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General Data Protection Regulation

A legal framework that sets guidelines for the collection and processing of personal information from individuals who live in the European Union (“EU”).

Thank you for choosing Havana Ana’s LLC.  We are committed to protecting your personal information and your right to privacy.  If you have any questions and/or concerns about our policy and practices, please contact us at: info@havanaanas.com or call us at: (833) HAVANAS

When you visit Havana Ana’s and use our services, you trust us with your personal information.  We take your privacy very seriously.  Please refer to details above in this agreement and if there are any terms in this privacy policy that you do not agree with, please discontinue the use of our site and services.

WHAT TYPE OF DATA IS COLLECTED

We collect the data necessary for making purchases and processing payments.  We also collect addresses, birthdays, credit and debit card information, email / IP address(es) and/or browser and devise characteristics, gender, telephone numbers, passwords, password hints and security information used to authenticate account access, which is collected automatically when visiting our website.  We may also collect limited data from public databases, joint marketing partners, social media platforms and other outside and third-party sources.  All payment data is stored by our secured payment processor.  This information is needed primarily to maintain the operation of our Site and for our internal analytics and reporting purposes.  Like many other businesses, we collect information through Cookies and similar technologies.

WHAT IS THE DATA COLLECTED USED FOR

We use the information collected for purposes based on legitimate business interests, fulfillment of our contract with you, compliance with our legal obligations and/or with your consent.  We use information collected for the following reasons:

  • To facilitate account creation and logon process;
  • If you choose to link your account with us to a third-party account;
  • To send marketing and promotional communications;
  • To sent administrative information to you for business purposes;
  • To send you product(s), service(s) and/or new information about any changes
  • To fulfill and manage orders, payments exchanges or returns
  • To develop and display content and advertising and/or work with third-parties who do so
  • To request feedback and to contact you about your use of our Site;
  • To protect our Site and keep it safe and secure for fraud monitoring and prevention;
  • To enable user-to-user communications;
  • To enforce our Terms and Conditions policy;
  • To respond to legal requests, by inspecting the data we hold to determine how to respond;
  • To comply with applicable law, governmental requests, a judicial proceeding, court order, legal process, subpoena (including response to public authorities to meet law enforcement), vital interests and legal rights
  • To investigate, prevent or take action with regards to any possible violations of our policies, suspected fraud, potential threats to our safety and the safety of any person and illegal activities or as evidence in a litigation in which we are involved.
  • To analyze data, identify usage trends, determine the effectiveness of our promotional campaigns and to evaluate and improve our Site, products, services, marketing and your experience as a consumer
  • To share data collected with third-party agents, contractors, service providers and/or vendors who perform services for us or on our behalf and who require access to such information in order to handle, such as: Contacting Customer Service, data analysis, email delivery, hosting services, marketing efforts and payment processing, among possible others
  • To share data collected with other users by contributions or other content to the Site; descriptions of your activity; posting comments; your Facebook, Instagram or Twitter

 

THIRD-PARTY SERVICE PROVIDERS, VENDORS AND CONSULTANTS

We may share your data with third-parties to encourage and facilitate them to use the tracking technology on this Site, which enables them to collect data about how you interact with the Site over time. 

This information may be used to analyze and track data, determine the popularity of certain content; to better understand online activity and tracking status. 

We do not share, sell nor trade any of your personal information with third-parties for their promotional purposes and/or personal gain.

We may share or transfer your information in connection with or during negotiations of any merger, financing, sale of company assets or acquisition of all or a portion of our business to another company and/or individual.

THIRD-PARTY ADVERTISERS

We may use third-party advertising companies for ads on our Site.  These companies may use your information to track your visits to our website and any other websites that are contained in web cookies and other tracking technologies, in order to provide advertisements about goods and services of interest to you.  Refer to Cookies Policy above in this Agreement.

AFFILIATES

We may share your information with our affiliates (if any), in which case, we will require them to honor this private policy. 

Affiliates may include, but not limited to possible joint ventures, partners or other companies that may be under our control.

BUSINESS PARTNER

We may share your information with business partner or partners (if any), to offer certain products, services, promotions or sales.

COOKIES AND OTHER TRACKING TECHNOLOGIES

We use Cookies to collect and store your personal information as a tracking technology tool to access and store information.

