Privacy Policy

Transparency: Pepin Distributing Company (“PDC”), provides clear notice of its privacy practices through a single Privacy Policy that is readily accessible across all PDC Web Sites. PDC also provides clear information about its online advertising practices.

Choice: PDC allows you to enjoy content and features on the PDC Web Site without directly providing any contact information.

If you choose to share contact information with us, PDC will identify any options you have for controlling the use of this information at the time it is collected.
You are also given the opportunity to opt out of commercial email or text messages from the PDC Web Site or service by following the instructions contained in any such message.
You have choices about the collection and use of your data by third parties to deliver relevant advertising, as described in our overview of third-party online advertising.

Access: PDC allows you to update or disable the contact information you have provided through our Web Site.

Security: PDC has adopted commercially reasonable information security policies and practices to help protect your information.

Accountability: PDC responds to user inquiries, participates in industry programs, and has adopted privacy practices that are consistent with applicable country, state, and local data protection laws.

If you have any questions about these principles or PDC’s Privacy Policy, please contact us.

Important Privacy Policy Highlights

Scope of Privacy Policy

PDC owns, operates, or provides access to, additional interactive web sites and other interactive features that provide an authorized link to the PDC Privacy Policy (collectively “PDC Web Sites”). This Privacy Policy, effective June 6, 2012, is guided by a core set of Privacy Principles and applies only to the PDC Web Sites.

Information Collected

We collect a variety of information about you, including:

Information you provide directly to a PDC Web Site.
Information about your computer and browsing activities on the PDC Web Sites, including through cookies, web beacons, and other technologies.
Information about you from other sources where permitted by law.

Use of Information

We use the information we collect:

To provide the services you request.
To tell you about offers we think you will value.
To customize the content and advertising you see.
To improve your experience on PDC Web Sites.
As otherwise described to you at the point of collection or with your consent.

Disclosure of Information

We may share your information:

When we have obtained your consent.
With our third-party service providers.
With business partners who sponsor a sweepstakes, contest, or promotion or who jointly offer a service or feature with a PDC Web Site.
To protect or defend the rights of PDC or our users.
When required by law or public authorities.

Your Choices

If you choose to share contact information with us, you will have the opportunity to update that information.
You can stop the delivery of commercial email messages from a PDC Web Site or service by following the instructions in any such email you receive.

You have choices about the collection and use of your information by third parties to display relevant advertisements, as described in our overview of third-party online advertising.

Other Information

PDC is committed to working with you to obtain a fair resolution of any privacy concern.
We have adopted commercially reasonable procedures to help protect your information, but please note that no data transmission or storage can be guaranteed to be 100% secure.

How to Contact Us

If you have questions regarding the PDC Privacy Policy, please contact us.

PDC Privacy Policy

Effective Date: June 8, 2012

Pepin Distributing Company (“PDC”), is committed to protecting your privacy. PDC owns, operates, or provides access to, interactive web sites and other interactive features that provide an authorized link to this Privacy Policy.

This Privacy Policy describes, among other things, the types of information collected about you when you visit a PDC Web Site; how your information may be used and when it may be disclosed; how you can control the use and disclosure of your information; and how your information is protected.

1. Scope of Privacy Policy

This Privacy Policy applies to information, including contact information, collected about you by a PDC Web Site. This Privacy Policy does not cover any information collected through any other web site. Please note that some PDC Web Sites may contain links to non-PDC Web Sites. We are not responsible for the privacy practices of those sites, and we recommend that you visit the privacy policies of each web site that you visit.

2. Information Collected

Information you provide directly to PDC Web Sites

You are not required to provide information about yourself when you visit a PDC Web Site. PDC Web Sites may ask you for some or all of the following types of information when you register for certain services, access various content or features, or directly contact the Web Site:

Contact information, such as name, email address, postal address, phone number, facsimile number, and mobile number;
User name, password, and password reminder questions and answers;
Age and date of birth;
Other demographic information, such as gender, job information, and zip code;
Information for a public profile, such as your interests and the address of your web site;
Communications preferences, such as which newsletters you would like to receive;
Search queries;
In limited circumstances, payment and identity verification information, such as credit card number, social security number or comparable national identifiers, and driver’s license number where needed for payment or to access a particular service (e.g., contests);
Contact information about others when you provide information about others or refer a friend to a particular site or service (note: such information is used solely to facilitate the communications requested);
Information posted in community discussions and other interactive online features;
Correspondence you send to us; and
Information collected about you offline (including via facsimile, mail, or in person for sweepstakes entrance forms).

