EFFECTIVE DATE: May 3, 2023

Last Reviewed: May 3, 2023

MPL Brands NV, Inc. and its affiliates (“Patco Brands,” “we,” “our,” and/or “us”) value the privacy of individuals who use our websites and related services (collectively, our “Services”).
This Privacy Notice explains how we collect, use, and share the information of users of our Services (“Users” or “you”). By using our Services, you agree to the collection, use, disclosure, and processing of your information as described by this privacy policy (the “Privacy Policy”).  This Privacy Policy does not apply to how third parties define personal data or how they use it. We encourage you to read their privacy policies and know your privacy rights before interacting with them. 


If you are a resident of California, Colorado, Connecticut, Utah, and Virginia, please see our Detailed State Privacy Notices section below. 


Persons Under Legal Purchase Age Are Not Allowed

Patco maintains this Site for the use of individuals who are of legal purchase age of alcoholic beverages under applicable law, and you must be of legal purchase age where you reside to access this Site or provide any information to us. We do not solicit or knowingly collect any information from any individuals under such legal purchase age, and we do not knowingly market our products or services to persons under such legal purchase age. Prior to the collection of any information, you will be required to affirm that you are of legal purchase age. Please do not provide us with your information if you are not of legal age to purchase alcohol in the jurisdiction in which you reside and (if different) in the jurisdiction in which you are interacting with us.  If we receive notice or believe that someone under the legal purchase age has provided us with information we will use reasonable efforts to remove such information from our files, or to flag such information and (to the extent permitted by law) retain it for the sole purpose of ensuring that it is no longer used.

Information We Collect

We may collect a variety of information about you or your devices from various sources, as described below.

• Information You Provide to Us

Registration Information. If you sign up for an account, register, or sign up for emails or other updates, we may ask you for basic contact information, such as name, email, phone number, or mailing address. We may also collect certain account, employment and demographic information when you register for an account on our Site, including age. Additionally, when you use and interact with the Site, we may collect information about you, such as when you enter our website via our age gate, or when you participate in contests, sweepstakes and promotions, we may collect information in connection with your entry, such as your name, phone number, e-mail address, social security number, address, social media ID, and other information.

Communications. If you contact us directly, we may collect additional information from you. For example, when you reach out to our customer support team, we may ask for your name, email address, mailing address, phone number, or other contact information so that we can verify your identity, communicate with you and facilitate transactions. We may also store the contents of any message or attachments that you send to us, as well as any information you submit through any of our forms or questionnaires. The contents of your email communications including any information, resumes, ideas, concepts or inventions, will not be subject to this Privacy Policy. We may keep a record of your communications with us and use the contents of those communications for any purpose.

Events. If you register for an event that we host, whether in-person or online, we may collect relevant information such as your name, address, company, phone number, and email address, as well as specific information relevant to the event for which you are registering. 

Job Applications. If you apply for a job with us, we may collect relevant information such as your name, phone number, email address, position, job history, education history, references, a cover letter, and similar information.

Third Parties Services and Providers. If we offer any service in connection with other third parties, information that you provide to those third parties may be sent to Patco. We process your information in accordance with this Privacy Policy, however, such third parties may have different privacy practices. Therefore, we encourage you to read their privacy polices prior to disclosing any Personal Information. We may also receive information collected by from our other third party partners, affiliates and service providers who we engage to provide services, such as when you enter a sweepstakes or contest sponsored by Patco. All information collected by such third parties and shared with Patco will be treated in accordance with this Privacy Policy, unless otherwise stated herein.

• Information We Collect Automatically When You Use and Interact with the Site.

Device Information. We may collect information about the devices and software you use to access our Site, including interacting with our advertisements and email notifications, such as your IP address, web browser type, operating system version, device identifiers, and similar information.

Usage Information. To help us understand how you use our Site and to help us improve them, we may collect data about your interactions with our Site, including interacting with our advertisements and email notifications. This includes information such as crash reports, session lengths and times, the pages or other content you view, and any searches you conduct.

Cookies and Similar Technologies. We and our third-party partners may collect information using cookies, pixel tags, or similar technologies. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services. Most Internet browsers automatically accept cookies. If you do not want cookies from us or other websites, you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. 

Analytics. We also use third-party services to help us track and understand user data such as Google Analytics. These third-parties may collect information sent by your browser or mobile device, such as cookies, your IP address, or device ID. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Site, along with the time of the visit and the page(s) that were visited. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Site. We may also derive your location from your IP address.

Pixel Tags, Web Beacons and Similar Technology. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with the Site to, among other things, track the actions of users of the Site (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Site and response rates. 

