BeerHole Privacy Policy Welcome to BeerHole. BeerHole, Inc. (“BeerHole,” “we,” “us” and/or “our”) provides an online craft brewery locator, social exchange, and beer review platform that brings individual users and breweries together. This Privacy Policy describes how your personal information is collected, used, and shared when you visit our website at https://www.MyBeerHole.com (the “Site”), any sub-domains of the Site, BeerHole’s mobile applications (each, an “App”), and various online tools and services (collectively, the “Services”). BY USING THE SITE OR SERVICES, YOU ARE HEREBY CONSENTING TO OUR COLLECTION, USE, DISCLOSURE, TRANSFER AND STORAGE OF INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. Our Commitment To You At BeerHole, we value and respect your privacy. Privacy considerations are at the core of the way we design and build services and products for you, so that you can fully trust BeerHole and take advantage of everything the Services offer. We do not compromise when it comes to your privacy, we seek to be transparent with you in the way we process and manage your personal information, and we work hard to protect your information and keep it secure. This Privacy Policy sets forth how we go about accomplishing our privacy initiatives, and provides you with the information you need to be comfortable that your data is being handled with care. We encourage you to read this Privacy Policy carefully. If you have any questions, please don’t hesitate to contact BeerHole directly using the contact information provided below. What personal information do we collect from our users? Automatically Collected Information When you visit the Site or Services, we automatically collect certain information about your device, including information about your web browser, mobile device, IP address, unique device identifiers, software and hardware attributes (including the type of operating system you use), approximate geographic location, time zone, and some of the cookies that are installed on your device (collectively, “Device Information”). Additionally, as you browse the Services, we collect information about how you use the Services, such as the date and time you logged in, the individual web pages or products that you view, what websites or search terms referred you to the Services, and information about how you interact with the Services and other users (including, for example, breweries you review or users you connect and interact with as a brewery) (collectively, “Usage Information”). Information You Provide Additionally, when you visit the Services, we may either require or collect “Personal Information.” Personal Information is information that could personally identify you, for example, your name, address, phone number, e-mail address, birth date, and requested payment information. Personal Information does not include any data where the identity has been removed (anonymous data). For purposes of this policy, your Device Information and Usage Information is included within the discussion of “Personal Information” (unless we clearly state otherwise herein). In the following instances, we collect and require you to actively submit Personal Information:  When you visit the Services, regardless of whether you are a registered user or not, you need to provide your birth date in order to access the Services.  When you set up your account with BeerHole (whether you are an individual or an individual acting on behalf of a company), you need to provide your name, email address, birth date, and gender. Accounts may also be set up using a user’s Facebook, Google, or American Homebrewers Association account information.  When you set up and use your account with BeerHole, you also provide us with specific profile data, such as your username and password, favorite beer and breweries, and your interests and preferences.  When you contact us with a question or concern, you may be required to provide certain personal information like your name, email, mailing address, and/or phone number.  When you sign up for and purchase a paid subscription, you will be required to provide your name, email address, and phone number as well as your billing address and payment information (based on the third party payment method you choose, i.e. PayPal, iTunes, Google Play) (collectively, “Payment Information”).  When you sign up to receive marketing communications, such as our newsletter or updates about the Services, you must provide us with your email address.  When you respond to a survey or enter a promotion provided through the Services, you may be required to provide your name, email address, mailing address, and/or phone number.  When you enter information into the BeerHole app such as: beer lists, pictures, descriptions, comments, videos, operational information, history, and personal preferences. Information We Receive or Collect from Other Third Parties or Public Sources We may receive or collect information about you from third parties and store it on our servers with other information we may have already received or collected from you, such as publicly available information you provided third party platforms. BeerHole is not responsible for, and will assume no liability, if a business partner or other entity whom you have authorized collects, uses or shares any information about you in violation of its own privacy policy or any applicable laws, rules, or regulations. Cookies and Similar Technologies We use Cookies and similar technologies to enable our systems to recognize your browser/device and to provide certain features. We also collect some Device Information and Usage Information using such technologies. 1. “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. A cookie may enable the website owner to track how a visitor navigates through its website and the areas in which they show interest. This is similar to a traffic report: it tracks trends and behaviors, but does not identify individuals. Information gathered may include date and time of visits, pages viewed, time spent at the site, and the website visited just before and just after a visit to our Services. Cookies can be set to expire: (1) on a specified date; (2) after a specific period of time; (3) when a transaction has been completed; or (4) when a user turns off his/her Internet browser. A cookie that is erased from memory when a visitor’s Internet browser closes is called a “session” cookie. Cookies that expire based on a time set by the Web server are called “persistent” cookies. Our Services may use both “session cookies” and “permanent cookies.” Most people do not know that cookies are being placed on their computers when they visit our Service or most websites because browsers are typically set to accept cookies. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. 