PRIVACY POLICY

BERGAMOT WINE COMPANY LLC

Last Updated: September 15, 2018

PLEASE READ THE FOLLOWING PRIVACY POLICY CAREFULLY BEFORE USING THE WEBSITE.

PRIVACY POLICY

Thank you for visiting the Bergamot Wine Company LLC (the “Company”) website including
bergamotwine.com. You arrived at this Privacy Policy (the “Privacy Policy”) from one of the
aforementioned sites, referred to in herein as “this web site”, the “Website”, the “Site” or “us”.
Our Company Privacy Policy (the “policy” or “privacy policy”) is set forth below. You
acknowledge that this Privacy Policy is part of our Site ​​Terms and Conditions of Use (“TOU”)
https://bergamotwine.com/​, and by accessing or using our site, you agree to be bound by all of its
terms and conditions. This Privacy Policy applies only to the Website. It does not apply to any third
party site or service linked to our Website or recommended or referred by our Website or by our
staff, or to any of our offline activities.

IF YOU DO NOT AGREE TO BE BOUND BY THE TERMS OF THIS PRIVACY POLICY
PROMPTLY EXIT THIS SITE. We may change this Privacy Policy at any time by removing
this version and posting a new one on this page or on a successor page. The new version will
become effective on the date it’s posted, which will be listed at the top of the page as the new
Effective Date.

We understand the importance that Internet users place on privacy and this Privacy Policy
describes how we use personal information that is collected at our web sites. This Privacy
Policy lays out our policies and procedures surrounding the collection and handling of any such
information that identifies an individual user or that could be used to contact or locate him or her
(“Personally Identifiable Information” or “PII”) including such PII in the categories that are
specifically mentioned below.

Our Privacy Policy is intended to describe to you how and what data we collect, and how and
why we use your personal data. It also describes options we provide for you to access, update or
otherwise take control of your personal data that we process.

Personal Data. ​ Your personal data may include information including any of the following
items:

Identification Information. ​ Your name; email address; mailing address; phone number;
photograph; birthdate; passport; driver’s license; Social Security, Taxpayer
Identification, or other government-issued identification; or other historical, contact, and
demographic information; and other data collected that could directly or indirectly
identify you.
Financial Information. ​ Financial information such as bank account, payment card
numbers, credit reports, and other publicly available information.

Tax information. ​ Withholding allowances and tax filing status.

Transaction Information. ​When you use our Services to make, accept, request, or
record payments, we collect information about when and where the transactions occur,
the names of the transacting parties, a description of the transactions, the payment or
transfer amounts, billing and shipping information, and the devices and payment methods
used to complete the transactions.

Other Information You Provide. ​ Information that you voluntarily provide to us, which
will include your wine club online account information, survey responses and
participation in contests or any other actions performed on the site.

Non-personally Identifiable Information: ​ This refers to information that does not by
itself identify a specific individual. We gather certain information about you based upon
where you visit on our site in several ways. This information is compiled and analyzed on
both a personal and an aggregated basis. This information may include the Web site’s
Uniform Resource Locator (“URL”) that you just came from, which URL you next go to,
what browser you are using, and your Internet Protocol (“IP”) address. A URL is the
global address of documents and other resources on the World Wide Web. An IP address
is an identifier for a computer or device on a Transmission Control Protocol/Internet
Protocol (“TCP/IP”) network, such as the World Wide Web. Networks like the Web use
the TCP/IP protocol to route information based on the IP address of the destination. In
other words, an IP address is a number that is automatically assigned to your computer
whenever you are surfing the web, allowing web servers to locate and identify your
computer. Computers require IP addresses in order for users to communicate on the
Internet.

In addition, we may also collect, or our third party ad server and/or content server may collect,
certain Non personally Identifiable Information. This information is ultimately stored in the form
of store categories, and, in some cases, specific URLs. We use your IP address to diagnose
problems with our servers, software, to administer our site and to gather demographic
information. Our third party ad servers will also provide us with summary, but not individual,
reports that will tell us how many ads were presented and clicked upon at out site.

