PRIVACY POLICY

EFFECTIVE DATE: October 25, 2022

Last Reviewed: October 25, 2022

Privacy Policy

This privacy policy (the “Privacy Policy”) describes how and when MPL Brands NV, Inc. d/b/a Patco Brands (“PATCO “us” “we” “our”) uses and shares your information that we collect through websites, software, social media sites and applications controlled by Patco, as well as through e-mail messages that we send to you (collectively, 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. By using the Site, you consent to the terms of this Privacy Policy.

This 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 California resident, please see the “Notice to California Residents” notice 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 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

Information such as your name, email address, mailing address, zip code, telephone number, date of birth, gender, age verification, social media account ID, 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.”

When You Use and Interact with the Site:

When you use and interact with the Site, we may collect Personal 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 Personal Information in connection with your entry, such as your name, phone number, e-mail address, location, social media ID, and other information.

When you sign up or receive newsletters and/or contact us via email or via the contact form on the Site, 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 Services and Providers:

If we offer any services in connection with other third parties, Personal 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 Personal Information collected by from our other third party partners, affiliates and service providers who we engage to provide services. 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 your Personal Information from other online and offline sources 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, products, events and promotions, to 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 our products and services, to improve the Site, and to facilitate your participation in sweepstakes, contests and similar promotions and to administer these activities. We or the third party service provider may also add your Personal Information to either of our databases.  

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 may also use your Personal Information as required to comply with applicable law, or for other purposes with your consent.

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.

Public Postings: Please note that your Personal 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 Personal 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 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. We do not sell your Personal Information, and we do not share your Personal Information with third party service providers for their own marketing purposes.

Partners: We may share your personal information with third parties that co-sponsor or co-brand activities with Patco, including to permit them to send you marketing communications. Please note that we will never sell your Personal Information to third parties for their own marketing purposes.

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 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 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

“Non-Personal Information” is any information that does not reveal your specific identity or does not relate directly to an individual, such as demographic information, aggregated information, browser and device information, IP address, and other information collected through cookies, pixel tags, web beacons and other technologies that does not individually identify you. If we are required to treat Non-Personal Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Policy.

We and/or our third party service providers collect Non-Personal Information when you interact with the Site, including our email notifications, advertisements, third-party services, and applications, by redirecting clicks or through other means.

Cookies

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.

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.

What We Do With Non-Personal Information

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. 

You have options to control or limit how we and our third party service providers use cookies and similar technologies:

• To prevent your data from being used by Google Analytics, and our use of its Advertising Features visit https://tools.google.com/dlpage/gaoptout and https://adssettings.google.com/.

• Most browsers and devices accept cookies by default, however, their settings usually allow you to clear or decline cookies.

• If you would like more information on how our third party advertising service providers allow you to opt out of receiving ads based on your web browsing history, please visit http://optout.aboutads.info/

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.

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 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 info@patcobrands.com.

Notice to California Residents

If you are a California resident and our past, current, or prospective employee or contractor or an emergency contact or benefits beneficiary of any such employee or contractor, please click here for our privacy notice applicable to you.

California consumers have a right to knowledge, access, and deletion of their personal information under the California Consumer Privacy Act (“CCPA”). California consumers also have a right to opt out of the sale of their personal information by a business, and a right not to be discriminated against for exercising their California privacy rights.

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“Personal Information”). Personal information does not include publicly available information from government records, deidentified or aggregated consumer information or other information excluded from the CCPA’s scope.

Categories, Sources, Purpose and Use of Personal information Collected

Purpose: We may use or disclose collected Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, to:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry.
• To provide, support, personalize, and develop the Site, products, and services.
• To create, maintain, customize, and secure your account with us.
• To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through third-party sites, and via email or text message (with your consent, where required by law)
• To advertise, market, and provide our products and services and related customer service;
• To help maintain the safety, security, and integrity of the Site, products and services, databases and other technology assets, and business, and to conduct risk and security control and monitoring
• For testing, research, analysis, and product development, including to develop and improve our Site, products, and services and to maintain records
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations, or to exercise and defend legal claims
• To defect and prevent fraud and perform identity verification
• To perform accounting, audit, and other internal functions, such as internal investigations and evaluations; and/or
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

Sources: We collect this Personal Information directly from California residents themselves, as well as from other online and offline sources, such as, trusted third-party service providers, advertising networks, internet service providers, business partners, data analytics providers, operating systems and platforms, public databases, joint marketing partners, and social media platforms.

Categories and Third Parties: Below are details about the categories of Personal Information of California residents that we may have collected or disclosed during the last 12 months.  We may share such Personal Information by disclosing it to a third party for a business purpose as described above.

