We at Via Carota Craft Cocktails, Inc. (the "Company," "we," "us," or "our") take your privacy seriously and are committed to protecting it through our compliance with this policy. This Privacy Policy (this "Policy") describes how your Personal Information (as defined in Section 2) is collected, used, and shared when you visit or make a purchase from Drinkviacarota.com (the "Website"). Accordingly, we have developed this Policy to explain our use of your Personal Information as well as our precautions to keep your Personal Information confidential and secure. By ordering our Products ("Products") and using or accessing our websites, services and applications (the "Services"), you are consenting to the collection and use practices described in this Policy, as modified from time to time by us in our sole discretion.

By accessing the Website, ordering our products and/or using our services, you are consenting to the collection of Personal Information and use practices described in this Policy, as modified from time to time by us in our sole discretion.

1. Policy Coverage.

This Policy covers our treatment of Personal Information that we gather when you are using or accessing our Services, but not the practices of companies we do not own or control, or people that we do not manage. Our Website may contain links to third-party websites. These linked websites are not under our control, and we are not responsible for their content or privacy policies. We provide such links only as a convenience, and the inclusion of a link on our Website does not imply endorsement of the linked site. If you provide any Personal Information through any such third-party website, your transaction will occur on such third party's website, and the Personal Information you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties.

1. Collection of Personal Information.

When you visit the Website, we automatically collect certain information about your device, including information about your web browser, operating system, IP address, time zone, and some of the Cookies that are installed on your device. Additionally, as you browse the Website, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Website, and information about how you interact with the Website. We refer to this automatically-collected information as "Device Information."

We collect Device Information using the following technologies:

• "Cookies" are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about Cookies, and how to disable Cookies, visit http://www.allaboutcookies.org.
• "Log files" track actions occurring on the Website, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• "Web beacons" "tags," and "pixels" are electronic files used to record information about how you browse the Site.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Website (for example, by generating analytics about how our customers browse and interact with the Website), and to assess the success of our marketing and advertising campaigns.

When you purchase something from our store as part of the buying and selling process, we collect other personally identifying data and information from you, such as your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as "Order Information."

When we talk about "Personal Information" in this Policy, we are talking about both Device Information and Order Information.

We may use the information we collect automatically to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services–for example, this information can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to as many users as possible.

We gather Personal Information only for specific and limited purposes that we inform you about when you use our Services. For example, we may use your Personal Information to:

• Provide, maintain and improve the Website and our products;
• Manage your account and send you related information, including confirmations, updates, technical notices, security alerts and support and administrative messages;
• Respond to your comments, questions and requests and provide customer service;
• Communicate with you about the Website, products, offers, surveys, events and other news and information we think may be of interest to you;
• Monitor and analyze trends, usage and activities in connection with the Website;
• Detect, investigate and prevent fraudulent transactions and other illegal activities and protect our rights and property;
• Personalize and improve the Website and provide advertisements, content and features that match your profile or interests;
• Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;
• Link or combine with information we get from others to help understand your needs and provide you with a better experience; and
• Carry out any other purpose for which the information was collected.

In certain cases, we may also share some Personal Information with third parties, but only as described below.

In addition, from time to time, we may offer sweepstakes, contests and other promotions (each, a "Promotion") that require online registration. If you want to participate in those Promotions, you may be asked to provide some Personal Information. Some of the Personal Information that may be requested for this purpose will be optional, but other requested Personal Information, such as your name and e-mail address, will be mandatory because it will be needed to contact you if you win. Also, some Promotions may require you to select a user ID and password. You should carefully review the rules, if any, of each Promotion in which you participate through our websites, as they may contain additional important information about our use of your Personal Information. To the extent that the terms and conditions of such rules concerning the treatment of your Personal Information conflict with this Policy, the terms and conditions of such rules shall control.

1. Consent.

How do you get my consent?

You consent to our collection and use of Device Information by using or accessing the Website.

You consent to our collection and use of Order Information when you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase.

We will ask directly for your express consent to use your Order Information for a secondary reason, like marketing, or provide you with an opportunity to say no.

How do I withdraw my consent?

You may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us via email at info@drinkviacarota.com.

If you decide you don't want to receive marketing emails from us, you can opt out of marketing emails by clicking the "Unsubscribe" link in our emails or emailing us at info@drinkviacarota.com.