We will primarily use your Personally Identifiable Information to provide our services to you, as
required by our agreements with you. We will also use Personally Identifiable Information to enhance
the operation of our site, fill orders, improve our marketing and promotional efforts,
statistically analyze site use, improve our product and service offerings, and customize our site’s
content, layout, and services. We may use Personally Identifiable Information to deliver
information to you and to contact you regarding administrative notices. We may also use
Personally Identifiable Information to resolve disputes, troubleshoot problems and enforce our
agreements with you, including our Terms of Use and this Privacy Policy.

What Information We Collect and What We Do With Your Information. ​ Our primary goal
in collecting information from you is to provide you with a smooth, efficient, and customized
experience while using our site. When you purchase something from our site, as part of the
buying and selling process, we collect the PII you give us such as your name, address and email
address and credit card number and information. This enables us to both fulfill and support the
products you purchase.

We use your Personally Identifiable Information to communicate with you about products and/or
services you have purchased from our Site, to offer you additional products and services, and to
bill you for goods you have requested. We also use that information to the extent necessary to
enforce our TOU and to prevent imminent harm to persons or property.

When ordering goods or services on the site, you may be asked to provide a credit card number.
Depending upon the activity, some of the information we ask you to provide is identified as
mandatory and some as voluntary. If you do not provide the mandatory data with respect to a
particular activity, you will not be able to engage in that activity.

Activities on the Website which may allow us to collect PII may include, but are not limited to,
any of the following:
Determining whether particular goods or services are available in your state or country;
Processing or recording payment transactions or money transfers;
Displaying your historical transaction information;
Providing, maintaining and improving our Services;
Developing new products and services;
Delivering the information and support you request, including technical notices, security alerts,
and support and administrative messages including to resolve disputes, collect fees, and provide
assistance for problems with our Services or your account;
Improving, personalizing, and facilitating your use of our Services;
Measuring, tracking, and analyzing trends and usage in connection with your use or the
performance of our Services; .
Providing you with products and features you choose to use on our site;
Protecting our Services and maintaining a trusted environment;
Protecting our, our customers’, or your customers’ rights or property, or the security or integrity
of our Services;
Enforcing our Terms of Use (TOU) or other applicable agreements or policies;
Verifying your identity (e.g., through government-issued identification numbers);Investigating,
detecting, preventing, or reporting fraud, misrepresentations, security breaches or
incidents, other potentially prohibited or illegal activities, or to otherwise help protect your
account, including to dispute chargebacks on your behalf;
Complying with any applicable laws or regulations, or in response to lawful requests for
information from the government or through legal process;
Fulfilling any other purpose disclosed to you in connection with our Services;
Contacting you to resolve disputes, collect fees, and provide assistance with our Services.

Advertising and Marketing. ​ Marketing activities on the Website which may allow us to
collect PII may include, but are not limited to, any of the following:
Communicating with you about opportunities, products, services, contests, promotions,
discounts, incentives, surveys, and rewards offered by us and select partners; and

Emails. ​If we send you marketing emails, each email will contain instructions permitting you
to“unsubscribe” from receiving future emails from us.

Other Uses. ​ We may collect other PII for other purpose disclosed to you in connection with our
Services from time to time.

Cookies. ​ The Company utilizes cookies to create a more customized experience for our users
and customers. A cookie is a small data text file, which a website stores on your computer’s hard
drive (if your Web browser permits) that can later be retrieved to identify you to us. Our cookies
store randomly assigned user identification numbers, the country where you are located, and
your first name to welcome you back to our site. The cookies make your use of the site easier,
make the site run more smoothly and help us to maintain a secure site. You are always free to
decline our cookies if your browser permits, but some parts of our site may not work properly in
that case. Cookies also allow our Website to remind you of your past purchases and to suggest
similar products and services. Finally, we use information gained through cookies to compile
statistical information about use of our Website, such as the time users spend at the site and the
pages they visit most frequently. We also use tracking pixels (i.e. Google Analytics) to aid in
measuring and tracking where our website traffic is coming from and to track the performance of
our site.

