SOVEREIGN BRANDS PRIVACY POLICY

This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from sovereignbrands.com (the “Site”) or any of its sub domains (lucbelaire.sovereignbrands.com, bumbu.sovereignbrands.com, mcqueenvioletfog.sovereignbrands.com, villonfrance.sovereignbrands.com, or deacon.sovereignbrands.com) as well as any of its subsidiaries or future sites.

Effective Date: May 15th, 2024

UNAUTHORIZED USE

YOU MUST BE OF LEGAL DRINKING AGE TO VISIT SOVEREIGN BRANDS’ WEBSITES. IF YOU ARE NOT, YOU MUST LEAVE THE SITES IMMEDIATELY. BY USING OUR SITES, AND ANY TO WHOM YOU SUBSEQUENTLY ELECT TO BE DIRECTED, YOU HAVE REPRESENTED TO US UNDER PENALTY OF LAW THAT YOU ARE IN FACT OF LEGAL DRINKING AGE.

INTRODUCTION

Welcome! You have arrived at a website operated by Sovereign Brands, L.L.C., or our affiliates (“Sovereign Brands,” “we”, “our” or “us”). Sovereign Brands is a true family wine & spirits company, with four generations of history in the industry. Since 1999, Sovereign Brands has pursued its goal of becoming the wine & spirits industry’s most innovative creator of unique, forward-thinking new brands. Through partnerships with high-quality, family-owned wineries and distilleries worldwide, we build each of our brands from the ground up to meet our standards of product quality and innovation. The Sovereign Brands family of companies includes the following entities:

Bumbu Rum Company

LLC Luc Belaire International Limited

Luc Belaire LLC

Sovereign Brands, L.L.C.

Villon International LLC

Violet Fog International LLC

At Sovereign Brands, we take your privacy very seriously. This Privacy Notice (“Notice”) describes the types of Personal Information (as defined below) that we collect, how we use it, how and when we share it, and the rights you have with respect to your information. It also explains how we communicate with you and how you can make inquiries and requests to us about your information. We strive to help you understand how we use your information to improve our products, services, marketing, and interactions with you, as part of our commitment to maintaining your trust.

SCOPE

This Notice applies when you use or access one of the following websites or any other website or landing page operated by us that links to this Notice, as well as their subdomains or portals (collectively, the “Sites”) or otherwise provide Personal Information or interact with us online or in-person at one of our events:

For the purpose of this Notice, “Personal Information” means any Personal Information relating to an identified or identifiable individual that is protected by applicable privacy laws. We refer to all of the above as “Services.” By using the Services, you agree to our Terms of Use. Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that Personal Information is necessary to provide you with the Services or if we are legally required to collect it. If you have any questions about this Privacy Notice, please contact us at privacy@sovereignbrands.com.

WHAT INFORMATION WE COLLECT

This section describes what information we collect from you through our Sites and Services, including in-person events. We may receive information (including Personal Information) in the following ways:

INFORMATION THAT YOU PROVIDE TO US

As you interact with our Sites and Services, we may collect Personal Information via the online chat function and webforms or inputs/uploads on our Sites, and through telephone calls, letters, emails and other communications with you. We also collect Personal Information through online and in-person events (terms and rules may apply) that we occasionally organize and host to promote our products and Services. We may collect information such as:

Date of birth. Provided to enter our site and enable purchases through a third party.
Contact and account information. Contact and account information such as your first and last name, email address, home or business address, telephone numbers, mobile numbers and password;
Social media information. Social media handles, content and other data shared with us through third-party features that you use on our Sites and other service (such as tools, payment services, widgets and plug-ins offered by social media services like Facebook, Instagram, Twitter and Pinterest) or posted on social media pages (such as our social media page or other pages accessible to us);
Employment information. If you apply for employment with us, your current or past employment or educational information, as well as references and referrals provided to us in connection with your employment applications; and/or
Other information. Other information that could reasonably be used to identify you personally or identify your household or device.

