Section 1: Are You of Legal Purchase Age?

• By interacting with this Site, you certify that you are at least 21 years of age or older (United States), or of legal drinking age in your location of residence. If you are not of legal drinking age, please leave the Site immediately.
• The Sites and/or mobile applications provided by Heaven Hill Brands are intended only for adults who are of legal drinking age within their local jurisdiction. Heaven Hill Brands does not knowingly collect or solicit personal information from, nor market our products to, anyone who is not of legal age to consume alcoholic beverages. Please contact us via the instructions provided in the “Contact Us” Section 12 of this Privacy Policy if you believe this site has collected information from anyone who is under 21 years of age, or not of legal drinking age in the jurisdiction of their residence.
• If we have reason to believe that you are under the legal purchase age, we will remove your information from our records.
• We make it a priority to ensure that our advertising and marketing is never designed to appeal to persons younger than the legal drinking age of alcoholic beverages.

Section 2. What Personal Information Is Collected and When Do We Collect It?

We collect personal information from you individually, either directly or indirectly, when you interact with us on our Sites. Personal information is information about an identifiable individual, as defined by applicable law. The personal information we collect may include: (a) information that you provide to us; (b) information that we automatically collect/generate; and (c) information that we obtain from third parties. We collect personal information to better meet the needs of our customers and to improve our offerings to you. The types of personal information that we collect include:

• Name, username, password, any unique user ID, registration information, contact details, mailing address, email address, geographic location, or telephone number
• Your date of birth as it applies to legal purchase age confirmation, which could include photographic proof of age
• Shopping habits, transaction history, and payment and purchase information, such as bank account, credit card information or delivery address
• Marketing communications, cookie preferences, and data gathered by cookies
• Information posted online and usage information about how you interact with our website, newsletters, and other online content
• Details of your contact with us, including phone calls, posted stories, testimonials, or reviews that you have submitted to us through our Sites.
• General details about your hobbies, lifestyle interests, and consumption preferences
• Photographs or videos posted to our Sites by you or other users, as well as photographs or videos taken on Heaven Hill premises or at events
• Personal information about third parties if you have disclosed that information to us. By disclosing this information, you certify that you have the authority to do so and that we are permitted to use any of this information in accordance with our Privacy Policy.

Most often, you voluntarily provide us with your personal information. This happens when you interact with us through our Sites. Some interactions may include your use of our Sites and apps, your purchase of products or services on our online or physical stores and/or when you return items to us; or when you register on our website, sign up for promotions or sweepstakes, ask us a question, opt in for messaging or e-mail, apply for employment with us, or submit content or comments to Heaven Hill Brands Sites and social media channels.

Please be aware that feedback provided to us on our Sites via submitted reviews, message boards, blog posts or chats, or social media engagement may be posted in a public forum and viewed by other users and members of the public. Please do not include any information that should be kept confidential.

From time to time, we obtain additional information from third-party data suppliers who source data from commercially and/or publicly available sources, such as data aggregators, public databases, or third-party social media or consumer feedback platforms. These items may include things like demographic information, device information, purchase preference information, or such other information involving personal preferences that we may need to help us to understand our customers.

Social Media and Third-Party Advertisers

We may work with third-party advertising companies to deliver targeted ads on other websites and social media channels. This enables us to present you with advertising that we think you are most interested in viewing. These companies might also perform reporting and tracking functions on other websites and may place cookies on your device as you browse targeted advertisements. Third-party companies do not collect your personal information at our request, nor do we give or sell them your information as part of this interaction. Their processes are covered under their own respective privacy policies. The mere inclusion of a link on our Site does not imply any Heaven Hill Brands endorsement of the linked services or sites.

As with all websites and apps, when you browse, click on advertisements, or use the tools on the Sites, some information about your visit is automatically recorded using cookies and other similar information collection technology. This includes your IP address, your device operating system and browser type, the pages you viewed, and the date/time of your visit. We may also collect information using cookies. You may find more information about Cookies detailed in SECTION 4 of this policy below.