Third Party Services. ​ We do not sell, rent or otherwise disclose your personal information to
any third parties, including but not limited to advertisers, strategic partners or vendors. Again, we
take your privacy very seriously.The Company does utilize third party providers to help us provide
the best experience and service possible to our website users. In general, the third-party providers
used by us will only collect, use and disclose your information to the extent necessary to allow them
to perform the services they provide to us. However, certain third-party service providers, such as
payment gateways and other payment transaction processors, have their own privacy policies in
respect to the information we are required to provide to them for your purchase-related transactions
For these providers, we recommend that you read their privacy policies so you can understand
the manner in which your personal information will be handled by these providers. Some of the
vendors we currently use include Sam Cart for payment, Stripe for payment processing and
Facebook for advertising. This list is subject to change.

Children’s Privacy. ​ We take Children’s Privacy very seriously. Our TOU only allow this
website to be accessed by persons 21 years or older. You must be at least 21 years old to have
our permission to use this site. Our policy is that we do not knowingly collect, use or disclose
Personally Identifiable Information about visitors that are under 21 years of age. ​As required by
the Communications Decency Act of 1996, we hereby notify you that parental control
protections (such as computer hardware, software, or filtering services) are commercially
available that may assist you in limiting access to content that may be harmful to minors.

Age Requirements for Purchase of Alcohol. ​ ​You may only order alcoholic beverages from this
Website if you aver over the age of twenty one (21). ​By using this site, you affirm and
acknowledge that you are over the age of 21. If you place an order for the purchase of alcoholic
beverages (Alcohol) on this Site, you affirm that you are over the age of 21 and you further
acknowledge and understand the requirement that receipt of any shipments from us containing
Alcohol will require the signature of a person 21 years of age or older to receive those goods. By
using this Site, you also acknowledge and represent that any Alcohol purchased from this Site is
intended for personal consumption and not for resale. It is our Company policy that if you
intentionally or unintentionally misrepresent your age in order to provide alcohol to or for a
person under the age of 21, we will take all available legal actions available under the law
including referral of the matter to any appropriate law enforcement agencies, and in which case
we may also share with such law enforcement any personal information you have provided to us.

Federal and California state law also requires us to request identification from each consumer to
prove that you are of age to legally purchase alcohol. To process an order, we will need your
name, home or other physical address, including street name and name of city or town, email
address, telephone number, date of birth and credit card number which information will be
requested on our online order forms. We understand the sensitivity of this information and
maintain our files on a secured server to protect against unauthorized access. In addition to
obtaining personal information, we may collect tracking information for statistical purposes,
which is disclosed to third parties for statistical purposes only. This aggregate information is for
statistical purposes only. It is for understanding consumer trends and does not contain any
personal information about you.

Finally, as the result of legal restrictions on the sale of Alcohol, we cannot ship Alcohol to every
state. Contact us for further details.

No Sale of Your Personal Information. ​ We do not and will not, under any circumstances, sell
your personal information to anyone for any purpose.

Alcohol and Health. ​ We recognize that excessive or irresponsible consumption of alcohol may
have personal, social or health consequences. As part of its commitment to responsible
consumption, our Company will only send out communications regarding our products that do
not show or encourage excessive consumption or misuse of any kind. We are committed to
promoting the responsible advertising of our products and encouraging improved advertising
standards for the industry as a whole.

Commitment To Data Security. ​ All information collected from you is stored in a technically
and physically secure environment. Furthermore, employees, contractors, and vendors who have
access to your personally identifiable information in connection with providing services for us
are required to keep the information confidential.

