PRIVACY POLICY

Pasha's and our clients (“we” or “us”) are committed to protecting your privacy and maintaining a safe, quality online experience for our clients and visitors. This privacy policy applies to websites we own or sponsor including, without limitation, drinkpashas.com and client websites. Please read the complete privacy policy below and contact us if you have any questions.

Information We Collect

We may collect personal information (such as your name, company name (if any), mailing address, email address, telephone number, social media profile name, IP address, device information, browser information, or payment information) when you:

• Enter your information with us online;

• Save your information with us online;

• Subscribe to receive our emails;

• Order products;

• Submit payments online;

• Provide your information over the telephone, including via SMS or other forms of text messaging to our representative;

• Provide your information in person to our representative;

• Submit a job application, employment inquiry, or résumé;

• Participate in a contest, sweepstakes, promotion, or survey;

• Post comments to our message boards, online chat, or blogs (see Voluntary Posting below);

• Are referred to us through a marketing promotion; or

• Visit our websites (see Cookies and Web Beacons below).

Purposes of Collection

We may use your personal information to:

• Display content and information to you about our products or services;

• Display products that may be of interest to you;

• Permit you to access web-based programs or use software applications we provide or operate;

• Provide you with customer service or order support, including processing returns or make goods;

• Ship products to you or provide services to you;

• Process payments or other financial transactions, including providing your information to third parties to help process or complete the payment or other financial transaction;

• Customize the content of the website or software application for you or others;

• Inform you of and administer promotions (either our promotions or for third parties), contests or sweepstakes;

• Market our products or services or the products and services of third parties;

• Sharing your information with clients, vendors, or service providers that provide services to us;

• Learn about your preferences and improve your website experience;

• Track Internet traffic and visitor use of our websites, webpages, or software applications;

• Help us address problems with and improve our websites, webpages, or software applications;

• Provide content via a content distribution network;

• Maintain suppression or opt-out lists that we may share with vendors or service providers so that you are not contacted if you request to opt-out of commercial emails or data sales;

• Analyze trends or other statistical information, which may be provided to our vendors or service providers using anonymous, aggregate, or de-identified data;

• Develop new products or services;

• Enhance existing products or services;

• Archive or backup our website, software applications, databases, or other data storage;

• Protect the security and integrity of our websites, computer networks, and software applications; or

• Contact you for other business reasons, if necessary.

You always have the right to "opt out" of receiving communications from us (see Making Communication Choices below).

Information We Share

We may share your personal information in the following ways:

• With other parties involved in processing any purchase or transaction you engage in, such as licensed distributors, retailers, or common carriers.

• We may contract with other companies to provide certain services, such as name and address verification, email distribution, customer relationship management, payment processing, marketing, accounting, or collections. We provide these companies with only that information needed in order for them to render the services we request, and they are not entitled to use it for their own marketing or any other purpose.

• On rare occasions, we may disclose information upon law enforcement’s request, in response to a court order, or when required by law. We also may share information to assist in fraud investigations or as necessary to protect our rights and interests (such as for purposes of protecting against malware or phishing).

• In the event we are engaged in a transfer or divestiture of substantially all of our assets, or substantially of a portion of one of our division’s assets, information we have collected as described in this policy may be among the transferred assets.

Who We Share Your Information With

We may share your personal information with any of the following:

• You;

• Your authorized representatives;

• Licensed manufacturers, distributors, wholesalers, retailers, warehouses, or common carriers;

• Security software or services providers;

• Customer relationship management providers;

• Website analytics providers (as further described in Cookies and Web Beacons below);

• Identity verification or fraud prevention providers;

• Payment processing providers;

• Email publishing services or other email-related providers;

• Social media networks or social media service providers; or

• Marketing service providers or remarketing service providers.

Voluntary Posting

We may offer customer reviews, message boards, customer support online chat, or blogs on portions of our website or software applications. Any information you voluntarily disclose when you post to one of these areas becomes public and may be used by us for online and offline promotional and commercial uses. If you choose to post, comment or otherwise share content on our website or software application, you should be aware that any personal information you submit may be public and may be read, collected, or used by other users of those areas, who may include advertisers and other commercial enterprises. We are not responsible for any personal or company information you choose to submit to such publicly available portions of our website or software applications. You should be aware that if you voluntarily disclose information, personal or otherwise, online in any community area, such information can be collected and used by others. For example, if you post personal information online (such as your e-mail address), you may receive unsolicited messages from others. We have no control over this use of your personal information. We reserve the right to delete or remove any content you send to or publish on our website or to our software application, but have no obligation to do so to protect your personal information or otherwise.

Making Communication Choices

If you do not wish to be contacted via email, direct mail, or telephone, please let us know your preferences by contacting us at the contact information provided below, or by filling out the form on the “Do Not Sell My Personal Information” webpage, if that webpage is present. Please provide your name, mailing address, email address, and/or telephone number so that we may identify you correctly. You may also unsubscribe from our email using the link provided in each email. If you ask us to remove you from promotional lists, we will maintain your name on a "do not contact" list to ensure that we continue to honor your requests. We may request authentication or verification, such as logging in with your username and password, or confirmation of information you previously provided to us. If you ask us to remove you from marketing email lists, we will maintain your name on a "do not contact" list to ensure that we continue to honor your requests. Due to privacy concerns and our inability to verify individual requests and contact information, we are unable to honor "opt out" requests made by a third party on your behalf, unless the third party is a parent of a minor or your authorized representative. For removal from mailing lists, it may take up to ten business days to process your request and, due to the fact that mailings are planned long in advance, up to 60 days to process your postal mail request. When you interact with our website to pay for a service, we will continue to confirm such transactions via email and, if questions arise concerning your payment, we may contact you via email, postal address or telephone number. If you change your mind about your choices, you may start receiving promotional communications from us again by logging onto your online account and changing your preferences, or by signing up when you visit our website.

We do not use automated telephone or text message marketing. However, we may communicate with you about your order or inquiry via individual telephone call or text message. If you wish for us to no longer communicate with you via text message, please inform a customer support representative or email us at info@drinkpashas.com.

Accessing and Changing Your Information

To review or change the information you previously provided, please contact us at the contact information listed below. We may provide an electronic means on our website for you to update your account information.

You can do the following at any time by contacting us at info@drinkpashas.com, by sending a letter to Customer Support at the address below, or by calling the phone number provided on our website:

• See what data we have about you, if any.

• Change/correct any data we have about you.

• Have us delete any data we have about you.

• Express any concern you have about our use of your data

You may request the personal information we have collected and stored about you by contacting us at info@cylindervodka.com with the subject line “Request to Know” or by sending a letter to our postal address below with the same request. For any request to disclose, modify, or delete your information, we will take reasonable steps to verify your identity prior to disclosing or changing your information, such as requesting verification of other information you have previously provided to us, verifying information we have provided to you such as an account number, or by matching your means of connecting to the Site to similar information we previously collected.

You may designate an authorized agent to act on your behalf by sending a letter to the postal address below with a signed letter that includes your name, email address, and date of birth for verification, along with either your signed designation of the authorized agent or a court order or similar legal document designating the authorized agent as acting for you (for example, a power of attorney or letters testamentary).

Cookies and Web Beacons

Your web browser offers so-called “cookies” which, if you allow their use, store small amounts of data on your computer when you visit a website. Cookies do not contain any personal information about you and therefore cannot be used to identify you personally. However, cookies assist us in tracking which of our features you like best. You have the ability to accept or decline cookies by modifying your browser and our websites are viewable even if you disable the cookie function on your browser. However, if you disable cookies, some advanced and customized features or offerings may not be available to you.

Some pages on our websites may contain electronic images known as web beacons, which are also called “single-pixel gifs.” These images allow us to count users who have visited those pages and to deliver certain services. We also may include web beacons in promotional e-mail messages or newsletters in order to count how many messages have been opened and acted upon. Web beacons are not used to access your personal information, but they are a technique we use to compile aggregated statistics about usage on our websites. Web beacons collect only a limited range of information, including the time and date of page view, cookie number and description of the page on which the web beacon resides. Our website does not honor “Do Not Track” requests.

Security

We use a variety of technologies and processes to protect your personal information. However, we do not guarantee the absolute security of your personal information, but we do take reasonable efforts to secure your personal information, including the encryption of sensitive personal information. We will never request your credit card information by email. If you receive an email that appears to be a request from us for credit card information, do not respond as this may be a "phishing" scam designed to steal your personal information. Email is not a secure means of communication.

Links to Other Websites

Our websites and software applications may contain links to websites owned by third parties. Please review the privacy policy of any third party’s website you access via a link from our website.

Children's Privacy

We do not permit the use of this website by persons under the age of 21. A minor’s parent or guardian should contact us if we have inadvertently collected information about that child without the parent or guardian’s authorization, so that we may delete such information from our files. By using our website, you agree to provide us with accurate information concerning your age or identity if we request it. You also agree not to assist persons under the age of 21 in accessing our website, or to attempt to contact children under 18 through our website.

Our website is intended solely for wholesale business customers or potential customers, and are not intended for persons or businesses that are not residents (legally or otherwise) in the U.S.

Policy Changes

We update this Privacy Policy as we believe is necessary to protect our clients and to comply with a changing environment. We recommend that you check the Privacy Policy when you visit our website to be sure that you are aware of and understand our current policy. If we make material changes to this policy, or in how we use or collect your personal information, we will prominently post a link to such changes at least 10 days prior to implementing the change. Your continued use of the site will constitute acceptance of the revised Privacy Policy. If we make retroactive changes to the Privacy Policy, we will prominently post a link to such changes and we will email affected users at least 10 days prior to implementing the change.

Your California Privacy Rights

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice describing what categories of personal customer information we share with third parties or affiliates for our direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident and would like a copy of this notice, please submit a written request to us (see Contact Us below). In your request, please include your postal address and specify that you want a "Your California Privacy Rights Notice." Please allow at least 30 days for a response.

Periodic Changes

This privacy policy may be updated with five business days’ notice, with such notice posted until at least five business days after the revised privacy policy takes effect. Any material revisions to this privacy policy will be reasonably prominently posted on our websites, and will apply to information collected both before and after the revision to the extent permitted by law. Your use of the websites following any such revisions will be deemed your acceptance of such revisions. You should periodically visit this page to review our current policies on our collection and use of information. You may submit inquiries about this policy to us at the mailing address below, via email to info@drinkpashas.com, or by using the Contact Us webpage.

Contact Us

To "opt out" or make other choices about receiving communications, to update your personal information, or to submit comments or ask questions about our privacy policy, please contact us by email: info@drinkpashas.com