Section 3. How Does Heaven Hill Brands Use Personal Information?

We primarily use your personal information to improve the efficiency of our Sites and the ways in which we provide services to you; as well as any information, products, or services that you may request from us. We also use your personal information to enhance your user experience and display the most appropriate and relevant content to you on our Sites and upon other media through which you interact with us. Your personal information may also be used to verify your identity to comply with legal obligations, and to assist us in maintaining the security and integrity of our Sites and business. Any time that you make a purchase, request a refund or process a return through any of our Sites, we may use data that we have collected from you to verify your identity and prevent fraudulent transactions. We may also use your personal information to verify your identity and distribute prize(s) in the event you are a winner in any promotions or sweepstakes offered by us.

We will only use the personal information that we collect for legitimate business interests that we believe will better serve you and give you the best experience possible. We may also use your personal information to provide you with specific information that you have requested or to provide additional information and services that may be of interest to you based upon this information.

We retain your personal information for only so long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

Section 4. Cookies and Other Data Collection Technologies on Our Websites

When you use our website, apps, or engage with us on our social media channels, some transaction information is collected, including cookies, scripts, Flash Local Shared Objects (flash cookies), pixel tags, e-tags, web beacons, clear GIFs and similar technologies (here, collectively referred to as “Cookies”). These technologies are intended to improve your browsing speed, provide consistency among a variety of content channels, and improve our advertising efforts. We may also use these Cookies as a means to digitally “fingerprint” your device, by gathering attributes and information about the device that you are using to browse our Sites. We may create a unique ID for your device or browser that may assist us in identifying it when it browses our site. This identification allows us to tailor content to you based upon your use of our Site and aids us in preventing fraud and other misuse of our Sites. The use of Cookies is subject to this Privacy Policy and all applicable regulations.

What are cookies?

Cookies are small files placed in your browser’s cache that are triggered by your visit to our website. Once you enter your personal information, such as when you choose “remember me” on the age verification page, the details are cached on your computer. As a convenience, the next time you fill in a field or form, it may automatically populate with information as you begin to type. Cookies may also gather information on the type of browser and device that you use, your IP address, age gate information, language preference information, your online path to our Sites, the number of your visits to our Sites (including your first and last Site visit), the length of time that you spent on our Sites, and the number of pages you visited while on our Sites.

Cookies may also track your movements within our Sites and provide us with information including details of the content that you interact with and access. This information helps us evaluate what types of content might be of interest to you and other visitors. This information may also be used to serve you targeted advertising about our products through our methods and those of our advertising partners.

Types of Cookies found on our Sites

Strictly Necessary- these Cookies are essential for the provision of the Sites and any requested services but do not perform any additional functions, or store directly identifiable personal information. While you may set your browser to block or alert you to these Cookies, blocking these Cookies may prevent some Site functions from working.

Performance Cookies- these Cookies provide data and other statistical information related to site usage. These Cookies provide us with information about how users move about our Sites and assist us in maintaining and improving the Sites. If you do not allow these Cookies, we will not know when you have visited our Site and will not be able to monitor its performance.

Functionality Cookies- these Cookies allow for enhanced Site functionality and personalization based upon your choices, such as videos, language preferences, and live chat. They may be set by us or third-party providers whose services we have added to our pages. By disabling or removing these Cookies, some or all functions of our Sites may not work properly.

Targeting Cookies- these Cookies may be set through our Sites by us or our third-party advertising partners and are used to create user profiles or provide you with personalized content. These Cookies may collect information about your activities on our Sites so that we, and third party advertisers may provide you with advertisements that are more directly suited to your interests. If you do not allow these Cookies or remove these Cookies, the ads provided to you may be less relevant to your interests. Again, by removing or disabling these Cookies, some functions or our Sites may not work properly or may be unavailable to you.

If you do not visit our site frequently, the Cookie will expire over time and remove itself from your computer or web browsing device. If you continue browsing this site without changing your settings, you accept the use of Cookies. However, you can set your browser to delete and/or refuse cookies. Some of these Cookies are essential to your ability to navigate the Site and effectively use its services and features. You may not be able to access all of the Site content or use all features of our Site if you disable all Cookies. Please refer to your browser’s manual for more information.

