Updated as of April 15, 2019
Personal Information. “Personal Information” may include, but is not limited to information that identifies you as an individual or relates to an identifiable person, such as name, postal address, telephone number, email address, etc. The Company does not collect any personal data from visitors to its website that is not voluntarily provided. The Company only collects your Personal Information if you register for an account with the Company’s Website, when you use the Company’s Services, and when you send the Company communications in connection with your use of the Services.
Use and Sharing of Personal Information. We use the information we collect from our Website and your use of our Services to provide and improve existing Services; to develop new Services; and to protect you and the Company. We also may use this information to offer you tailored content when you visit our Website. We will not share your personal information with anyone except for our Company’s authorized service providers*, business affiliates**, and business partners*** for business purposes; or unless we specifically inform you and give you an opportunity to opt out of our sharing your personal information.
In general, we may use and/or share your Personal Information:
To respond to your inquiries and your requests regarding our Services.
To send you information regarding our services and changes to our terms, conditions, and policies.
To complete your user account registration, and communicate with you regarding your purchase of our Services.
To send you marketing communication and newsletters about our Services. The Company likes to keep its clients, personnel and other interested parties informed of legal developments of interest to them. If you do not wish to receive publications or details of events or seminars that we consider may be of interest to you, please let us know by emailing firstname.lastname@example.org.
To facilitate social sharing functionality.
To collaborate with business affiliates, partners, vendors, or service providers to provide you with our Services. In connection with our business purposes, including but not limited to data analysis, audits, fraud monitoring and prevention, developing or enhancing new and existing Services, expanding our business activities, etc.
We will not use and/or share your Personal Information:
To run interest-based advertising campaigns that collect personal data such as email addresses, telephone numbers, and credit card numbers. To use or associate personal data with remarketing lists, cookies, data feeds, or other anonymous identifiers.
To use or associate targeting information, such as demographics or location, with any personal data collected from the ad or its landing page. To share any personal data with Google or third party companies through our remarketing tag or any product data feeds which might be associated with our ads.
To send Google or third party companies precise location information without obtaining your consent.
We also will never share your Personal Information with others unless you have explicitly granted us your consent.
However, we reserve the right to disclose Personal Information that we believe to be necessary or appropriate in the following circumstances:
As required by law, such as to comply with a subpoena or similar legal process.
When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
To enforce our Terms and Conditions.
To allow us to pursue available remedies or limit the damage we may sustain.
Personally Non-Identifiable Information: We may collect personally non-identifiable information, including but not limited to demographic data, age, education level, profession, geographic location or gender, from you at the time of registration, or when you choose to use our Services. This information is not, by itself, sufficient to identify or contact you. The Company may store such information, or it may be included in databases owned and maintained by partners, affiliates, agents, or service providers of the Company. The Company may use such information and pool it with other information to track data related to growing the business, such as the total number of visitors to our Website and the domain names of our visitors' Internet service providers.
Passively Collected Information: Your visit to our Website may allow us to obtain certain additional, personally non-identifiable information that is collected passively using various technologies. This information includes but is not limited to, for example, IP addresses, browser types, date and time of page views, location information associated with your IP address, domain names, your interactions to an ad delivered by us or our ad technology partners and other anonymous statistical data involving your use of the Website and/or our services. This information cannot presently be used to specifically identify you.
Aggregated Personal Data: The Company may analyze your personal data provided through the Website or in connection with rendering the Services, in aggregate form. This aggregate information does not identify you personally. We may share this aggregate data with our partners, affiliates, agents, or service providers for business purposes. We may also disclose aggregated statistics to explain our Services to current and prospective business partners, and to other third parties for other lawful, business-related purposes.
Customer Credit Card Information. The Company may use a third-party payment processor(s) to keep a protected copy of your credit card number. This billing data belongs to you, and by utilizing the Service, you grant the Company a license to use this data to bill you for services rendered.
Tracking and Advertising. The Company’s Website may use the foregoing technologies to track your activity on our Website:
Cookies. When you visit our Website or otherwise interact with the Service, we may send one or more “cookies” to your computer or other devices. Cookies are alphanumeric identifiers stored on your computer through your web browser and are used by most websites to help personalize your web experience. Some cookies may facilitate additional site features for enhanced performance and functionality such as remembering preferences, allowing social interactions, analyzing usage for site optimization, providing custom content, allowing third parties to provide social sharing tools, and serving images or videos from third party websites. Some features on this site will not function if you do not allow cookies.
We may link the information we store in cookies to any Personal Information that you submit while visiting our Website. We may use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. Persistent cookies enable us to track and target the interest of our users to enhance the experience on our site.
Functional cookies, persistent and session type, store information to enable core site functionality, such as Live Chat and Client ID remembrance.
Analytics cookies allow us to count page visits and traffic sources so we can measure and improve the performance of our site and our marketing campaigns.
