JS-WR JV LLC PRIVACY POLICY

This Privacy Policy was last updated on 27 February 2025

This privacy policy (“Privacy Policy”) describes how JS-WR JV LLC. and its respective subsidiaries, parents and affiliates (collectively, “JS-WR JV LLC” or “Company” or “we” or “ us” or “our”), collects, stores, and uses personal information through the following websites and online applications [www.drinkwillies.com, @drinkwillies] as well as any other media form, media channel, or any of our past, present or future websites related or connected thereto (collectively, the “Site”), and any content, information, functionality, products or services supplied by or on behalf of us through the Site (collectively, the “Services”). This Privacy Policy has been compiled to explain how information, including personal information, is collected or used. By accessing, browsing, or otherwise using the Site, you agree to our collection, storage, use and disclosure of your information, as described in this Privacy Policy and the Terms of Service.

All updates to this Privacy Policy are noted at the top of this page, with time-date reference for your convenience. We reserve the right in our sole discretion to amend this Privacy Policy at any time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes so please check the policy periodically for updates. This Privacy Policy does not apply to websites that post different privacy policies or statements.

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, or the European Union (EU), European Economic Area (“EEA”), and UK, you may be entitled to certain individual rights under the California Consumer Privacy Act of 2018 [as amended by the California Privacy Rights Act of 2020 (“CPRA”)] (collectively, “CCPA”), Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (“CPA”), Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), Utah Consumer Privacy Act (“UCPA”), or the General Data Protection Regulation (“GDPR”) and the UK Data Protection Act 2018 respectively. Please see the Notice to Certain Residents of Data Subject Rights Section of our Privacy Policy for your rights and how to exercise them for users located in California, Virginia, Colorado, Connecticut, Utah, and the EEA and UK only.

PRIVACY OF CHILDREN

Our Site and Services are not intended for children or persons under the age of 21. Children or persons under the age of 21 are not allowed to use our Site and Services. If we learn or have reason to suspect that a user is under age 21, we will promptly deactivate that user’s account (“User Account”) and delete any personal information collected in connection therewith. If you believe we might have any information from or about a child or person under the age of 21, please contact us at [hello@drinkwillies.com].

What is Personal Information?

For the purposes of this Privacy Policy, personal information means information that identifies, relates to, describes, is capable of being associated with, or could be linked, directly, or indirectly, with a particular individual or household. Personal information does not include publicly available information.

Information We Collect?

Information You Give Us.When you contact us or opt in by registering on the Site and creating a User Account, utilizing our Services, registering to receive alerts or other information via email, text, or instant message, we may collect your‎ age, location information, email address, phone number, as well as other information, including demographic information such as gender, that you directly give us. We collect your personal information for the purposes described in this Privacy Policy.

Information We May Automatically Collect.We may automatically log information about you and your computer or mobile device when you access the Site, such as your computer operating system type, browser type, IP address. We may collect data identifying the web pages you visited prior to and after visiting our Site or use of our Service, your movement and activity within the Site, which is aggregated with other information, your purchase activity, mobile device information, including the type of device you use, operating system version, and the device identifier.

Mobile applications may collect real-time information about the location of your device. If you do not want us to collect this information, you may decline our request or disable location services in your mobile device’s settings. However, opting out of the collection of location information will cause location-based features to be disabled and the online and/or mobile application may not function properly

We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends and to learn more about the demographics of our users. Such third-party service providers may use data collection tools to compile reports and provide us with other services in connection with the Services. We will not collect any location information that you do not volunteer or enable. We will delete any location information that you request us to delete.

Cookies. We may use cookies from time to time. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. They are also used to help us understand your preferences based on previous or current site activity. We also use cookies to help us compile aggregate data about Site traffic and Site interaction so that we can offer better Site experiences and tools in the future.

• Understand and save users’ preferences for future visits; and
• Compile aggregate data about Site traffic and Site interactions in order to offer better Site experiences and tools in the future.

We may also use trusted third-party services that track this information on our behalf..

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You can do this through your browser settings. Because each browser is a little different, look at your browser’s “Help Menu” to learn the correct way to modify your cookies.

If you turn cookies off, some of the features that make your Site experience more efficient may not function properly or otherwise be available to you.

Pixel Tags and other similar technologies. Pixel tags (which also may be referred to as “web beacons” or “clear GIFs”) are small images that we (or our licensees or other third party service providers) may use in connection with the Services so we may provide you with access to the Services, track our Services users’ actions and other similar purposes including to evaluate marketing campaigns. The type of information collected by Pixel tags may include the pages and links accessed by you as well as your IP address and other information about the device you used to access the Services.