Your decision to provide us with Personal Information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all the features of the Sites or our Services.

INFORMATION THAT IS AUTOMATICALLY COLLECTED

Like many businesses, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Sites and Services (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Sites. Usage Information may include:

Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);
Referring and exit web pages and URLs;
The areas within the Sites that you visit and your activities there, including remembering you and your preferences;
Your Device location or other location information, including the zip code, state or country from which you accessed the Services;
Your Device characteristics;
Certain other Device data, including the time of day you visit our Sites or other information used to provide analytics or other usage information;
Information about your engagement with our emails; and
Statistical information about how both unregistered and registered users, collectively, use the Sites and Services. This aggregate information is derived from Personal Information but cannot be tied back to you or your web browser.

For location information, some of our Services may include features based on users’ actual locations and may report on users’ current locations (“Location-Based Services”). To the extent you use any Location-Based Services, we may collect and store information about your location at the time you use those Location-Based Services (in addition to some automatically collected geolocation data). This information can come from a variety of sources depending on the device you use to access the Services; for example, a mobile phone may report its GPS location at the time Location-Based Services are used. If you no longer wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device manufacturer settings for instructions. Please note that if you disable such features, your ability to access certain features, Services, content, promotions, or products may be limited or disabled.

INFORMATION COLLECTED FROM THIRD PARTIES

The Sites may include functionality that allows certain kinds of interactions between the Sites and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of Sovereign Brands from third parties. We might also provide links to facilitate sending a communication from the Sites, or we may use third parties to facilitate emails or postings to social media (like a “Share” or “Forward” button). These third parties also use cookies and other tracking technologies to capture information about your interactions with Sovereign Brands. Sovereign Brands does not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

We may also collect personal information from third party retailers or other entities who engage in e-commerce (the “Retailer”) when you use their website to make purchases of our products from the Retailer. For example, if permitted by the Retailer, we may collect information from those websites about your purchases including, without limitation, your name, date of purchase, delivery details, products purchased and contact information.

HOW WE USE YOUR INFORMATION

We use your information for business and commercial purposes, including to browse the Sites, to offer our products and services, to provide you with customer service, to prevent security and fraud, to provide marketing information about our products and services, and to perform website analytics. We may use the information we collect about you in a variety of ways, including the following:

TO VERIFY THAT YOU ARE OF LEGAL DRINKING AGE

We ask you to verify that you are of legal drinking age prior to entering our Sites, as required by law.

TO PROVIDE OUR SERVICES

We may process certain Personal Information when you access or use our services, including to:

facilitate your purchases of, or requests for, our products and merchandise from a third party provider (this will take you to the shop.sovereignbrands.com site);
register and verify user accounts;
facilitate the functionality of our websites; and
customize experiences and personalization when you are on our Sites.

TO COMMUNICATE WITH YOU

We may process certain information in order to communicate with you in relation to your accounts, our services, our marketing, and your requests, including to:

communicate with you about Sovereign Brands’ products and Services, accounts, programs, contests, and sweepstakes;
respond to your customer service inquiries and requests for information;
post your comments or statements on our websites;
send you personalized promotions, content, and special offers;
communicate with you about our brands, products, contests, events, or other promotional purposes;
implement your communications preferences, such as sharing information with our business partners so that they may email you about their promotions, products and initiatives; and
provide important product safety information and notice of product recalls.

FOR IMPROVEMENT OF OUR SITES AND SERVICES

We want to ensure that our Sites and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain Personal Information, including to:

maintain, improve, and analyze our Sites, and the products and services we offer; and
detect, prevent, or investigate suspicious activity or fraud.

TO COMPLY WITH APPLICABLE LAWS

We may be required to process certain Personal Information under certain laws and regulations as well as to:

maintain appropriate records for internal administrative purposes; and
comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.

