PRIVACY POLICY

1. Introduction

This website is operated by Nolet Spirits U.S.A. located at 30 Journey, Aliso Viejo, CA 92656, U.S.A.

All references to ‘our’, ‘us’, ‘we’ or ‘company’ within this policy and within the opt-in notice are deemed to refer to Nolet Spirits U.S.A., its subsidiaries, affiliates and associates.

We endeavor to protect private personal information that you provide to us as set forth in this Privacy Policy. We provide this Privacy Policy to help you to understand what we may do with any personal information that we obtain from you. By providing your personal information to us, you signify your acceptance of our Privacy Policy and agree that we may collect, use and disclose your personal information as described in this Privacy Policy. If you do not agree to this statement, please do not provide your personal details to us. This Privacy Policy is incorporated into, and part of, the Terms and Conditions, which govern your use of the site in general. We will use your information only for the purposes set out below.

We may need to update this Privacy Policy from time to time. We recommend that you regularly check this page to ensure that you have read the most recent version.

Changes to the Privacy Policy are noted here:

Date last revised: September 1, 2009.

3. What is personal information?

Personal information is information about an identifiable individual, as defined by applicable law.

4. Collecting personal information

It is your choice to provide us with personal information. We will only collect personal information that you choose to provide. In certain instances, we may provide you with the option to select whether you would like to receive information from us or from trusted third parties (for example, by choosing to opt-in or opt-out of receiving special promotional offers). In some circumstances, you will not have the option to opt-out, such as when we are satisfying the obligations of a contract with you, administering a transaction requested by you, or as required by law.

5. Use of cookies on our websites

In common with many websites, we use “cookies” to help us gather and store information about visitors to our websites. A cookie is a small data file that our server sends to your browser when you visit the site. The use of cookies helps us to assist your use of certain aspects of the site. You can delete cookies at any time or you can set your browser to reject or disable cookies. You can obtain information about how to manage cookies at www.aboutcookies.org.

We primarily use information from cookies for the following purposes:

1. Traffic monitoring, e.g., the IP address from which you access the site, the type of browser and operating system used to access the site, the date and time of your access to the site, the pages you visit, and the Internet address of the website from which you accessed the site.

2. To register you in programs and to recognize your website preferences.

3. To recognize repeat visitors for statistical / analytical purposes.

4. Anonymous tracking of interaction with online advertising, e.g., to monitor the number of times that a banner ad is displayed and the number of times it is clicked.

5. To compile and report to third parties (such as advertisers) aggregate statistics about our users in terms of numbers, traffic patterns and related site information.

We may also use clear gifs (also known as web bugs or web beacons), which are tiny graphics embedded in web pages and email messages that we use, in connection with cookies, to collect non-personal information from users to analyze site U.S.A.ge, manage content on the site, track visits to other related sites, and track the performance of online advertising.

We may also connect the information that we collect through cookies and clear gifs with other personal information that you provide to us in order to:

1. Customize or personalize your experience of the site; for example, so that we can greet you on the site by name;

2. Conduct transactions, such as credit card sales; and

3. Monitor your use of our website(s) in order to make our communications to you as relevant as possible and for other marketing and advertising research purposes.

6. Use of personal information

We may use personal information collected from you in order to provide you with specific services that you request as well as in order to provide you with additional services that may be of interest to you. For example, we may use your personal information in the following ways:

Marketing Communications . We may use your personal information in order to communicate with you about our products and services and those of our subsidiaries, affiliates, and parent companies and any of their related businesses.

Marketing analysis . We may use information for internal marketing analysis, for example, to assess trends amongst our consumers or to measure the amount of traffic to our websites.

Transactional purposes . We may use your personal information in order to respond to your queries and requests, maintain your accounts, and to manage transactions such as credit card payments for any goods that you order from us or any of our agents, or for the fulfillment of such transactions (e.g., delivery).

Forward to a friend . When you provide us with information regarding another individual, such as when you request that we send someone information from one of our website, we will only send that individual the information that you specifically requested that we send. We will not send them additional communications based on you providing us with their information.

