SKREWBALL SPIRITS, LLC WEBSITE PRIVACY POLICY 

Last Revised on November 16, 2020

This Privacy Policy for Skrewball Spirits LLC (“Company”, “we”, “us” “our”) describes how we collect, use and disclose information about users of the Company’s website https://skrewballmain.wpengine.com (the “Website”). For the purposes of this Privacy Policy, “you” and “your” means you as the user of the Website.

PLEASE READ THIS PRIVACY POLICY CAREFULLY.  BY USING OR ACCESSING ANY OF THE WEBSITE, YOU AGREE TO THE USE OF YOUR INFORMATION DESCRIBED IN THIS PRIVACY POLICY AND TO THE OTHER TERMS OF THIS PRIVACY POLICY.  The Website is for individuals in the United States only and is not intended for users located outside the United States. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY OR ARE NOT IN THE UNITED STATES, PLEASE DO NOT ACCESS AND USE THE WEBSITE.

1. UPDATING THIS PRIVACY POLICY

   • We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make changes that are material, we will use reasonable efforts to attempt to provide notice to you and, where required by applicable law, we will obtain your consent. Notice will be consistent with applicable law. The updated Privacy Policy will be effective as of the time of posting, or such later date as may be specified in the updated Privacy Policy.  If you do not agree to any updates to this Privacy Policy PLEASE DO not access or CONTINUE TO use the Website.

2. COMPANY’S COLLECTION AND USE OF INFORMATION

   1. In order to provide you with our Website, we may ask you to provide us with certain details or information about you. Information that you submit through our Website may include:

      • Basic contact details, including name, address and email.  We collect basic contact details to communicate with you and provide you with information on products and Website.
      • Any other information you choose to include in communications with us, for example, when sending a message.

   2. Our Website may require you to enter certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

      We may also collect personal information about you from third parties.  Such information may come from sources such as:

      • Consumer marketing databases or other data enrichment companies, which is used to better customize advertising and marketing to you

   3. Any information we receive from outside sources will be treated in accordance with this Privacy Policy.  We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices.  See Sections 5 and 6 below for more information.

      We also automatically collect certain information about your interaction with the Website (“Usage Data”). To do this, we may use cookies, web beacons/clear gifs, pixels, tags and other tracking technologies (“Tracking Technologies”). Usage Data may include:

      • Unique device identifier
      • Device type, such as your phone, computer or tablet
      • IP address
      • Browser type
      • Date and time stamps, such as the date and time you first accessed the Website
      • Operating system
      • Log data
      • Precise location
      • Clickstream data
      • Ad impressions

   4. We use the information we collect automatically to tailor features and content to you and to run analytics and better understand user interaction with the Services.

      In addition to the foregoing, we may use all of the above information to comply with any applicable legal obligations, to enforce any applicable terms of service, and to protect or defend the Website, our rights, the rights of our users, or others.

3. HOW THE COMPANY SHARES YOUR INFORMATION

   1. In certain circumstances, the Company may share your information with third parties. Such circumstances may include:

      • With vendors or other service providers, such as
        • Data analytics vendors
        • IT service management vendor
        • Email distribution vendors
        • Security vendor
        • Social media marketer
        • Marketing and digital advertising agencies
      • With our affiliates or otherwise within our corporate group
      • To comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries
      • In connection with an asset sale, merger, bankruptcy, or other business transaction
      • To enforce any applicable terms of service
      • To ensure the safety and security of the Company and/or its users
      • When you request us to share certain information with third parties, such as through your use of social media widgets or login integrations.
      • With professional advisors, such as auditors, law firms, or accounting firms

   2. You acknowledge that such sharing of information may occur in all of the aforementioned circumstances and is permitted by and subject to this Privacy Policy and applicable law.

4. COOKIES AND OTHER TRACKING TECHNOLOGIES

   1. Do Not Track Signals

      Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers. To learn more about “Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

   2. Cookies and Other Tracking Technologies

      You may control the way in which your devices permit the use of Tracking Technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Website, including general functionality, to work incorrectly.

      Most browsers accept cookies automatically. However, you may be able to configure your browser settings to use the Website without some cookie functionality. You can delete cookies manually or set your browser to automatically delete cookies on a pre-determined schedule.  For example, in the Internet Explorer menu bar, select: Tools Internet OptionsBrowsing HistoryDelete to view manual and automatic options.

      To opt out of tracking by Google Analytics, click here.

      We may also use Flash cookies (also known as “persistent identification elements” or “local shared objects”) on certain pages. Because Flash cookies cannot be controlled through your browser settings, you may click here to adjust your preferences. You can also identify Flash cookies running on your computer by visiting the Flash Player folder. Flash cookies, or LSO files, are typically stored with a “.SOL” extension. Please note that if you block cookies, some functions otherwise available on the Website may be unavailable, and we may not be able to present you with personally-tailored content.

