensuring the security of your Personal

Information and may use passwords, encryption, firewalls, restricted

employee access or other methods, in our discretion. We will use

appropriate security measures when destroying your Personal

Information such as shredding documents or deleting electronically

stored information, in our discretion.

Log Data

We may also collect information that your browser sends whenever

you visit our Service ("Log Data"). This Log Data may include

information such as your computer's Internet Protocol ("IP") address,

browser type, browser version, the pages of our Service that you visit,

the time and date of your visit, the time spent on those pages and

other statistics.

Cookies are files with small amount of data, which may include an

anonymous unique identifier. Cookies are sent to your browser from a

web site and stored on your computer's hard drive.

We use "cookies" to collect information. You can instruct your browser

to refuse all cookies or to indicate when a cookie is being sent.

However, if you do not accept cookies, you may not be able to use

some portions of our Service. If you do not instruct your browser to

refuse all cookies or to indicate when a cookie is being sent, your

consent to our use of your Personal Information may be implied.

Service Providers

We may employ third party companies and individuals to facilitate our

Service, to provide the Service on our behalf, to perform Servicerelated

services or to assist us in analyzing how our Service is 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.

Communications

We may use your Personal Information to contact you with

newsletters, marketing or promotional materials and other information

that may be of interest to you. You may opt out of receiving any, or all,

of these communications from us by following the unsubscribe link or

instructions provided in any email we send.

Security

The security of your Personal Information is important to us, but

remember that no method of transmission over the Internet, or method

of electronic storage is 100% secure. While we strive to use

commercially acceptable means to protect your Personal Information,

we cannot guarantee its absolute security.

Links To Other Sites

Our Service may contain links to other sites that are not operated by

us. If you click on a third party link, you will be directed to that third

party's site. We strongly advise you to review the Privacy Policy of

every site you visit.

We have no control over, and assume no responsibility for the

content, privacy policies or practices of any third party sites or

services.

Children's Privacy

Our Service does not address anyone under the age of 18 ("Minor").

We do not knowingly collect personally identifiable information from

Minors. If you are a parent or guardian and you are aware that your

Minor has provided us with Personal Information, please contact us. If

we become aware that we have collected Personal Information from

Minors without verification of parental consent, we take steps to

remove that information from our servers.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify

you of any changes by posting the new Privacy Policy on this page.

You are advised to review this Privacy Policy periodically for any

changes. Changes to this Privacy Policy are effective when they are

posted on this page.

If we make any material changes to this Privacy Policy, we will notify

you either through the email address you have provided us, or by

placing a prominent notice on our website.

Contact Information

Please contact our Chief Privacy Officer to obtain further information about our policies and procedures or if you have any unresolved inquiries or concerns.

Chief Privacy Officer - Secret Spirits Ltd.

talk2us@secretspirits.com