Advertising. We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Site and other websites or online services, based on information relating to your access to and use of the Site and other websites or online services on any of your devices, as well as on information received from third parties. These advertising partners may set and access their own cookies, pixel tags and similar technologies on our Site and they may otherwise collect or have access to information about you which they may collect over time and across different websites and online services. They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.

For more information about interest-based ads, and to learn about options for opting out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. 

• Information We Receive From Other Sources

We may receive information about you from other sources, including third parties that help us update, expand, and analyze our records, identify new customers, or detect or prevent fraud. We may also receive information about you from social media platforms, for example when you interact with us on those platforms or access our social media content. What information we receive from third parties is governed by the privacy settings, policies, and/or procedures of the relevant organizations, and we encourage you to review them. 

What We Do With Information We Collect

We may use the information we collect:

• To provide, maintain, improve, and enhance our Site;
• To understand and analyze how you use our Site and develop new products, services, features, and functionality;
• To host events; 
• To evaluate and process applications for jobs with us; 
• To communicate with you, provide you with updates and other information relating to our Site provide information that you request, respond to comments and questions, and otherwise provide user support;
• To facilitate transactions, verify identities, check qualifications, optimize or improve our products and services and operations, detect investigate and prevent activities that may violate our policies, fraudulent, or be illegal;
• For marketing and advertising purposes, including developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
• To detect and prevent fraud, and respond to trust and safety issues that may arise;
• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency;
• As required to comply with applicable law;
• To help us understand the use of the Site, to help us better understand how you interact with the Site, to monitor aggregate usage by our users and web traffic routing on the Site, to improve our marketing services, for sales and marketing purposes, to customize the Site, and for other internal purposes; and
• For other purposes for which we provide specific notice at the time the information is collected.

When Do We Share Information We Collect

Your Consent. We may share or disclose your information at your direction or with your consent. 

Public Postings. Please note that your information may be shared by you when you post on social media profile pages and other services to which you are able to post information and materials visible to others and/or the general public via the Site. Also please note that all information you post or disclose on these public areas will become public information, and you will be subject to the privacy policy of such third party website or application.  Your Personal Information may be shared with your friends associated with your social media account, to other users of the Site and to your social media account provider, in connection with your social sharing activity. If you do not want your information shared with other users or with your social media account provider, please do not participate in social sharing on the Site.

Service Providers. We engage service providers to perform functions and provide core services to us (such as marketing, public relations, hosting, data management and analysis, storage security, marketing, delivery of products and services, customer service, email delivery, and reporting services) related to the operation of the Site and services and promotions offered. This includes third party sponsors and administrators of sweepstakes, contents and similar promotions. These companies are only permitted to use this information to help us provide our Site, not for their own purposes. We do not sell your information, and we do not share your information with third party service providers for their own marketing purposes. 

Partners: We use analytics services to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. We also work with third-party advertising partners.  These partners include:

Please note that this table may be >updated from time to time to provide you with the latest information. For more information about your choices regarding how these partners use your information, see the Your Privacy Choices section below. 

Law and Harm: Notwithstanding anything to the contrary in this Privacy Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect Patco’s rights or property. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information. Additionally, we may disclose information in situations that we believe to be emergencies involving potential threats to the physical safety of any person or property if we believe that your information in any way relates to that threat. Specifically, we may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. In particular, we may disclose relevant information to the appropriate third parties if you post any illegal, threatening, or objectionable content on or through the Site.

Business Transfers: We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or in which we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

Events. We may share your information with event partners or co-sponsors to facilitate the events for which you register.

Your Privacy Choices

Our Communications. From time to time you may receive marketing or other informational email messages from us. You can unsubscribe from our promotional and informational emails via the link provided in the emails. Users may continue to receive administrative messages from us necessary to service User accounts after opting out of receiving promotional messages from us.

Cookies. Most web browsers allow you to manage cookies through the browser settings. Be aware that, if you opt out from and do not agree to the use of certain cookies, your experience on our Services may be diminished and some features may not work as intended depending on the cookie. To find out more about cookies, you can visit www.aboutcookies.org or www.allaboutcookies.org.

Our Partners. You can learn more about Google’s privacy practices and your options about how they use your information on Google’s website. You can also install the Google Analytics Opt-out Browser Add-on. Meta, the parent company of Facebook, provides information about how it uses the information it collects through our Services in its Data Policy. You can also learn specifically about Facebook’s advertising practices on its website. Some of our advertising partners are members of the Network Advertising Initiative or the Digital Advertising Alliance. You can visit those organizations’ websites to learn about how you may opt out of receiving web-based personalized ads from their member companies. You can also access any settings offered by your mobile operating system to limit ad tracking. To inquire about your choices regarding our business partners generally, contact us at privacy@patcobrands.com.

