Privacy Policy PARODI HOLDINGS LLC Doing Business As Avanti Cigar CO

Last modified: July 15^th, 2020

This privacy policy is in place to give you information about Parodi Holdings LLC DBA Avanti Cigar Company’s privacy practices. More specifically, we are providing this policy so that you can understand what information we collect, how we use it, and when and with whom we may share it. We do this so that you may be informed about how we use your personal information and the choices you have regarding that use.

This privacy policy applies to information we collect online, through the Parodi Holdings LLC website DBA Avanti Cigar Company, located at https://www.avanticigar.com/ (which we refer to in this privacy policy as the “site”, which includes all content, functionality, and services offered on or through the site.

In addition, because Parodi Holdings LLC DBA Avanti Cigar Company fulfills and ships orders placed through the Toscano Cigar online store, located at www.toscanocigars.com/shop (the “Toscano Cigar Shop”), this privacy policy also applies to information that we collect in connection with such fulfillment and shipment.

The Avanti Cigar Company site is owned and operated by Parodi Holdings LLC DBA Avanti Cigar Company who we refer to, together with our affiliates, as “us”, “we” or “our”. When we refer to “you” and “your” in this privacy policy, we are referring to you as a visitor to and user of the site and/or the Toscano Cigar Shop.

The Toscano Cigar Shop website is owned and operated by Manifatture Sigaro Toscano S.p.A. (“Toscano SpA”).

We are committed to respecting the privacy and security of the personal information of every individual who uses our site and who makes purchases through the Toscano Cigar Shop.

PLEASE READ THIS PRIVACY POLICY COMPLETELY AND CAREFULLY BEFORE USING THE SITE, MAKING PURCHASES THROUGH THE TOSCANO CIGAR SHOP, OR SUBMITTING ANY INFORMATION, PARTICULARLY PERSONAL INFORMATION, TO US. BY USING THE SITE AND/OR MAKING PURCHASES THROUGH THE TOSCANO CIGAR SHOP, YOU ARE AGREEING TO THESE PRIVACY TERMS.

1. APPLICABILITY OF THIS PRIVACY POLICY

This privacy policy applies only to information provided and collected through the site and through our fulfillment of orders through the Toscano Cigar Shop. It does not apply to information that we or other parties may collect through other means, such as information we may learn through a business or employment relationship with you, or information you may provide to us in person at an event or over the phone. It also does not apply to information collected through social media sites, even if we link to those sites or communicate with you on those sites (such as through an exchange of comments on the Avanti Cigar Facebook and Instagram page).

Information collected by Toscano SpA through the Toscano Cigar Shop and through their www.toscanocigars.com website is governed by Toscano SpA’s privacy policy, located at https://www.toscanocigars.com/privacy-policy/

Because of changes in Internet technology and practices, this privacy policy may change from time to time. It is our practice to post any changes we make to this privacy policy on this page, and any changes will be effective once the new policy is posted. It is your responsibility to check this privacy policy for updates. You will be able to determine when this privacy policy was last updated by referring to the “Last Modified” legend at the top. By using the site or the Toscano Cigar Shop after we post any changes to this privacy policy, you agree to accept those changes, whether or not you have reviewed them.

2. How We Collect and Use YOUR PERSONAL Information

The Meaning of Personal Information. Personal information refers to information that we can use to personally identify a specific individual. Different states and countries define personal information (and similar terms, such as personal data, personally identifiable information, and PII) to include different things, but it generally includes information like your name, mailing address, e-mail address, and phone number. It may also include your computer or mobile device IP address, if that IP address can be linked to a particular person, or geo-location information, again if that information can be used to pinpoint a specific person.

Providing Personal Information Is Your Choice. You are in control of whether you provide us with any personal information – we do not automatically collect personal information, and you can visit and view the site and the Toscano Cigar Shop without disclosing any personal information about yourself. However, if you choose to make use of certain features of the site or to make purchases through the Toscano Cigar Shop, you may need to provide certain personal information to us. The type of information you may be asked to provide, and the circumstances in which we request that information, are described below. If you are not comfortable with providing particular information, you should not use these features or provide your information. That will affect our ability to provide you with products and services through the site and/or the Toscano Cigar Shop; however, that is your choice.

