This
Privacy Notice describes how Q DEVAUGHAN, LLC. and its subsidiaries and affiliates (collectively, “we,”
“our” or “us”) collect, use and disclose information about visitors and users
(collectively, “users”) of our websites, mobile applications, and other online
features, products, and services that link to this Privacy Notice (each a
“Service” or collectively, “our Services”). You can identify the brand that
hosts or provides a particular Service through the website’s footer, “About”
link, or as identified directly above.

INFORMATION
WE COLLECT AND RECEIVE ABOUT YOU

By
visiting or using our Services, we may collect the following categories of
personal information ("Personal Information") you provide to us:

Identifiers,
such as:

Birthdate;

Name
and surname;

Demographic
information (such as your gender and age);

Email
address;

Telephone
number;

Mailing
address; and

Username
and password;

Commercial
Information, such as:

Credit
card number and payment information, in limited circumstances;

Details
of transactions that you carry out through our Services and the
fulfillment of your orders;

Loyalty
account and/or wine club information; and

Other
Personal Information you volunteer, including in the order notes, in
relation to a promotion (including contests, sweepstakes, offers, and
rebates) or survey, at our tasting rooms or hospitality centers, or on any
of our community forums, social media offerings or blogs.

We
may from time to time request you post comments and images from your social
media account(s) (including, but not limited to, Instagram, Twitter and
Facebook) with certain hashtags. In certain instances, if you add those
hashtags to your image, depending upon your social media privacy settings, the
image may be redisplayed on our Services. While you retain ownership of the
image, using the hashtags we request gives us permission to display and
re-display the image. The image may contain information about you, and we may
collect and use that information for marketing and research purposes. If you do
not want your image posted on our Services, please do not use our requested
hashtags.

In
addition, in limited circumstances we may receive certain categories of
Personal Information listed above, such as from sources other than you,
specifically from third-party applications (including, but not limited to,
Instagram, Twitter and Facebook) that you use in conjunction with this Service
(e.g., for age-gating purposes), as well as from our other brands, affiliates,
subsidiaries, business partners, and third-party data providers, which we may
combine with the information you have provided for the purposes described in
this Privacy Notice.

We
may also automatically collect the following categories of network activity
and/or device information (some of which may qualify as "Personal
Information" or "Personal Data" under applicable law) from
devices (e.g., mobile, computer, laptop, tablet) used to visit or use our
Services ("Device Information"):

IP
address;

Device
identifier;

The
website you visited before using our Services;

Browser
type;

Any
search terms entered on or through our Services;

General
location data based on your Device Information, such as country, state or
province;

Computer
operating system;

Access
times; 

Usage
patterns and page views within our Services;

Log
files;

Cookies;

Clear
gifs; and

Flash
LSOs.

For
Services related to our mobile applications, we may also collect general
geo-location information from your device with your consent in accordance with
applicable law. If you do not consent to collection of this information,
certain Services (e.g., personalized location-based services and content) will
not function properly and you will not be able to use those Services. You can
stop our collection of location information at any time by changing the
preferences on your mobile device.

Personal
Information and Device Information are collectively referred to as
"information." Information may be combined to assist us with drawing
inferences or otherwise as may be relevant to the purposes for which the
information was collected, as described below.

We
will retain your information for the period necessary to fulfill the purposes
outlined in this Privacy Notice and as otherwise needed to comply with
applicable law and internal company policies. 

