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Privacy Policy

Introduction

At Thompson Cigar Company, your privacy is important to us. We have created this Privacy Policy to describe how we collect, use and share the information that we collect from and about you and the choices you have regarding your information. As more fully described below, we collect, use and share your 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 "TCC 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 Privacy Policy. 

Thompson Cigar Company is a brand owned by Lilly Online, LLC. Lilly Online, LLC may receive information about you from our affiliated brands and companies, meaning companies that we own, that own us, or that are under common ownership with us (our “affiliates”). We also may provide information about you to our affiliates, and when we do, this Privacy Policy also describes how our affiliates collect, use and share your information. For purposes of this Privacy Policy, when we use the terms “TCC,” “we,” “us” and “our,” or similar terms, we are referring to Lilly Online, LLC and our affiliates.

This Privacy Policy does not describe the collection, use and disclosure practices of any third parties. For information on the collection, use and disclosure practices of any other companies with which you are doing business, please review their privacy policies. 

Services offered by TCC 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.

This policy is effective as of June 30, 2020.

Information We Collect

Information is gathered from your use of the TCC Services by us, our service providers, advertisers, sponsors and partners.

Information You Provide. We may collect information that you choose to provide during use of the TCC Services in a variety of ways, such as when you:

  • purchase products or services from us. This information may include your name, address, telephone number, email address, and payment or credit card information;
  • register for one of our services;
  • make information available to us or interact with us via social media website and applications;
  • express an interest in receiving marketing or promotional materials regarding cigars, pipe tobacco, or related products or services;
  • participate in chats, web forums or other interactive sessions;
  • subscribe to newsletters or provide feedback; and
  • participate in surveys, sweepstakes, contests or other promotions.

Automated Information. Information regarding your use of the TCC Services may be collected and/or aggregated by automated means. This automatically collected information may include information such as:

  • your IP address, the type of browser and operating system used, referrer URL;
  • date and time of your visit to a TCC site and the pages you visit, and, if you linked from or to another website, the referrer URL;
  • email you open and links you click on within an email; and
  • your ISP or mobile carrier, and the type of handheld or mobile device that you used.

When you use the TCC 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 the TCC 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 the TCC sites and other websites and mobile applications (that may not be the TCC 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. 

We may use a trackable toll-free telephone number in advertisements. If you call one of these uniquely generated toll-free numbers, we (or a service provider acting on our behalf) may collect non-personally identifiable information about the call (e.g. date, time, duration), as well as personally identifiable information (e.g. your name, and the telephone number from which your call originated).

Videos. We may target and track the videos you view on the TCC sites. You consent to our tracking of your video viewing through the TCC sites or third-party social media for up to two years or as permitted by applicable law.

Location Information. When you download or use the TCC sites, we may also use precise geolocation information ("Location Information"). Please note that we only collect Location Information with your permission (e.g., such as when you agree to provide it to us after you initially access or download the TCC sites). We use Location Information to provide location-based services and content, as well as to understand traffic patterns in and around our retail locations. You can adjust the setting on your mobile device(s) to limit tracking or to decline cookies, but as a result you may not be able to use certain features of the TCC sites or Content or take full advantage of all of our offerings.   

Publicly Posted Information. Information that you make available to us and others via social media networks, forums, blogs, list serves, chat rooms or similar functionality is public information that we or others may share or use in accordance with the law.

Combined Information and Information from Other Sources. We may combine information that you provide to us, directly or indirectly, through our affiliates and other sources, with other information that is automatically collected. The combined information may include information about your use of the TCC sites, your use of other websites, devices and mobile applications and information from our affiliates and other sources.

