Last updated: June 28, 2020
1. Who we are
US Envoy Foundation (“US Envoy,” “we,” “us”) operates usenvoy.org (the “Site”). Our address is 100 Park Avenue, 16th Floor, New York, NY 10017, USA. For data protection purposes, US Envoy is the controller of the personal information described in this policy.
Discretion is central to our fellowship. This policy explains what personal information we collect, how we use it, with whom we share it, and the choices and rights you have.
2. Information we collect
Information you give us
- Inquiries and membership consideration: name, email, telephone, country of residence, how you heard of us, and anything you write in your message.
- Age confirmation: your confirmation that you are of legal smoking age.
- Members: membership details, preferences (such as favored houses, vitolas and strength), event attendance, and correspondence with the Secretariat.
- Orders: billing and shipping address, order history and delivery details for Humidor allocations and Boutique purchases.
- Donations: name, contact details, gift amount and frequency, dedication (“in honor of”), and whether you prefer anonymity.
- Accounts: login credentials for your Boutique Account or Donation Dashboard.
Payment information. Card and bank details are entered directly with our payment processor is Stripe. We do not store full card numbers.
Information collected automatically. When you visit the Site we and our service providers collect device and usage data: IP address, browser type, pages viewed, referring pages, approximate location and time stamps, using cookies and similar technologies (see Section 8).
Information from others. We may receive information about you from a member who recommends you for consideration, from carriers about delivery status, and from payment processors about transaction status.
3. How we use your information
- To respond to inquiries and consider requests for membership.
- To provide member services: allocations, events, tastings, salons and personal service.
- To process, ship and track orders, and to verify authenticity.
- To process contributions, send acknowledgments, and provide stewardship briefings and annual reports.
- To confirm age and eligibility, and to comply with laws that govern the sale and shipment of tobacco products, including sanctions and export rules.
- To send communications you have asked for. You may opt out of marketing at any time.
- To operate, secure and improve the Site, and to prevent fraud and misuse.
- To meet legal, tax, accounting and regulatory obligations, and to establish or defend legal claims.
Legal bases (UK/EU visitors). We rely on: performance of a contract (orders, membership); legitimate interests (running and securing the Site, member relations, reviewing inquiries); consent (marketing emails, non-essential cookies); and legal obligation (age, tax, sanctions and tobacco rules).
4. How we share information
We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We share it only as follows:
- Service providers who act on our behalf: website hosting, payment processing, shipping and fulfillment, email delivery, analytics and IT security. They may use the information only to provide services to us.
- Fund administration: donation details are shared with Rothswell Financial, Inc., which administers contributions to the US Envoy™ Fund.
- Legal and safety: when required by law, subpoena or regulator, or to protect the rights, property or safety of US Envoy, our members or others.
- Business transfers: in connection with a merger, reorganization or transfer of assets, subject to this policy.
- With your consent or at your direction.
We never publish member or donor names without permission. Anonymous gifts stay anonymous.
5. International transfers
We are based in the United States and may process information in the US and other countries. When we transfer personal data from the UK or EEA, we use recognized safeguards such as the European Commission’s Standard Contractual Clauses and the UK International Data Transfer Addendum.
6. How long we keep information
We keep personal information only as long as needed for the purposes above:
- Inquiries that do not lead to membership: 24 months.
- Member records: for the duration of membership plus 7 years.
- Order and donation records: 7 years, for tax and accounting.
- Analytics data: 26 months.
We then delete or anonymize it.
7. Security
We use administrative, technical and physical safeguards, including encryption in transit, restricted access and vetted providers. No system is perfectly secure; if we learn of a breach that affects you, we will notify you as the law requires.
8. Cookies and similar technologies
We use:
- Essential cookies to run the Site, remember your age confirmation, keep your cart and keep you signed in.
- Analytics cookies [e.g., Google Analytics] to understand how the Site is used.
- Preference cookies to remember your settings.
Where required, we ask for consent before setting non-essential cookies. You can change your choices at any time through the cookie settings link in the footer or your browser settings. We honor Global Privacy Control signals as an opt-out where the law requires.
9. Your rights and choices
Everyone. You may ask us to access, correct or delete your information, or to stop sending marketing emails (use the unsubscribe link or contact us).
California and other US states. Residents of California, and of other states with comprehensive privacy laws, may have the right to know what personal information we collect, use and disclose; to access and delete it; to correct it; to opt out of sale, sharing or targeted advertising (we do not sell or share); and not to be discriminated against for exercising these rights. You may use an authorized agent. We will verify your request before acting on it.
UK and EEA. You have the rights of access, rectification, erasure, restriction, portability and objection, and the right to withdraw consent at any time. You may lodge a complaint with your local supervisory authority, such as the UK Information Commissioner’s Office.
To exercise any right, email privacy@usenvoy.org or write to the address in Section 1. We respond within the time the law allows.
10. Age restriction
The Site is intended only for adults of legal smoking age (21 or older in the United States). We do not knowingly collect information from anyone under that age. If we learn that we have, we will delete it.
11. Third-party links
The Site may link to sites we do not control, such as partner cigar houses or video platforms. Their privacy practices are governed by their own policies.
12. Changes to this policy
We may update this policy from time to time. We will post the new version here with a new “Last updated” date and, if changes are material, notify members by email.
13. Contact us
The Secretariat, US Envoy · 100 Park Avenue, 16th Floor, New York, NY 10017, USA · privacy@usenvoy.org · +1 (212) 960-8330