THE
BUSINESS AND COMMERCIAL PURPOSES FOR WHICH WE USE YOUR INFORMATION

Categories of Personal Information 

Purpose of Collection and Use 

Legal Basis 

Identifiers

Commercial
Information

Other
Personal Information

Device
Information

Provide you with information, services, and products
offered on or through our Services, including products from across our
portfolio of brands that we believe might be of interest

Necessary to perform a transaction

Identifiers

Commercial
Information

Other
Personal Information

Device
Information

Administer our loyalty and/or wine club programs

Necessary to perform a transaction

Commercial
Information

Device
Information

Develop new products and services

Necessary for legitimate interests 

Identifiers

Commercial
Information

Other
Personal Information

Device
Information

Provide, with your consent, information, services, and
products to our customers

Consent

Identifiers

Commercial
Information

Other
Personal Information

Device
Information

Track responses to our emails and advertisements and to
measure the success of our marketing campaigns

Necessary to perform a transaction; necessary for
legitimate interests 

Identifiers

Commercial
Information

Device
Information

Respond to or follow-up on your comments, inquiries, or
other requests

Necessary to perform a transaction

Identifiers

Commercial
Information

Device
Information

Communicate with you about your account or use of our
Services

Necessary to perform a transaction

Identifiers

Commercial
Information

Other
Personal Information

Device
Information

Improve the quality of our websites, services, and
products, and tailor them to your preferences

Necessary for legitimate interests 

Identifiers

Commercial
Information

Other
Personal Information

Device
Information

Communicate with you about special offers and other
marketing communications

Necessary for legitimate interests 

General
location data

Provide location-based services and content, as well as to
understand traffic patterns in and around our retail locations

Consent

Identifiers:
Birthdate

Verify that you are of legal drinking age and offer
relevant consumer promotions based on such information. 

Necessary to perform a transaction; necessary for
legitimate interests

Identifiers

Commercial
Information

Device
Information

Comply with our company policies and procedures, for
accounting and financial purposes, and as otherwise consented to by you and
as required or permitted by law

Necessary for legitimate interests, consent

Identifiers

Commercial
Information

Other
Personal Information

Device
Information

As described in the section "How We Disclose Your Information for Other Purposes" of
this Privacy Notice

Necessary to perform a transaction; necessary for
legitimate interests, consent 

HOW
WE DISCLOSE YOUR INFORMATION FOR OUR BUSINESS PURPOSES

From
time to time, we may disclose the following categories of information to our
affiliates, subsidiaries, business partners, third party service providers and
authorities: Identifiers; Commercial Information; Device Information.

This
information may be disclosed in the following circumstances:

Our Affiliates, Subsidiaries and Business Partners. We may share your information with our
affiliates, subsidiaries and business partners in the US and worldwide for
the purposes described above and for other general legitimate business
administration purposes. By visiting or using our Services or otherwise
providing us with your information, you consent to this transfer of your
information throughout our network of entities. To opt-out of such
disclosures, please see the "Other Choices and Rights" section
below.

Service Providers. We
may share your information with third parties who perform functions on our
behalf (e.g., hosting or operating our Services, processing credit card
payments, sending email marketing communications, carrying out contests,
special offers, or promotions, processing job applications, data analysis
and other business support services). We do not authorize these third
parties to use your information for purposes other than for which it was
provided, and do not authorize these third parties to disclose that
information to unauthorized parties. We require these third parties to
maintain appropriate security to protect your information from
unauthorized access or processing.

As Required or Appropriate by Law. We may disclose your information to regulatory
authorities, courts, government agencies and other third parties where we
believe that doing so would be in accordance with or permitted or required
by any applicable law, regulation or legal process, to defend the
interests, rights, and/or property of us or others, or to respond to
emergencies.

Business Transfers. We
may transfer your information to a third party in the event of any
reorganization, merger, sale, joint venture, assignment, transfer or other
disposition of all or any portion of our business, brands, affiliates,
subsidiaries or other assets.

In
addition to the above circumstances, we may disclose your information to other
parties as directed by you or subject to your consent. We may also disclose and
otherwise process aggregated information or de-identified information that does
not identify you individually with other parties. For example, we may disclose
aggregated statistics about pages viewed on our websites or Services,
demographic information and sales, and other shopping information to third
parties to enrich your visitor experience.

