PRIVACY POLICY

Date Effective: November 3, 2023

Welcome to Casa Lotos! This Privacy Policy explains how Thompson Beverages LLC (together, with its affiliates, “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes personal information in connection with our services, including when you visit www.casalotos.com (the “Website”), engage with us on social media, participate in a sweepstakes, contest, or promotion, or interact or use any of our services that link to this Privacy Policy (the “Services”). The Services are intended for people who are 21 years of age or older.

BY USING OR ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH OUR POLICIES OR PRACTICES, YOU SHOULD NOT USE OR ACCESS THE SERVICES OR PROVIDE US WITH ANY PERSONAL INFORMATION.

PERSONAL INFORMATION WE COLLECT FROM YOU

We use the term “personal information” to refer to information that reasonably identifies, relates to, describes, or can be associated with you. Data that has been deidentified or that otherwise cannot reasonably be related back to a specific person is not considered personal information.

Personal Information You Provide: We collect personal information that you provide to us directly, such as when you fill out a form on the Website, subscribe to any of our newsletters or marketing communications, or participate in a promotion, contest, or sweepstakes. The personal information we collect may include your first and last name, phone number, email address, date of birth, and any other information you provide to us.

Personal Information We Collect Automatically: When you use the Services, we or third parties we work with may automatically collect certain information using technologies such as cookies and other tracking technologies described below.

• Cookies and Similar Technology: "Cookies" are pieces of information that may be placed on your computer by a website for the purpose of collecting data to facilitate and enhance your communication and interaction with that website. Such data may include, for example, the address of the websites you visited before and after you visited our Services, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Services you visited and what links you clicked on, the region where your device is located, and geographic information based on your IP data. We may store some information on your device or device hard drive as a cookie or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of the Services. We may also use cookies to customize your visit to the Services and for other purposes to make your visit more convenient or to enable us to enhance the Services and Services.

• Social Media: If you interact with us on social media or use features, such as plugins, widgets, or other tools made available by social media platforms (such as Instagram or Facebook) in connection with our Services, we may collect information that you share with us on social media or that such platforms share with us. Please review the privacy policies and settings of the social media platforms and networks that you use for more information about their privacy practices.

Personal Information We Obtain From Third Parties: We also obtain personal information from third parties, which we often combine with personal information we collect either automatically or directly from an individual. We may receive the same categories of personal information as described above from the following third parties:

• Business Partners: We are not a retailer, and any orders you place for our products or merchandise are completed through our third party business partner, Speakeasy and are governed by their privacy policy. Please note that you provide your information (including your payment card information, which we do not receive) directly to these companies, and they are lawfully permitted to process your information for their own business purposes and legal requirements.

• Information from Other Sources: We may obtain information from other sources, including through third-party information providers, and we may combine this information with other information we collect from or about you. In these cases, our Privacy Policy governs the handling of the combined personal information. We use this information to operate, maintain, and provide to you the features and functionality of the Services, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.

HOW WE USE YOUR PERSONAL INFORMATION

We collect and use personal information for the following purposes:

• To communicate with you, which may include contacting you about and providing you with our Services, responding to your direct inquiries and providing customer service, and adding you to our mailing lists and sending you emails or text messages from time to time;
• For marketing and promotional purposes;
• For security and fraud prevention;
• To comply with legal obligations;
• To support core business functions; and
• For any additional purposes that you specifically consent to.

HOW WE DISCLOSE OR SHARE YOUR INFORMATION

In addition to using your personal information ourselves for the reasons stated above (and as otherwise mentioned in this Privacy Policy), we may disclose your personal information to other affiliates and entities in the following instances:

• Affiliates. We may share personal information with other companies owned or controlled by us, and other companies under our common ownership, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.

• Service Providers: We may share your personal information with third-party service providers who may use your information to provide us with services including, but not limited to, website hosting, infrastructure provision, information technology services, customer service, and email delivery services. These service providers may have access to personal information that is necessary to perform their functions, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.