To the extent that any personal information is collected by or through these cookies, the contents of this Privacy Policy shall apply.

Physical Location Information- We may use your physical location data, collected from your device through your use of systems such as Wi-Fi networks, satellites, and cell phone towers. We may be able to determine the precise location of your device in locations where you use free Wi-Fi that we provide. This physical location information may be shared with our marketing partners to allow them to study and improve upon their advertising campaigns. This location information may also be combined with your browser history as collected by Cookies to provide us and third-party advertisers with the ability to offer you location-based advertisements. You may often choose to permit or deny such location-based data collection and the sharing of such information by adjusting the permissions on your mobile device. By denying such data collection services, you may negatively impact our ability, and the ability of third-party advertisers, to offer you personalized services and content.

Google Analytics- Our Sites do make use of Google Analytics. This is a web analytics service which may use Cookies to gather and analyze data related to your use of our Sites, as well as other sites, services and apps. Google may also transfer the personal information that it collects to third parties. For more information about Google Analytics, how it operates, and how you may opt out of such Cookies as Google may place on your browser, please click the following link: How Google uses information from sites or apps that use our services – Privacy & Terms – Google

For further reading on Cookies, how they interact with your device, and how you may interact with and manage them, please visit https://www.allaboutcookies.org/manage-cookies/index.html

Section 5. How Can I opt Out of Targeted Cookie Advertising?

There are two ways to for you to control which advertisements are shown to you based on your browser cookies.

• If you see any advertising with this logo , you can control whether you see this type of ad. This means the ad is compliant with AdChoices, a self-regulatory program aimed to give consumers enhanced transparency and control. Click on the logo to receive information about the companies that provide you interest-based ads on the websites you browse. You can learn about how AdChoices works and update your privacy choices in the program. If you do not want to see this ad or those similar to it, you can click through to opt-out. For more information, please visit http://www.youradchoices.com/.
• You may also manage your cookies through your browser. Please refer to your browser’s help manual for how to manage your Cookies. Below are directional steps provided for your convenience:
  • In Google Chrome, go to Menu ➔ Settings ➔ Privacy ➔ Cookies, and adjust your settings and site data there.
  • In Safari, navigate to Preferences ➔ Privacy, and then click the "Manage Website Data” option.
  • For Internet Explorer, go to Tools ➔ Internet Options ➔ Privacy Tab to control how your browser interacts with cookies.
  • In Firefox, go to Preferences, and a new tab will open. In the left column, click Privacy & Security, and then find the Cookies and Site Data option
  • In Microsoft Edge, go to Settings & More ➔ Settings ➔ Cookies and Site Permissions to adjust how your browser interacts with Cookies.

Section 6. Your Rights and Choices

You have rights to control how your personal information is used. These include the right to withdraw previous consent and the right to limit communications from us. You have the right to access your personal information and the ability to update, amend, suppress, port or remove it from our records.

If we possess personal information belonging to you that is incorrect, you have the right to inform us that such information is incorrect and ask us to fix any errors. We will do this consistent with applicable law and within a reasonable amount of time. You may also exercise your rights and choices as they relate to interest-based ads from third-party and social media providers.

Section 7. How Do I Update My Information?

You may request to access, update, or remove your personal information. In some cases, we may need further information to verify your identity, or to identify your information within our system. We will respond to your requests consistent with applicable law. Please allow a reasonable period of time for your request to be processed.

Accessing your information

You may learn what personal information we hold about you and request a copy of this information by using the contact form at https://heavenhill.com/make-a-request.php.

Updating your information

You may request that we update or correct your information by using the contact form at https://heavenhill.com/make-a-request.php.