HOW
WE DISCLOSE YOUR INFORMATION FOR OTHER PURPOSES

We
may also share with our affiliates, subsidiaries, business partners and other
third parties the following categories of information: Identifiers; Commercial
Information; Device Information, which may use this information for the
purposes noted in the “The Business and Commercial Purposes for which We Use Your
Information” chart above. You may have the right under
applicable law to opt out of or object to such disclosures as described below
in the "Other Choices and Rights" section of
this Privacy Notice. The purposes for which we disclose your information in
this context are: analytics, marketing, retargeting.

COOKIES
AND SIMILAR TECHNOLOGIES

When
you use our Services, we along with our affiliates, subsidiaries and
third-party service providers may use "cookies" and similar
technologies (e.g., beacons, log files, pixels and Flash LSOs) (collectively,
"technology"). This technology involves placing small files/code on
your device or browser that serve a number of purposes, such as remembering
your preferences (e.g., language) and generally improving your experience on or
with our Services. Specifically, we may use such technology for purposes such
as to:

Provide
us with general analytics about our Services, including demographic
information in a non-identifiable form, in order to improve our Services'
performance and customize users' experience;

Support
security measures, such as requiring re-login into your account;

Allow
you to engage in our social media offerings on our Services (e.g.,
Facebook "Like" button);

More
effectively market our Services and advertise other Services (including
the Services of products from across our portfolio of brands) that may be
of interest to you; and

Where
required by law, we collect your consent for the use of such
technologies. 

Cookies. A cookie is a small text file
saved on your device or browser. Some of these cookies are necessary for the
functioning of our Services (known as "Strictly Necessary" cookies),
while others are not (known as "Non-Essential" cookies). Some cookies
(known as "persistent cookies") will remain on your device until you
delete them, while others (known as "session cookies") are
automatically erased when you exit your Internet browser.

You
can set your device or browser to accept or reject most cookies, or to notify
you in most situations that a cookie is offered so that you can decide whether
to accept it. However, if you block cookies, certain features on our Services
may not function. Additionally, even if you block or delete Cookies, not all
tracking will necessarily stop.

With
your prior consent where required by applicable law, we may place or recognize
technology on your browser or device when you visit or use our Services for
purposes of serving you targeted advertising (also referred to as "online
behavioral advertising"). We also work with third party advertising
companies who place their own cookies or similar technology on your browser or
device, subject to your prior consent where required by applicable law, when
you visit or use our Services and other websites to serve customized
advertisements to you as you browse the Internet. As noted above, you can set
your device or browser to accept or reject most cookies, or at least notify you
in most situations that the technology is offered. In addition, the advertising
companies we engage participate in one of the following self-regulatory
programs for online behavioral advertising, which provide the corresponding
user opt-outs:

Networking Advertising Initiative (US Only)

Digital Advertising Alliance (US Only)

European Interactive Digital Advertising Alliance (EU Only)

Digital Advertising Alliance - Canada (Canada Only)

DAA App
Choices Mobile App (Mobile Devices Only) -
For mobile devices (e.g., smartphone, tablets), you may consider
downloading the DAA AppChoices Mobile App to manage such technology.

Please
note that even if you reject such technology, you may continue to receive
advertisements, but the advertisements will not be tailored to your browsing
activities and interests.

Log Files. We automatically gather log
files, such as your IP addresses, browser type, internet service provider,
referring/exit pages, operating system, date/time stamp, and clickstream data
when you use our Services in order to ensure compliance with laws and
applicable requests.

Clear Gifs (Web Beacons/Web Bugs/Embedded Pixels). Clear Gifs are embedded on our Services and are about
the size of the period at the end of this sentence. We use Clear Gifs in order
to ensure compliance with laws and applicable requests.

Third party applications and APIs. We
also offer and deliver services, content or interactive features through and/or
using third-party application programming interfaces, gadgets, and/or
extensions that are hosted on our Services or through other third-party
websites or social networking platforms. When you use these services, content,
or interactive features, or otherwise connect with, or "accept" or
"allow" third party applications, networks, platforms or services
through our Services, you are authorizing those third parties to receive your
information and additionally to potentially share any or all of your
information with us, based on your privacy or other settings on the particular
third-party network or platform. Any information we receive by these means will
be treated and/or processed according to this Privacy Notice.