2. “Log files” track actions occurring on the Services, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps. 3. “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Services. We may also collect or receive various Usage Information and Device Information from third party analytics providers, such as Google, Facebook, Amazon Web Services, mLab, Braintree, Paypal, App Store, Cloudinary, Twitter and Instagram as well as from other advertising networks. You have a variety of tools available to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your Internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking certain non-strictly necessary cookies. Note that if you disable cookies, there may be parts of our Services that may not function properly. How do we use the information we collect? We use your Device Information and Usage Information to monitor the usage of our Service, assess its performance, ensure technological compatibility with your computer or mobile device, and understand the relative importance of the information provided on our Services. We may also use this data to conduct statistical analyses on visitors’ usage patterns and other aggregated data. We do this to improve and optimize our Services for you. We also use your Device Information and Usage Information to help us screen for potential risk and fraud (in particular, your IP address). We use the Personal Information you provide us in order to perform basic business functions. This may include communicating with you, processing any requests by you, identifying and fixing any problems with the Services, and otherwise making the Services available to you. Our use of this Personal Information is most commonly based on our legitimate business purposes or other lawful bases set forth below. When we make a decision to use your information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative) to ensure that our rights or interests do not override your fundamental rights and interests. We also use your Personal Information in order to perform the contractual relationship with our subscribers (or prospective subscribers), and where we have your specific consent, typically for marketing purposes only. See the “Communications” section below for more information. As referenced above, we may use your Personal Information for legitimate business purposes or other lawful bases, including to:  Operate, evaluate and improve our business, our Services, and other products and services we offer  Aggregate certain information that does not include your Personal Information and disclose it for analysis, demographic profiling and/or targeted advertising  Provide you with technical service and support, including updates  Tailor the content we display in our communications with you and/or improve your user experience  Administer surveys and other market research  Provide you with information regarding BeerHole’s benefits and services  Store, archive, retrieve, and make copies of your user generated content  Process payments  Comply with legal requirements, judicial process, and our company policies (including to verify users’ identity in connection with access or correction requests)  Protect against, identify, investigate, and respond to fraud, illegal activity (such as incidents of hacking or misuse of our Services), and claims and other liabilities, including by enforcing the terms and conditions that govern the services we provide Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. How do we share the information we collect? We do not rent or sell your Personal Information without your permission. However, we may share your Personal Information with others for the purposes described below:  We may share your Personal Information whenever you specifically consent to us doing so.  We may share or disclose your Personal Information where necessary to provide you with the Services and/or associated services, including with trusted third-parties who assist in operating the Services, providing any associated BeerHole services, and otherwise conducting our business.  We may share your Personal Information with our third party payment processors.  We may share your Personal Information, where necessary, with BeerHole’s parents, subsidiaries, successors, assigns, licensees, affiliates, or business partners.  We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.  We may share your Personal Information when doing so is needed to help prevent against fraud or the violation of any applicable law, statute, regulation, ordinance, or treaty.  We may disclose Personal Information you provide us in connection with the sale, assignment, or other transfer of the business or a portion of the business of the Site, including a corporate merger, consolidation, restructuring, sale of assets, or other corporate change of our company. Without limiting the foregoing, BeerHole currently shares your Personal Information with the following third-parties:  Amazon Web Services – data housing  Google – map integration  Trembit – software development  Paypal – third party payment processor  Braintree – third party payment processor  Google Play Store – third party payment processor  Apple App Store – third party payment processor  Uber – transportation accommodations Aggregated Data We may aggregate and/or de-identify any Personal Information, Usage Information or Device Information that you provide or we collect, such that the information no longer identifies any specific individual. We may use, disclose and otherwise process such information for our own legitimate business purposes – including historical and statistical analysis, marketing, and business planning – without restriction. However, if we combine or connect any aggregated data with your personal data so that it can directly or indirectly identify you, we treat this combined data as Personal Information which will be used in accordance with this privacy notice. Communications General When you provide us consent to do so (either upon contacting us through our Services or through our normal marketing communications), we will communicate with you through general marketing communications via email and push notifications directly to your mobile device. You must affirmatively opt-in to receive these communications before you receive them. Third-party Marketing We will get your express opt-in consent before we share your Personal Information with any company outside the BeerHole group of companies (or other third parties listed herein) for marketing purposes. Opting Out Regardless of where you live, you may also opt-out of these marketing communications at any time by following the instructions provided in any marketing communication you receive. Please note that even if you opt-out of receiving marketing communications, you may still receive-business related communications, such as transactional emails. Do