Information Collected from Third Party Platforms. If you communicate with us through or mention us on a social media or other third-party platforms, we may collect information about you, such as your name, your username associated with that platform and any information or content you have permitted the platform to share with us. The platform provider’s privacy policy will apply to your interactions with the platform and its collection, use and sharing of your personal information, including when you interact with pages that we maintain on social media platforms. We will treat such personal information about you that we receive from such platforms as described in this Privacy Policy. You should check your privacy settings in your social media accounts to understand what information is sent to us through these services and how to restrict it.

Sensitive Information. With your consent, we may collect and process information about your actual location (geolocation data). We use various technologies to determine location, including IP address. You can deactivate access to your mobile device’s precise geolocation in your mobile device’s settings

How We Use Your Information

We use the information and personal information provided by you to provide Services and to manage our business operations. We may use your personal information we collect from you to:

• Improve our Services, functionality, and overall user experience on the Site;
• Deliver our Services to you;
• Better cater and market to our users, as well as learn about preferences and usage habits;
• Respond to customer service requests, comments and questions;
• Personalize content and tailor our Services based on your geographical location;
• Send periodic emails, notifications, and text messages regarding our Services;
• Notify you about changes to our Site or any events, products, or services we offer or provide through the Site, as well as events, products, or services of select partners;
• Follow up with you after correspondence (live chat, email, or phone inquiries);
• Provide you with targeted offers, marketing and promotional information on our behalf or on behalf of our marketing partners, and/or their respective affiliates and subsidiaries and other third parties, provided that you have not already opted-out of receiving such communications;
• Communicate about our partners’ products and services;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Troubleshoot technical difficulties and errors;
• Link or combine user information with other personal information;
• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information held by us about our Site users is among the assets transferred;
• As permitted or required by applicable law or regulatory requirements; and
• For any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

We may also use personal information that has been de-identified and/or aggregated for purposes not otherwise listed above.

Interest-Based Advertising. We work with third party advertising companies and social media companies that display ads on our Services and other online services. These companies use cookies and other technologies to collect data (including the device and usage data described above) on your activity over time across our Services and other online services or your interaction with emails, which they use to try to tailor the ads you see online to your interests. These ads are known as “interest-based advertisements.” You can learn more about your choices for limiting interest-based advertising in the Internet-Based Advertising Choices section below. We may also share user contacts with third party online services, such as social media platforms, to facilitate interest-based advertising to those contacts or similar users on third party online services.

Artificial Intelligence. We, our service providers and the third parties we work with use artificial intelligence (AI) and machine learning technologies, including generative AI, to facilitate the processing of personal information described in this Privacy Policy.

Sharing or Disclosing Your Information

Except as disclosed in this Privacy Policy, we do not disclose your personal information to any companies not part of COMPANY or its parent, subsidiaries, affiliates, or related entities. In no event will we ever sell or rent any identifying personal information, except in the form of aggregate consumer information, as described below. We may, however, share your personal information as follows:

• We may share personal information for legal, protection, and safety purposes.
• We may share information to comply with laws or as permitted by laws.
• We may share information to respond to lawful requests and legal processes.
• We may share information with other companies and brands owned or controlled by COMPANY, including our subsidiaries.
• We may share information to protect the rights and property of COMPANY, our agents, customers, and others. This includes enforcing our agreements, policies, and Terms of Service.
• We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any other person.
• We may share your personal information with vendors, service providers, contractors and agents in connection with the performance of services on our behalf. These service providers are prohibited from using your information except as needed to perform our work or as required by law.
• We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
• Social media platforms and networks such as Facebook, X, TikTok, Pinterest, and Instagram that offer functionalities, plugins, widgets, or tools in connection with our Services (e.g., to log into an account, or to share inspiration, finds, purchases, and other content with your friends and followers on social media). If you choose to use these functionalities, plugins, widgets, or tools, certain information may be shared with or collected by those social media companies—for more information about what information is shared or collected, and how it is used, see the applicable social media company’s privacy policy.
• We may share personal information for any other purpose disclosed by us when you provide the personal information.

We may also share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you, including trusted third parties that provide services to us or on our behalf. For example, we may share your personal information from time to time with third-party information technology, data processing, and call center service providers so that we may operate our business.