We do not currently maintain any procedures for you to review the information that we collect about you; your only option at this time is to request alteration or deletion of all Personal Information about you in our databases.

Information Security

We restrict access to your Personal Information to PATCO employees, contractors, agents and third party service providers who need to know that information in order to operate, develop or improve the Site. These individuals and entities are bound by confidentiality obligations. 

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.

Updates and Changes to this Policy

We may revise this Privacy Policy from time-to-time, without advanced notice to you. The most current version of our Privacy Policy will be posted to this URL. If we make changes to the Privacy Policy that we determine, in our sole discretion, are material, we will notify you either via email, if you have provided one, or by posting a notification on the Site. Once posted, the changes to the Policy will be effective immediately. By continuing to access or use of the Site after changes have become effective, you agree to be bound by the terms of the revised Privacy Policy. If you do not agree with our Privacy Policy, please do not use our Site.

How We Respond to “Do Not Track” Requests

We currently do not respond to Do Not Track signals sent by browsers. 

Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services are directed toward children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at privacy@patcobrands.com.

Third Party Sites

This Privacy Policy only addresses the use and disclosure of information by us. Our Site may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the content provided by, or the privacy practices of, these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information to them.  

If you interact with us on social media platforms, such as Facebook or Twitter, those interactions are also governed by the terms and privacy policies of the social medial platform providers. 

Foreign Users

Our Site is hosted in the United States and intended for visitors located within the United States. If you choose to use the Site from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Site. By using our Site, you consent to the transfer, storage, and processing of your information as described in this Privacy Policy.

LIMITATION OF LIABILITY

By providing us with any Personal Information you expressly and unconditionally release and hold harmless PATCO, its parents, subsidiaries, affiliates, related companies and their respective shareholders, owners, members, directors, officers, managers, employees and agents (collectively, the “Releasees”) from any and all liability for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of your collected Personal Information. In addition, we cannot be held liable for any injuries, loss or damage of any kind arising from or in connection with the use and/or misuse of your Personal Information by any third parties who receive your Personal Information. We make no representations or warranty regarding any third-party’s use, collection or disclosure of your Personal Information.

Contacting Us

If you have any questions, concerns or comments about this Privacy Policy or the treatment of your Personal Information please email us at privacy@patcobrands.com. 

 



MPL Brands NV, Inc. Detailed State Privacy Notices 

For California, Colorado, Connecticut, Utah, and Virginia Residents

We collect Personal Data from US residents and comply with the consumer privacy laws of California, Colorado, Connecticut, Utah, and Virginia (“US Privacy Laws”).  This Detailed State Privacy Notice (this “Privacy Notice”) applies to residents of California, Colorado, Connecticut, Utah, and Virginia (“State Resident”, “you” or “your”).

For the purposes of this Privacy Notice, “Personal Data” means information that is linked or reasonably linkable to a particular individual or household. However, the following categories of information are not Personal Data:

• • Publicly available information;
  • Deidentified or aggregated data; or

• Information otherwise excluded from the scope of US Privacy Laws.

This Privacy Notice provides the following information:

• Categories of Personal Data we collect;
• Purposes for which we use Personal Data;
• Categories of Personal Data we disclose to third parties;
• Categories of third parties to which we disclose Personal Data; and
• How State Residents can exercise their rights under US Privacy Laws:

• The rights to access, correct, or delete Personal Data;
• The right to obtain a portable copy of Personal Data;
• The right to limit the use of sensitive personal data in certain circumstances; and

• The rights to opt out of targeted advertising, sales of personal data, or profiling.

Categories of Non-Sensitive Personal Data

The table below outlines the non-sensitive categories of Personal Data MPL Brands NV, Inc. collects about State Residents and whether and how they are disclosed to third parties.

We collect Non-Sensitive Personal Data from the following sources:

• Directly from our users
• From our affiliates
• From our business partners
• From our advertising partners

Categories of Sensitive Personal Data

The table below outlines the categories of Sensitive Personal Data MPL Brands NV, Inc. collects about State Residents and whether they are shared with third parties. MPL Brands NV, Inc. obtains affirmative consent from State Residents to process Sensitive Personal Data to the extent required by US Privacy Laws.