We use SSL encryption to protect sensitive information online, and we do everything we can to
protect user information offline. Unfortunately, even with these measures, we cannot guarantee
the security of PII. By using our Website, you acknowledge and agree that we make no such
guarantee, and that you use our Website at your own risk.

In order to most efficiently serve you, credit card transactions and order fulfillment are handled
by established third party banking, processing agents and distribution institutions. They receive
the information needed to verify and authorize your credit card or other payment information and
to process and ship your order. 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 Personally Identifiable 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.

Occasionally we may be required by law enforcement or judicial authorities to provide PII to the
appropriate governmental authorities. We will disclose PII upon receipt of a court order,
subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law
enforcement agencies in identifying those who use our services for illegal activities. We reserve
the right to report to law enforcement agencies any activities that we in good faith believe to be
unlawful in accordance with our TOU.

We may also provide Nonpersonally Identifiable Information about our customers’ sales, traffic
patterns, and related site information to third party advertisers, as part of our research and
business development for our own company, but these statistics do not include any Personally
Identifiable Information.

Consent to Use Personally Identifiable Information. You may withdraw your consent to our
retention of your PII at any time by contacting us at info@bergamotwine.com or mailing us at:
711B Healdsburg Ave, Healdsburg, CA, 95448. Your request shall be subject to the terms and
conditions of this Privacy Policy.

How Can You Verify Your PII. You may contact us to identify the PII that we possess about
you, or to verify, update or correct the PII that we have, and to have obsolete information
removed. If you created an account on our website, you can access and change your online
account profile yourself. If you do not have an online account with the Company, you can ask
to review the PII that we have retained, how we have used it, and to whom we have disclosed it
at any time by contacting us as indicated below under the heading ​Data Protection Officer
below.​ Subject to certain exceptions prescribed by law, and provided we can authenticate your
identity, you will be given reasonable access to your personal information and will be entitled to
challenge the accuracy or completeness of the information and have it amended as appropriate.
You may also ask us to change your preferences regarding how we use or disclose your
information or let us know that you do not wish to receive any further information from us.

How Long We Retain Your Information. ​ We generally retain your information as long as
reasonably necessary to provide you the Services or to comply with applicable law. Even after
you request deletion of your PII, the Company shall be entitled to retain or use copies of your
PII to the extent necessary to collect fees you owe to the Company (if applicable), to resolve
disputes between you and the Company (if applicable), to enforce our TOU or other applicable
agreements or policies as the Company deems appropriate to preserve or enforce Company’s
rights, or to take any other actions consistent with applicable law.

Copyright Infringement and Digital Millennium Copyright Act. For claims of copyright
infringement and/or any violation of the Digital Millennium Copyright Act, please contact Sarah
at info@bergamotwine.com. We will terminate the accounts of users who are repeat copyright
infringers.

If you have a complaint please provide the following information to the person identified above
(17 USCA § 512):
a. A physical or electronic signature of the copyright owner or authorized agent
Identification of the copyrighted work(s) claimed to have been infringed;
b. Identification of the material that is claimed to be infringing or to be the subject of the
infringing activity and that is to be removed or access to which is to be disabled, and
information reasonably sufficient to permit us to locate the material;
c. Information regarding how we may contact you (for example, mailing address,
telephone number, e-mail address);
d. A statement that the copyright owner or its authorized agent has a good faith belief that
use of the material in the manner complained of is not authorized by the copyright owner,
its agent, or the law; and
e. A statement that the information in the notification is accurate, and made under
penalty of perjury, and, if an agent is providing the notification, a statement that the agent
is authorized to act on behalf of the owner of an exclusive right that is allegedly
infringed.