TO ENFORCE OUR TERMS, AGREEMENTS, OR POLICIES

To maintain a safe, secure, and trusted environment for you when you use our Sites, and other services, we may use your Personal Information to ensure our Terms of Use, policies, and agreements with you and any third parties are enforced.

EVALUATE YOUR APPLICATION FOR EMPLOYMENT

We may collect personal information to evaluate your application for employment or administer employment benefits.

WITH YOUR CONSENT

We may process certain Personal Information in order to fulfill any other business or commercial purposes at your direction or with your consent.

USE OF COOKIES

We use cookies and other tracking technologies to personalize your experience, analyze user trends, and improve the Services. These tracking technologies allow us to collect information such as your device type, browser type, interactions with our Sites, geographic location, your web request, the date and time of your web request, your Internet Protocol address, the domain name of your Internet service provider and other data. If you can be identified from this information, for example by combination with other pieces of information, then we will treat this information as Personal Information. You can alter the configuration of your browser to refuse to accept cookies, but it is possible that doing so may cause limited functionality of the Sites. For example, we may not be able to recognize your computer or device, and you may need to verify your age every time you visit. We may use “cookies” (a small text file sent by your computer each time you visit our site) or similar technologies to record log data. Many browsers default to accepting cookies. You may be able to change this setting in your browser and you can also clear your cookies. If you do, you may lose some functionality of our site. Check your browser’s help function to learn more about your cookie setting options. We may use the following types of cookies:

Advertising cookies
Essential cookies
Functionality cookies
Social Media cookies

We might also use a pixel tag which is a small graphic file that allows us and third parties to monitor the use of the site and provide us with information based on your interaction with the site. These tags may collect the IP address from the device which you loaded the page, the browser type. Pixel tags are also used by our third parties to collect information when you visit our site, the links and other actions you take on our site, and we may use this information in combination with cookies to display targeted advertisements. Other data technologies may be used that collect comparable information for security and fraud detection purposes. If you have any questions about cookies or to generally find out more about cookies, visit this site.

YOUR CHOICES

CONTROLLING COOKIES

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

Note, however, that if you reject our request to use cookies or turn cookies off, you may be unable to access certain parts of the Sites and you may not be able to benefit from the full functionality of the Sites. To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit www.allaboutcookies.org, and/or www.youronlinechoices.com.

DO NOT TRACK

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites and platforms. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed-upon standard for what Sovereign Brands should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.

COMMUNICATION PREFERENCES

With your consent, Sovereign Brands may communicate with you via a variety of media, including email and text messages. To help us make e-mails more useful and interesting, we often receive a confirmation when you open e-mail from us if your computer supports such capabilities. You can opt out of receiving emails and text messages from us at any time. To manage your communications preferences with Sovereign Brands — or to opt out of communications entirely — please unsubscribe at the bottom of our emails or contact us at privacy@sovereignbrands.com.

ANALYTICS

We may use Google Analytics to help us understand how our customers use the Sites. You can read more about how Google uses your Personal Information here: https://policies.google.com/privacy?hl=en. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

HOW WE SHARE YOUR INFORMATION

SERVICES PROVIDERS

We may share your Personal Information with our third-party service providers who provide services such as website hosting, payment processing, online chat functionality, data analysis, information technology, customer service, email delivery, online advertising, auditing, event planning and other services.

THIRD PARTY ADVERTISING

We may share information about your use of our Sites and Services, your purchases, and your interaction with our ads on other websites with our advertising partners to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location). For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. You can opt out of targeted advertising by visiting the following:

Facebook – https://www.facebook.com/settings/?tab=ads
Google – https://adssettings.google.com
Bing – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Pinterest – https://help.pinterest.com/en/article/personalized-ads-on-pinterest

OTHER

Aside from the instances described above, we will only share your Personal Information:

to comply with the law;
to respond to claims or comply with legal process served on Sovereign Brands (e.g., a lawful subpoena, warrant, or court order);
to enforce or apply our policies or agreements;
to protect and defend our rights or property or that of our customers, employees, visitors, or the public;
in connection with a business transfer, sale, liquidation, or merger;
if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure; and
with your consent.

