BottleJockey, and its affiliates (collectively, "we", "our", "us" or "BottleJockey") is committed to protecting your private information while promoting responsible data sharing. This Privacy Policy (“Privacy Policy” or “Policy”) applies to and governs data collection and usage on the BottleJockey Site, http://www.bottlejockey.com and any of its sub-domains (collectively, the "Site") and describes BottleJockey's policies and procedures on the collection, use and disclosure of your information. BottleJockey receives your information through our Site as well as through other licensed third-party web sites, mobile applications, products and services in conjunction with your use of our services, products and networks found at or related to the Site (the "Services"). When using any of our Services you consent to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. Irrespective of which country that you reside in or create information from, your information may be used by BottleJockey in the United States or any other country where BottleJockey operates.

We encourage you to read this Privacy Policy carefully when using the Site or the Services, or when providing information to us through the Site. You understand that by using Site or the Services you are accepting our practices as described in this Policy.

2.1 We collect information from and about users of our Site:

• Directly from you when you provide it to us.
• Automatically when you use the Site.

2.2 We do not collect special categories of personal data such as information relating to or about the below or information about criminal records.

• Health
• Racial or ethnic origin
• Political opinions
• Membership of a political association, professional or trade association
• Membership of a trade union
• Religious beliefs or affiliations
• Philosophical beliefs
• Sexual orientation or practices
• Biometric information

2.3 Information that you provide to us (“personal information”) when you register on our Site may include:

• First Name, Last Name;
• Email Address;
• Telephone number; and
• Date of Birth

This information may be collected as a result of you using our Site.

2.4 This information may also include:

• Information that you provide us via the Site such as first name, last name, email address, telephone number and address (“Contact Information”). This includes information provided at the time of registering to use the Site and requesting further services.
• Information you provide to us when you complete user surveys or surveys for research purposes such as your Contact Information.
• Information you provide to us when you report a problem with the Site such as your first name, last name and email address.
• Records and copies of your correspondence (including e-mail addresses and phone numbers), if you contact us.
• Details of transactions you carry out through the Site when you make payment to BottleJockey.
• Your correspondence within the Site with other users (your username and location).

Any information collected by us is for a purpose in relation to your use of our Site, including for providing the services, processing, and delivering your orders.

• Provide Services to you: We collect information to send you email about your registration, perform tasks required to complete a transaction, provide customer support, or provide other types of customer relationship management and fulfillment. We may also use your information to optimize or improve our Services and operations, for example, training and quality assurance.
• Fulfilling legal and compliance obligations: We collect information to fulfill our legal obligations. Examples of this may include satisfying regulatory screening requirements in connection with entity formations, responding to subpoenas and other legal requests for information, and maintaining records as required in our role as Registered Agent. We may also collect information to detect fraud or other suspicious activity.
• Analytics: We collect information for use in performing various types of analytics. For example, we use the information to analyze how visitors interact with our Site, where visitors to our Site arrive from and exit to, pages visited, links clicked, text entered and mouse movements to understand site usage, to detect fraud and potential threats and improve our services.
• To communicate with you: We collect your email address and phone number to (i) contact you regarding your use of our Site/Site, (ii) respond to your questions, complaints, and queries, and (iii) send you updates regarding our services or this Policy and other agreements;
• For other purposes through your consent: We may also process your information for some other reasons which your consent will be sought before we process such information. You may also withdraw your consent at any time.

4.1 Automatic Information Collection and Tracking.

When you access and use the Site, it may use technology to automatically collect:

• Usage Details. When you access and use the Site, we may automatically collect certain details of your access to and use of the Site, including traffic data, location data, logs and other communication data and the resources that you access and use on or through the Site.

4.2 If you do not want us to collect this information, please do not create an account with us.

4.3 We may also use these technologies to collect information about your activities over time and across third-party Sites, Sites or other online services (behavioral tracking).

4.4 Information Collection and Tracking Technologies.
The technologies we use for automatic information collection may include:

• Cookies (or mobile cookies). A cookie is a small file placed on your smartphone or device. It may be possible to refuse to accept mobile cookies by activating the setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Site.

The cookies we use include “analytical” cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.

These cookies are used to collect information about how visitors use our Site. We use the information to compile reports on general user traffic, conversion statistics and to help us improve the site. The cookies collect information anonymously.

• Third Party Cookies. The Site may link to other Sites owned and operated by certain trusted third parties (for example Google Analytics). These other third-party Sites may also use cookies or similar technologies in accordance with their own separate polices. Please note that our advertisers may also use cookies, over which we have no control. For privacy information relating to these other third-party Sites, please consult their policies as Appropriate.

5.1 Lawful Bases for Processing under the GDPR

What are the lawful bases for processing personal data? The lawful bases for processing are set out in Article 6 of the GDPR. At least one of these must apply whenever we process personal data. We mainly use consent, contract, legal obligations and legitimate interests as the bases to process your personal data in accordance with this privacy policy.

• Consent: the individual has given clear consent for us to process their personal data for a specific purpose.
• Contract: the processing is necessary for a contract we have with the individual, or because they have asked us to take specific steps before entering into a contract.
• Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
• Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

BottleJockey does not sell or share your personal information to third parties but may share your information if need arises such as the following:

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about our Site users is among the assets transferred.
• For any other purpose disclosed by us when you provide the information.
• For the purposes of academic research.
• For any other purpose with your consent.
• To comply with any court order, law or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account

• You can review and change your personal information by logging into the Site and visiting your account settings page.
• You may also send us an e-mail at eric@bottlejockey.com. to request access to, correct or delete any personal information free of charge that you have provided to us. We cannot delete your personal information except by also deleting your user account.
• We will respond to a request to access, correct or delete any data within 30 days of the date we receive the request.
• We may not accommodate a request to change information if we believe the change would violate or breach any law or legal requirement or cause the information to be incorrect.
• If, on your request, we refuse to amend, correct or delete your personal information, we will set out our reasons for not doing so and provide you with details of how you may complain about our refusal.
• If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including User Contributions, is governed by our Terms and Conditions.

We will only retain personal data for as long as is reasonably necessary. Upon deletion of an account, all personal data will be removed as soon as possible, and always within 90 days of the deletion.

1. We rely upon both consent and legitimate business interests for processing PII. For example, we may process PII with a User’s consent when they agree that we may place cookies on their devices, or that we can process information that they enter into a form on one of our sites.
2. It is in our interest as a business to enhance the services that we provide which may include processing your information to enable us to:
   • Respond to User enquiries and to fulfil User requests
   • Send Customers or Potential Customers relevant marketing information and offers
   • Complete transactions
   • Provide customer service
   • Send administrative information
   • Personalize Users’ experiences with our sites
   • Do so where we are required to by law
3. We may also process PII when it is in our or a Users’ legitimate interests to do so and when these interests are not overridden by an individual’s data protection rights.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services or Sites, you have the right to request removal of unwanted data that you publicly post on the Services or Sites. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services or Sites, but please be aware that the data may not be completely or comprehensively removed from our systems.

We have implemented multiple security measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Site home page. If we make material changes to how we treat our users' personal information, we will notify you by e-mail to the primary e-mail address specified in your account and/or through a notice on the Site home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Site and this privacy policy to check for any changes.