Finally, we may also sell, rent, or share aggregate consumer information (i.e., anonymized summary data) with others for their own uses. Specifically, we may sell, rent or share certain aggregate consumer information that we compile using personal information collected about you and other users. This aggregate consumer information will never include your specific personal information. We may sell, rent or share this aggregate consumer information with our partners and other companies for their own marketing, product development, research, or other uses.

We do not sell, trade, or otherwise transfer to outside parties your personal information outside of the situations detailed above, unless you consent otherwise.

Security and Protection of Your Personal Data

We take the security of your personal information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your information. We are not responsible for circumvention of any privacy settings or security measures. Whenever we collect personal information, that information is encrypted and transmitted in a secure way.

We are dedicated to protecting all personal information to the greatest extent possible. However, if you create a User Account, you are responsible for maintaining the confidentiality of your personal information by keeping your password confidential. You should change your password immediately if you believe someone has gained unauthorized access to it or your User Account. If you learn of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody, you should notify us immediately.

Data Retention

We will retain your personal information for as long as needed to provide you Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In accordance with our routine record keeping, we may delete certain records that contain personal information you have submitted to us. We are under no obligation to store such information indefinitely and disclaim any liability arising out of, or related to, the destruction of such personal information.

Consent

By using our Services, we assume that you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy. You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting us using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be addressed to hello@drinkwillies.com. Please note that in some circumstances, withdrawing or changing your consent to certain uses of your personal information may affect: (i) our ability to provide you with the Services you request; and (ii) your ability to access to the Site.

Please refer to the Terms of Service, which incorporates this Privacy Policy by reference, for instructions regarding opting out of receiving push notifications, text messages, and emails from COMPANY. Additional information regarding your rights with respect to the collection of your personal data is included below.

Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes. You may update your account information by emailing us at hello@drinkwillies.com and You may update your information by emailing us at …and providing your first, last name.

In some circumstances we may not agree with your request to change your personal information such as when we cannot verify your request, when we need to complete a transaction, for certain business security practices, to comply with legal obligations, exercise legal claims or rights, or if the information is not considered personal information under state privacy laws. In such cases, we will instead append an alternative text to the record in question.

Access to Your Personal Information

Subject to applicable laws, you can review, verify or correct your personal information. Please review the information in the “Your Rights” section below regarding your rights with respect to the collection of your personal data or contact us at the email below for further details.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

Your Choices About Data We Collect and How to Opt Out

You have a choice about how we use your personal information. Although you cannot opt out of all data collection when you visit our Site and use our Services, you can limit the collection, use, and sharing of your personally identifiable information. Please note that this may affect your ability to access certain Services. You may opt out at any time by contacting us at hello@drinkwillies.com

Do Not Track Signals

We honor do not track signals and do not track, plant cookies or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Your Privacy Rights and Choices

Except as otherwise provided, this section applies to residents of California, Colorado, Connecticut, Utah, Virginia, and other states where privacy laws applicable to us grant their residents the rights described below. With respect to the collection of your personal information, you have the following rights with respect to your personal information. The right: (1) to update or amend personal information that we have collected about you if it is inaccurate or incomplete; (2) to request that we disclose the personal information that we hold about you; (3) to request the categories of sources from which your personal information is collected; (4) to request the categories of third parties with whom we share personal information; (5) to request the commercial purpose for collecting your personal information; (6) to request the categories of personal information sold and the categories of third parties to whom the personal information was sold; (7) to request that we delete or restrict personal information; (8) to request that we limit the ways we use and disclose sensitive personal information (as defined by California law) to uses which are necessary to perform the Services; (9) to opt out of the processing of your personal information with respect to direct marketing or targeted advertising purposes; and (10) not to receive discriminatory treatment for the exercise of your privacy rights. You also have the right to designate an Authorized Agent to submit a request on your behalf.

How to Exercise Your Rights

You can request to know whether we have collected your personal information, and in certain cases, information about how we use and share it. You have the right to request this information once within a twelve (12) month period. If you are a California resident, you have the right to request this information up to two times in a twelve (12) month period. You have the right to designate an authorized agent to make a request on your behalf. To exercise your rights, please contact us at hello@drinkwillies.com or the mail address set forth in the section entitled “Contact Us” below. Requests must include “Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are not required to respond to requests made by means other than through the provided email, telephone number, or mail address. You have the right to appeal our denial of any request you make under this section.

Google Analytics Opt-Out

You can learn more about Google Analytics, one of the analytics services we use, and how to opt-out of being tracked by Google Analytics, here: https://tools.google.com/dlpage/gaoptout at
https://www.facebook.com/privacy/explanation. You can learn about and opt out-out of personalized ads from Google by visiting https://adssettings.google.com, or from Facebook by visiting https://safety.google/intl/en/privacy/ads-and-data/ and following the instructions to manage your ad preferences.