OTHER
CHOICES AND RIGHTS

Email. If you no longer wish to
receive email marketing communications from us, you may opt-out of receiving
marketing-related emails by using the unsubscribe method provided in our
communications (e.g., by clicking on the "unsubscribe" link in the
email to unsubscribe) at any time. Alternatively, to the extent that applicable
law requires your prior opt-in consent to receive marketing and promotional
emails, we will ask for your consent and you can choose not to opt-in or
subsequently withdraw your consent at any time.

Text Messages. If you no longer want to
receive text messages from us, reply STOP (or as otherwise instructed) in the
text message. Alternatively, to the extent that applicable law requires your
prior opt-in consent to receive text messages, we will ask for your consent and
you can choose not to opt-in or subsequently withdraw your consent at any time.

Online Accounts. If you have created an online
account with us and would like to update the information you have provided to
us, you can access your account to view and make changes or corrections to your
information.

Jurisdiction-Specific Privacy Rights. Where
required by applicable law (such as the EU General Data Protection Regulation
or various state privacy laws in the United States), you may have the right to
obtain confirmation that we maintain certain Personal Information relating to
you, to verify its content, origin, and accuracy, as well as the right to
access your Personal Information, request their update, integration or
completion, request deletion or portability of your Personal Information. You
may also object to the processing of your information or request restriction of
the processing, including for targeted advertising; withdraw your consent to
the processing of Personal Information (without affecting the lawfulness of
processing based on consent before its withdrawal), and opt-out of the “sale”
of your Personal Information, as the term is defined under applicable law. You
can exercise your rights by contacting us as detailed under the "Contact Us" heading below. We will try
to comply with your request as soon as reasonably practicable and as required
by applicable law. Please note that we may need to retain certain information
for recordkeeping purposes, to complete any transactions that you began prior
to your request, or for other purposes as required or permitted by applicable
law. In any event, should you choose to exercise any of your rights as detailed
above, we will not discriminate against you by offering you different pricing
or products, or by providing you with a different level or quality of products,
based solely upon this request. You may also have the right to lodge a complaint
with the relevant data protection supervisory authority. You always have the right to object to the processing of your
Personal Information for direct marketing purposes at any time.

SECURITY
OF YOUR INFORMATION

We
take commercially-reasonable technical, administrative, and physical security
measures to protect your information, including generally accepted industry
standards to protect the information submitted to us during transmission and
once we receive it. However, no method of transmission over the Internet, or
method of electronic storage is 100% secure, so we unfortunately cannot
guarantee absolute security. If you have reason to believe that your
interaction with us is no longer secure (e.g., if you feel that the security of
any account you might have with us has been compromised), please contact us
immediately as detailed under the "Contact Us" heading below.

RETENTION
OF YOUR INFORMATION

We
typically retain Personal Information related to marketing activities for as
long as you accept marketing communications from us, and upon request we will
securely delete such information in accordance with applicable law. For
Personal Information that we collect and process for other purposes described
above, we typically retain such Personal Information for no longer than for the
period necessary to fulfill the purposes outlined in this Privacy Notice and as
otherwise needed to address tax, corporate, compliance, litigation, and other
legal rights and obligations.

INTERNATIONAL
TRANSFERS

Some
of the parties identified above may be located in countries that do not provide
an equivalent level of protection as your home country. Where required, we have
taken appropriate measures to allow and secure the transfer of information
about you to these recipients for the purposes described above and in order to
comply with local data privacy laws. With respect to transfers originating from
the European Economic Area ("EEA"), we implement standard contractual
clauses approved by the European Commission, and other appropriate solutions to
address cross-border transfers as required by applicable law. Where required by
such laws, you may request a copy of the suitable mechanisms we have in place
by contacting us as detailed below. 