Removing your information

You may ask us to remove or delete your personal information from our database by completing a request form at https://heavenhill.com/make-a-request.php. To opt out of our email marketing efforts, please click the “unsubscribe” link at the bottom of any email that we have sent. Please be aware that even if you opt out of receiving marketing communications from us, we may still contact you for transactional purposes such as customer services, product information, service notices, recalls, or to comply with other applicable laws or regulations.

If you are a resident of California, please see Section 11 “California Consumer Privacy Act of 2018” for more information on your existing privacy rights and how to exercise them.

Section 8. Disclosure of Personal Information

Being trusted with your personal information is important to us, and we understand that you do not want us to provide it to other parties without your consent.

In limited cases, we may share your Personal Information with third party service providers or affiliates if they help perform functions on our behalf- but only for legitimate business interests to which you have expressly agreed. We may also use and disclose general details about you that are not personally identifiable, with our partners- but, again, only for legitimate business interests. We require our service providers to keep your information secure. Unless otherwise disclosed to you, our service providers are not authorized to use or disclose your personal information for their own marketing purposes.

Some examples of the business purposes for which we may use or disclose the personal information you provide include:

• For data management functions, web hosting, and data analysis about the performance of our websites
• To confirm that our internal processes function as smoothly as possible and comply with regulations and requirements
• To monitor our web site security to protect against fraud or cyber attacks
• To identify trends among our users to find out what interests them most about our products, and so we may develop new products and services
• To learn more about how you use our web sites and social media
• Transactional purposes such as payment processing systems, customer support, and product fulfillment and delivery services
• To analyze the impact of our promotional campaigns, so we can make better offers to you

Legal Disclosure- We may disclose your personal information in other special circumstances. For example, we may provide personal information about you to regulatory/law enforcement authorities in accordance with applicable law, when we otherwise believe in good faith that the law requires it, or to respond to requests from governmental authorities.
There may be instances when we may use or disclose your personal information in order to protect or defend the legal rights, property or operations of Heaven Hill Brands or our affiliates, employees, or agents; protect the rights, privacy, safety or security of users, members or others; protect against fraud; and to allow us to pursue available remedies or limit the damages that we may sustain.

Business Transactions- Heaven Hill Brands also has a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale (including sales made as a part of any bankruptcy proceeding), joint venture, assignment, transfer or other disposition of all or any portion of our business, which may include any and all third parties necessary to the transaction (i.e. acquiring entities, advisors, attorneys, or other such persons or entities with a need to know). We may also disclose or transfer your personal information among the Heaven Hill family of brands, including all subsidiaries, affiliates, and assigns.

Section 9. Security

We take the security of your information very seriously and will continue to take appropriate precautions to keep your information secure. Heaven Hill Brands maintains reasonable and appropriate physical, administrative, technical, and organizational procedures to guard the information we collect and to protect it from loss, misuse and unauthorized access, disclosure, alteration and destruction, while taking into account the risks involved in the processing and the nature of Personal Information. We implement industry standard technology to keep your information encrypted and safe.

You can trust that browsing our sites and engaging our content is as safe as any general activity on the internet. That said, no data exchange is ever guaranteed to be 100% secure. Please use your best judgment when providing sensitive or confidential information and take any steps reasonably necessary to protect your personal information against unauthorized disclosure or misuse.

If you believe that your security has been compromised or that your interactions are no longer secure, please contact us immediately using the contact form at https://heavenhill.com/make-a-request.php. In the unlikely event that we believe the security of your information has been compromised, we will use the means of contact available to us, such as your email address, to notify you as soon as possible.

We ask that you do not disclose, and we do not need to know, any sensitive or confidential information. This would include but is not limited to personal details such as social security numbers, biometrics or genetic data, information related to religious beliefs, racial or ethnic origin, political opinions, or criminal background. Please keep this information private.

We make no warranties, express, implied, or otherwise, as to the effectiveness of our reasonable and appropriate safeguards. You are responsible for taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.

Section 10. Privacy Information for Users Located in the European Union

It is the intention of this Privacy Policy to be fully compliant with the General Data Protection Regulation of the European Union (GDPR). We aim to protect and keep the data of all citizens from the European Union (EU) safe from unauthorized access through this Privacy Policy statement. Please note that we use software from third party partners to ensure our compliance with all GDPR regulations.