• Network and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We do not control how these third parties use and share your personal information once they receive it. You will need to contact such third parties directly for information about their privacy practices or to exercise any rights you may have (including if you would like to opt-out of marketing messages).

• Contests, Sweepstakes, and Promotion Providers: We may share personal information with third parties that assist us in delivering our contests, sweepstakes, or promotion offerings.

• Legal Compliance and to Defend Our Rights: We may disclose personal information and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our Terms of Use  (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

• Business Transfers: We may share your personal information and other information with third parties in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which the assets transferred may include information about the users of our Services.

Please note that if you specifically consent to additional uses of your personal information, we may use your personal information in a manner consistent with that consent.

LINKS TO OTHER SITES AND SOCIAL MEDIA SERVICES

We may create links to other websites that we think may be of interest to you, such as providers of various products and services. We may also provide links that allow you to send or forward a post from our Services through or to third-party social media sites, or other means of electronic communication, such as an email or text messaging service. We do not endorse any other websites, providers, or services by providing such links, and this Privacy Policy only applies to your use of our Services. We are not responsible for the privacy policies of any websites and services we link to on our Services, and you should read the privacy policies of each site you visit to determine what data that site may collect about you.

The Services may also integrate with social media services. We do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Services, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.

You should be aware that any personal information which you voluntarily include and transmit online in a publicly accessible blog, forum, social network, or otherwise may be viewed and used by others. By using such features, you assume the risk that the personal information provided by you may be viewed and used by third parties.

INTEREST BASED ADVERTISING

• Targeted Advertising / Behavioral Advertising: We may ourselves, or with third-party vendors, use your information to deliver targeted advertising to you when you visit our Services or other websites. Cookies and other similar technologies described below may be used in this process. For example, if you are searching for information on a particular product, we or our vendor may cause an advertisement to appear on other websites you view with information on that product. This form of advertising, sometimes called “targeted advertising,” “behavioral advertising,” or “cross-context behavioral advertising,” enables us and our vendors to know about your interests in connection with the delivery of a specific ad. We believe that such advertising is helpful because it allows you to see advertisements that are relevant to your interests.

• Cross-Device Matching: We may use your information to help us, or our third-party vendors, determine if you have interacted with our Services across multiple devices and to match such devices. To accomplish this, we may rely on information (including demographic, geographic and interest-based data) from third parties such as data vendors, pursuant to their own privacy policies, or we may use information we collect in conjunction with such third-party data. Based on this data, we may then display targeted advertisements across devices that we believe are associated with each other, and may further provide services to our advertisers to better enable cross-device targeting and analysis.

If you would like to opt out of these interest-based advertisements, or to opt-out of or restrict our use of certain cross-device data, please follow the opt-out process described in the section titled Your Choices below.

HOW WE PROTECT YOUR PERSONAL INFORMATION

Personal information is maintained on our servers or those of our vendors, and is accessible by authorized employees, independent contractors, representatives, and agents as necessary for the purposes described in this privacy policy. We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal information. However, no method of safeguarding information is completely secure, and we cannot guarantee that our safeguards will be effective or sufficient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us at info@casalotos.com.

DATA RETENTION

We will retain your personal information for as long as your inquiry is active or as needed to provide you with the Services, and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your information, we may continue to retain and use anonymous or aggregate data, or any other data that constitutes non-personal information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.

YOUR CHOICES

Consistent with applicable law, you may exercise the choices described in this section regarding your personal information and communications from us. You may also have certain additional rights available depending on laws in your state or country of residence, as described further below in the Privacy Policy.

• Opting Out of Messages or Services: We may send you marketing messages via email and SMS message. If you receive a marketing email from us, you may unsubscribe from future messages in accordance with our standard unsubscribe process (such as by using the unsubscribe link included in an email), or by sending an unsubscribe request to us at info@casalotos.com. We will process your request within a reasonable time after receipt. Please note that if you opt out of certain electronic communications, certain aspects of our services may no longer be available to you.