LINKS
TO OTHER WEBSITES

Our
Services may contain links to other websites or services that are not owned or
controlled by us, including but not limited to links to websites of our
advertisers, sponsors, and partners. This Privacy Notice only applies to
information collected by our Services. We have no control over these
third-party websites, and your use of third party websites and features are
subject to privacy policies posted on those websites. We are not responsible or
liable for the privacy or business practices of any third-party websites linked
to our Services. Your use of third parties' websites linked to our Services is
at your own risk, so we encourage you to read the privacy policies of any
linked third-party websites when you leave one of our Services.

NO
DATA COLLECTED FROM CHILDREN/MINORS/THOSE UNDER THE LEGAL DRINKING AGE

Our
Services are intended only for those of legal drinking age and we do not
knowingly collect information from individuals under the legal drinking age,
children or minors. If we have actual knowledge that information about a child
has been collected, we will take the appropriate steps to delete the
information.

INFORMATION
FOR CALIFORNIA RESIDENTS

If
you reside in California, we are required by the California Consumer Privacy
Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”)
(collectively, “California Privacy Law”) to provide you with information about
how we use and disclose your Personal Information, and you may have certain
rights with regard to your Personal Information. We have included this
California-specific information below.

CA Personal Information. We
may collect certain categories and specific pieces of information about
individuals that are considered "Personal Information" in California
("CA Personal Information"). Specifically, we may collect the
following categories of CA Personal Information: Identifiers, Customer records
information, Characteristics of protected classifications under California or
federal law, Commercial information, internet or other electronic network
activity information, and Inferences.

Sources of CA Personal Information. We
may collect this CA Personal Information from you and other third parties. The
categories of third parties from whom we collect CA Personal Information
include the following: third-party partners; third party applications;
advertising service providers and partners; and other companies or
organizations, such as market research firms and data aggregators.

Purposes of Collection. We
collect and use CA Personal Information as follows:

Business Purposes

Provide
you with information, services, and products offered on or through our
Services, including products from across our portfolio of brands that we
believe you might be interested in; 

Develop
new products and services; 

Provide,
with your consent, information, services, and products to you; 

Respond
to or follow-up on your comments, inquiries, or other requests; 

Communicate
with you about your account or use of our Services; 

Improve
the quality of our websites, services, and products, and tailor them to
your preferences;

Verify
that you are of legal drinking age;

Comply
with our company policies and procedures, for accounting and financial
purposes, and as otherwise consented to by you and as required or
permitted by law

Commercial Purposes

Track
responses to our emails and advertisements and to measure the success of
our marketing campaigns; 

Administer
any applicable loyalty programs the Company develops;

Provide
location-based services and content, as well as to understand traffic
patterns in and around our retail locations

Disclosure of CA Personal Information. We
also share and/or disclose your CA Personal Information as follows:

Disclosing your CA Personal Information for Business
Purposes. We may disclose the above
categories of CA Personal Information to third-party partners; third party
applications; and other companies or organizations, such as market
research firms and data aggregators, for any of the Business Purposes
described above.

Disclosing your CA Personal Information for Commercial
Purposes. We may share the above
categories of CA Personal Information with third-party partners; third
party applications; advertising service providers and partners; and other
companies or organizations, such as market research firms and data
aggregators, for any of the Commercial Purposes described above.

Certain
CA Personal Information that we collect about you may be considered sensitive personal information within the meaning
of California Privacy Law, including: credit card information (for billing and
transactional purposes in connection with providing products and services). We
only use and disclose sensitive personal information as necessary in connection
with the performance of services and the provision of goods, compliance with
federal, state, or local laws, and as otherwise permitted by California Privacy
Law.

We
do not knowingly share the CA Personal Information of individuals under 16
years of age, in a manner that constitutes a "sale" under California
law.