For those individuals who are visiting our Sites from the EU, please be aware that your personal information may be stored and processed in the United States or any country in which Heaven Hill Brands or its service providers maintain facilities. These countries may have different data protection rules than your country of residence. By using these Sites, you give us your consent to store, process and transfer your information. If you object to such information being transferred, stored, or used in this or any way, please do not use our Site.

For those individuals visiting our Sites from the EU, please know that you may also file a complaint or allege an infringement of an applicable data protection law with a data protection authority in your country or region.

If you are a user visiting from the EU and would like to make a request to us to access, correct, delete, or port your personal information, or to file an objection to our processing of your personal information, please click the following link: https://heavenhill.com/make-a-request.php

Section 11. California Consumer Privacy Act of 2018 (CCPA)

Pursuant to the California Consumer Privacy Act of 2018 (CCPA), this Privacy Policy sets forth disclosures and rights for California residents regarding their personal information. Under this Privacy Policy, Heaven Hill Brands, and/or its affiliates and brands (collectively, “Heaven Hill”, “we”, “us”, or “our”) provide additional details about the categories of Personal Information that we collect from California residents generally, the sources of information, the purposes for which we use the information, and the categories of third parties to whom we disclose the information for business purposes and to whom we sell Personal Information as defined by CCPA. You will also learn how to opt out under the CCPA.

(“Personal Information”) is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer or household.

The Personal Information collected about you will depend on how you use our Sites or interact with us. Accordingly, we may not collect all of the information outlined below about you. The following are additional details regarding the categories of Personal Information about California residents that we have collected or disclosed within the preceding twelve (12) months:

• We collected the following categories of Personal Information:
  • Identifiers- such as your name, contact information, Social Security number, other government issued ID numbers and online or device identifiers;
  • Personal Information as described in the California Customer Records Law- such as your name, address, phone number, information about your employment or education, financial information, medical information, health insurance information, employment and work related information (including references, qualifications and CV), and other categories of information classified as “personal” under California customer records law (Cal. Civ. Code §1798.80(e));
  • Characteristics of protected classifications under California or federal law- may include information such as sex, age, race, religion, national origin, disability, medical conditions, citizenship, immigration status, and marital status;
  • Commercial information- This category includes transaction information such as payment information that you provide for goods and services, customer service records, and information about the products you have purchased;
  • Internet or other electronic network activity information- This category includes information about the web browser and operating system you are using and browsing history, as well as your online behavior including the website or ad that referred you to our Sites, areas of the Sites that you visited, and terms entered into a search engine that led you to the Sites;
  • Geolocation Data- This category includes information such as device location and IP location;
  • Audio, electronic, visual and similar information- This category includes information such as images and audio, video or call recordings created in connection with our business activities;
  • Inferences drawn from any of the information identified above to create a consumer profile- These inferences may relate to your perceived interests, preferences, characteristics, or behavior.
  As described in our Privacy Policy, we collect this Personal Information from you and from other sources, including the following: cookies and tracking technologies, third parties (service providers, data processors, business partners, social media companies, data resellers) when they share this information with us, information received as part of routine fraud checks, and publicly available databases. We may share this Personal Information with third-party groups, which may include: our affiliates, data processors, service providers (which includes those who help manage our Sites and deliver our communications); business partners, third party advertising and analytics companies, third-party contest and promotions partners, successors-in-interest, or other such third-parties or affiliates to whom you have agreed or requested that we share your information. Heaven Hill Brands also reserves the right to share this Personal Information with our advisors, auditors, service professionals, government authorities or regulators, entities who may acquire your information as a result of merger, acquisition, or other ownership transaction in whole or in part; or other government agencies as required by international, federal, state, or local law. We may use this personal information in a variety of ways, including, but not limited to: respond to and fulfill your requests for products and services; register and service your account; operate, manage and maintain our business and Sites; administer surveys, sweepstakes, contests, promotions, and events; provide customer service and alert you to important product information, including recalls; improve and customize our service offerings, websites and advertising; perform identity verification; perform accounting, auditing, and other internal functions such as performing internal investigations, as well as exercising and defending legal claims and maintaining compliance with all laws, legal processes, and internal policies.
• Within the past twelve (12) months, we also disclosed the following Personal Information to third parties (such as service providers, data processors, advisors, business partners, and other public or government authorities) for operational business purposes:
  • Identifiers- This category consists of information such as your name, contact information, Social Security numbers, other government issued ID numbers and online or device identifiers;
  • Personal Information as described in the California Customer Records Law- This information includes your name, address, phone number, information about your employment or education, financial information, medical information, health insurance information, employment and work related information (including references, qualifications and CV information), and other categories of information classified as “personal” under California law;
  • Characteristics of protected classifications under California or federal law- This includes information such as sex, age, race, religion, national origin, disability, medical conditions, citizenship, immigration status, and marital status;
  • Commercial information- This category includes transaction information such as payment information that you provide for goods, services, customer service records, and information about the products you have purchased;
  • Internet or other electronic network activity information- This category includes information about the web browser and operating system you are using and browsing history, online behavior including the website, ad, or search engine terms that referred you to our Sites, areas of the Sites that you visited;
  • Geolocation Data- This category includes information such as device and IP location;
  • Audio, electronic, visual and similar information- This category includes information such as images and audio, video, or call recordings created in connection with our business activities;
  • Inferences drawn from any of the information identified above to create a consumer profile- These inferences relate to your perceived interests, preferences, characteristics, or behavior.
• SALE OF PERSONAL INFORMATION: The CCPA provides a right to California residents to request to opt-out of the sale of Personal Information. While we will not “sell” your information for money or other valuable consideration, we may allow third-party advertising companies to collect data from visitors to our Sites to better serve you more relevant advertisements. This may potentially be considered “sales” under CCPA under certain circumstances. You may submit a written request to us to mark your Personal Information as “Do Not Sell” by contacting us through the following link: https://heavenhill.com/make-a-request.php.