How We May Use the Information We Collect

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

  1. for everyday business purposes, such as establishing and managing your user account, for accounting and financial purposes such as processing and collecting payments, providing the products and services you request, responding to your queries, and providing customer support;
  2. to offer you our products or services and/or the products or services of others;
  3. to communicate about, and administer your participation in, special events, programs, surveys, sweepstakes, contests, and other offers or promotions;
  4. to enable you to interact with TCC and other users through various means, such as through message boards, blogs and social media;
  5. to evaluate and improve our business, including developing new products and services and analyzing the effectiveness of products, services, applications, and websites; 
  6. to diagnose and address technical and service problems;
  7. to perform data analyses, including market and consumer research, trend analysis, demographic analysis, and financial analysis; 
  8. to deliver content (including advertising) correlating to your interests and browsing and usage history, both within the TCC Sites and on other websites and applications;
  9. to comply with applicable legal requirements and our policies; and 
  10. to contact you via telephone, email, mail, text, or chat. We will obtain your consent to contact you in the manner required by law.

Third Party Applications, Widgets and Social Media

We may include applications or widgets from social media providers that allow interaction or content sharing by their users. These widgets, such as a Facebook "Share" or "Like" button, are visible to you on the web page you visit. Integration between the TCC and social media networks such as Facebook, Twitter and others may allow social media networks in which you participate to collect information about you, and additionally to potentially share any or all of your information with us. Please visit the applicable social media network’s privacy policy to better understand their data collection practices and the choices they make available to you. The privacy policy of the social media network controls the collection, use and disclosure of all personal information transmitted to that network. Any information we receive by these means will be treated and/or processed according to this Privacy Policy.


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 the TCC sites and on third-party’s websites and mobile applications, allowing TCC 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: 

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.

Information We Share

We do not sell or otherwise share information about you that we collect or receive, except as described below: 

  1. Affiliates, Subsidiaries and Business Partners. We may share your information with our affiliates, subsidiaries and business partners in the U.S. and worldwide for the purposes described above and for other general business administration purposes. By visiting or using our Services or otherwise providing us with your information, you consent to this transfer of your information throughout our network of entities. To opt-out of such sharing, please see the “Contact for More Information” section below. 
  2. Our Service Providers. We may engage certain vendors to provide the services offered through or in connection with the TCC Services on our behalf. By written contract, we require such providers to maintain personal information about you as confidential and to use that information only for the specific business purpose of performing the services specified by us, and in a matter consistent with this Privacy Policy, and not to retain, use or disclose the information for any other purpose.
  3. Third Party Promotions or Co-Sponsored Promotions. In the event that you participate in a survey, sweepstakes, contest or other promotion conducted by a third party, or that is co-sponsored by TCC and a third party, information collected in conjunction with the survey, sweepstakes, contest or promotion, including personal information, is shared with that third party. Once the information is provided to those third parties, the subsequent use or disclosure of such information is subject to their privacy policies and practices. Surveys, sweepstakes, contests, and other promotions conducted on behalf of TCC and a third party will include branding from both TCC and the third party.
  4. Manufacturers and Distributors. We may provide manufacturers or distributors, and their agents or third-party service providers, with information about you when you access the TCC via TCC branded advertising and/or functionality found on their websites or other third-party websites. If you have expressed an interest in a particular product offering, information about you may be shared with the manufacturer or distributor of that product. In either case, the provider will use that information in accordance with its own privacy policies.
  5. Corporate and Asset Transactions. If we sell all or substantially all of our business or sell or transfer all or a material part of our assets, or are otherwise involved in a merger or transfer of all or a substantial part of our business, we may transfer all information we have collected and stored, including personal information, to the party or parties involved in the transaction as part of that transaction.
  6. Other. We may access or disclose information, including personal information, to: 

                    a. protect or defend our interests and the legal rights or property of TCC and our affiliates;

                    b. protect the rights, interests, safety and security of users of the TCC Services or members of the public;

                    c. protect against fraud or for risk management purposes; or

                    d. comply with applicable law or legal process, as well as prudent legal practice as we may determine.

Your Choices

You are entitled to make certain choices about how we communicate with you.  