The Personal Information We Collect. Below is information about the information we collect, our purposes and legal bases for collecting and using the information, and our retention practices. We have presented the information below based on the categories of information collected so that you can better understand how and when we collect and use information. However, please be aware that similar specific pieces of information may apply to multiple categories. For example, your name and address may be included within each of the “Identification and Contact Information,” “Age Verification Information,” “Billing Information,” and “User-Generated Information” categories.

• Identification and Contact Information
  • This is information that identifies you as an individual, such as your first and last name, information that allows us to confirm your identity, such as your government-issued ID information and birth date, and information that enables us to contact you, such as your email address, mailing address, or phone number. This information is collected when you create an account on our site, when you sign up for our rewards program, when you make a purchase through either our site or the Toscano Cigar Shop, when you opt in to receive newsletters and other promotional materials, and when you participate in any interactive services or features, such as surveys, contests, promotions, and interactive forums on our site, such as review features and blog pages. We will also be provided with your name and email address when you email us using any “Contact Us” feature of the site or regarding your Toscano Cigar Shop purchases, as well as any other information you include in your message.
  • We collect and use this information for the purposes of (a) verifying your identity and confirming your eligibility when you make a purchase, create an account, or sign up for our rewards program; (b) managing and personalizing your experience on the site; (c) transacting business with you, which includes administering your account and providing you with products and services, contacting you regarding your purchase or your account, delivering products to you, and seeking feedback on products, services or events; (d) responding to any inquiry you send to us; (e) subject to your right to opt out and subject to applicable law, sending you newsletters and other promotional materials about products and services you may be interested in; (f) complying with legal requirements, including requirements relating to the tobacco industry; and (g) preventing and addressing fraud and breaches of our site and the Toscano Cigar Shop requirements and policies.
  • Our legal basis for processing this information is our legitimate business interests, specifically our ability to offer our products and services and to engage in marketing to our customers, and to fulfill orders placed through the Toscano Cigar Shop.
  • We will retain this information for as long as we continue to have a business need to do so (which will be at least as long as you continue to maintain an active account on the site or at the Toscano Cigar Ship, or have a rewards program membership with us), unless a longer period is required by law. Business needs include legal, taxation, accounting, risk management, and other business purposes.
• Age Verification Information
  • This is information that verifies your birth date using trusted data sources or public records, such as government birth records and other official public records. This includes information that you provide as well as information we obtain from third parties, such as our third party age verifier and the party maintaining the public records.
  • We collect this information because we are required by law to ensure that we provide tobacco products only to people who meet the legal age requirements. Therefore, if you want to register for an account, sign up for our rewards program or newsletters, or make a purchase, we need to verify your age. We will do this by using agechecker.net, a third party age verifier, to verify your identity and validate the age you provide using public records.
  • Our legal basis for processing this information is that we have a legal obligation to do so.
  • We will retain this information only as long as necessary to complete the verification process and as otherwise required by law.
• Billing Information
  • If you purchase products through the site or the Toscano Cigar Shop, or if you sign up for any paid event or service on the site, we will collect applicable billing information, such as credit card or bank account information. This information may be collected through a third-party service provider.
  • We collect and use this information to process required payments.
  • Our legal basis for processing this information is your contractual agreement to pay for products and any events or services we may offer from time to time.
  • We will retain this information only as long as necessary to complete your purchase, unless you have opted to save your billing information. If you do so, we will retain the information as long as you maintain this information in your registered account profile.
• User-Generated Information
  • If you participate in any interactive area of our site, we will collect any personal information that you include as a part of your participation. The specific information collected will depend on the nature of your participation and submission, but may include information such as your name, image, likeness, and voice.
  • We collect and use this information for the purpose of allowing our customers and fans to participate in events and to engage with interactive features on our site.
  • Our legal basis for processing this information is your consent.
  • We will retain this information for so long as we continue to have a business need to do so, unless a longer period is required by law. Note that while you can in some circumstances request removal of this type of information, as described in this privacy policy below, in some cases we may not be able to remove personal information voluntarily disclosed by you due to technical limitations (for example, the data may not be searchable). We will inform you if we cannot remove information as requested.
  • A Special Note About User-Generated Information. If you use interactive features of the site that allow you to post content on the site, such as a product review, a blog comment, or other user forum, that information will be considered public, and it will be able to be seen and republished by others for as long as the page remains active, and may be visible longer if pages are archived or cached. We are not responsible for the personal information you choose to post in this manner, and we encourage you to think carefully before posting anything in any public area of our site.
• Location Data
  • If you access the site on a mobile device, depending on your permissions and settings, certain location data may be collected. The specificity of the location data will depend on a number of factors, including the device you are using (smartphone or tablet), and how you are connected to the Internet (cellular or WiFi). Most mobile devices allow users to disable location services, usually via the device settings menu. If you have questions about disabling your device’s location settings, you should contract your mobile service provider or device manufacturer.
  • We will ask for and collect this information because some features of the site may need this information to function, such as any “Find a retailer near you” or “Local events” features.We use this information in order to provide the applicable location-based content to you.
  • Our legal basis for processing this information is our legitimate business interest in providing our customers with products and services, and in understanding where our users are accessing and using our site.
  • We will retain this information only as long as the location services are active on your device.