Information we collect automatically on PDC Web Sites.PDC Web Sites may collect certain information automatically, including:

Your browser type and operating system;
Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;
Sites you visited before and after visiting a PDC Web Site;
Web pages and advertisements you view and links you click on within PDC Web Sites;
Unique identifiers, including mobile device identification numbers, that can identify the physical location of such devices in accordance with applicable law;
Information collected through cookies, web beacons, and other technologies;
Information about your interactions with video content, such as the type of content viewed, and information about your interactions with email messages, such as the links clicked on and whether the messages were opened or forwarded;
Upon request, your bandwidth speed and information about the software programs installed on your computer; and
Standard server log information.

Information we obtain from other sources. We may collect information about you from other sources, including through interactive applications (such as mobile devices, third-party services, and embedded video players), from co-branded partners, and from commercially available sources (such as data aggregators and public databases). The following are examples of information we may collect from other sources:

Name, postal address, and telephone number;
Demographic data, such as age, gender, and income level;
If you access third-party services (such as Facebook Connect) through a PDC Web Site, your username and password for those services and other information available about you on those services;
Your interests and purchase behavior;
Publicly-observed data, such as activities on blogs, videos, and other online postings; and
Other navigation data, such as web sites visited and advertisements viewed or clicked on.

Please note that all of the information we collect about you may be combined, including to help us tailor our communications to you and to develop rich online content and services across the PDC Web Sites.

3. Use of Information

We only use payment and identity verification information, such as credit card numbers, driver’s license numbers, social security numbers, or comparable national identifiers as necessary for completing a particular transaction or fulfilling a service (e.g., paid subscriptions or awarding prizes to contest winners) or as otherwise required by law.

We generally use other information we collect about you to:

Fulfill your requests for products, services, and information, including to send you electronic newsletters, authorize a purchase, and complete a transaction that you have requested;
Enable you to participate in features such as surveys, polls, sweepstakes, and message boards;
Provide you with special offers and promotional materials on behalf of PDC Web Sites, companies within our corporate family, and third parties, in accordance with applicable law;
Analyze the use of PDC Web Sites and information about visitors to our Web Sites to understand and improve our service offerings;
Customize the content you see when you visit a PDC Web Site;
Prevent potentially prohibited or illegal activities and otherwise in accordance with PDC’s Terms of Use; and
For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

4. Disclosure of Information

PDC is committed to maintaining your trust and we want you to understand when and with whom we may share information collected about you.

With your consent. You may be asked to consent to have your contact information shared with third-party business partners. For example, PDC Web Sites sometimes run contests with prizes provided by a beverage manufacturer (e.g. a contest with a prize provided by the manufacturer). When entering such a contest you may be asked if the third party may contact you to provide information about their products or serices or to provide you with special promotional opportunities.
Authorized third-party service providers. We share your information with third-party vendors who help us with specialized services, including customer support, email and text message deployment, business analytics, marketing, and data processing. These third parties are allowed to use your contact information to help us provide our services and not for any other purpose.
Sweepstakes, contests, or promotions. When you choose to enter a sweepstakes, contest, or other promotion, and in accordance with the terms and conditions of the promotion, your information may be disclosed to sponsors and third parties who help administer the promotion, including in connection with winner selection and prize fulfillment. Your information also may be disclosed as required by law, such as on a winners list. Also, by entering a promotion, you are agreeing to the official rules that govern that promotion, including allowing the sponsors to use your name, voice, and likeness in advertising and marketing associated with the promotion in accordance with applicable law.
Co-Branded Partners. Co-Branded Partners are third parties with whom a PDC Web Site may jointly offer a service or feature. You can tell when you are accessing a service offered by a Co-Branded Partner because the Co-Branded Partner’s name will be featured prominently. You may be asked to provide information about yourself to register for a service offered by a Co-Branded Partner. In doing so, you may be providing your information to both us and the Co-Branded Partner, or we may share your information with the Co-Branded Partner. Please note that the Co-Branded Partner’s privacy policy may apply to its use of your information.
Legal requirements. We may disclose information about our users, including contact information, to respond to subpoenas, court orders, legal process, and other law enforcement measures, and to comply with other legal obligations, such as the department of professional and business regulations.
Protect our Web Sites and users. We may disclose information to protect and defend the legal rights, interests, and safety of PDC Web Sites, (including enforcing our agreements); to protect the safety and security of users of the Web Sites and members of the public; and as otherwise disclosed in our Terms of Use.