Retention of CA Personal Information. We
retain your CA Personal Information for as long as needed or permitted in light
of the purpose(s) for which it was obtained. The criteria used to determine our
retention periods include (i) for as long as we have an ongoing relationship
with you; (ii) as required by a legal obligation to which we are subject to; or
(iii) as advisable in light of our legal position (such as in regard of
applicable statutes of limitations, litigation, or regulatory investigations).

Your Rights under California Law. Subject
to certain exceptions detailed in California Law and other applicable laws and
regulations, as a California resident, you have the right to: (i) request to
know/access your CA Personal Information, including the specific pieces and the
categories of CA Personal Information we have collected or shared about you and
the categories of sources from which we have collected the CA Personal
Information; (ii) request deletion of your CA Personal Information; (iii)
receive information about the CA Personal Information about you that we have
"sold" to (as such term is defined under California Law) or “shared”
with  third parties within the past 12 months, including the categories of
third parties; and (iv) request correction of your CA Personal Information; and
(iv) opt-out of the “Sale” or “sharing” of your CA Personal Information, as
such terms are defined under California Privacy Law.

Exercising California Consumer Rights. If
you are a California resident and wish to request the exercise of these rights
as detailed above or have questions regarding the CA Personal Information
collected or shared with third parties, please click here or call us at 1-888-659-7900 (U.S).

You
may be asked to provide additional proof of identification so that we can
verify your identity and validate the request. 

Please
note that you are limited by law in the number of requests you may submit
per year. In some instances, we may decline to honor your request. For
example, we may decline to honor your request if we cannot verify your
identity or confirm that the CA Personal Information that we maintain
relates to you. In other instances, we may decline to honor your request
where an exception under California privacy laws applies, such as where
the disclosure of California Personal Information would adversely affect
the rights and freedoms of another consumer. 

In
any case, we will not discriminate against you by offering you different
pricing or products, or by providing you with a different level or quality
of products, based solely upon this request.

Authorized Agents. To the
extent that you elect to designate an authorized agent to make a request on
your behalf, they must provide appropriate documentation including written
signed permission from you, proof of your identity, and verification of their
identity; or a valid, designated power of attorney as defined under the
California Probate Code.

CA Shine the Light. Under
California's "Shine the Light" law (California Civil Code Section
1798.83), if you are a California resident who provides Personal Information in
obtaining products or services for personal, family, or household use, you may
request to opt-out of such sharing by a brand at no-cost by following the
instructions in the "Other Choices and Rights" section
above, or by contacting us as detailed in the "Contact Us" section below. Please be
aware that your opt-out will apply only to the sharing by that particular
brand.

CHANGES
TO THIS PRIVACY NOTICE

Except
to the extent limited by applicable law, we reserve the right to update this
Privacy Notice to reflect changes to our information practices by prominently
posting notice of the update on our Services. Any updates will become effective
immediately after posting the updates to the Privacy Notice and apply to all
information collected about you. If we make any changes to this Privacy Notice
that materially impact previously collected information about you, we will, to
the extent that we have your email address, notify you by email.

LIMITATIONS
TO THIS PRIVACY NOTICE

Please
note that the aforementioned rights might be limited under the applicable
national data protection law. Please contact us, as detailed in the “Contact Us” section below, for any questions.
 In case of complaints, you also have the right to lodge a complaint with
the competent supervisory authority.

CONTACT US

If you have any questions about this Privacy Notice or information we have collected about you, or to exercise your rights as detailed above, please contact us by email at celebrate@qdevaughan.com, or by phone at 1-404-939-6789 (U.S.)
or by postal mail at:

QDEVAUGHAN.com Privacy Notice
Q DEVAUGHAN, LLC.
1920 Dresden Drive NE, #190575
Atlanta, GA 30319

Q DEVAUGHAN LLC SUBSIDIARIES AND AFFILIATES

Q DEVAUGHAN, LLC.
1920 Dresden Drive NE, #190575
Atlanta, GA 30319
Brand: Q10