GOOGLE MAPS

We use Google Maps to provide excellent service.  Please Google their Private Policy for better understanding.

YOU MAY REVOKE YOUR CONSENT AT ANY TIME WITH PRIOR WRITTEN NOTICE.

LOGINS AND HOW THEY ARE HANDLED

By logging into our website using a social media account, we will automatically have access to certain information about you (i.e., name, email address, friends list, profile picture and other information you chose to make public), using third-party social media provider account details.

We will use the information we receive for the sole purpose(s) described in this private policy or that otherwise, was made clear on our Site. 

Please note that we do not have any control, nor are we responsible for other uses of your personal information by your third-party social media provider.  We highly recommend that you review their private policy to better understand how they collect, share and use your personal information.  It is also important that you set your Private Policy preferences on their sites and applications.

INTERNATIONAL TRANSFER OF YOUR INFORMATION

We may transfer, process and store your information in countries other than your own.

Our servers are located in the United States.  If you are accessing our Site(s) from outside the United States, please be aware that your information may be transferred, processed and stored in our facilities and by those third-parties with whom we may share your personal information in the United States and other countries.

If you are a resident of the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country.  We however take all necessary measures to protect your personal information in accordance with this Private Policy and applicable law.

European Commission’s Standard Contractual Clauses for transfer of personal information between our group companies and between us and our third-party providers, which require all such recipients to protect personal information that they process from the EEA in accordance with European data protection laws.

EU – U.S. Private Shield Framework for International transfers:

Havana Ana’s LLC complies with the EU – U.S. Private Shield Framework as set forth by the U.S. Department of Commerce and with regards to the collection, use and retention of personal information transferred from the European Union to the United States and has certified its compliance with it.

Havana Ana’s LLC is committed to subjecting all personal information received from European Union (“EU”) member counties, in reliance on the Privacy Shield Frame work to the Framework’s applicable Principles.  For further details, please visit the Private Shield List on the U.S. Department of Commerce platform.

Havana Ana’s LLC is responsible for the processing of personal information it receives under the Privacy Shield Framework and eventually transfers to a third-party acting as an agent on its behalf.  The information received is also subject to the regulatory enforcement powers of the U.S. FTC.  At times, we may require to disclose personal information in response to lawful requests by public authorities, including but not limited to, meeting national security and/or law enforcement requirements.

OUR STANCE OF THIRD-PARTY WEBSITES

HAVANA ANA’S IS NOT RESPONSIBLE FOR THE SAFETY OF ANY INFORMATION THAT OU SHARE WITH THIRD-PARTY PROVIDERS THAT ADVERTISE, BUT WHICH ARE NOT AFFILIATED WITH OUR WEBSITE.

The Sites may contain advertisements that are not affiliated with Havana Ana’s LLC and which may link to other websites, mobile applications or online services. 

HAVANA ANA’S DOES NOT GUARANTEE THE SAFETY AND PRIVACY OF THE DATA YOU PROVIDE TO ANY THIRD-PARTIES.

Any data collected by third-parties is not covered by this private policy.

HAVANA ANA’S IS NOT RESPONSIBLE FOR THE CONTENT, SECURITY PRACTICES NOR POLICIES OF ANY THIRD-PARTIES, INCLUDING OTHER APPLICATIONS, OTHER SERVICES NOR OTHER WEBSITES THAT MAY BE LINKD TO OR FROM THE SITES. 

We highly recommend that you review the policies of such third-parties and contact them directly to answer and/or respond to any questions and/or concerns.

LENGTH OF TIME WE KEEP YOUR INFORMATION FOR

We keep your information for as long as necessary to fulfill the purposes outlined in this private policy, unless otherwise required by law or a longer retention period is permitted or required by law, such as accounting, legal or tax requirements. 

There is no purpose that will require us to keep your personal information for longer than two (2) years past the termination of your account.  We will either anonymize your information or delete it.  If this is not possible, because your information has been stored in backup archives, then we will securely isolate it from any further processing until deletion is possible.

HOW WE KEEP YOUR INFORMATION SAFE

We protect your personal information through a system of organizational and technical security measures, which we implemented and is designed to protect and secure any and all information that we process. 