1. Retention of Personal Information.

We will only retain your Personal Information for as long as necessary to fulfill the purpose we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We retain Personal Information for the duration of any actively engaged user of our Website and services and for a period after this time as necessary and relevant to our legitimate operations and in accordance with applicable law obligations. This may include retention necessary to identify, issue or resolve legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

1. Disclosure of Personal Information.

We do not sell, rent, share or otherwise make your Personal Information available to third parties, except when we are required to for legal or regulatory purposes or when we transfer your Personal Information to third parties who act on our behalf for further processing in accordance with the purposes for which your Personal Information was originally collected. For instance, some Personal Information, such as your IP address and email address, may be shared with third parties we work with to run our website, advertising and email communications. In addition, we reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with laws or court orders; enforce or apply our terms of use, if any, and other agreements; or protect the rights, property or safety of the Company, our employees, our users or others.

1. Security.

To protect your Personal Information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. Unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Accordingly, we cannot be responsible for or liable for the security of your Personal Information when it is in transit to us over the internet.

If you provide us with your credit card information, the information is encrypted using secure socket layer (SSL) technology and stored with an AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

Although we have tried to create secure, reliable and trustworthy websites for our visitors, please be aware that the Internet is generally not regarded as a completely secure environment, and that therefore the confidentiality of your Personal Information provided or transmitted via our Website or by e-mail cannot be guaranteed by us. Thus, we are not responsible or liable for the security of your Personal Information whilst in transit via the Internet to us.

By using the Website or providing information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Website. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on the Website or sending a message. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us via email.

Furthermore, individuals who are under the age of 18 or under the legal drinking age should not provide any Personal Information to us, and we will not knowingly collect, use or disclose any Personal Information from such individuals. Our websites are not designed or intended to collect Personal Information from individuals under the age of 18 or under the legal drinking age.

1. Data Access.

You have the right to access, update and require the deletion of your Personal Information. If you have any questions about viewing, updating or removing the Personal Information that we have on file about you, please contact us.

1. Privacy Notice For California Residents.

If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information, including under the California Consumer Privacy Act of 2018 ("CCPA"). To learn more about your California privacy rights under the CCPA, visit https://oag.ca.gov/privacy/ccpa.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

In addition, California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please email us at info@drinkviacarota.com.

1. International Users.

Our Website is based in the United States. If you are visiting from the European Union or other region with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information, you expressly consent to any transfer and processing in accordance with this Policy while acknowledging that privacy laws in the United States may be different, and in some cases, less protective, than those in effect in your jurisdiction.

Users in the European Economic Area (the "EEA") and Switzerland. If you are a resident of the EEA or Switzerland, the following information applies.

1. Purposes of processing and legal basis for processing: As explained above, we process personal data in various ways depending upon your use of our Site. We process Personal Information on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide services; and (3) as necessary for our legitimate interests in providing the services where those interests do not override your fundamental rights and freedom related to data privacy.
2. Right to lodge a complaint: Users that reside in the EEA or Switzerland have the right pursuant to the General Data Protection Regulation ("GDPR") to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here: https://edpb.europa.eu/about-edpb/board/members_en.
3. Transfers: Information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. We will ensure that transfers of personal data to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR.
4. Individual Rights: If you are a resident of the EEA or Switzerland, you are entitled to the following rights. Please note: In order to verify your identity, we may require you to provide us with personal data prior to accessing any records containing information about you.

• The right to access. You have the right to obtain (i) confirmation as to whether personal data concerning you is processed or not and, if processed, to obtain (ii) access to such data and a copy thereof.
• The right to rectification. You have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
• The right to request data erasure. You have the right to have your data erased from our App if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
• A right to data portability. You have the right to receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller without hindrance from us. This right only applies when the processing of your personal data is based on your consent or on a contract and such processing is carried out by automated means.
• The right to restrict or object to our processing. You have the right to restrict or object to our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.

If you would like to exercise any of these rights, please contact us via email at info@drinkviacarota.com.

1. Changes to this Privacy Policy.

We reserve the right to modify this Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the Website. If we make material changes to this Policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. Your use of the Website signifies your acceptance of this Policy. If you do not agree to the terms of this Policy, please do not use the Website.

If the ownership of all or substantially all of our business changes, or we otherwise transfer assets relating to our business or any of the services to a third party (such as by merger, acquisition, bankruptcy proceeding, or other change of control transaction), we may transfer or sell your information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to this Policy unless we notify you otherwise.

1. Trademark Rights.

We and our affiliates, licensors and content providers are the owners of all the trademarks used on the Website. Third parties are not allowed to use and apply any of the trademarks, logos and identifying marks without our express written consent.

1. Questions And Contact Information.

If you would like to: access, correct, amend or delete any Personal Information we have about you, register a complaint, or simply want more information, contact our team via email info@drinkviacarota.com.

We urge you to also carefully read our Terms of Use for more information on the use of our Website.

Effective Date: February 1, 2023