• Your California Privacy Rights Under the Shine the Light Law. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with which they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for those third parties’ own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to hello@drinkwillies.com. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information

Google Analytics Opt-Out

You can learn more about Google Analytics, one of the analytics services we use, and how to opt-out of being tracked by Google Analytics, here: https://tools.google.com/dlpage/gaoptout at
https://www.facebook.com/privacy/explanation. You can learn about and opt out-out of personalized ads from Google by visiting https://adssettings.google.com, or from Facebook by visiting https://safety.google/intl/en/privacy/ads-and-data/ and following the instructions to manage your ad preferences.

We do not sell, trade, otherwise transfer your personal information outside of the situations detailed above, so we do not have an opt-out. If you have questions about these practices, please contact us at hello@drinkwillies.com

You have the right to opt out of the sale of your personal information by clicking on the following link: Do Not Sell My Personal Information.

Interest-Based Advertising Choices. Some of our advertising partners are members of the Network Advertising Initiative (NAI) and are subject to the Self-Regulatory Principles for Online Behavioral Advertising published by the Digital Advertising Alliance (DAA). You can obtain more information about these companies’ information collection practices and opt-out of receiving interest-based advertising from participating NAI and DAA members at http://optout.networkadvertising.org/?c=1 and/or the DAA’s website
at optout.aboutads.info. Mobile app users may opt out of receiving interest-based advertising in mobile apps provided by participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available
at https://youradchoices.com/appchoices. In addition, your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for targeted online advertising purposes. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you. Please note that we also may work with companies that do not participate in the opt-out mechanisms described above. Even after using these opt-out mechanisms, you may receive interest-based advertising from other companies.

Your European Privacy Rights

If you are a data subject in Europe, you have the right to access, rectify, or erase any personal data we have collected about you through the Services. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Services. In addition, you have the right to ask us not to process your personal data (or provide it to third parties to process) for marketing purposes or purposes materially different than for which it was originally collected or subsequently authorized by you. You may withdraw your consent at any time for any data processing we do based on consent you have provided to us.

To exercise any of these rights, contact us at the address set forth in the section entitled “Contact Us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfill the purposes for which it was collected and may continue to retain and use the information even after a data subject request for purposes of our legitimate interests, including, as necessary, to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

If you have any issues with our compliance, you have the right to lodge a complaint with a European supervisory authority.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your state privacy rights We will not:

• Deny you products or Services.
• Charge you different prices or rates for products or Services, including through the use of discounts or other benefits or imposing penalties.
• Provide you with a different level or quality of products or Services.
• Suggest that you will receive a different price or rate for products or Services or a different level or quality of products or Services.

Accessibility

Individuals who need assistance accessing this Privacy Policy or need technical or customer support in an alternative format can do so by contacting us at the email address below.

• JS WR JV LLC is committed to providing access to our websites and apps to as many users as possible. With respect to this ongoing goal, we understand how many of our customers are currently living with one form of disability or another (including auditory, physical, neurological, visual, and cognitive disabilities), many of which can greatly inhibit access to information technologies including the Internet. JS WR JV LLC is committed to ensuring equal access to our users with disabilities, as we recognize how critical such access truly is in today’s society. We are also committed to providing maximum access our websites and apps to those users who, while not suffering from a current disability, are nevertheless subject to access barriers including low bandwidth and language issues. We encourage and welcome all users and strive to help those achieve maximum access so that everyone can enjoy and benefit from our offerings equally. In furtherance of this goal, our web content has been designed in compliance with the American with Disabilities Act of 1990 (ADA), 42 U.S.C. § 12101 , the World Wide Web Consortium’s (W3C) Web Content Accessibility Guidelines (WCAG) 2.0, Level AA (WCAG 2.0 AA), and the Authoring Tool Accessibility Guidelines 2.0 (ATAG).
• If you have any questions, please contact

Terms of Service

This Privacy Policy is subject to the Terms of Service, a copy of which is available here: [TERMS OF SERVICE]. It is important that you read the Terms of Service, as where there is a conflict between this Privacy Policy and the Terms of Service, the Terms of Service shall prevail.

Contact Us

If you have any questions or requests relating to this Privacy Policy, please contact:

JS WR JV LLC

Address: 12190 DEARBORN PL POWAY, CA 92064

Phone: 858-800-6945

Email: hello@drinkwillies.com