Privacy policy

Privacy Policy

This Privacy Policy applies to information we collect in relation to your use and access of the napago.com and any other websites, mobile and other applications, or services that post a link to this Privacy Policy (collectively "Sites and Forums").

This Privacy Policy applies to information we collect about:

• Visitors to our websites;

• Visitors to our premises;

• Customers; Potential Employees; and

• Suppliers

By using or accessing any of the Sites and Forums, you agree to our Terms of Service and consent to our collection, use and disclosure practices, and other activities as described in this Privacy Policy.

IMPORTANT INFORMATION AND WHO WE ARE

This Privacy Policy is issued on behalf of the Napa Go, Inc. so when we mention "Napago", "we", "us" or "our" we are referring to the relevant company in the Group responsible for processing your data.

The purpose of the Privacy Policy is to describe how the Napa Go, Inc. collects, uses, and shares information about you.

If you have any questions or suggestions regarding this Privacy Policy, please feel free to contact us by phone, e-mail, or mail at:

Napa Go, Inc.

1370 Trancas St #736

Napa, CA 94558

Email: info@napago.com

WHAT DATA DO WE COLLECT ABOUT YOU

1 Personal data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites.

• Profile Data includes your username and password, purchases, or orders made by you, your interests, preferences, feedback, and survey responses.

• Usage Data includes information about how you use our website, products, and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

2 Aggregated Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature, or the number of customers purchasing certain products. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic, and biometric data). Nor do we collect any information about criminal convictions and offences.

HOW IS YOUR PERSONAL DATA COLLECTED?

1 Online

(a) Visitors to our websites

When you visit our websites, we use third party service providers (including Google Analytics and Adjusts) to collect standard internet log information and details of visitor behavior patterns. We do this to find out things such as the number of visitors to the various parts of the websites. This information is only processed in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our websites.

You may decide to submit personal information to us through the website, for example, when purchasing goods or services, signing up to a newsletter, filling in a survey, or entering a competition. When we collect personal data in this way this policy sets out what we intend to do with it.

Visitors and Users from outside of the United States should note that we collect, process and store information in the United States we collect from our Sites and Forums. By using our Sites and Forums from locations outside of the United States, you consent to the transfer of your personal information to, and the collection and processing of such personal information in the United States. The laws pertaining to the collection, use, disclosure, and processing of personal information in the United States may vary from those in other countries and may be less or more stringent than the applicable laws in your state or country. Accordingly, those who choose to access and provide personal information to our Sites and Forums from outside of the United States do so based on their own initiative and are solely responsible for compliance with applicable local laws.

(b) Cookies

Our website uses cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

(c) Search Engine

Search queries and results of searches on our website are logged anonymously to help us improve our website and search functionality. We do not collect any user-specific data.

(d) Security and performance

To maintain the security and performance of our websites we use a third party service which processes the IP address of visitors and other Technical Data.

This information is retained for a maximum period of 24 months.

(e) Social Media

We use various social media channels, including Wechat, Weibo and Facebook and will process your personal information when you interact with us (for example by liking or sharing a post). We use this information to improve our services.

(f) Internet Based Advertising

Napago engages third-party advertising companies to serve advertisements when you visit our websites and to serve advertisements on our behalf on non-affiliated websites. These advertising companies may use cookies, web beacons, pixels, embedded scripts, and other technologies to automatically collect information about your use of our websites, such as your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by us and others to analyze and track data, deliver adverting content targeted to your interests on our website and other websites, determine the popularity of certain content, and understand your online activity. This means that some information about your browsing of our websites and other third-party sites may be shared with these advertising companies for the purpose of delivering ads to you on our websites and certain third-party sites, and Napago may receive from some of these companies' information about third-party sites that you have visited. This information is used for marketing purposes, a practice sometimes referred to as "retargeting" to indicate that information from one website is used to suggest relevant products offered by another website.

These and other third parties may also collect data about your online activities over time and across different websites when you use Napago's websites.

Napago may also work with third parties to serve advertisements to you as part of a customized campaign on other websites or platforms.

(g) Children's Privacy

We are in compliance with the requirements of COPPA (Childrens Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products, and services are all directed to people who are at least 13 years old or older.