3. HOW AND WHY WE SHARE PERSONAL INFORMATION

We may share personal information with third parties in the following circumstances:

• We will provide personal information to our trusted service providers who need to use that information to conduct business on our behalf. For example, our service providers may:
  • complete the required age verification;
  • process payments made when you make purchases;
  • deliver products you have ordered;
  • handle our data management and newsletter and email distribution; or
  • assist us with, co-sponsor, or otherwise participate in any surveys, contests, events, and promotions.

We provide these service providers only with the information they need to perform their services, and work with them to respect and protect your privacy.

• We may share your personal information with our corporate affiliates and business partners for our and their legitimate business purposes, including so that we or they may provide you with periodic mailings regarding products, services, or events. If you do not wish for us to share your information in this manner, please let us know by contacting us at customerservice@avanticigar.com.
• We will share personal information with third parties for other purposes if we have your express “opt-in” consent to do so.
• We will release information, including personal information, if we believe that such action is appropriate to (a) comply with law, regulations, legal process or governmental request, (b) enforce any policies applicable to the site and/or the Toscano Cigar Shop, including potential violations, (c) detect, prevent or otherwise address fraud, security or technical issues, or (d) otherwise protect the rights, property or personal safety of us, our employees, site and Toscano Cigar Shop users and visitors, or others.
• We may share information, including personal information, in connection with, during negotiations of, or as a part of the closing of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company in which personal information about the users of our site and/or customers of the Toscano Cigar Shop is among the assets transferred.

We do not sell, rent, or lease any personal information that we collect about you through the site or the Toscano Cigar Shop to anyone for any purpose, other than as disclosed, unless you have given us your separate express permission to do so.

4. How We Collect and Use Non-Personally Identifiable Information

What is Non-Personally Identifiable Information? Non-personally identifiable information, also called NPII, refers to information that is not and cannot be used to identify a specific individual. This may include information about the statistical characteristics of the visitors to our site and/or the Toscano Cigar Shop. While this information may define how you fit into a particular group of people, it is not unique to you, and it cannot be used (without other information) to specifically identify you.

How and Why We Collect NPII. Like most websites, our site automatically collects certain information as you browse, but the data we collect in this manner is limited to “browsing data,” which is data that is automatically collected by the computer systems responsible for the management and operation of the site and the use of Internet communication protocols. Browsing data may be used to understand how you use the site, which pages you visit, and what content you view. More information about the technology we use to automatically collect information is provided below under the heading “Cookies and Other Tracking Technology.”

In addition, NPII includes some of the demographic information that you may provide when you use our site or make purchases through the Toscano Cigar Shop. Demographic information includes things like gender, age, ZIP code, interests, and product purchase information, once separated from any identifying information. Unless a particular law requires that we treat any standalone demographic data as personal information, or unless we associate it with any personal information in a way that would allow your demographic information to identify you, we will not treat it as personal information under this privacy policy. NPII will also include the personal information we collect that has been anonymized or de-identified, which means we have removed any personally identifiable elements.