7. Disclosure of personal information

We value your personal information and only share such information with third parties that provide adequate protection for such information. From time to time we may disclose personal information to:

(a) third parties to whom you have provided your consent;

(b) our service providers and subcontractors, including our affiliates, retained to perform functions on our behalf or to provide services to us, such as warehousing and delivery; marketing and advertising; credit card and data processing; age verification; software development; website hosting and management; information technology and office services; legal, accounting, audit and other professional service providers; and other services related to our business; and further, provided such service providers and subcontractors do not collect, use or disclose the personal information for any purpose other than to perform such functions on our behalf or to provide services to us or as otherwise required by law;

(c) third parties who, in our reasonable judgment, are providing or seeking the information as the authorized or appointed legal agent of the subject individual; or

(d) carefully selected third parties, including our affiliates, to send you third party marketing and promotional information that may be of interest to you. In such circumstances your personal information may be disclosed to these organizations that will be bound by confidentiality obligations and restrictions on use of personal information. We will obtain your express permission before we allow a third party that is not an affiliate to send you any such marketing and promotional information;

(e) a person or entity, including our affiliates, in the event of a sale, merger, consolidation, change in control, transfer of substantial assets, financing, reorganization or liquidation, whereby we transfer, sell, or assign to such third party information concerning your relationship with us, including without limitation, personally identifiable information that you provide and other information concerning your relationship with us; and

(f) law enforcement, governmental or regulatory agencies, or other third party in order to comply with law or where we believe such action is necessary in order to comply with law or detect, protect or defend us and/or other third parties against error, negligence, breach of contract, theft, fraud and other illegal or harmful activity, to comply with our audit and security requirements, and to audit compliance with our corporate policies, procedures, legal and contractual obligations.

8. Public (or Interactive) areas of our websites

Information that you post on or through the public areas of the site (e.g., chat rooms, bulletin boards and discussion groups) is generally accessible to, and may be collected and used by, others and may result in unsolicited messages or other contact from others. You should not provide personal information about yourself in public (or interactive) areas of the site. Such personal information is not covered under this Privacy Policy.

9. Security

We take security seriously and we take precautions to keep your personal information secure. We have put in place commercially reasonable physical, electronic and managerial procedures to safeguard the information we collect. We have no control over the privacy of any communications while in transit to us. We recommend that you not include confidential, proprietary or sensitive information in such communications.

In the unlikely event that we believe that the security of your personal information in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail.

You are reminded that, in accordance with the Terms and Conditions for this website, which include this Privacy Policy, you are responsible for maintaining the strict confidentiality of your account password, and you are responsible for any activity under your account and password. It is your sole responsibility to control the dissemination and use of your password, control access to and use of your account, and notify us when you desire to cancel your account. We will not be responsible or liable for any loss or damage arising from your failure to comply with this obligation.

10. Unsubscribe, access, questions and further information

At your request and where the law requires us to do so, we will confirm what personal information we hold about you, update your information, remove your information, fulfill specific opt-out requests, including requests where you have previously opted-in with respect to the use of your personal information, and/or correct any inaccuracies in such personal information if you contact us using the unsubscribe details provided below.

If you would like to unsubscribe from Nolet communications or from all communications about Nolet brands, please contact: info@noletspirits.com

11. Portfolio permissions

If you have given permission to receive communications about Nolet brands generally (for example, by opting to receive news and special offers by email about Nolet’s other great alcohol brands) you may from time to time receive communications about brands to which you have not opted-in specifically. Information about many of Nolet’s brands can be found at www.noletspirits.wpengine.com.

We may occasionally send you communications about brands not featured on www.noletspirits.wpengine.com (e.g. new brands). We recommend that you refer to www.noletspirits.wpengine.comfrom time to time as the list of brands featured will be updated periodically.

Providing general permission for us to communicate with you about our brands does not mean that you will receive communications about all Nolet’s brands. We will only communicate with you about those brands that we think may be of particular interest to you. Any such communications will provide you with an opportunity to unsubscribe from the brand in question and/or from all communications about Nolet brands.

If you have any privacy-related questions, concerns or complaints, please contact: info@noletspirits.com.

12. Links

The site may contain links or references to other websites outside of our control. Please be aware that we have no control over these websites and our Privacy Policy does not apply to these sites. We encourage you to read the Privacy Policies and terms and conditions of linked or referenced websites you enter.

As required, this Privacy Policy will be supplemented by additional legal requirements in jurisdictions where we conduct business. Nothing in this Privacy Policy or otherwise will create, or add to, any right or claim (whether legal, equitable or otherwise) that any individual or person may have at law or otherwise against the company or any third party or any of their respective directors, officers, employees, agents or representatives (collectively the “Nolet Group”); nor will the existence of this Privacy Policy or its application impose or add to any obligations or liability upon the Nolet Group that the Nolet Group does not already otherwise have under law.

©2017 Nolet Spirits U.S.A., 30 Journey, Aliso Viejo, CA 92656. All rights reserved. Version 3.0 August 8, 2017.