Please note that we may share information with manufacturers. We also may share aggregated or anonymized information with third parties, including to help us develop content and services we hope you will find of interest. This information cannot be used to individually identify you.

5. Your Choices

You can choose to enjoy content and features on PDC Web Sites without directly providing us with any information about you; however, as described above, some information may automatically be collected or may be requested so you can take advantage of certain features and services offered on PDC Web Sites.

You can opt out of receiving commercial email or text messages from a particular PDC Web Site or service by following the instructions contained in any such message. Please note that even if you unsubscribe to commercial messages, we still may need to send you communications relating to your use of the PDC Web Sites, such as service announcements.

6. Access

If you choose to share contact information with us, you may have the opportunity to update that information on a PDC Web Site. You also may update or amend your information by contacting us. If you ask us to shut down your account or delete your information, we will disable your account within a reasonable period of time. Please note that we may need to retain some information about you in order to satisfy our legal and security obligations. For example, some of your information may remain in back-up storage even if you ask us to delete it. In some cases, you may be entitled under local laws to access or object to the processing of information that we hold relating to you.

7. Protection of Information

We are committed to protecting your information. We have adopted commercially reasonable technical, administrative, and physical procedures to help protect your information from loss, misuse, and alteration. Please note that no data transmission or storage can be guaranteed to be 100% secure. We want you to feel confident using PDC Web Sites but we cannot ensure or warrant the security of any information you transmit to us. Please refer to the U.S. Federal Trade Commission’s web site for information on how to protect yourself from identity theft.

8. Visiting from Outside the United States

PDC is headquartered in the United States. Please be aware that information you provide to us or we obtain as a result of your use of the PDC Web Sites may be processed and transferred to the United States and be subject to United States law. The privacy and data protection laws in the United States may not be equivalent to such laws in your country of residence. By using and participating in any PDC Web Site or providing us with your information, you consent to the collection, transfer, storage, and processing of information to and in the United States.

9. California Visitors

Residents of the State of California may request a list of all third parties to which a PDC Web Site has disclosed certain information during the preceding year for the third parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us. For all requests, you must put the statement “Your California Privacy Rights” in the subject field of your email and include the name of the PDC Web Site with respect to which you are requesting the information, as well as your name, street address, city, state, and zip code. Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

10. Privacy Protections for Persons Under 21 Years of Age

The PDC Web Sites are intended for an audience over the age of 21 and do not knowingly collect or store contact information about persons under the age of 21. Some PDC Web Sites may ask for a birth date to ensure that they are not collecting information from persons under 21.

11. User-Generated Content

Some PDC Web Sites enable users to submit their own content for contests, blogs, videos, message boards, and other functions. Please remember that any information you disclose becomes public information and exercise caution when deciding to disclose your contact, financial, and other information in a submission. We cannot prevent such information from being used in a manner that may violate this Privacy Policy, the law, or your personal privacy and safety.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices and service offerings. If we modify our Privacy Policy, we will update the “Effective Date” and such changes will be effective upon posting. If we make any material changes in the way we use your information, we will notify you by sending an email message to the email address you most recently provided to us or by prominently posting a notice of the changes on PDC Web Sites.

13. Questions

If you have questions regarding this Privacy Policy, please contact us and we will endeavor to respond to your request within a reasonable period of time. You may also submit questions or comments using the postal address listed below:

Pepin Distributing Company
4121 N. 50th Street
Tampa, FL 33610

We are committed to working with you to obtain a fair resolution of any privacy concern.

