Privacy Policy

Last Updated: May 17, 2018

Cellar Door Media LLC (“Cellar Door”) has developed this Privacy Policy to help you understand how Cellar Door collects, uses and discloses information Cellar Door may collect from you and/or your device (computer, phone or other mobile device), or that you may provide to Cellar Door, while using Lockr (the “Service”). By using the Service, you agree to how Cellar Door collects, uses and discloses information that is collected from you.  If you are under 18 years old, you acknowledge that your legal guardian has consented to this Privacy Policy.  This Privacy Policy is an integral part of the Terms of Use. If you, or your legal guardian do not accept or understand this Privacy Policy, please do not use the Service.

If you have questions or complaints regarding Cellar Door’s Privacy Policy or practices, please contact Cellar Door at info@cellardoormediagroup.com.  

1. Definitions.  The following defined terms shall have the meanings set forth below:

  • Financial Information” means information relating to payments and billing (e.g., name, account information, billing address) provided by you. All Financial Information is collected for billing and payment purposes only by Cellar Door and/or our authorized third-party partners.
  • Non-Personal Information” means information that, by itself, does not identify a specific individual or entity (e.g., demographic information, usage data or downloads).
  • Personal Information” means specific identifiable information about an individual or entity which may be used to identify, contact or locate that person or entity (e.g., name, mailing address, site ID , email address or phone number).

 

2. What Information Is Collected?

Information You Provide. Cellar Door may receive and store any Personal Information, Financial Information and/or Non-Personal Information that you provide when you interact with Cellar Door or the Service. Some features and/or functionality of the Service may be unavailable if you choose not to share certain information. Cellar Door may use information you provide to communicate with you, provide you with access to the Service, and to improve the Service. Here are some examples:

  • Account Setup.  You may provide Cellar Door with Personal Information, such as your name and email address, when you register for an account on the Service.
  • Payment Information.  You may provide your Financial Information, including your credit card number, billing address and phone number when paying to use the Service. Cellar Door will share this payment information with the third-party processing company as detailed below in “How Information Is Used, Shared and Disclosed.”  Cellar Door does not store your payment information.
  • Email Communications.  Cellar Door may use your Personal Information to send you emails with respect to important information, notices, or changes relating to the Service.  Cellar Door may also use your Personal Information to send you newsletters and emails related to promotions and/or events. You can opt out of receiving promotional emails by following the instructions in the relevant correspondence. Once Cellar Door has processed your opt-out request, Cellar Door will not send you further promotional emails unless you later opt back in.
  • Contact Us.  You may choose to contact Cellar Door, either by email or by using a web form available on https://lockr.io.  When you contact Cellar Door, you may be asked to provide Personal Information and to describe the purpose for which you are contacting Cellar Door.  Even if you are not a registered user of our Service, if you email or contact us we may retain a record of such communication, including your email address, the content of your email, and our response.  If Cellar Door is aware that you are under the age of 13, Cellar Door will delete your email address once your request has been fulfilled. 
  • Other Information. You may provide other Personal and Non-Personal Information whenever you interact with the Service, including, without limitation, when you search the Service, participate in a contest, survey or questionnaire, place an order, or communicate with Cellar Door by phone or email.

Information Collected Automatically or Through Technology.  Cellar Door may receive and store certain Personal Information and Non-Personal Information whenever you interact with Cellar Door or the Service. Such information may be gathered by the following methods:

  • Cookies.  Cookies are small pieces of information that are stored on your device’s hard drive which work by assigning to your device a unique number that has no meaning outside of the Service. Cookies do not generally contain any Personal Information. Most web browsers automatically accept cookies, but you can usually configure your browser to prevent this. However, because cookies enable you to take advantage of some of the features of the Service, Cellar Door recommends that you leave them turned on or you may not have access or use of such features. The use of cookies by third-parties is not covered by Cellar Door’s Privacy Policy. Cellar Door does not have access to or control over this information.
  • Metadata.  Metadata is data collected and used to facilitate the Service, monitor system usage, prevent fraud, and for other services. Some examples of metadata that Cellar Door may collect and analyze include, without limitation, the Internet Protocol (“IP”) address used to connect your computer, tablet, mobile telephone or other electronic devices to the internet, computer and connection information (such as browser type, version, and time zone setting, browser plug-in types and versions, operating system, and platform), the full Uniform Resource Locator (URL) click sequence to, through, and from the Service, including date and time, cookie number and any products, services or features you use or interact with arising out of or in connection with your use of the Service.
  • Log files.  When you use the Service, our servers automatically record certain information in server logs. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type and language, Internet Service Provider (“ISP”), referring/exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, mobile carrier, and other such information. Log files help us to monitor, analyze, improve and maintain the Service and to diagnose and fix any Service-related issues.
  • Tools.  Cellar Door may use software tools to measure and collect information about your use of the Service, including, without limitation, response times, upload and transfer errors, interaction information (such as scrolling, clicks, and mouse-overs), features use, purchase tracking and order fulfillment and methods. Sometimes, you will have a choice whether or not to provide information, but if you fail to provide certain information it could impact some features and/or functionalities of the Service.
  • Location Information.  Cellar Door does not ask you for, access, or track any location-based information at any time while using the Service.
  • Information from Other Sources.  Cellar Door may receive information about you from Cellar Door’s third-party service providers, or other sources such as purchase information, Service usage, payment information, reporting information, page-view information, technical, fulfillment, advertising, search information and credit history information.
  • Local Storage Objects.  Cellar Door uses Local Storage Objects (“LSOs”) such as HTML5 or Flash to store content information and preferences.  Third-parties with whom Cellar Door partners to provide certain features on Cellar Door’s site or to display advertising based upon your web browsing activity use LSOs such as HTML5 or Flash to collect and store information.  To manage Flash LSOs, please click here:http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