We collect Sensitive Personal Data from the following sources:

• Directly from our users
• From our affiliates
• From our business partners
• From our advertising partners

Use of Personal Data

We use Personal Data for the purposes described above. Personal Data may also be used or disclosed as otherwise permitted or required by applicable law

Data Retention

We store the information we collect about you for as long as is necessary for the purposes for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

Disclosing Personal Data

We share Personal Data with the following categories of third parties:

• Processors: We use processors to securely handle Personal Data on our behalf and only on our instructions. These companies may not use your Personal Data for their own purposes.
• Affiliates: We may share your information with our affiliates, subsidiaries, and representatives as part of providing our services. 
• Our Analytics and Advertising Partners: We use analytics services to collect and process certain data and to provide you with relevant advertising. These services may also collect information about your use of certain other websites, apps, and online resources. 
• Our Business Partners: We may share relevant personal data with our business partners to provide you with exclusive offers for products and services that may interest you. 

See the tables above for more details about how different categories of Personal Data are shared.

We do not sell Personal Data to anyone.

Exercising Your Personal Data Rights

State Residents have the following rights under US Privacy Laws:

(1) Right to Know and Access. State Residents who have provided Personal Data to us have the right to request and obtain from us, free of charge: (i) a list of the categories of Personal Data collected and the sources of such information, (ii) the specific pieces of Personal Data collected, and the business or commercial purpose for collecting or selling (if applicable) such Personal Data, (iii) the categories of Personal Data we sold and for each the categories of third parties to whom we sold your Personal Data (if applicable), and (iv) the categories of Personal Data that we otherwise shared or disclosed and the categories of third parties with whom we shared or disclosed your Personal Data, during the preceding calendar year.

(2)  Right to Request to Correct and/or Delete.  You may request that we correct inaccurate Personal Data and/or delete Personal Data we collected from you.

(3) Right to Request to Opt-Out and Limit Use.  You have the right to opt out of targeted advertising, sales of personal data, or profiling. You additionally have the right to limit the use of Sensitive Personal Data in certain circumstances.

(4)  Right to Non-Discrimination.  You have the right to be free from unlawful discriminatory treatment for exercising your rights. We will not discriminate against you for exercising any of your rights. However, we may offer you certain financial incentives permitted by US Privacy Law such as loyalty or reward programs. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

If you are a State Resident, you can submit a request to exercise your personal data rights under US Privacy Laws by sending an email to privacy@patcobrands.com with the subject line “Privacy Rights Request” or calling our toll-free number at 1-833-447-1121. 

To submit an opt-out request, you may visit our Online Portal or call our toll-free number at 1-833-447-1121. 

To protect your privacy, we may need to authenticate your identity before we respond to your rights request. We will use commercially reasonable efforts to verify your identity for this purpose. Any information you provide to authenticate your identity will only be used to process your rights request.  Please be aware that we do not accept or process rights requests through other means (e.g., via fax or social media).

After submitting your request online, you will receive a follow-up email, which may include a link you must click on in order to verify your identity. If you do not click on that link, we may be unable to complete your request due to lack of verification. It is important that you provide a valid email address in order for us to be able to process your request.

We will respond to your rights request within 45 days, though in certain cases we may inform you that we will need up to another 45 days to act on your request. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic. Also note that each of the rights are subject to certain exceptions. If you believe our response to your rights request is insufficient, you can appeal our decision by contacting Privacy Appeals Officer at privacy@patcobrands.com and we will inform you of our final decision within 45 days.

We reserve the right to decline to process, or charge a reasonable fee for, requests from a State Resident that are manifestly unfounded, excessive, or repetitive.

Targeted Advertising

“Targeted advertising” as used in this Privacy Notice means the disclosure of Personal Data to a third party for behavioral advertising. An example of this is displaying advertisements to a State Resident where the advertisement is selected based on Personal Data obtained from that person’s activities over time and across nonaffiliated websites or online applications to predict such person’s preferences or interests. We share some Personal Data for behavioral advertising. You can opt out of the sharing of your Personal Data for targeted advertising by submitting a rights request as described above.

Limiting the Use of Sensitive Personal Data

You have the right to limit some uses of Sensitive Personal Data. In particular, you may direct companies not to use Sensitive Personal Data except as necessary to provide goods or services you have requested. 

You may submit a request to limit the use of your sensitive Personal Data by submitting a rights request as described above. 

Authorized Agent Requests

You may designate an authorized agent to make a rights request on your behalf. Your authorized agent may submit such a request by following the same method described above. We may require verification of your authorized agent in addition to the information for verification above for State Residents and households.

Contact Us

If you have any questions or concerns regarding this Privacy Notice, contact us at privacy@patcobrands.com.

If you need to access this Privacy Notice in an alternative format due to having a disability, please contact privacy@patcobrands.com  by e-mail or call us at 1-833-447-1121.

Drink Responsibly.

PATCO BRANDS

All Rights Reserved.