  1. You may choose not to provide personal information, even though that may impact your ability to register or receive a particular product or service.
  2. We use your email address to send order confirmations and invoices. If you have elected to receive our weekly email specials by providing us with your email address, we will send you exclusive specials. You can opt out of receiving promotional emails from us, either by clicking on the “unsubscribe” link at the bottom of any email, or by contacting our customer service department. 
  3. If you do not want to receive interest-based advertisements, you can opt out as discussed in the "Advertising Networks" section above.
  4. To exercise choices regarding cookies set through the use of our Services, as well as other types of online tracking and interest-based advertising, see our “Advertising Networks” section above.

Change Your Information

We cannot change your personal information over the phone. You can change your personal information by logging into your account.

Your California Privacy Rights

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

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 from consumers, which we collect 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.                          

TCC collects at least one item from each of the below categories of personal information identified in the California Consumer Privacy Act. 

Category / Examples:

A. Identifiers. 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.

B. 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.

C. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

D. Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

E. Geolocation data. Physical location or movements.

F. Inferences drawn from other personal information. Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We obtain the categories of 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 the TCC 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

Access to or Requesting Deletion of 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 rights and explains how to exercise those rights.

Requests to Know

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.

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. 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 and Request to Delete Rights

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

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 requests made more frequently than that.

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. To request that your personal information not be sold, please follow this hyperlink: Do Not Sell My Personal Information. 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 Web portal above, to make your specific request. 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.  

Correcting Your Information

If you are a registered user of the TCC sites, you may make changes or updates to certain information by logging into your password-protected account within the TCC sites. Additionally, if you believe that information we maintain about you is inaccurate, subject to applicable law, you may request that we correct or amend the information by contacting us as indicated in the "Contact For More Information" section below. 

Online Tracking Policy for California Residents

As of the effective date of this Privacy 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.

Additional Information Regarding Privacy Policy

Links

The TCC Sites may contain links to websites not operated by us, as well as third party widgets and applications discussed above. Once you leave the TCC sites, we suggest that you review the applicable privacy policy of the third-party website or application. We are not responsible for the content or use of any websites or applications other than on the TCC Sites or the privacy practices of those websites or applications. 

Data Security

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. 

Consumers with Disabilities

Any consumer with a disability (or their authorized agent) may contact us by visiting our website or calling our customer service department at 1-800-237-2559. Additionally, you can access our accessibility interface by clicking the "Accessibility" link under the Customer Service links on the bottom of each web page.

The Privacy of Children

Services offered by TCC are not directed to individuals under the age of twenty-one (21). We do not knowingly collect, use, or share the personal information of children under the age of thirteen (13), and the TCC Sites are not directed to individuals under 21. If you are under the age of 13, you should not provide any personal information to us, and you may not use the TCC Sites. If you are made aware that we have collected personal information from an individual under age 13, please contact us. Once verified, we will delete this information as soon as possible. 

Disputes

If you choose to use the TCC Services, any dispute regarding privacy is subject to this Privacy Policy and our Terms of Use.

Self-Service

If you are a registered user of the TCC sites, you may make changes or updates to certain information by logging into your password-protected account within the TCC sites. 

Contact for More Information

If you have any questions or comments about this Privacy Policy, or if you would like assistance updating information we have about you or your preferences, please contact us by email at [email protected] or consult our Privacy Policy. Alternatively, you may send a written request to the following address:

ATTN: THOMPSON CIGAR COMPANY PRIVACY OFFICE

            1911 Spillman Drive

            Dept. # 375

            Bethlehem, PA 18015

Updates to this Privacy Policy

We will review our Privacy Policy periodically (at least annually). We reserve the right, in our sole discretion, to revise, change, or modify this Privacy Policy at any time. You should check this web page periodically to see if any recent changes to this Privacy Policy have occurred. By continuing to engage with us after this Privacy Policy has been updated, you agree to the updated terms of this Privacy Policy. If we make changes, we will revise the date at the top of this Privacy Policy.

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