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EFFECTIVE DATE: April 30, 2019

Privacy Policy

This privacy policy (the “Privacy Policy”) describes how and when MPL Brands, Inc. (“MPL” “us” “we” “our”) collects, uses, and shares your information when you use the website owner and operated by MPL located at www.mplbrands.kinsta.com (the “Site”). This Privacy Policy explains the information gathering, use and sharing practices for the Site, including what information is collected, how that information is acquired, maintained, stored, shared and/or used, and your privacy choices. This Privacy Policy is independent from our offline personal data collection practices. By using the Site, you consent to the terms of this Privacy Policy. This policy does not apply to the practices of companies or persons that MPL does not control or employ.

Information such as your name, email address, mailing address, zip code, telephone number, date of birth, gender, age verification, and/or other information that is identifying or can be used to identify, contact or locate the person to whom such information pertains is referred to herein as “Personal Information.”

Persons Under Legal Purchase Age Are Not Allowed

MPL 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 Personal 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 Personal Information, you will be required to affirm that you are of legal purchase age. Please do not provide us with your Personal 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 Personal Information we will use reasonable efforts to remove such Personal Information from our files, or to flag such Personal Information and (to the extent permitted by law) retain it for the sole purpose of ensuring that it is no longer used.

When We Collect Personal Information and What Types of Personal Information We Collect

When You Send Email Communications or Sign Up for Newsletters: When you sign up or receive newsletters and/or contact us via email, the Personal Information you use or submit to communicate with us will be subject to this Privacy Policy. 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.

Third Parties and Affiliated Services: If we offer any services in connection with other third parties, Personal Information that your provide to those third parties may be sent to MPL. 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 Personal Information collected by from our other third party partners, service providers and affiliates in order to facilitate transactions in connection with the your use of the Site and/or who we engage to provide services to facilitate the operation of the Site. All Personal Information collected by such third parties will be treated in accordance with this Privacy Policy, unless otherwise stated herein.

Other sources of Personal Information or data: If we receive Personal Information from you through the Site other than as described in this Privacy Policy, it will still be used and managed in accordance with this Privacy Policy, unless otherwise stated at the time you provide the information.

What We Do With Personal Information We Collect

We may use and store your Personal Information to send you information about our Site, respond to your requests, communicate with you, answer questions, resolve concerns, facilitate use of the Site, facilitate transactions, to inform and notify you of new products, services, or events (this may be our products, services or events, or our partners, or other third parties), send you service notifications, and to solicit your feedback and input. We may also use your Personal Information to send you marketing materials, (these may be about our products, services or events, or our partners, sponsors or other third parties) newsletters, or other information related to the Services, and to improve the Site. In addition, we may use your Personal Information to verify your identity, to check your qualifications, optimize or improve our products and services and operations, detect investigate and prevent activities that may violate our policies or be illegal. We or the third party service provider may also add your Personal Information to either of our databases in order to inform you of upcoming events, offers or other information that may be of interest to you.

When Do We Share Personal Information We Collect

Your Consent: We may share or disclose your Personal Information at your direction or with your consent.

Service Providers and Partners: We engage service providers to perform functions and provide core services to us (such as marketing, hosting, billing, data, storage security, delivery of products, and reporting services) related to the operation of the Site. We may share your Personal Information with such service providers subject to confidentiality obligations consistent with this Privacy Policy, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions.

Law and Harm: Notwithstanding anything to the contrary in this Privacy Policy, we may preserve or disclose your Personal 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 MPL’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 Personal 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.

Business Transfers: In the event that we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your Personal Information may be sold or transferred as part of that transaction. The promises in this Privacy Policy will apply to your information as transferred to the new entity.

Cookies and Other Non-Personal Information Collection, Sharing and Use

We may keep track of how you interact with links across the Site, our email notifications, third-party services, and applications, by redirecting clicks or through other means. We do this to help improve and better understand our Site.

Like many websites, we use “cookie” technology to collect additional website usage data and to improve our Site, but we do not require cookies for many parts of the Site. A cookie is a small data file that is transferred to your computer’s hard disk. We may use cookies to better understand how you interact with the Site, to monitor aggregate usage by our users and web traffic routing on the Site, and to customize and improve the Site. 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. 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.

We use non-personal information collected through your use of the Site to help improve the Site, 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. We may also use non-personal information collected through use of the Site for any purpose. We may share or disclose your non-private, aggregated or otherwise non-personal information, such as the number of users who clicked on a particular link or how many users visit the Site (even if only one did) with any third party for any purpose.

Your Privacy Choices

You may opt-out of receiving email communications and other marketing materials from us (or any third party email marketing service we may use) via link provided in each email or by contacting us. Please note, if you do not wish for us to provide certain information to one or more of our service providers, we may be unable to complete a transaction you request.

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 MPL 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. This policy reflects the practices of any third party service providers that collect information that we use and store on our behalf.

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- California Do Not Track Disclosures

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

Notice to California Residents

Under California law, California residents who have provided personally identifiable information to a company may have the right to request a list of all third parties to whom that company had disclosed such information for the third parties’ direct marketing purposes during the preceding calendar year, along with a list of the categories of personal information that had been so disclosed. If you are a California resident who would like information on how to exercise your rights concerning third party disclosures, you may send an email to us or contact us via postal mail at:

MPL BRANDS, INC.
2280 Union Street
San Francisco, CA 94123
Attn: California Privacy Rights Administrator
Email: info@mplbrands.com

The Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

Third Party Sites

This Privacy Policy only addresses the use and disclosure of information by us. Other websites that may be accessible through this Site have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.

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

If you are outside the United States, by using the Site, you are consenting to having your Personal Information transferred to the United States.

LIMITATION OF LIABILITY

By providing us with any Personal Information you expressly and unconditionally release and hold harmless MPL, 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 info@mplbrands.com.

Drink Responsibly.
MPL BRANDS, INC.
All Rights Reserved.

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