Depending on a California resident’s particular interactions and relationship with us, we may not have collected or disclosed each of the above categories about each resident.

“Sales” of Personal Information.  The CCPA defines a “sale” as the disclosure of Personal Information in exchange for monetary or other valuable consideration. We do not sell and have not sold in the past any collected Personal Information for payment, but we may have engaged in certain types of online interest-based advertising that may be deemed a “sale” for purposes of the CCPA. For example, we may allow certain third parties (such as certain advertising partners ) to collect your personal information via automated technologies on the Site in an effort to serve your content and advertisements that may be of interest to you. We may also share your personal information with third parties for cross-context behavioral advertising.

We may have “sold” each of the following categories of Personal Information to our affiliates, service providers, social networks, and joint-marketing partners:

– Identifiers. Identifiers, such as name, IP address, email address, online identifiers, and government-issued ID numbers;

– Customer Records Information. Personal information, as defined in the California customer records law, such as contact and financial information;

– Protected Class Information.   Characteristics of protected classifications under California or federal law, such as age, gender, and marital status; and

– Online Use Information.  Internet or network activity information, such as browsing history and interactions with our websites and applications.

Depending on a California consumer’s particular interactions and relationship with us, we may not have “sold” each of the above categories about each consumer. Additionally, we do not collect or sell the Personal Information of minors under 16 years of age.

To opt out of these “sales,” use the following link: [ LINK].  

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.

Your Rights and Choices

If you are a California resident, you have the right to make the following requests:

(1) Request to Know. You may request that we disclose to you the following information covering the 12 months preceding your request:

• The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
• The specific pieces of Personal Information we collected about you;
• The business or commercial purpose for collecting or selling (if applicable) Personal Information about you;
• The categories of Personal Information about you that we sold and, for each, the categories of third parties to whom we sold such Personal Information (if applicable); and
• The categories of Personal Information about you that we otherwise shared or disclosed, and, for each, the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).

(2)  Request to Delete.  You may request that we delete Personal Information we collected from you.

To make a Request to Know or a Request to Delete as a California resident or an authorized agent of a California resident, please e-mail info@patcobrands.com with the subject line “California Request To Know or Delete”. We will verify your request by asking you to provide information that matches information we have on file about you, such as your name, email address, etc. You can also designate an authorized agent to exercise these rights on their behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly.

(3) Request to Opt Out of Sale. You may request to opt out of future “sale” of Personal Information about you by clicking Do Not Sell My Personal Information.

(4)  Right to Non-Discrimination.  You have the right to be free from unlawful discriminatory treatment for exercising your rights under the CCPA. We will not discriminate against you for exercising any of your CCPA rights. However, we may offer you certain financial incentives permitted by the CCPA 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.

(5)  Right to Request Information About Our Information Sharing. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who have provided Personal Information to a company have the right to request and obtain from us, free of charge: (i) a list of the categories of personal information collected and the sources of such information, (ii) the specific pieces of personal information collected, the business or commercial purpose for collecting or selling (if applicable) your Personal Information, (iii) the categories of Personal Information we sold and for each the categories of third parties to whom we sold your Personal Information (if applicable), and (iv) the categories of Personal Information that we otherwise shared or disclosed and the categories of third parties with whom we shared or disclosed your Personal Information, during the preceding calendar year. You may also request that we delete Personal Information we collected from you.

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 (please use “Privacy Rights” in the subject line) to us or contact us via postal mail at: 



MPL BRANDS NV, INC.

3960 Howard Hughes Parkway,

Suite 500-6001

Las Vegas, NV, 89169

Email: info@Patcobrands.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.

Notice of Financial Incentive 

We may offer our customers certain perks, such as rewards programs, exclusive offers, sweepstakes, contest, or other similar promotional campaigns (collectively, the “Programs”). When you sign up for one of these Programs, we typically ask you to provide your name and contact information (such as email address, home or physical address, etc.) to contact you regarding your participation in the program. Because our Programs involve the collection of personal information, they might be interpreted as a “financial incentive” program under California law. The value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable Program. This value is based on the expense related to offering those products, services, and benefits to Program participants. You may withdraw from participating in a Program at any time by contacting us using the designated method set forth in the applicable Program rules. Visit the terms and conditions page of each Program to view full details, including how to join.

If you need to access this Policy in an alternative format due to having a disability, please contact info@patcobrands.com by e-mail or 415-729-9453.

Drink Responsibly.

PATCO BRANDS

All Rights Reserved.