      If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the contact information listed below.

5. SOCIAL FEATURES

   1. Certain features of the Website permit you to initiate interactions between the Website and third-party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to click and access the Company’s pages on certain third-party platforms, such as Facebook and Twitter, and from there to “like” or “share” our content on those platforms. Use of Social Features may entail a third party’s collection and/or use of your data. If you use Social Features or similar third-party services, information you post or otherwise make accessible may be publicly displayed by the third-party service you are using. Both the Company and the third party may have access to information about you and your use of both the Website and the third-party service. For more information on third-party websites, services, and platforms, see Section 6.

6. THIRD PARTY WEBSITES AND LINKS

   1. Our Website may contain links to other online platforms operated by third parties; these websites may contain goods and services with Company branding. We do not control such other online platforms and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook or Twitter) may also be viewable by other users of the Website and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Website. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal information by third parties. Any information submitted by you directly to these third parties is subject to that third party’s privacy policy.

7. DATA SECURITY

   1. Please note that any information you send to us electronically, while using the Website or otherwise interacting with us, may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” Any information you send us through any means is transmitted at your own risk.

8. CALIFORNIA PRIVACY RIGHTS

   1. Terms used in this section and not otherwise defined have the meaning given to them under the California Consumer Privacy Act of 2018 (“CCPA”). We do not sell personal information collected about you. We do not have actual knowledge that we sell personal information of individuals under 16 years of age.

      In the preceding 12 months, we collected and disclosed for a business purpose the following categories of personal information about California consumers:

      Category	Examples	Collected?	Categories of Recipients
      A. Identifiers	Name, postal address, e-mail, IP address	Yes	Service providers who process data on our behalf Internet service providers
      B. Personal information categories listed in the California Customer Records statute	Name; signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number; etc.	Yes	Service providers who process data on our behalf Internet service providers
      C. Protected classification characteristics under California or federal law	Race; gender, etc.	Yes	Service providers who process data on our behalf Internet service providers
      D. Commercial information	Records of personal property, products or services purchased	No	No
      E. Biometric information	Physiological, biological, or behavioral characteristics	No	No
      F. Internet or other similar network activity	Information on a consumer’s interaction with the Website	Yes	No
      G. Geolocation data	IP address data	Yes	Service providers who process data on our behalf Internet service providers
      H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	No	No
      I. Professional or employment-related information	Title of profession; employer	No	No
      J. Non-public education information collected by certain federally funded institutions	None	No	No
      K. Inferences drawn from other personal information	Profile reflecting a person’s preferences	Yes	Service providers who process data on our behalf Internet service providers

      Purposes for Collection, Use, and Sharing. We use and disclose the personal information we collect for our commercial purposes, as further described in this Privacy Policy, including for our business purposes:

      • • Auditing related to our interactions with you;
        • Legal compliance;
        • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and necessary prosecution;
        • Debugging;
        • Performing services (for us or our service provider);
        • Internal research for technological improvement;
        • Internal operations;
        • Activities to maintain and improve our services; and
        • Other one-time or short-term uses.

   2. Your Rights. Where applicable, if you are a California resident you may have the following rights under CCPA in relation to “personal information” we have collected about you as defined in the CCPA; these rights are, to the extent required by the CCPA and subject to verification and any applicable exceptions:

      • Right to Know/Access: You have the right to request that we disclose certain information to you about our collection and use of certain personal information about you as described below:
      1. 1. • • The specific pieces of personal information collected;
      1. 1. • • The categories of personal information collected;
      1. 1. • • The categories of sources from whom the personal information is collected;
      1. 1. • • The purpose for collecting the personal information; and
      1. 1. • • The categories of third parties with whom we have shared the personal information.
      • Right to Delete: You have the right to request that we delete the personal information.
      • Freedom from Discrimination: You have the right to be free from unlawful discrimination for exercising any of the rights above.

      To make a request in relation to the above rights, please contact us using the information below.  To fulfil your request, we will need to verify your identity.

      Only you, or someone legally authorized to act on your behalf, may make a request related to personal information collected about you. To designate an authorized agent, the authorized agent must provide sufficient information that allows us to reasonably verify that they have been authorized by you to act on their behalf.

9. HOW TO CONTACT US

   1. To request your exercise of the rights described above or for questions relating to this Privacy Policy, please contact us as follow:

      1. 1. • Calling us toll-free at 1-833-757-3933;
      1. 1. • Emailing us at [email protected].