LAST UPDATED: [Insert Date]
Never Sober, LLC (“Never Sober,” “we,” “us,” or “our”) respects your privacy and understands the importance of safeguarding your personal information. This Privacy Policy explains how we collect, use, disclose, and protect information through our websites, software, social media pages, and applications that we control, as well as HTML-formatted emails that link to this Privacy Policy (collectively, the “Services”). The section titled California Privacy Rights describes our practices with respect to personal information about California residents.
“Personal Information” is information that identifies you as an individual or relates to an identifiable person. Examples include:
Name
Email address
Postal address
Telephone number
Payment information (e.g., credit/debit card number)
Social media account ID
We may collect Personal Information in a variety of ways, including:
Through the Services: For example, when you create an account, make a purchase, sign up for marketing, or pass through an age or content gate (if enabled).
From Other Sources: We may receive Personal Information from public databases, joint marketing partners, social media platforms (including from people with whom you are connected), and other third parties. If you connect your social media account to a Services account, certain profile information may be shared with us as permitted by that platform’s privacy policy.
We may use Personal Information to:
Respond to inquiries, fulfill requests, process transactions, and provide customer service.
Send administrative information, including updates to our terms, conditions, and policies.
Send marketing communications we believe may be of interest to you.
Text marketing: With your permission, we may send SMS/MMS about our store, new products, and updates (including checkout reminders triggered via webhooks).
Personalize your experience by presenting products and offers tailored to you.
Allow participation in sweepstakes, contests, and similar promotions, and administer these activities (subject to additional rules).
Facilitate social sharing functionality.
Conduct business operations such as data analysis, audits, fraud monitoring and prevention, new product development, Service enhancement, usage trend identification, campaign effectiveness measurement, and expansion of our business activities.
We may disclose Personal Information:
To our affiliates for the purposes described in this Privacy Policy.
To service providers (e.g., hosting, data analysis, order fulfillment, IT, customer service, email delivery, auditing).
To co-sponsors or co-branding partners (e.g., event or promotion partners) so they may send you marketing communications, where permitted by law and your preferences.
To third-party sponsors/administrators of sweepstakes, contests, and similar promotions.
By you via public features of the Services (e.g., message boards, blogs, profile pages) that are visible to other users and/or the public (“Public Postings”). Anything you disclose in Public Postings becomes public information—please use caution.
To your social connections and/or your social media platform provider in connection with social sharing activity. If you do not want this sharing, please do not connect your social media account and do not use social sharing features.
In connection with a business transaction, such as a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or part of our business, assets, or stock (including in bankruptcy).
We may also use and disclose Personal Information as we believe necessary or appropriate: (a) under applicable law (including laws outside your country of residence); (b) to respond to requests from courts, law enforcement, regulators, and other public authorities; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
“Other Information” is information that does not reveal your specific identity or directly relate to an identifiable individual, such as:
Browser and device information
App usage data
Cookies, pixel tags, web beacons, and similar technologies
IP address
Approximate location
Demographic and preference information you provide
Aggregated or de-identified information
If applicable law requires us to treat Other Information as Personal Information, we will use it for the purposes described in this Policy for Personal Information.
We and our service providers may collect Other Information in various ways, including:
Through your browser or device: e.g., MAC address, device type, screen resolution, OS, language, browser type/version, and the name/version of the Services you use—to help ensure the Services function properly.
Through your use of an app: e.g., timestamps of server access, content viewed/downloaded.
Cookies: These allow us to collect information such as browser type, time on the Services, pages visited, language preferences, and traffic data, and to help with security, navigation, personalization, analytics, and advertising relevance.
Most browsers let you block or manage cookies. Restricting cookies may affect certain features.
Pixel tags and similar technologies: Used to track user actions (including email recipients), measure campaign success, and compile usage statistics.
Analytics: We may use tools such as Google Analytics. To learn about Google’s practices, visit www.google.com/policies/privacy/partners/ and to opt out, use https://tools.google.com/dlpage/gaoptout.
Adobe Flash and similar technologies: Manage Flash Local Shared Objects via the Adobe settings panels. Limiting Flash LSOs may impact some functionality.
IP Address: Logged automatically for usage levels, diagnostics, administration, and approximate location derivation.
Location: We may collect the physical location of your device (e.g., via GPS, Wi-Fi, or cell signals) to provide location-based content or services.
From you: e.g., preferences and demographics you provide voluntarily.
Aggregation: We may aggregate information for analytics and reporting.
We may use and disclose Other Information for any purpose, except where restricted by applicable law. If we combine Other Information with Personal Information, we will treat the combined information as Personal Information.
Some browsers transmit “Do Not Track” signals. Our Services are not currently configured to respond to such signals.
This Privacy Policy does not address—and we are not responsible for—the privacy, information, or other practices of third parties, including any third party operating any site or service to which the Services link. Inclusion of a link does not imply endorsement. We are not responsible for the practices of other organizations (e.g., social media platforms, operating systems, wireless providers, device manufacturers) regarding any Personal Information you disclose to them in connection with the Services.