Choice of Law and Venue. ​ This Privacy Policy and all conditions and covenants set forth
herein ​ ​ are entered into in the State of California and shall be governed by and construed in
accordance with the laws of the State of California, exclusive of its choice of law rules. Each
person using this website submits to the exclusive jurisdiction of the state and federal courts
sitting in the County of Sonoma in the State of California and waives any jurisdictional, venue,
or inconvenient forum objections to such courts. In the event that any of the terms of this Privacy
Policy are held by a court or other tribunal of competent jurisdiction to be unenforceable, those
provisions shall be limited or eliminated to the minimum extent necessary so that the terms of
this Privacy Policy shall otherwise remain in full force and effect

Transfer of Personal Data Abroad. ​ If you utilize our website from a country other than the
country where our servers are located, your communications with us may result in transferring
your personal data across international borders. In these cases, your personal data is handled
according to this Privacy Policy. If you are located in the European Union, you also have the
privacy rights set forth below under ​“​Your European Privacy Rights”[LINK]

Location Information. ​ In order to provide certain Services, we may require access to location
information, including precise geolocation information collected from your device. If you do not
consent to collection of this information, certain Services will not function properly and you will
not be able to use those Services. You can stop our collection of location information at any time
by changing the preferences on your mobile device. If you do so, some of our mobile
applications will no longer function. You also may stop our collection of location information
via mobile application by following the standard uninstall process to remove all Square mobile
applications from your device.

Do Not Track. ​ Do Not Track (“DNT”) is an optional browser setting that allows you to express
your preferences regarding tracking across websites. We do not have a mechanism in place to
respond to DNT signals.

Your European Privacy Rights ​- For European residents only. We collect and process personal
information about you only where we have a legal basis for doing so under applicable data
protection law, including under the General Data Protection Regulation (GDPR). The legal
bases will depend on the purpose for which we process your personal information. This means
we collect and use your personal information only where:
a. We need it to provide the Services under a contract to which you are a party, or in
order to take steps at your request prior to entering into a contract;b. It satisfies a legitimate
interest (which is not overridden by your rights and interests), such as for research and
development, to market and promote the Site and to protect our legal rights and interests;
c. You give us consent to do so for a specific purpose; or
d. We need to process your personal information to comply with a legal obligation.

If you have consented to our use of personal information about you for a specific purpose, you
have the right to change your mind at any time.

We may use your email address to send you newsletter or marketing emails. We will ask for your
consent in line with the applicable law when you first provide your personal information. You
can opt out by following the unsubscribe instructions included in these emails, or you can contact
us by emailing sarah@bergamotwine.com.

Request access to your personal information. ​You may have the right to request access to any
personal information we hold about you as well as related information, including the purposes
for processing the personal information, the recipients or categories of recipients with whom the
personal information has been shared, where possible, the period for which the personal
information will be stored, the source of the personal information, and the existence of any
automated decision making.
Request correction of your personal information. ​ You may have the right to obtain without
undue delay the rectification of any inaccurate personal information we hold about you.

Request erasure of your personal information. ​ You may request that PII held about you by the
Company is deleted or any account you may maintain on our website is deactivated.
Request restriction of processing your personal information. ​You may have the right to
prevent or restrict processing of your personal information.
Request transfer of your personal information. You may have the right to request transfer of
personal information directly to a third party where this is technically feasible.

If you wish to make any of the requests outlined above you should contact the ​Data Protection
Officer ​whose contact information is set forth below.

Where you believe that we have not complied with our obligation under this privacy policy or
European data protection law, you have the right to make a complaint to an EU Data Protection
Authority, such as the UK Information Commissioner’s Office.

Data Protection Officer and Contacting Us. We strive to provide excellent products, along with
equally excellent customer service. If you have any questions about this Privacy Policy or our
practices, please feel free to contact us using one of the methods listed above. If you need to
contact us, you can email our Data Protection Officer, Sarah, or mail us a letter at: 711B
Healdsburg Ave, Healdsburg, CA, 95448.

Thank you for taking the time to read all this Legalese. It may be long but it is worth it.

With love,
Bergamot Wine Co.