All of the NPII we collect may be used to understand our visitor and customer base, to gather broad demographic data for aggregate use, to conduct market research, to analyze trends, to develop products and services, and to provide those products and services to other users and third parties.

If we associate any NPII with the personal information you provide us, we will treat the associated information as personal information, in accordance with this privacy policy. This may be required if we or our service providers need to recognize you as you use the site, such as to keep track of your subscription preferences, or to enable your use of a “shopping cart.”

5. COOKIES AND OTHER TRACKING TECHNOLOGY

How We Place Cookies. When you view the site, we might store some information on your computer in the form of a “cookie” or similar file. “Cookies” are small text files that are either used for the duration of a session (‘session cookies’), or saved on a user’s hard drive in order to identify that user the next time he/she logs on to the site (‘persistent cookies’). Session cookies may be used to identify registered users logging in to the site. These cookies are deleted from the component’s server soon after the session ends and are not collected or saved. Persistent cookies may be used to recognize you when you return to the site, to manage preferences (such as your preferred language), and to analyze visitor behavior.

Some cookies are essential, meaning they are cookies that our website needs in order to function. Examples of where these cookies are used include: enabling basic functions like page navigation and access to secure areas of the site, storing items that are in your shopping cart, anonymously determining when you are signed in to your account, and determining which currency you should use based on your preferred delivery location when displaying prices to you.

Analytics Cookies. We also use various software tools, such as Google Analytics, that allow us to study, and then improve, how customers interact with our website – this is known as website analytics.

Analytics cookies allow us to understand more about how many visitors we have to the website, how many times they visit the site, and how many times a user viewed specific webpages within our site. Although analytics cookies allow us to gather specific information about the pages that you visit and whether you have visited our site multiple times, we do not use them to find out details such as your name or address.

Other Tracking Technologies. We may also use “web beacons,” also called “tracking pixels,” “pixel tags,” or “single pixel/transparent/clear GIFs” on the site. These are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you view a particular website tied to the beacon. These web beacons perform various functions, such as (a) compiling information about visitor usage of our site, site page views, and interaction with links on the site; (b) allowing us to send you emails in a format you can read; (c) notifying us when you have read an email, or when you click on a link in an email that directs you to our site. We use web beacons to help us analyze our users’ online behavior, operate and improve our site and our communications.

In addition, web beacons are used to allow ad networks to provide anonymized, aggregated auditing, research, and reporting for us and for advertisers. They also enable ad networks to serve targeted advertising to you when you visit other websites. Because your browser must request these web beacons from the ad network’s servers, the operators of these other websites can view, edit, or set their own cookies, just as if you had viewed a web page on their own website.

Third Party Tracking Technologies. We may allow third parties to set cookies during your visit to the site. These are third parties that have been selected by us to provide us with information about how you use the site. They may also use cookies, on our behalf, to promote our newest products and services on other websites based on your activity on our site. For example, you may see products that you viewed on our site presented on other websites as you move around the internet.

In addition, various third parties, including our analytics provides and our ad partners, may use cookies, alone or with web beacons or other tracking technology, to collect information about you when you use the site for their own purposes, independent from us. These third parties may be able to associate the information they collect with your personal information, or they may collect information, including personal information, about your online activities over time and across other website and online services. They may use this information to provide you with behavioral advertising or other targeted content on other websites and through other media.

We cannot control any third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How To Disable Tracking Technologies. Most web browsers automatically accept cookies and other tracking technologies, but you can usually change your browser to prevent that, such as by having your computer warn you each time a cookie is being sent or choosing to turn off all cookies. This can be done through your web browser settings, and because each browser is different, you should look at your browser’s “Help” menu to learn how to modify your cookie settings. You can also learn more how to opt out of targeted behavioral advertising from many major third party network advertisers by reviewing the information here and here.

If you do disable cookies from your browser you may not be able to access certain sections of the site that use essential cookies, and this may make your experiences on the site less efficient.

Do Not Track Requests. Currently, certain browsers, including Firefox, Google Chrome, Safari and Internet Explorer, offer a “do not track” (DNT) option. This option, using a technology known as a DNT header, sends a signal to websites visited by the user about the user’s DNT preference, if any, set on the browser. We do not currently commit to responding to browsers’ DNT signals. We cannot make this commitment because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators.