We may use third-party advertising companies to serve ads that may interest you based on your activities across websites and apps and across your devices. These companies may set or recognize cookies and use similar technologies to recognize you across devices.
For more information and opt-out options (on the device you use to visit these links), please visit:
http://www.aboutads.info/
For mobile apps, you may also use the AppChoices app: http://youradchoices.com/appchoices
We use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. No data transmission or storage system can be guaranteed 100% secure. If you believe your interaction with us is no longer secure, please notify us immediately (see Contacting Us below).
You may opt out of marketing emails by following the instructions in those emails. Some Services may offer opt-out controls in your account settings. We may still send you important administrative messages from which you cannot opt out.
To request to review, correct, update, suppress, or delete Personal Information, email us at support@neversober.com. We will respond consistent with applicable law. We may retain certain information for recordkeeping and/or to complete transactions initiated prior to your request. Residual data may remain in our archives.
Residents of California should also see California Privacy Rights below.
The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than the United States. Your information may be stored and processed in any country where we have facilities or service providers. By using the Services, you understand your information may be transferred to countries (including the U.S.) that may have data protection rules different from those of your country.
Please do not send or disclose sensitive Personal Information (e.g., Social Security numbers; information about racial or ethnic origin, political opinions, religion, health, biometrics, genetics, or criminal background) through the Services or otherwise to us.
We may update this Privacy Policy from time to time. The LAST UPDATED date above indicates when it was last revised. Changes take effect when we post the revised Policy on the Services.
If you have questions about this Privacy Policy, please contact us at privacy@neversober.com. Because email communications are not always secure, please do not include payment card or other sensitive information in your emails to us.
This section applies to California residents and explains your rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA). For this section, “Personal Information” generally means information that identifies, relates to, describes, or could reasonably be associated with a particular consumer or household.
We may have collected and disclosed for business purposes the following categories of Personal Information to our affiliates, service providers, social networks, and joint-marketing partners:
Identifiers (e.g., name, IP address, email address, online identifiers, government-issued ID numbers)
Customer Records Information (e.g., contact and payment information)
Protected Class Information (e.g., age, gender, marital status)
Transaction Information (e.g., purchase history)
Online Use Information (e.g., browsing history, interactions with our sites/apps)
Geolocation Data (e.g., device location)
Audio/Video Data (e.g., electronic, visual, or similar information)
Inferences drawn to create profiles reflecting preferences and characteristics
Depending on your interactions with us, we may not have collected or disclosed all categories about you.
We collect Personal Information directly from you and from other online/offline sources, such as service providers, business partners, analytics providers, operating systems/platforms, data brokers, public databases, joint marketing partners, and social media platforms.
We use Personal Information to operate, manage, and maintain our business; provide and improve products and Services; personalize and market our offerings; perform research and analytics; maintain facilities and infrastructure; ensure quality and safety; monitor and secure our Services; detect and prevent fraud; verify identity; perform internal functions (e.g., accounting, audit); comply with law; maintain records; and exercise or defend legal claims.
The CCPA/CPRA define “sale” broadly and also regulate “sharing” for cross-context behavioral advertising. While we do not sell customer lists for money, our use of certain advertising and analytics cookies may be considered a “sale” or “sharing” of Personal Information under California law. We do not knowingly sell or share Personal Information of consumers under 16.
The categories that may have been “sold” or “shared” in this way include:
Identifiers
Customer Records Information
Protected Class Information
Online Use Information
You can opt out of sale/sharing by using our Do Not Sell or Share My Personal Information controls where available (e.g., cookie banner or link in the site footer).
California residents may have the right to:
Know/Access: Request that we disclose the categories and specific pieces of Personal Information we collected about you; the categories of sources; business/commercial purposes; categories of third parties with whom we disclose, sell, or share Personal Information.
Delete: Request deletion of Personal Information we collected from you.
Correct: Request correction of inaccurate Personal Information.
Opt Out of Sale/Sharing: Opt out of sale or sharing of Personal Information for cross-context behavioral advertising.
Limit Use/Disclosure of Sensitive Personal Information (if applicable).
Non-Discrimination: You will not receive discriminatory treatment for exercising your CCPA/CPRA rights.
To make a Request to Know/Access, Delete, or Correct, email privacy@neversober.com. To exercise Do Not Sell or Share rights, use the “Do Not Sell or Share My Personal Information” link where provided or adjust cookie preferences in our consent tool.
We will verify and respond consistent with applicable law, considering the type and sensitivity of the information. We may request additional information (e.g., the email you used with us) to verify your identity and protect against fraudulent requests. For deletion requests, we may ask you to confirm before we delete.
If you are an authorized agent submitting a request on behalf of a California resident, we may require:
Proof of your registration with the California Secretary of State to conduct business in California; and
Written permission signed by the resident or a valid power of attorney.
If you do not provide a power of attorney, we may also require the resident to verify identity directly with us and to confirm authorization.