Not Track Please note that we do not alter our Services’ data collection and use practices when we see a Do Not Track signal from your browser. Access to and Managing Your Information; Opt-Out We believe it is important for you to be able to: (1) find out what Personal Information you have provided to us through our Services; (2) update your information; or (3) “opt out” of receiving future marketing communications. To inquire about your Personal Information, update your Personal Information, or “opt out” of receiving future marketing communications or any other collection or use practice based on your consent, please send an email with your request and current contact information to info@MyBeerHole.com. We generally respond to email requests within 24 hours of receiving a request, but it may take up to 30 days depending on the volume of requests we receive. Your Rights to the Personal Information You Provide You have the right to access and control the Personal Information you provide us. These rights include the right to:  Access your Personal Information;  Correct, update, or delete your Personal Information;  Withdraw or limit your consent (to Personal Information that was provided based on consent);  Data portability of certain Personal Information;  Object to us processing your Personal Information for reasons such as direct marketing purposes and for scientific or historical research or statistical purposes;  Not be subject to automated decision-making, which includes profiling, where such decisionmaking could have a legal, or similarly significant, effect on you from being made solely based on automated processes. If you would like to exercise these rights (which you may do at any time) or inquire as to any additional rights you may have under applicable law, please contact us through the contact information provided below. We will respond to any request as promptly as possible. Personal Information Transfer and Storage Please note that your Personal Information will be transferred outside of Europe, including to the United States, where it is stored. When we transfer your information to the U.S., we will protect it as described in this Privacy Policy. Through your use of the Services, you consent to the processing and storage of your Personal Information in this manner. We also are working to and have worked to incorporate appropriate safeguards such as standard contractual clauses with any third party processors identified herein. We further will make best efforts to protect information from EU residents in accordance with applicable law. When you provide information to us, you understand and agree that BeerHole will retain your Personal Information as long as is necessary and relevant for our operations, and in accordance with applicable laws. How We Protect Your Information We strive to maintain internal controls and procedures to ensure that the information you share with us is handled in a safe, secure and responsible manner. We have security measures to help protect against loss, unauthorized access and alteration of the information in our control. We will only disclose such information to employees and authorized service providers who require such information for the purposes described in this Policy. Our databases are protected by physical, technical, and procedural measures that restrict access to authorized persons in accordance with this Policy. Although no data transmission over the Internet can be guaranteed 100% secure, and we cannot ensure against any loss, misuse, unauthorized disclosure, alteration, or destruction of data, we take reasonable precautions to prevent such unfortunate occurrences. Nevertheless, we cannot and do not guarantee that information you post on or transmit to the Services will not be viewed by unauthorized persons. Third-Party Service Providers and Third-Party Links Any third parties to whom we may disclose Personal Information (identified herein) have their own privacy policies which describe how they use and disclose your Personal Information. Those policies will govern use, handling and disclosure of your personal information once we have shared it with those third parties as described in this Privacy Policy. BeerHole has no responsibility or liability for the activities of these third parties. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties. When you click on links on our Services that take you to third-party websites, you will be subject to the third parties’ privacy policies. While we support the protection of privacy on the Internet, we cannot be responsible for the actions of any third-party websites. We encourage you to read the posted privacy policies of any and every website you visit, whether you are linking from our Services or browsing on your own. California Privacy Rights Under California’s “Shine the Light Law,” California residents have the right to receive information that identifies any third-party companies or individuals that BeerHole has shared your Personal Information with in the previous calendar year, as well as a description of the categories of Personal Information disclosed to that third party. You may obtain this information once a year and free of charge by contacting BeerHole at the address below. Personal Information About Children Our Services is targeted for use by users over the age of 21. Accordingly, we do not knowingly collect age identifying information, nor do we knowingly collect any personal information from children under the age of 13 years. However, we hereby advise all visitors to our site under the age of 13 not to disclose or provide any personally identifiable information on our Services. If you are concerned that Personal Information may have been inadvertently provided to or collected by BeerHole, please contact us immediately so appropriate steps may be taken to remove such information from BeerHole’s database. Changes to this Policy We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. We suggest that you review the current Privacy Policy at the start of each visit to our Services. Unless we clearly express otherwise, we will use Personal Information in accordance with the Privacy Policy then in effect. YOU ARE HEREBY ADVISED THAT YOUR CONTINUED USE OF OUR SERVICE CONSTITUTES YOUR ACCEPTANCE OF ANY AMENDMENTS TO AND THE MOST RECENT VERSION OF THIS PRIVACY POLICY. Suspected Violations If at any time you believe we have not adhered to the policies and principles set forth in this Privacy Policy, please notify us using the contact information provided below. We will make all commercially reasonable efforts to promptly respond to your concerns. Contact Us If you have any questions or comments concerning our Privacy Policy, please submit your inquiry along with your current contact information to: info@MyBeerHole.com; Privacy Policy © 2022 BeerHole, Inc.