2 Third-party links

Our website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

This Privacy Policy only addresses the use and disclosure of information by us through your interaction with our Sites and Forums. We do not control other third-party websites that may be accessible through links from our websites and are not responsible for their privacy statements or the information that you share to them through our websites. When you leave our website, we encourage you to read the privacy notice of every website you visit prior to sharing any personal information with them.

3 Direct interactions

We may collect personal information from our direct interactions with you. This may include through correspondence, email, text messages, applications, phone calls, attendance at meetings with you, or other direct interactions.

4 From third parties

We may receive personal data about you from various third parties and public sources as set out below:

• Technical Data analytics providers such as Google, and others based both inside and outside the United States;

• Contact Data from providers of technical services;

• Identity and Contact Data from data brokers or aggregators;

• Identity and Contact Data from publicly available sources;

HOW IS YOUR INFORMATION USED?

We may use your personal data for various purposes, including the following:

• To register you as a new customer, including verifying your email address(es) are active and enrolling you in various Napago programs;

• To facilitate, improve, and personalize your online experience;

• To manage your account(s), including purposes, orders, payments, and comments;

• To manage our relationship with you, including notifying you about changes to our Terms of Use Agreement, Privacy Policy or other policies, providing member and customer services, and asking you to leave a review or take a survey;

• To communicate with you about products, services, offers, promotions, rewards, and events, including those offered by third parties;

• To administer and enable you to partake in a prize drawing, promotions, competitions, or sweepstakes;

• To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising or understand the effectiveness of the advertising that we serve to you;

• To use data analytics to improve our platforms, products/services, marketing, customer relationships and experiences, we analyze audience acquisition, behavior and conversions;

• To make suggestions and recommendations to you about goods or services that may be of interest to you;

• To monitor our websites for compliance with our Terms of Use Agreement;

• Respond to subpoenas or other legal processes and government investigations;

• To monitor and prevent fraudulent activity and threats;

• To perform other business activities as needed or described elsewhere in this policy;

• Carry out any other purpose disclosed in this Privacy Policy or at the time you provide your personal information to us;

• Any other purpose, with your consent or as permitted or required by applicable law.

PRODUCT AND SERVICE DEVELOPMENT

We use Aggregated Data to develop our services and products, but we may from time to time use your personal data, including feedback, responses to polls and surveys and other information provided by you to also improve our business. For example, this may include using recordings of calls for training purposes, and we will tell you if this is likely to be the case. You can ask for the call to not be used in this manner.

We may also use personal information that you have provided (including your communications with us) to offer better customer support and fix problems.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out above. These parties may be:

• Other members and affiliates of the Napago, Inc. who provide us with services to enable us to operate our business. We may also share personal data so that we can improve the Napago’s products and services as a whole.

• Third party service providers (acting as processors) who provide IT and system administration services and support.

• Professional advisers (acting as processors or joint controllers) including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities (acting as processors or joint controllers) based in the United Kingdom who require reporting of processing activities in certain circumstances.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

• We may also share your information at your direction or request, or when you otherwise consent.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

DATA SECURITY

We have put in place appropriate security measures to help prevent your personal data from being lost, used or accessed in an unauthorized way, altered, destroyed, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

Although Napago uses reasonable efforts to help protect your information, transmission via the Internet is not completely secure and Napago cannot guarantee the security of your information collected through our service. Further, you are responsible for protecting your password.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

UPDATING YOUR PERSONAL INFORMATION

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

You may contact us to review, update, or modify personal information that you have provided to us or request that we deactivate your account. We may retain certain personal information in our archives for record-keeping purposes. We do not have the ability to remove information from the databases of third parties with which we have already shared your information.

CALIFORNIA RESIDENTS' PRIVACY RIGHTS AND CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

 

Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We, therefore, will not distribute your personal information to outside parties without your consent.

CHANGES TO THIS PRIVACY POLICY

may change from time to time.  If there are material changes to this Privacy Notice or in how we use your personal information, we will post a notice on our home page that this Privacy Notice has changed. You are also encouraged to periodically review this Privacy Notice to stay informed on how we are protecting your personal information.