THIRD PARTY LINKS

Out Sites may contain links to other websites such as social media platforms, other websites, and event and partner websites. These websites are not covered by this Privacy Notice. Please review the Privacy Notices or Policies of those websites to understand the privacy practices of these third parties.

INTERNATIONAL TRANSFERS OF DATA

The Sites are operated in the United States. If you are located in another jurisdiction, please know that your information will be transferred to, stored, and processed in the United States. By using these Sites and providing us with information, you consent to this transfer, processing and storage of your information in the United States. It is important to note that the privacy laws in the United States may not be as comprehensive as those in other countries such as those in the European Union (“EU”). Our service providers use appropriate safeguards to transfer your Personal Information to the United States.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Where we have given you (or where you have chosen) a password so that you can access certain areas of our site, you are responsible for keeping this password confidential. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us at privacy@sovereignbrands.com.

RETENTION OF PERSONAL INFORMATION

Sovereign Brands will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. All information you provide to us is stored on our secure servers or those of our third-party data storage providers.

When deciding how long to keep your information, we consider:

How long we have had a relationship with you or provided our Services to you;
Whether we are subject to any legal obligations (e.g., any laws that require us to keep transaction records for a certain period of time before we can delete them)
Whether we have taken any legal positions (e.g., in connection with any statutes of limitation).

Rather than delete your data, we might de-identify it by removing identifying details.

YOUR RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION

This section of our Privacy Notice applies if you are a data subject who resides or is located in the European Economic Area (“EEA”). We adopted this Policy to comply with European privacy laws, including the General Data Protection Regulation (“GDPR”). Any terms defined in the GDPR have the same meaning when used in this Section. In most instances, Sovereign Brands is the data controller for processing Personal Information provided to us through the Sites. We hope to ensure that the Personal Information we possess are always accurate and therefore we encourage you to update your information in your own account in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information, subject to applicable law. We take every reasonable step to ensure that the Personal Information that we process are limited to the Personal Information that are reasonably required in connection with the purposes set out in this Privacy Notice. If you are a resident of or located within the EEA, you have certain data protection rights. These rights include:

The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Information by contacting us at the contact information below.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Information.
The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable, and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Sovereign Brands relied on your consent to process your Personal Information.

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

We rely on the following legal bases for processing your Personal Information:

Contract: To conclude or perform a contract with you; for example:
- To manage and fulfill orders, facilitate delivery, and to provide other Services;
- To manage our accounts and records;
- To handle your inquiries and requests;
Legitimate Interests: When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below. Examples of legitimate interests include:
- To respond to your customer service inquiries and requests for information;
- To maintain, improve, and analyze our Site and Services we offer;
- To conduct marketing activities;
- To detect, prevent, or investigate security breaches or fraud; and
- To facilitate the functionality of our Site;
Legal Compliance: To comply with our legal obligations; for example:
- To maintain appropriate records for internal administrative purposes and as required by applicable law, and
- To provide important product safety information and notice of product recalls
Consent: We will send you information by email on our Services or other promotions only with your consent or if you otherwise opt-in to receiving those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time as described below.

EXERCISING YOUR RIGHTS UNDER GDPR

If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the contact details below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the EEA in order to obtain the information. We will respond to your request within 30 days or let you know if we need additional time. Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request. Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us as follows:

Sovereign Brands, L.L.C.
383 West Broadway 5th Floor
New York, NY 10012

Email: privacy@sovereignbrands.com

Designated representative: Sovereign Brands, L.L.C. c/o Luc Belaire International Limited, 5^th Floor, 76 Sir John Rogerson’s Quay, Dublin 2, Ireland

YOUR CALIFORNIA PRIVACY RIGHTS

This section of our Privacy Notice applies to consumers who reside in California. We adopt this section to comply with the California Consumer Privacy Act (“CCPA”) and California Privacy Reform Act (“CPRA”). If you are a California resident, you may be able to exercise the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.