You may also limit the access that these third-party advertising companies have to information about you when you use our Sites by installing a browser or browser extension that can enable you to block the functionality of some tracking technologies. If you use different computers, devices, apps or browsers, you may need to indicate your opt-out choices across those computers and browsers.

YOUR RIGHTS UNDER THE CCPA

If you are a California resident, you have the right to submit the following requests regarding your Personal Information that we collected within the twelve (12) months preceding your request:

• Access your Personal Information:
  • The categories of Personal Information that we have collected about you and the categories of such sources from which we collected that Personal Information
  • Access to your Personal Information data that we have collected, including the specific pieces of Personal Information that we have collected
  • The categories of your Personal Information that we have shared and the categories of those third parties to whom we have shared or disclosed your Personal Information
• Deletion of your Personal Information, if we are permitted by applicable law
• Request to “Opt Out” of the sale of your Personal Information

Where we have obtained your consent for the processing of your personal data, you have the right to withdraw your consent at any time.

If you are a California resident and would like to exercise your right to access the Personal Information that we collected about you in the prior twelve (12) months or if you would like to request that we delete your Personal Information, please contact us by using the following form https://heavenhill.com/make-a-request.php.

You may be required to provide us with such information as your name, phone number, or email address so that we may verify your request.

To submit a request to access or a request to delete your Personal Information, you may also contact us toll free at [1-888-914-9661] and enter the access PIN: 839079.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you of goods or services;
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties as a result of your request;
• As a result of your request, provide or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and will contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Please note that from time to time we may update and revise this CCPA notice affecting California residents. We will notify you of any recent updates by altering the “Last Updated” language at the top of this Section 11 CCPA Notice.

Section 12. Contact Us

If you have any privacy-related questions, concerns or complaints, please contact us using the following web form:
https://heavenhill.com/make-a-request.php

Or via email: Privacy@heavenhill.com