6. SOCIAL SHARING FEATURES

Our site may offer social network and similar sharing features, such as Facebook, Twitter, Instagram, and LinkedIn buttons, which let you share information related to the site through your preferred social media platforms. If you use these features on the site to connect with your social network, you permit us to share or publish information about your activity on our site with that social network. This information may include your basic social network information, your location data, your contacts and friends/followers lists, and certain information about your activities on the social network. If you permit a connection between our site and your social network page(s), we (and the social network) may be able to identify you, and associate the information we (and they) receive with information we (and they) already have about you. In addition, depending on how you use those features and your settings with the social network provider(s), the information you share to your social network pages will be available to others, including your friends and/or the public. For more information about how your information may be shared through those social networks once it is provided to them, you should review the privacy policies of those social networks.

We also may share certain data with these social networks to allow us to target existing users and customers with relevant advertising. In this situation, we do not share your identification or contact information with anyone. Instead, a unique code is shared with the applicable social network, allowing that code to be matched against existing users of the applicable social network, and to identify potentially relevant audiences for target advertising.

7. Our Security Measures

We use a variety of industry-standard security measures to maintain the safety of your personal information, including measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.

Unfortunately, no electronic data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we believe that we use reasonable measures to protect personal information, we cannot ensure or warrant the security of any information transmitted or otherwise provided to us or received from us. This is especially true for information that is transmitted via e-mail that is unprotected until it reaches our servers.

8. YOUR RIGHTS REGARDING Your Information

Opting Out of Certain Communications. You can always opt out of receiving promotional communications from us by contacting us at us at customerservice@avanticigar.com. Please note that notwithstanding your email preferences, we may need to contact you regarding open orders, as required by law, or regarding legal matters. However, we will not send you marketing communications if you have opted out of receiving them.

Correcting and Updating Information. If you believe that any of the personal information we have about you is incorrect, you can contact us at any time at customerservice@avanticigar.com to request that we make the appropriate corrections.

Removal of Information. As noted above, we have standard retention practices with respect to the personal data we collect. If you would like to request any earlier removal of your personal information, please contact us at customerservice@avanticigar.com. Please note that we may not be able to completely remove personal information from the site or our systems in certain circumstances. This will be true if the data is not in a searchable format, if it is retained in backup systems or cashed or archived pages, if we need it in order to prevent fraud or future abuse, or if we are required by law to keep it.

California “Shine the Light” Rights. California’s “Shine the Light” law permits California residents to request certain details about our disclosure of their personal information to third parties for those third parties’ own direct marketing purposes. If are a California resident and you would like to make such a request, please contact us at customerservice@avanticigar.com. Please note that there are legal limits on how often you can make such a request, and we are only obligated to respond to one information request per customer per year.

In addition, although users of our site and purchasers of products through The Toscano Cigar Shop are required to be at least 21 years old, if any California residents under the age of 18 have improperly used the site, created an account, and posted content or information on the site, or made any purchases, they can request removal by contacting us at customerservice@avanticigar.com, detailing where the content is posted and confirming that they posted it. Following such as request, we will terminate the unauthorized account, and will make reasonable good faith efforts to remove the post from public view, or anonymize it so that the minor cannot be individually identified. However, as noted above in this privacy policy, removal of public postings cannot ensure complete or comprehensive removal, as third parties may republish, archive, or cache web content in a manner that is out of our control.

9. VisiTING OUR WEBSITE FROM OUTSIDE THE UNITED STATES

If you are visiting this site or the Toscano Cigar Shop from outside the United States, please be aware that your information will be transferred to, stored, and processed in the United States, where our servers are located and our site is operated. Except as expressly stated in this privacy policy, we make no representation that the practices we describe are compliant with the laws of other jurisdictions, including laws that apply to the collection, use, disclosure, and security of personal information.

10. A Note about Children

Our site and the Toscano Cigar Shop are not targeted to, and we have no interest in collecting information from, children. We do not knowingly gather any personal information from children under the age of 13. If you are a parent or legal guardian who believes that your child has provided us with any personal information, please contact us at customerservice@avanticigar.com