Web Beacons. Web beacons are electronic files that signal when a webpage, advertisement, video, other content, an email or newsletter has been viewed. They are usually invisible to you. We may use web beacons alone or in conjunction with cookies to compile information about our Service. Web beacons may be used within the Service to track email open rates, web page visits or form submissions. In some cases, we tie the information gathered by web beacons to your Personal Information to gauge the effectiveness of certain communications and our marketing campaigns.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third-party service provider is active only while you are connected to the Service, and is deactivated or deleted thereafter.
ETag, or entity tag. A feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks HTTP, Flash and/or HTML5 cookies.
Children. The Website and our related Services are not intended for anyone under 13, and we do not knowingly collect information from anyone under the age of 13. Anyone aged 13 or under should not submit any Personal Information without the permission of their parents or guardians. By using the Website and our related Services, you are representing that you are at least 13 years old.
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Google, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Website or Service.
Security. We maintain reasonable and appropriate, although not infallible, security precautions. However, we cannot guarantee that hackers or unauthorized personnel will not gain access to your Personal Information, despite our reasonable efforts. You should note that in using the Website and our related Services, your information will travel through third party infrastructures which are not under our control. Please feel free to raise any questions, concerns or specific directions you may have regarding the privacy and security of your information to
SMS Marketing. We may, from time to time, and with your consent, provide you special offers via SMS (“text”) messaging. If you request text offer through our website interface by providing us with your mobile number and clicking the I CONSENT button, or your text us using an advertised shortcode we have listed, that constitutes your consent to receive marketing text messages from 82Labs. You do not have to provide us with your mobile number to receive any special offers or to make any purchases. Any and all coupons, discounts, and special offers are available throughout website. Providing your mobile number is also not a condition of purchase. We send text messages through automated technology. To stop text messages from us, send STOP or reply stop to any text message you receive. For more information, please contact our support team at email@example.com. Message and data rates may apply.
Data Retention. We will retain your Personal Information for as long as needed to provide the applicable Services unless a longer retention period is required or permitted by law.
Analytics Software. We and our third-party tracking-utility partners use log files on our Service to automatically gather certain information, including but not limited to internet protocol (“IP”) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data, for analytics purposes. Specifically, we analyze trends, administer the site, track users’ movements around the Website, and gather demographic information about our user base as an in the aggregate.
Your California Privacy Rights. Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. You may request and obtain from us once a year, free of charge, certain information about the personal data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal data that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to firstname.lastname@example.org.
Google or Facebook Connect/Open ID Providers. You may log into your account on our Website and/or access our Services using sign-in services such as Google or Facebook Connect, or another Open ID provider. These services will authenticate your identity and provide you with the option to share certain Personal Information with us such as your name and email address to pre-populate our registration form. Services like Google or Facebook Connect give you the option to post information about your activities on this Website to your profile page to share with others within your network if you so choose.
Referrals. If you choose to use our referral service to tell a friend about our Services by email, we will ask for your friend’s email address, and send your friend a one-time email inviting them to visit our Website and inform them of our Services. We will only store your friend’s email address for the sole purpose of sending this one-time message and tracking the success of the referral program. Your friend may contact us at to request that we remove this information from our database at any time.
Testimonials, Ratings and Reviews. If you submit testimonials, ratings, or reviews of the Services directly on our Website, any Personal Information you include will be displayed on the Website. We may also partner with third-party service providers to collect and display ratings and review content on our Website. If you provide our third-party service providers with your Personal Information in the process of submitting your rating and review, the content and Personal Information collected by a third party will be posted on our Website, absent your express instruction not to do so. If you want your testimonial, rating, or review removed from our Website at any time, please contact us at email@example.com.
Opt-Out Policy. If at any time after registering, you change your mind about receiving information from us or about the use of information volunteered by you, or if you prefer that we do not share your Personal Information with third parties for marketing purposes, please contact us at firstname.lastname@example.org.
Contact Us. If you have any questions or concerns relating to our use of your Personal Information, please email email@example.com.
Users from the European Union
Data Controller. Smart Drinking tm.. Smart Drinking is the data controller for the processing of Personal Information, and can be contacted at the details provided above or through firstname.lastname@example.org.
International Transfers. As necessary in connection with the purposes of processing Personal Information detailed above, the Company’s authorized service providers, business affiliates, and business partners, and any other third parties with which we share Personal Information (and have informed you of the same), as well as limited members of the Smart Drinking., on a need-to-know basis. Limited members of Smart Drinking tm., that are located outside of the EEA, including in countries that may not provide the same level of data protection as your country of residence (for example, the United States), may access and otherwise process Personal Information in connection with their job responsibilities or contractual obligations. You acknowledge that we take appropriate steps to ensure that such parties are bound to duties of confidentiality to ensure that any transferred personal data, remains protected and secure.
Your Rights. You may be entitled, in accordance with applicable law, to object to or request the restriction of processing of your Personal Information, and to request access to, rectification, erasure and portability of your Personal Information. Requests should be submitted by contacting us by emailing If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may also lodge a complaint with a supervisory authority if you consider that our processing of your Personal Information infringes applicable law.