RIGHT TO ACCESS AND INFORMATION REGARDING PERSONAL INFORMATION

You have the right to request that we disclose to you the categories and specific pieces of Personal Information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:

The categories of Personal Information we have collected about you;
The categories of sources from which the Personal Information is collected;
Our business or commercial purpose for collecting or selling Personal Information;
The categories of third parties with whom we share Personal Information;
The specific pieces of Personal Information we have collected about you;
The categories of Personal Information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of Personal Information for each third party to which we disclosed the Personal Information; and
The categories of Personal Information about you that we disclosed for a business purpose.

RIGHT TO DELETION OF PERSONAL INFORMATION

You have the right to request that we delete Personal Information about you that we have collected from you. There may be certain exceptions to our obligation to delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.

RIGHT TO CORRECT PERSONAL INFORMATION

You have the right to request that we correct any inaccurate information that we maintain about you.

RIGHT TO OPT-OUT

You have the right to opt out of the sale of Personal Information. We do not sell Personal Information, but we recognize that some privacy laws define “Personal Information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” To opt-out of this, please click on this link.

RIGHT TO NON-DISCRIMINATION

We may not discriminate against you because you have exercised any of the aforementioned rights, including by:

Denying you goods or services;
Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
Providing you a different level or quality of goods or services; or
Suggesting that you will receive different price or rate for goods or service or at a different level or quality of goods or services.

However, as permitted by the CCPA, we may offer you certain financial incentives. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

PERSONAL INFORMATION WE COLLECT ABOUT CALIFORNIA CONSUMERS

We may collect certain types of Personal Information about you during your relationship with us, as stated above. In particular, we collected the following categories of Personal Information from California consumers within the last twelve (12) months:

Category of Personal Information Collected	Collected (Yes/No)	Sources of Personal Information Collected	Business or Commercial Purpose for Collection	Sold	Shared
Identifiers such as name, address, email address, phone number, unique id, and other identifiers listed in the Personal Information Collected section above.	Yes	You Automatically Third Parties	To provide our products and Services To provide information you requested To improve our products and Services To identify potential customers To market our products and Services For verifying identity For fraud prevention purposes To process payments To comply with law To offer employment, to provide insurance and benefits, for background checks	No	No
The following categories of Personal Information described in California Civil Code §1798.80(e): (1) the Personal Information listed in the preceding bullet point as “identifiers,” and (2) the other information that identifies, relates to, describes, or is capable of being associated with a particular individual that we describe in “Information We Collect” above.	Yes	You Automatically Third Parties	To provide our products and Services To provide information you requested To improve our products and Services To identify potential clients To market our products and Services For verifying identity For fraud prevention purposes To process payments To comply with law To manage payroll and provide and administer employee benefits	No	No
Characteristics of protected classifications under California or federal law list any of these that you collect: race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.	No	N/A	N/A	No	No
Commercial information, including information about orders or purchases of any of our products or services; registration information, specials, and information you provide or submit to us when you participate in any event, program, contest, survey or other promotion that we may offer from time to time.	Yes	You Automatically Third Parties	To provide our products and Services To market our products and Services To improve our products and Services To provide information you requested To comply with law	No	No
Biometric Information.	No	N/A	N/A	N/A	N/A
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our websites, or Sovereign Brands pages or accounts on any third-party social media platforms.	Yes	Automatically	To provide our products and services To market our products and services To improve our products and services (e.g., usage pattern data) To track employee actions for internal reports and information security purposes	Yes	Yes
Geolocation data.	Yes	Automatically	To market our products and services For detecting security incidents and protecting our Site	No	No
Audio information from calls placed with customer service that may be reported, and electronic information in the form of Internet or other electronic network activity information described above.	Yes	Automatically	To provide our products and services	No	No
Professional or employment-related information.	No	N/A	N/A	No	No
Education information.	No	N/A	N/A	No	No
Inferences drawn from (1) the information we collect when you visit our websites, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumers preference and behavior that we collect on our websites or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.	Yes	Third Parties	To provide our products and services To market our products and services To improve our products and services For detecting security incidents and protecting our Site	No	No
Sensitive Personal Information such as racial / ethnic origin, political opinions, religious / philosophical beliefs, genetic data, biometric data, sex life / sexual orientation, past or spent criminal convictions, mail, email and text message content, precise geolocation data, social security, driver’s license, state identification card, or passport number, account login, financial account, debit card, or credit card number.	No	N/A	N/A	N/A	N/A