 

3. How Information Is Used, Shared and Disclosed.  Cellar Door does not sell, and generally does not disclose, your Personal Information to third-parties without your consent. Cellar Door uses Personal, Non-Personal and Financial Information, among other things, to monitor system performance, analyze internal business systems, improve the Service, fulfill requests for additional products and services, contact you about promotional and marketing activities, provide customer support, and conduct research. The use and protection of information is an important component of Cellar Door’s business. Examples of how Cellar Door shares and discloses your information is as follows:

 

  • Legal.  Cellar Door may disclose information you provide to respond to subpoenas, court orders, requests from authorities, and other legal processes, and to establish/exercise Cellar Door’s legal rights. Cellar Door may also disclose your information to defend against legal claims when Cellar Door believes that disclosure is necessary to protect Cellar Door’s rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. Cellar Door may share Personal Information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, and situations involving potential threats to the physical safety of any person, violations of Cellar Door’s Terms of Use, or as otherwise required by law.
  • Business Transfers.  As Cellar Door continues to develop its business, Cellar Door may reorganize as a business entity, acquire entities, subsidiaries, or business units, or enter into joint ventures with third-parties. In any of these types of transactions, any information you provide may be one of the transferred business assets. In the event that all or substantially all of Cellar Door’s assets are acquired, or Cellar Door merges with a third-party, your information will likely be one of the transferred assets. You understand and agree that Cellar Door reserves the right to transfer any information collected from you in the case of any such transfer. In such event, Cellar Door will use reasonable efforts to notify you before your Personal Information is transferred and becomes subject to a different privacy policy.
  • Third Party Service Providers.  Cellar Door may use third-party companies and individuals to perform functions on Cellar Door’s behalf. Examples include fulfilling orders, processing payments, hosting, data storage, sending postal mail and email, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, and providing customer service. Cellar Door will provide such third parties with access to certain information needed to perform their functions. They are required to have a privacy policy and security standards in place that are at least as protective of your information as is this Privacy Policy. Cellar Door may also store Personal Information in locations outside of its direct control (for instance, on servers or databases co-located with hosting providers). Currently, Cellar Door uses the following third-party companies for the purposes listed with each company:
  1.  Google Analytics – Process basic Google analytics to improve business operations and performance.
  2.  Stripe – Process customer payment transactions.
  3.  MailChimp – Conduct email marketing initiatives.
  4.  Amazon Web Services - Site information – Provides server and data storage services.

 

4. Legal Basis for Processing (EEA only).  If you are an individual from the European Economic Area (“EEA”), our legal basis for collecting and using your Personal Information depends on the Personal Information concerned and the specific context in which Cellar Door collects it. However, Cellar Door will normally collect Personal Information from you only when Cellar Door: (a) has your consent to do so, (b) needs the Personal Information to perform a contract with you (e.g. to deliver the Service), or (c) or a third party has a legitimate interest in processing the Personal Information (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, Cellar Door may also have a legal obligation to collect Personal Information from you or may otherwise need Personal Information to protect your vital interests or those of another person.

Where Cellar Door relies on your consent to process Personal Information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of any processing based on consent before you withdraw your consent.

If Cellar Door asks you to provide Personal Information to comply with a legal requirement or to perform a contract with you, Cellar Door will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information). Similarly, if Cellar Door collects and uses your Personal Information in reliance on Cellar Door’s (or a third party’s) legitimate interests which are not already described in the notice, Cellar Door will make clear to you at the relevant time what those legitimate interests are.

If you have any questions about or need further information concerning the legal basis on which Cellar Door collects and uses your Personal Information, please contact Cellar Door using the contact details provided below.