Cookies, Web Beacons and Other Technologies

Cookies

Cookies are small amounts of data that are stored in separate files within your computer’s Internet browser. Cookies are accessed and recorded by the web sites you visit, and by the companies that show advertisements on web sites, so they can recognize the same browser navigating online.

PDC Web Sites use cookies for the following general purposes:

To help us recognize your browser as a previous visitor and save and remember any preferences that may have been set while your browser was visiting one of our Web Sites. For example, if you register on a PDC Web Site, the Web Site may save your password so you do not have to re-enter it each time you visit.

PDC Web Sites may also allow third parties to place their own cookies within your browser in order to serve you with relevant advertising online. Please note that we do not share contact information with these third parties and PDC can only access cookies that we set on your browser, not the cookies sent to you by other companies.

You have the choice to set your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. (Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.) It is up to you whether to allow us or third parties to send you cookies, but if you block cookies, you may not be able to view or access some or all of a PDC Web Site.

Web Beacons and Other Technologies

We may use standard Internet technology, such as web beacons and similar technologies, to track your use of the PDC Web Sites. Web beacons (sometimes called transparent GIFs, clear GIFs, or web bugs) are small strings of code that provide a way for us to deliver a small graphic image (usually invisible) on a web page or in an email. Web beacons can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed.

We use web beacons to improve your experience on our Web Sites, including to provide you with content customized to your interests and to understand whether users read email messages and click on links contained within those messages so that we can deliver relevant content and offers. Our web beacons may collect some contact information (for example, the email address associated with an email message that contains a web beacon).

PDC Web Sites also may include third-party web beacons so that these third parties may receive auditing, research, and reporting information about advertisements viewed on the PDC Web Sites. Third parties do not have access to your contact information in connection with their use of web beacons.

Mobile Devices

Certain mobile devices contain unique identifiers that can be used, for example, to identify the physical location of such devices. Mobile devices also typically transmit caller ID data when used to transmit a telephone call or text message. PDC Web Sites may collect, use, transmit, process, and maintain unique identifiers, caller ID data, location-based data, and similar information when you rely on mobile devices, including to provide the services you request, tell you about offers we think you will value, and improve your experience on PDC Web Sites. PDC Web Sites also may require collection of your mobile phone number in order for you to participate in certain services or features and that number may be associated with such information.

PDC Online Advertising

In order to customize your experience on the PDC Web Sites, we may use cookies, web beacons, and other technologies to collect information about the content and advertisements you view on our Web Sites. Based on this information, and other information we may collect about you, we try to infer your interests and show content and advertising that is more relevant to you. For example, if you access an article about computers on one PDC Web Site, we may show you a computer-related advertisement on another PDC Web Site based on your apparent interests.

We also may receive information from third parties about you and your activities on other sites for the purpose of serving relevant advertisements to you on PDC Web Sites. For example, if you access an article on a third-party site about computers, we may use that information to serve you with a computer-related advertisement on a PDC Web Site.

Please note that we may share information about our users with manaufacturers so that they can measure the effectiveness of advertisements viewed on the PDC Web Sites. For example, we may tell manufacturers the number of users who clicked on a particular advertisement.

These online-advertising efforts across PDC Web Sites do not result in you seeing more advertisements, just more relevant advertising, and they allow us to provide you with free content and services on our Web Sites. We hope you value our efforts to show you content and advertising that more closely reflects your interests.

Have you made any substantively material changes to the Privacy Policy?

No, we have not made any substantively material changes to our Privacy Policy. We have simplified the policy, made it uniform across PDC Web Sites, and made it easier to follow.

What are the “core” privacy principles that PDC follows?

Trust is a cornerstone of our mission at PDC. We are committed to gaining and maintaining your trust by following five key principles: transparency, choice, access, security and accountability.

Will you share my contact information with third parties?

Like other businesses, we share contact information (such as name and email address) with vendors who process credit card transactions, with business partners who co-sponsor our Web Sites, and when we have consent from our users.

Can you give me an example when you will share my information with third parties?

If you enter a sweepstakes that is jointly sponsored by a third party, we will share your contact information with that third party.

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