• SMS Text Messages: If you opted-in to our SMS text messaging program, you may opt-out of receiving promotional text messages at any time. To unsubscribe from promotional SMS texts, please reply “STOP” to one of our marketing SMS texts. Note that if you unsubscribe from receiving promotional text messages, we may still send you transactional text messages about your account or any services you have requested or received from us (e.g., technical and security notices, responses to your communications). For more information, please see our Terms of Use.

• [Cookies and Tracking Technologies: If you would like to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our Services or some of its functionality may be affected.

Note that cookie-based opt-outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. Additionally, if you opt out on one of your devices, that opt out may not be effective on all of your devices. However, please be advised that cookie-based opt-outs are not effective on some mobile services.

Some browsers have a Do Not Track (“DNT”) feature that lets users signal to websites that they do not want to have their online activities tracked. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

• Modifying or Deleting Your Information: If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at info@casalotos.com. We may not be able to modify or delete your information in all circumstances.

• Interest-Based Advertising: You may opt out of receiving targeted ads from certain data and advertising partners that participate in certain industry self-regulatory programs. The DAA provides a website at www.aboutads.info/consumers with information about how to opt out of targeted advertising from some or all of the DAA’s participating companies. Additionally, the Network Advertising Initiative (“NAI”) offers a website at http://optout.networkadvertising.org/ where you can opt out of interest-based advertising from some or all of the NAI’s members. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities. In the event that we perform cross-device matching (as described above), once you have opted out on one device (“Opted-Out Device”), we will not use any new data from the Opted-Out Device to identify you on another device for interest-based advertising purposes, and we will not use data from another device for interest-based advertising purposes on the Opted-Out Device.

For targeted advertisements delivered through mobile apps, users may opt out of certain ads or reset advertising identifiers via their device settings. To learn how to limit ad tracking or to reset the advertising identifier on your iOS and Android device, visit the following links:

• iOS - https://support.apple.com/en-us/HT202074
• Android - https://support.google.com/ads/answer/2662922?hl=en

You can also install the DAA’s AppChoices app on your device to opt out of targeted advertising by certain providers, and to select system-level advertising preferences on your device (such as “Limit Ad Tracking” on Apple devices, or “Opt-out of Interest-based ads” on Android devices).

Finally, to learn more from the NAI about how to opt out of targeted advertising on mobile devices, you can also visit the following link: https://thenai.org/opt-out/mobile-opt-out/.

CROSS-BORDER DATA TRANSFERS

If you submit personal information to us, that information may be processed in a jurisdiction where privacy laws may be less stringent than those in your country of residence. By submitting your personal information to us, you agree to the transfer, storage, and processing of such information in foreign jurisdictions including, but not limited to, the United States. Please note that personal information transferred to the United States is subject to access by law enforcement.

CALIFORNIA RESIDENTS

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. To opt out of having your information shared in this manner, please email us at info@casalotos.com

NEVADA RESIDENTS

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Note we do not sell your personal information within the meaning of Chapter 603A. However, if you would still like to submit such a request, please contact us at info@casalotos.com.

INTENDED FOR 21+

The Services are not intended for anyone under the age of 21. We do not knowingly solicit or collect personal information from individuals under the age of 21.

CHANGES TO THIS POLICY

We reserve the right, at our discretion, to update this Privacy Policy at any time and will notify you of any material changes to the way in which we treat personal information by posting an updated Privacy Policy or other notice on relevant areas of our Website and/or sending you an email to the email address we have on record. Any updated version of this Privacy Policy will be effective immediately upon posting unless otherwise specified. Your continued use of the Services after the effective date of the revised Privacy Policy will constitute your consent to those changes. However, we will not, without your consent, use your personal information in a manner materially different from what was stated at the time your personal information was collected. We encourage you to periodically review the Website for the latest information on our privacy practices.

ASSISTANCE

If you have any questions about this Privacy Policy, please shoot us an email at info@casalotos.com.