 

5. Security.  The security of your Personal Information is important to Cellar Door. Cellar Door follows generally accepted industry standards to protect the Personal Information submitted to Cellar Door, both during transmission and once it is received. No method of transmission over the internet, or method of electronic storage, is 100% secure, however. Therefore, Cellar Door cannot guarantee its absolute security. While no security system is completely secure, Cellar Door takes commercially reasonable and industry-standard security measures to protect against unauthorized access or disclosure of the information it collects.  For Cellar Door, this includes, but is not limited to, ensuring that all Personal and Financial Information is disclosed only on a “need to know” basis and ensuring that all Personal Information collected by Cellar Door is done so via secured connections and protected and encrypted (using secure socket layer technology, “SSL”) by industrial grade security software to guard against unauthorized access.  Personal Information is encrypted prior to storage to ensure the highest level of protection possible.

 

6. Links to Other Sites.  Cellar Door is not responsible for the practices employed by websites linked to from within the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, this Privacy Policy is no longer in effect and your activities on that third-party website are subject to such third-party website’s own rules and policies.

 

7.  International Data Transfer.  Cellar Door may transfer information that is collected about you, including Personal Information, to affiliated entities, or to other third-parties (as provided herein) across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that Cellar Door may transfer information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to these other jurisdictions and the use and disclosure of information about you, including Personal Information, as described in this Privacy Policy.

Whenever Cellar Door shares Personal Information originating in the EEA with a third-party outside the EEA, it will rely on other lawful measures to transfer your Personal Information outside the EEA and Switzerland, such as the EU standard contractual clauses or Privacy Shield Framework detailed in Section 7 above.

If you are visiting a Cellar Door website from the EEA or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your Personal Information to the United States and other jurisdictions in which Cellar Door operates. By providing your Personal Information, you consent to any transfer and processing in accordance with this Privacy Policy.

If you are visiting a Cellar Door website from the EEA or other regions with laws governing data collection and use, please note that by providing this Personal Information, you acknowledge that your Personal Information may be transferred to the United States and other jurisdictions in which Cellar Door operate.

 

8.  Additional Rights for EEA and Certain Other Territories. If you are from certain territories (such as the EEA), you may have the right to exercise additional rights available to you under applicable laws, including:

  • Right of erasure: In certain circumstances, you may have a broader right to erasure of your Personal Information. For example, if Cellar Door no longer needs the information for the purpose the information originally was collected. Please note, however, that Cellar Door may need to retain certain information for record keeping purposes, to complete transactions, or to comply with its legal obligations.
  • Right to object to processing: You may have the right to request that Cellar Door stop processing your Personal Information and/or to stop sending you marketing communications.
  • Right to restrict processing: You may have the right to request that Cellar Door restrict processing of your Personal Information in certain circumstances (for example, where you believe that the Personal Information Cellar Door has collected about you is inaccurate or unlawfully held).
  • Right to data portability: In certain circumstances, you may have the right to be provided with your Personal Information in a structured, machine readable and commonly used format and to request that Cellar Door transfers your Personal Information to another data controller without hindrance.

If you would like to exercise such rights, please contact Cellar Door using the contact details provided below. Cellar Door will consider your request in accordance with applicable laws. To protect your privacy and security, Cellar Door may take steps to verify your identity before complying with the request.

You also have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.

 

9. Access/Data Retention.  If your information changes, or if you no longer desire the Service, you may make corrections and updates, delete inaccuracies, or request deletion or further contact with you or by updating your account information or by contacting Cellar Door at info@cellardoormediagroup.com. Cellar Door will respond to your request within 15 days.

Cellar Door will retain your information for as long as your account is active, or as needed to provide Services. If you wish to cancel your account or request that Cellar Door no longer use the information to provide Services, contact Cellar Door at the email address listed above. Cellar Door will retain and use the information as necessary to comply with our legal obligations, resolve disputes and/or enforce our agreements.

 

10.  Children’s Privacy.  The Service is not directed to persons under 13. Cellar Door does not knowingly collect or solicit Personal Information from anyone under the age of 13 or knowingly allow such persons to register for an account on the Service. If Cellar Door becomes aware that it has collected Personal Information from a child under age 13 without verification of parental consent, Cellar Door will take steps to remove that information. If you believe that Cellar Door may have any information from or about a child under 13, please contact us at info@cellardoormediagroup.com.

 

11. Conditions of Use/Changes to This Privacy Policy.  Cellar Door may update this Privacy Policy to reflect changes to information practices.  If Cellar Door changes its Privacy Policies, it will post those changes on this page to keep you aware of what information it collects, how it is used, and under what circumstances Cellar Door may disclose the information.  Changes to this Privacy Policy are effective when they are posted on this page.

 

12. Contact Us.  If you have questions or comments regarding how Cellar Door protects your information or this Privacy Policy, please contact us at:

 

Attn: Privacy Policy Issues
Phone: (920) 385-6257
Email: info@cellardoormediagroup.com
Address: 
Cellar Door Media, LLC
938 Broadway
Tacoma, WA  98402