CCPA Privacy Notice

Privacy Notice for California Residents

Last Updated Date: June 1, 2022

Effective Date: June 1, 2022

This Privacy Notice for California Residents (this “Notice”) supplements the information contained in the Sanzo Brands Inc. (the “Company” or “we”) Privacy Policy (the “Privacy Policy”) and applies solely to all visitors, users, and others who reside in the State of California (“California Users” or “you”). All capitalized terms used herein but not otherwise defined shall have the meaning ascribed in the Privacy Policy. We have adopted this Notice to comply with the California Consumer Privacy Act of 2018, as amended as of the effective date hereof (the “CCPA”).

Information Subject to this Notice

The rights of California Users set forth in this Notice apply to all information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device collected by us through our Web Properties (collectively, “Personal Information”). For the avoidance of doubt, the rights set forth in this Notice do not apply to any of the following:

publicly available information from government records;
deidentified or aggregated consumer information; or
information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

For additional clarity on Personal Information subject to the CCPA collected by us through our Web Properties, below is a list of the categories of Personal Information covered by the CCPA. Whether or not we have collected a particular category of Personal Information in the last twelve (12) months is set forth in the “Collected” column.

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Physical location or movements.	No
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information.	Current or past job history or performance evaluations.	No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other Personal Information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

We obtain the categories of Personal Information listed above from the sources identified in the Privacy Policy.

Use of Personal Information

Without limiting the generality of the uses described in the Privacy Policy, we may use and disclose Personal Information we collect for one or more of the following purposes:

to fulfill or meet the reason you provided the information (for example, if you share your name and contact information to ask a question about our products or services, we will use that Personal Information to respond to your inquiry; if you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery, and we may also save your information to facilitate new product orders or process returns);
to provide, support, personalize, and develop our Web Properties, products, and services;
to create, maintain, customize, and secure your account with us;
to process your requests, purchases, transactions, and payments and prevent transactional fraud;
to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
with your consent, to personalize your experience on our Web Properties and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Web Properties, third-party sites, and via email or text message;
to help maintain the safety, security, and integrity of our Web Properties, products and services, databases and other technology assets, and business;
for testing, research, analysis, and product development, including to develop and improve our Web Properties, products, and services;
to respond to law enforcement requests and as required by applicable law, court order, or governmental regulation;
as described to you when collecting your Personal Information or as otherwise set forth in the CCPA; or
to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our equity or assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Web Properties users is among the assets transferred.

We will not (i) collect additional categories of Personal Information or (ii) use Personal Information we collected for materially different, unrelated, or incompatible purposes, in each case, without providing you notice.

Sharing Personal Information

Without limiting the circumstances under which we may disclose your Personal Information set forth elsewhere in this Notice or in the Privacy Policy, we may disclose your Personal Information to third parties for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. We do not currently sell any Personal Information. In the event we begin selling Personal Information we collect through our Web Properties, the CCPA requires us to provide advance notice of any such proposed sale and provide you with an opportunity to opt-out, and prohibits third parties who purchase Personal Information we hold from reselling it unless you have received explicit notice from such third parties and an opportunity to opt-out of further sales.

Without limiting the third parties with whom we share your Personal Information set forth in the Privacy Policy, we may share your Personal Information with the following categories of third parties:

our subsidiaries and affiliates;
contractors, service providers, and other third parties we use to support our business;
a potential 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 equity or 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 Web Properties’ users is among the assets transferred;
governmental authorities when required by applicable law, rule, regulation or court order;
advertising networks;
internet service providers;
data analytic providers;
social networks;
data aggregators; and
internet cookie data recipients.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose to the category(ies) of third-party recipients set forth below:

Personal Information Category	Third-Party Recipients
Category A. Identifiers.	Subsidiaries and affiliates, contractors and service providers, ISPs, data analytics providers, and internet cookie data recipients.
Category B. California Customer Records Personal Information categories.	Subsidiaries and affiliates, contractors and service providers, ISPs, data analytics providers, and internet cookie data recipients.
Category C. Protected classification characteristics under California or federal law.	None
Category D. Commercial information.	Subsidiaries and affiliates, contractors and service providers, ISPs, data analytics providers, and internet cookie data recipients.
Category E. Biometric information.	None
Category F. Internet or other similar network activity.	Subsidiaries and affiliates, contractors and service providers, ISPs, data analytics providers, and internet cookie data recipients.
Category G. Geolocation data.	None
Category H. Sensory data.	None
Category I. Professional or employment-related information.	None
Category J. Non-public education information.	None
Category K. Interferences drawn from other Personal Information.	None

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their Personal Information. This subsection describes California residents’ CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

California residents have the right to request that we disclose our collection and use of your Personal Information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will disclose to you (to the extent applicable):

The categories of Personal Information we collected about you;
The categories of sources for Personal Information we collected about you;
Our business or commercial purpose for collecting Personal Information;
The categories of third parties with whom we share Personal information;
If we sold or disclosed your Personal Information for a business purpose, two (2) separate lists disclosing:
- for sales, Personal Information categories sold and each category of purchaser; and
- for disclosures for a business purpose, Personal Information categories disclosed and each category of recipients thereof.
The specific pieces of Personal Information we collected about you (also called a data portability request).

Note that unless required by applicable law, we do not provide these access and data portability rights for Personal Information collected in transactions with California businesses (“B2B Personal Information”).

Deletion Request Rights

California residents have the right to request that we delete any of your Personal Information that we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request to delete your Personal Information (see Exercising Access, Data Portability, and Deletion Rights below), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

Without limiting the generality of the foregoing, we may deny your deletion request if retaining the information is necessary for us or our service providers to:

complete the transaction for which we collected Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with applicable law, or otherwise perform our contract with you;
detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
debug products or identify and repair errors that impair existing intended functionality;
exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
comply with the California Electronic Communications Privacy Act (Cal. Penal Code 1546 et. seq.);
engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
comply with a legal obligation; or
make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B Personal Information unless required by applicable law.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: emailing us at hello@drinksanzo.com or completing the form accessible here [LINK].

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. Parents and legal guardians may make a verifiable consumer request on behalf of a minor child. To designate a representative authorized to submit verifiable consumer requests on your behalf, contact us using one of the methods described above.

A California resident may only make a verifiable consumer request for access or data portability twice within a twelve (12)-month period. The verifiable consumer request must:

provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative thereof; and
describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to a consumer request or provide California residents with Personal Information in response to a consumer request if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, or a person on behalf of whom you are authorized to make such request.

However, making a verifiable consumer request does not require you to create an account with us, but note that we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in a verifiable consumer request to verify the requester’s identity or authority to make the request.

Response Timing and Format

We will confirm receipt of a consumer request within ten (10) business days.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (not to exceed ninety (90) days from receipt of the request), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the twelve (12)-month period preceding our receipt of your verifiable consumer request. If we cannot comply with a request, our response will explain why. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically in a PDF file.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

We do not currently sell Personal Information collected through our Web Properties. However, in the event we begin such a practice, if you are a California resident ages 16 years old or older, you will have the right to direct us to not sell your Personal Information at any time, and we will not have the right to sell Personal Information of California residents we actually know are less than 16 years of age, unless we receive affirmative authorization in accordance with the then-applicable requirements of the CCPA.

Non-Discrimination

We will not discriminate against users for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

deny you goods or services;
charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
provide you a different level or quality of goods or services; or
suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. We do not currently provide any such financial incentives.

Changes to this Notice

We reserve the right to amend this Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on the Company’s website and update the Notice’s effective date. Your continued use of the Company’s website following the posting of an updated Notice constitutes your acceptance of such changes.

Contact Information

If you have any questions about this Notice or any of the information provided herein or wish to exercise any of your rights under California law, please feel free to contact us as set forth herein or in accordance with the Privacy Policy.

CCPA Privacy Notice

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