HAVANA ANA’S LLC DOES NOT GUARANTEE THAT THE INTERNET ITSELF IS 100% SECURE.  ALTHOUGH WE AIM TO DO OUR BEST TO PROTECT THE PERSONAL INFORMATION COLLECTED FROM OUR CONSUMERS, THE TRANSMISSION OF INFORMATION TO AND FROM OUR SITE IS ENTERED AT YOUR OWN RISK.  YOU SHOULD ONLY ACCESS THE SERVICES WITHIN A SECURE ENVIRONMENT.

INFORMATION FROM MINORS

We do not collect data, market data nor solicit data from children under the age of eighteen (18).  By using the Site, you automatically represent that you are at least eighteen (18) years of age, and that your parent and/or guardian of such a minor, consents to using this Site. 

If we learn that personal information is collected from a minor under the age of eighteen (18), we will deactivate the account and take full responsibility and measures to promptly delete such data from our records.  If you become aware that any date we have collected comes from children under the age of eighteen (18), please contact us immediately at: info@havanaanas.com .

YOUR PRIVACY RIGHTS

In some regions, such as the European Economic Area, you have rights that allow you greater access to control your personal information, so please feel free to terminate our account with us at any time; to request access and obtain a copy of your personal information; to request us to rectify or delete; and to restrict the processing of your information at any time you deem fit.  In particular instances, you also have the right to object to the processing of your information and/or withdraw your consent at any time, but this will not affect the lawfulness of the processing before its withdrawal.  You may terminate your account at any time by logging into your account settings and updating your account accordingly or by contacting us directly on the contact page of this Site.  Upon your request to terminate your account, we will deactivate and/or delete your account information from our active database.  However, some information may be retained in our files to prevent fraud, troubleshoot issues, assist with any legal investigations or requirement and/or enforce our terms of use.

If you are a resident in the European Economic Area and you believe that we unlawfully processed your personal information, you have the right to complain to your local data protection supervisory authority.  You can find their contact details at:  http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

COOKIES AND OTHER TECHNOLOGIES

Most web browsers are set to automatically accept cookies by default.  If you are not comfortable with that and prefer to avoid this method, you can choose to set your browser to remove cookies and reject them, although this could affect certain features of services of our Site.

You are free to unsubscribe from our marketing email list at any time by clicking on the “Unsubscribe Link” in the emails that we sent or by contacting us directly using the details provided below.  You will then be removed from any and all marketing advertisements, notifications and promotions.  However, we will still need to send you service-related emails that are necessary for the administration and use of your account.

CALIFORNIA RESIDENTS HAVE SPECIFIC RIGHTS

If you are a resident of California, you are granted specific rights with regards, to accessing your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, which permits our users (who are California residents), to request and obtain information from us about categories of personal information, if any, that we disclose to third-parties for direct marketing purposes and the names and addresses of all third-parties with which we shared personal information in the immediate preceding calendar year.  This can be done once a year and free of charge.  If you are a California resident and would like to make such a request, please submit that request to us in writing to us at the contact information provided below.

If you are eighteen (18) years of age, reside in California and have a registered account with the Site, mobile application, Facebook and/or Instagram, you have the right to request the removal of unwanted data that you publicly post.  To request the removal of such data, please contact us directly at the contact information provided below.  Please include the email address associated with your account and a statement that you reside in California.  We will make sure that the data is not publicly displayed.  Please be aware that the data may not be completely or comprehensively removed from our systems.

If you are a resident in the European Economic Area, the “Data Controller” of our personal information is the same as provided below.

UPDATES TO THIS POLICY

We have the right to update this policy as we deem fit and as necessary to stay compliant with relevant laws.  The updated version will be indicated by an updated “Revised” date and the updated version will take effect as soon as it is accessible.  If and when we make changes, we will notify you either by posting a notice or by sending an email.  We highly encourage you to review this private policy from time to time, in order to stay informed of how we are protecting your personal information.

OUR CONTACT INFORMATION

If you have any questions, comments, and/or concerns, please email us at: info@havanaanas.com

Or at:                                       HAVANA ANA’S LLC

                                                ANA PREGO, PRIVACY OFFICER

                                                1198 VENETIAN WAY, APT. 302

                                                MIAMI BEACH, FLORIDA 33139

                                                TELEPHONE: (833) HAVANAS

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