REQUESTS TO EXERCISE YOUR RIGHTS

You or your authorized agent may make a request to access, correct, delete or opt-out of the disclosure of your Personal Information for business purposes. You may also make a verifiable consumer request on behalf of your minor child if you believe we have received their information inadvertently. You may request to exercise the aforementioned rights by:

Submitting a request to privacy@sovereignbrands.com
Calling us at (888) 460-1205

Please note that we may take steps to verify your identity and residency before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. If you use an authorized agent, we may require proof of written authorization you have given to make the request. We may limit our response to your exercise of the above rights as permitted by law. We will confirm receipt of the request within 10 business days describing our verification process. We will respond to your request within 45 days or let you know if we need additional time.

DATA SHARING FOR DIRECT MARKETING PURPOSES

California Civil Code § 1798.83 further permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your Personal Information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at privacy@sovereignbrands.com.

YOUR PRIVACY RIGHTS UNDER OTHER US STATE LAWS

Based on the applicable law in the state where you live, you may have the following rights with respect to your Personal Information:

To confirm whether or not a controller is processing your personal data and to access such personal data;
To correct inaccuracies in your personal data;
To delete your personal data;
To obtain a copy of your personal data that you previously provided to us in a portable, and if technically feasible, readily usable format, if processing is carried out by automated means;
To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
Not to discriminate against you because you have exercised any of these rights, including by:
- denying you Services;
- charging different prices or rates for our Services, including through the use of discounts or other benefits or imposing penalties;
- providing you a different level or quality of Services; and/or
- suggesting that you will receive a different price or rate for Services, or at a different level or quality of Services.

To exercise any of these rights, you may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by selecting “unsubscribe” at the bottom of our email, if applicable, or by contacting us using the information in the Contact Us section below.

We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request up to twice annually. For emails, please include “Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a resident. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.

RIGHT TO OPT OUT

You may have the right to opt out of the sale of their Personal Information and targeted advertising. To exercise your right, please contact us using the information in the Contact Us section below.

OPT-OUT PREFERENCE SIGNALS

Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. GPC is a web browser-level setting, maintained by either a browser or a browser extension, that a user or privacy-focused technology can set. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.

APPEALS OF OUR DECISIONS

In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of certain choices described above. In order to appeal such a refusal, please contact us using the information in the Contact Us section below with the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email.

If we decline to take action on any request you make, we will provide you with the information required by the applicable law where you live. This may include an explanation of why we declined your request, information on how to appeal our decision, and/or how to make a complaint to your state Attorney General.

CHANGES TO THIS PRIVACY NOTICE

We may change this Privacy Notice at any time. We will post all changes to this Privacy Notice on this page and will indicate at the top of the page the modified notice’s effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy notice. If required by the applicable law, we will notify you of the changes. By continuing to use the Sites and/or the Services or providing us with information following such a replacement Notice being uploaded, you agree that you will be deemed to have agreed to be bound by the Privacy Notice as changed.

CONTACT US

If you have any questions or suggestions regarding this Privacy Notice, please contact us at: