Effective: 01/24/2022

Hand Barrel Bourbon, LLC (“Hand Barrel Bourbon” or “We”) recognizes the importance of your privacy, and We are committed to protecting the information We collect from you. The following privacy policy (the “Privacy Policy”) governs your use of the Hand Barrel Bourbon website, located at [https://handbarrel.com/], which includes without limitations, the home page and all other pages under the same top level domain name, and all content thereon (the “Site”) as provided by Hand Barrel Bourbon. We may change the Privacy Policy from time to time and at any time without notice to you by posting such changes on the Site. By using the Site, you agree to the terms of this Privacy Policy, which are also incorporated by reference into the Terms of Service for use of the Site, located at [https://handbarrel.com/] to which you must agree to in order to use the Site. We know that you care how information about you is used and shared, and We appreciate your trust that We will do so carefully and sensibly. By visiting the Hand Barrel Bourbon Site, you are accepting the practices described in this Privacy Policy.

What Information Do We Collect?

We collect information from you when you visit the Site, whether through the Site or via alternative means, including but not limited to completion of Hand Barrel Bourbon documents and forms. In this section, We describe what types of personal data We collect, the ways We collect it, and how We use it. While We have tried to be complete, this list is not necessarily exhaustive, given that these activities can vary from time to time. When We collect information, We will tell you at the point of collection what information is required and what information is optional. We collect personal information both directly from the information you provide us with as well as automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies. This collection of information includes any information that can personally identify you. This information may include details such as your name, age, gender, email address, mailing address, phone number, credit card information, and you Internet Protocol (“IP”) address.

Information You Provide to Us

Examples of information that you provide us with include information collected from filling in forms on our Site, when subscribing to promotional communications, when reporting a problem with our Site, when responding to a survey, and records and copies of correspondence, including email addresses and telephone numbers, if you make contact with us. The types of personal data typically collected by us may include the following, depending on your activities:

• Contact information and Geographic Location, including name, title, street address (home, work, billing, shipping), postal code, country, telephone numbers (home, work, cell, etc.), email address (home, work), operating system, browser type, company name and other similar information, and your geographic location. Contact information also includes any third-party contact information you provide us with. • Personal/demographic information, including birthday/age/age group, gender, birth date, salary range, occupation, level of education, contest- or promotion-specific information. • Authentication information, including user IDs, log-in names, passwords, password reminders, etc. (in addition to other personal data such as contact information, birth date and the like). • Transactional and financial information, including payment information for purchases made through the Site and debit/credit card information. • Preferences, views and comments, including communication preferences, feedback in response to surveys, etc. • Participation information, including event attendance, sweepstakes/contest entries (including all information submitted on an entry), registrations, information relating to use of online communities and all other user submissions and content you provide. • Order placement and customized product requests, including user formulas, methodologies, trademarks, tradenames, copyrights, and all other intellectual property provided to us. This type of data will be stored on the Site and may be used in advertisements, marketing, promotional communications, and may be publicly available to other users as a featured product creation on the Site.

Information Automatically Collected Through Data Collection Technologies As is the case with many websites, our Site may use cookies and other automated information collection means. Cookies are small files that a site or its service provider transfers to your computer hard drive through your web browser, if you allow, that enables the Site or service provider’s systems to recognize your browser and capture and remember certain information. Cookies also help us upgrade our Site by showing when and how users use our Site. You can set your browser to notify you when a cookie is sent or refuse cookies altogether, but certain features of our Site might not work without cookies. Where We use cookies or other similar technologies, We will seek your prior consent where required to do so by law. Where We use your email or other digital means to communicate marketing information to you, We will seek your prior consent where required to do so by law.

We may contract with third-party service providers to assist in better understanding Site visitors. These service providers are not permitted to use the information collected except to help Hand Barrel Bourbon conduct and improve our business. You may disallow receiving cookies at any time through your web browser. Although you may still use the Site if you reject cookies, some functionality, such as the shopping cart, may be limited.

Our Site may also use IP addresses for the same purposes identified above, as well as to analyze trends, administer our Site, track users’ movements and online activity and gather broad demographic information for aggregate use.

We may use web beacons (also known as Internet tags or clear GIFs) on our Site to access and set cookies and otherwise help us to better understand how users are moving through our Site. Information provided by the web beacon includes the computer’s IP address, the type of browser being used, traffic data, location data, information about your computer and internet connection, and the time that the web beacon was viewed. We may also use web beacons in emails and newsletters so that We know when such communications have been opened and to otherwise help us tailor our communications to individual users. The information We collect automatically is statistical data and may contain personal information. It helps us to improve our Site and to deliver a better and more personalized service, by enabling us to:

• Estimate our audience size and usage patterns • Store information about your preferences • Speed up your searches

Information Collected from Business Partners We may collect personal data related to employees, directors, authorized signatories and other individuals associated with our existing or prospective business partners (collectively “Business Partners”). Information may be collected from Business Partners directly, from a company that employs Business Partners, from our affiliates, during networking events that We have either hosted, or sponsored, or attended; and/or from publicly available sources. We may collect personal data relating to our Business Partners’ employees, officers, authorized signatories, or other associated individuals. Information collected includes but is not limited to names, business addresses, business email addresses, business telephone numbers, business fax numbers, job title or role, business bank account details, date of birth, language of communication, date of first contact, and/or categorization as a business partner.

Information is Used in the Following Ways:

• To personalize your experience: Your information helps Hand Barrel Bourbon to better respond to your individual needs and helps us to better understand the market in which We operate; • To improve the Site: We continually strive to improve the Site offerings based on the information and feedback We receive from you; • To improve customer service: Your information helps Hand Barrel Bourbon to more effectively respond to your requests and support needs; • To administer a contest, promotion, survey or other Site feature, to promote our goods and services, and to inform you of upcoming events; • To send periodic emails and text messages: The email address and telephone number you provide to us may be used by Hand Barrel Bourbon and affiliated businesses for marketing and promotional purposes; • To ensure security: Collection of your information helps to manage security, risk, and fraud prevention.

Who Do We Share Your Information With?

Information about our members, registrants, sponsors and exhibitors (collectively “Users”) is an important part of our business, and We are not in the business of selling it to others. We share customer information only as described below and with such entities that either are subject to this Privacy Policy or follow practices at least as protective as those described in this Privacy Policy. Data We collect may also be processed by staff operating outside the European Economic Area (the “EEA”) who work with us or for us, or for one of our affiliated companies, suppliers or service providers.

• Third-Party Service Providers: We employ other companies and individuals to perform functions on our behalf. Examples include agencies providing marketing assistance and providing User service. They have access to personal information needed to perform their functions but may not use it for other purposes. • Affiliated Businesses: We work closely with affiliated businesses. These businesses may be provided your name, address, email address, and phone number to send you promotional offerings. We cannot control and nor are We liable for contact attempts from these companies to you. Our affiliated businesses will process your data in compliance with the General Data Protection Regulation 2016/679 and any implementing legislation (the “GDPR”) and other relevant data protection laws. • Promotional Offers: Sometimes We send offers to users on behalf of other businesses. If you do not want to receive such offers, please let us know by contacting us at [contact@handbarrel.com]. • Release: We release account and other personal information when We believe release is appropriate to comply with the law; enforce or apply our Terms & Conditions and other agreements; or protect the rights, property, or safety of Hand Barrel Bourbon Users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. Obviously, this does not include selling, renting, sharing, or otherwise disclosing personally identifiable information from users for commercial purposes in violation of the commitments set forth in this Privacy Policy.

Transfers Outside the European Economic Area

If and when transferring your personal data outside the EEA (which consists of EU member states and Iceland, Lichtenstein and Norway), We will only do so using one of the following safeguards:

• the transfer is to a non-EEA country which has an adequacy decision by the EU Commission; • the transfer is covered by a contractual agreement, which covers the GDPR requirements relating to transfers to countries outside the EEA; • the transfer is to an organization which has Binding Corporate Rules approved by an EU data protection authority; or • the transfer is to an organization in the US that is EU-US Privacy Shield certified. You may request a copy of any relevant document in relation to transfers of your personal data outside the EEA by contacting us at [contact@handbarrel.com].

Your Rights

You are entitled to obtain information from us on how We handle your personal data, to see copies of all personal data held by us and to request that your personal data is amended, corrected, or deleted from our systems. You can also limit, restrict, or object to the processing of your data. We do not carry out any decision-making based solely on automated processing, including profiling. If you gave us your consent to use your data, e.g., so that We can send you marketing emails and texts, you can withdraw your consent at any time. Please note that even if you withdraw your consent, We can still rely on the consent you gave as the lawful basis for processing your personal data before you withdrew your consent. You can object to our use of your personal data. If you would like to exercise any of your above rights, contact Hand Barrel Bourbon at [contact@handbarrel.com].

How Do We Protect Your Information?

The security of your personal identifying information (such as your credit card number) is important to Hand Barrel Bourbon. Therefore, We implement a variety of appropriate technical and organizational security measures to protect personal data from loss, misuse, unauthorized access, disclosure, or alteration. All supplied sensitive/credit information is transmitted via Secure Socket Layer (“SSL”) technology. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards. After a transaction, your private information (credit card number, etc.) will not be stored on Hand Barrel Bourbon servers. Please keep in mind, however, there is no such thing as perfect security, and no Internet transmission is ever completely secure or error-free. Moreover, you are responsible for maintaining the confidentiality of any username and password you use, if applicable.

Do We Disclose Any Information to Outside Parties?

We do not sell, trade, or otherwise transfer to outside parties your personal identifying information. This does not include trusted third parties who assist in operating the Site, conducting business, sell products marketed on the Site, or servicing you, so long as those parties agree to keep this information confidential. However, non-personal identifying visitor information may be provided to other parties for marketing, advertising, or other uses.

Your Consent

By using this Site, you consent to this Privacy Policy and our Terms and Conditions incorporated herein by reference. Children

Our website is designed to appeal to adults only. We do not knowingly solicit any information from children or people under the legal drinking age, nor do We knowingly market or otherwise target our websites or our products or services to children or people under the legal drinking age. If We become aware that a visitor to our websites is a child or under the legal drinking age in the country or other territory in which he or she is located at the relevant time and has registered without verifiable parental consent, We will remove his or her personal information from our files.

Retention Period

We will keep and process your personal data only for as long as is necessary for the purposes for which it was collected in connection with your relationship with us, unless We have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defense of legal claims.

Information About Us

In the present Privacy Policy, “We” or “us” means Hand Barrel Bourbon, Inc. incorporated in Massachusetts. Our registered office and principal place of business is located at 501 Boylston St., 10th Floor, Saint James Ave., Boston, MA 02116. If you have any concerns about material which appears on our website or if you need to communicate with us, please contact us at [contact@handbarrel.com]. For the purpose of the GDPR, We will be the data controller responsible for any personal information about you.

Changes to our Privacy Policy

If We decide to change the Privacy Policy, We will post those changes on this page. We reserve the right to modify this Privacy Policy at any time. If We make material changes to this Privacy Policy, We will notify you here, by email, or a notice on our homepage. Legal Disclaimer

We reserve the right to disclose your personal identifying information as required by law and when We believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal process, to operate the Site properly, or to protect ourselves or our users. Choice/Opt-Out

You may choose to have your name taken off the Hand Barrel Bourbon email list or to “opt-out” of having your personal identifying information used for certain purposes, including but not limited to receiving additional marketing materials from Hand Barrel Bourbon. If you no longer wish to receive marketing and promotional materials from Hand Barrel Bourbon, you may contact us at [contact@handbarrel.com].

Unsolicited Materials:

Unless specifically requested, We do not solicit nor wish to receive any confidential, secret or proprietary information or other material from you through the Site, by email, or in any other way. Any unsolicited information or material submitted or sent to Hand Barrel Bourbon will not be deemed to be confidential or secret. Posting Information to the Site

You are solely responsible for any information and other content you post on or through the Site. You understand that anything you post on or through the Site is generally accessible to and may be collected and used by others and may result in unsolicited messages or other contact from others. Users of any available forums are encouraged to exercise caution when providing information about themselves.

Cookies Policy

Consent to the Use of Cookies on This Website We recognize the importance of your privacy, and We are committed to protecting the information We collect from you. The following cookies policy (the “Cookies Policy”) governs your use of the Hand Barrel Bourbon websites, which includes without limitations, the home page and all other pages under the same top level domain name, and all content thereon (the “Site”) as provided by Hand Barrel Bourbon. This website uses cookies. By using this website and agreeing to this policy, you consent to Hand Barrel Bourbon’s use of cookies in accordance with the terms of this policy. We will only set cookies on your device with your prior consent, if this is required by law. If you have consented to the use of cookies on our website, you have the right to withdraw your consent at any time.

About Cookies

Cookies are small files which often include an anonymous unique identifier sent by web servers to web browsers and stored by the web browsers which enable the site or service provider’s systems to recognize your browser and capture and remember certain information. The information is then sent back to the server each time the browser requests a page from the server. This enables a web server to identify and track web browsers. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, and the time spent at our website. There are two main kinds of cookies: session cookies and persistent cookies. Session cookies are deleted from your computer when you close your browser, whereas persistent cookies remain stored on your computer until deleted, or until they reach their expiry date.

Why We Use Cookies

We use cookies to help us save your preferences for future visits, keep track of advertisements and compile aggregate data about website traffic and website interaction so that We can offer better website experiences and tools in the future. We may contract with third-party service providers to assist in better understanding website visitors. These service providers are not permitted to use the information collected except to help Hand Barrel Bourbon conduct and improve our business.

How We Use Cookies

Our website requires you to enter your date of birth and cookies allow us to remember the data you have entered, so that We do not need to ask you to re-enter information every time you browse to a different page of the website. We also use Google Analytics types of cookies which, in conjunction with our web server’s log files, allow us to calculate the aggregate number of people visiting our website and which parts of our website are most popular. This helps us gather feedback so that We can improve our website and better serve our customers. We do not generally store any personal information that you provide to us in a cookie. Most of our cookies expire within 90 days although our analytics cookies may persist for two (2) to ten (10) years. If you delete cookies relating to this website, We will not remember things about you and you will be treated as a first-time visitor the next time you visit the site. The purpose of cookies, such as Google Analytics cookies, is storing information such as the time you visit the website, and whether you have visited it before.

We may also use “Social Media” cookies to personalize your interaction with third party social media platforms, such as Instagram and Facebook, where our website uses such features. Such cookies recognize users of these social media sites when you view social media content on our website. They also allow you to quickly share content across media, through the use of simple “sharing” buttons. We use the following Social Media cookies: Twitter, Facebook, Instagram, YouTube, LinkedIn, Pinterest, and Tumblr. For further information about those Social Media cookies please see here:

http://www.facebook.com/help/cookies https://twitter.com/privacy https://www.instagram.com/legal/cookies/ https://www.youtube.com/static?template=privacy_guidelines https://www.linkedin.com/legal/cookie-policy https://policy.pinterest.com/en/cookies https://www.tumblr.com/policy/en/privacy

Blocking Our Use of Cookies

You can block our use of cookies by activating the settings in your browser but in order to use certain services offered through our website, your web browser must accept cookies. Please visit All About Cookies where you can find comprehensive information on cookie management and blocking for a wide variety of browsers.

You may disallow receiving cookies at any time through your web browser. Although you may still use the site if you reject cookies, some functionality may be limited. Most browsers allow you to refuse to accept cookies:

• In Internet Explorer, you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector. • In Firefox, you can adjust your cookies settings by clicking “Tools”, “Options” and “Privacy”. • In Google Chrome, you can adjust your cookies settings by clicking the “Chrome Menu” on the browser tool bar, “Settings”, “Show Advanced Settings”, “Privacy”, “Cookies” and select your preferred setting.

Your California

Privacy Rights


As of January 1, 2020, subject to certain limitations under applicable law, California residents can request access to and deletion of their personal information.

Sale of Personal Information:

We do not sell your personal information in exchange for monetary compensation. We may allow certain third parties (such as certain advertising partners) to collect your personal information via automated technologies on our websites in an effort to serve you content and advertisements that may be of interest to you. The categories of personal information that may have been disclosed in this manner include: Identifiers, Protected Classifications, Commercial Information, Online Activity, Geolocation Data, and Inferences. We share these categories of personal information for online advertising purposes as described in this Privacy and Cookie Policy.

California Consumer Privacy Rights

If you are a California resident, please see the California Privacy Rights Statement for more information about our privacy practices and your rights.

Questions/Concerns/ Feedback

If you have any questions regarding the Privacy Policy or would like to contact us, please do so at: [contact@handbarrel.com]


This California Consumer Privacy Rights Statement (“CCPR Statement”) applies solely to the personal information we collect online and offline of California consumers. This CCPR Statement is designed to address the relevant legal notice requirements of the California Consumer Privacy Act of 2018 (the “CCPA”) and uses certain terms that have the meaning given to them in the CCPA. This CCPR Statement supplements the Hand Barrel Bourbon Privacy and Cookie Policy and is not intended to contradict or limit the applicability of the information provided in the Privacy and Cookie Notice.

  1. Notice of Collection and Use of Personal Information

We may collect or process the following categories of personal information as specified in the CCPA:

• Commercial Information: commercial information, including products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, IP address, email address, account name, and other similar identifiers. Social Security number, driver’s license number and passport information may be obtained in limited instances for identity and age verification and tax purposes.

• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements.

• Geolocation Data

• Sensory Information: audio, electronic, visual, olfactory, and similar information.

• Employment Information: professional or employment-related information.

• Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, and credit or debit card number.

• Protected Classifications: certain characteristics of protected classifications under California or U.S. federal law, such as age, sex, gender, disability, and military and veteran status.

• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use the categories of personal information listed above for the purposes described in our Privacy and Cookie Notice and for certain business purposes specified under the CCPA, as described below.

• Short-Term Use, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction.

• Performing Services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services.

• Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.

• Detecting Security Incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

• Debugging to identify and repair errors that impair existing intended functionality.

• Safety, including undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

  1. Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this CCPR Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, and (c) the categories of personal information we may have sold.

a. Categories of Sources of Personal Information

We may have obtained personal information about you from various sources, including:

• Directly from you (such as when you visit our website, enter a competition, take advantage of a promotion, redeem a coupon or offer, fill in a questionnaire or survey, purchase products or services from us, contact us with an inquiry, register on or post a comment on our website or app, attend our events, forward an item to a friend, communicate with us via social media or third-party apps and/or inform us of your marketing preferences)

• From your devices, such as when you browse or use our website or apps

• Your family or friends (such as when they contact us on your behalf, or refer you for one of our contests, sweepstakes or other participatory events)

• Our subsidiaries, affiliates, and parent companies, and any of their related businesses

• Vendors who provide services on our behalf

• Business partners (such as distributors and joint marketing partners)

• Social media platforms and other third-party websites with whom we have partnered

• Online advertising technologies companies

• Government entities

• Consumer data resellers

• Publicly available sources, such as public databases and data aggregators

b. Sale of Personal Information We do not sell your personal information in exchange for monetary compensation. We may allow certain third parties (such as certain advertising partners) to collect your personal information via automated technologies on our websites in an effort to serve you content and advertisements that may be of interest to you. The categories of personal information that may have been disclosed in this manner include: Identifiers, Protected Classifications, Commercial Information, Online Activity, Geolocation Data, and Inferences. We share these categories of personal information for online advertising purposes as described in our Privacy and Cookie Notice. You have the right to opt out of interest- based advertising, as detailed below and in the “Marketing Cookies” section of our Privacy and Cookie Notice.

  1. California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below. • Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months. To submit an access request, you may contact us here: [contact@handbarrel.com] • Deletion: You have the right to request that we delete certain personal information we have collected from you. To submit a deletion request, you may contact us here: [contact@handbarrel.com] • Opt-Out of Sale: You have the right to opt out of the sale of your personal information. For information about how to manage cookies and opt out of online interest-based advertising, please see the “Cookies” section of our Privacy and Cookie Notice. Your opt-out will be specific to the web browser or device you use at the time you exercise your opt-out rights; if you use multiple web browsers or devices, you will need to opt-out from each browser and device. Opting out of the sale of your information for interest-based advertising purposes does not mean you will stop seeing ads, including interest-based ads, and your information that was collected prior to 90 days before your opt-out request may be further used for interest-based advertising purposes. Please understand that we will still share your information in ways that are not a “sale,” such as with our service providers, for our own online advertising purposes.

To submit a request as an authorized agent on behalf of a consumer, contact us at [contact@handbarrel.com].

Verifying Requests. To help protect your privacy and maintain security, if you request access to or deletion of your personal information, we will take steps and may require you to provide certain information to verify your identity before granting you access to your personal information or complying with your request. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make a request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described above).

Shine the Light Requests: California Civil Code Section 1798.83 permits you to opt out of the disclosure of your personal information by Hand Barrel Bourbon to third parties for the third parties’ direct marketing purposes. To make an opt-out request of such disclosures, please send an email to [contact@handbarrel.com] or write us at: [contact@handbarrel.com]

Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.