Privacy Policy

This website is operated by NBTV Channels, LLC USA registered trading as Spirits Network, LLC USA registered and Spirits Network UK Limited which is registered at Companies House registered in the UK and Wales with registered number 13651599 and VAT number GB 396 7587 20. We value transparency and your privacy and to keep your personal data secure we have put in place appropriate physical, electronic and managerial procedures to safeguard the information you provide. This page has everything you need to know about how we use your data. If you have any questions about our Privacy Policy, we’d love to hear from you – just email us at privacy@spiritsnetwork.com. This Privacy Policy should be read in conjunction with our Cookies Policy. This is the Privacy Policy for the websites we operate hosted at https://spiritsnetwork.com and https://store.spiritsnetwork.com ; https://spiritsnetwork.co.uk and https://store.spiritsnetwork.co.uk and for the Spirits Network mobile and OTT applications (the "Services").

Definitions

All references to 'you &/or your' means you and 'we, us, our or company' within this policy means NBTV Channels, LLC USA registered trading as Spirits Network, LLC USA registered and Spirits Network UK Limited which is registered at Companies House (registered in the UK and Wales) with registered number 13651599 and VAT number GB 396 7587 20.

All references to 'service providers' means subcontractors (including any affiliated partners) retained by us for the specific purpose of performing functions on our behalf or to provide services to us. Such services include but are not limited to, warehousing and delivery; marketing and advertising; credit card and data processing; age verification; software development; website hosting and management; information technology and office services; legal, accounting, audit and other professional service providers; and other services related to our business.

Our aim is to protect you and your personal privacy and provide this Privacy Statement in order to help you understand what we may do with any personal information you provide. Provision of personal information will be acknowledged as your acceptance of this Privacy Statement and agreement to our collecting and use / disclose of your personal information only as described in this Privacy Statement.

If you do not agree to this statement, please do not provide your personal details to us. This Privacy Statement forms part of the Terms and Conditions which govern your use of the site.

We reserve the right to amend this Privacy Statement from time to time without notice and at our sole discretion. As such, it is your responsibility to review the Privacy Statement at regular intervals.

For the purposes of UK and EU data protection law, (the "Data Protection Law"), we are the data controller.

This policy sets out:

• Information we collect about you
• How we use your information
• Our promotional updates and communications
• Who we share your information with
• Where we store your information
• Direct messaging
• Payment processing
• How we protect your information
• How long we keep your information
• Age restrictions
• Your rights
• California residents
• Canada residents
• Changes to this policy

Please read this carefully to understand how we will collect and use your personal information. By using our Services you acknowledge you have read and understood this Privacy Policy.

Information we collect about you

We will collect and process certain personal information if you use our Services, including signing up for free, signing up for a subscription, or browsing content or the store.

YOU PROVIDE US WITH

You provide us with information about you when you use the Services, including if you:

- browse the Services
- search the Services
- watch or read any content
- register an account to use the Services
- register an account for a subscription
- submit a query to us
- report a problem with the Services
- sign up to email updates
- pay for a subscription
- order specific alcohol products through us from our retailers

When you interact with us, we collect the following types of personal information:

- Identity: including date of birth, first and last name.
- Contact: e-mail address and phone number.
- Analytics: you may voluntarily provide your preferences in your account such as preferred spirits, foods, travels, hobbies, etc.
- Interaction: your password, and queries and feedback which you provide to us, including via email, phone and social media platforms such as Facebook, Instagram or Twitter.
- Payment: credit or debit card type, card number, CVC/CVV code, card expiration date, and the name and billing address associated with the card.

OTHER PARTIES MAY PROVIDE US WITH

- We work closely with third parties (including brand and content partners, our retail partners, sub-contractors in communications, technical, and payment services, analytics providers, and search information providers). We'll tell you (usually in this Privacy Policy) when we receive information about you from another source, and for what purpose(s) we'll use that information.
- We may share personal information we collect or combine data from other sources with personal information you've given to us.
- This may involve processing your identity, contact, interaction and payment information.

WE AUTOMATICALLY COLLECT

We will automatically collect information from you each time you use our Service. This includes:

- Technical information
- Location information
- Information about your visit

- Technical information may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, Google ID, time zone setting, browser plug-in types and versions, operating system and platform.
- Location information may include the physical location (or approximate location) of your device by, for example, using satellite, GPS, phone towers, beacons, or Wi-Fi signals. This information may be used to provide you with personalized services and content, including advertising, and may also be shared with our marketing partners. You will be permitted to allow or deny such uses and/or sharing of your device 's location. For example, when you use our Services (including mobile application) on your device, you may have the opportunity to state that you would like to share your location. For information about opting out of location based services, please refer to settings in your device settings. Please be aware, however, that certain features of the Services may be unavailable if your device is not set to support or enable location-based services.
- Information about your visit may include the full Uniform Resource Locators (URL), clickstream to, through and from our Services (including date and time), pages you viewed or searched for, page response times, download errors, logins, length of visits to certain pages, title selections, watch history, page interaction information (such as scrolling, clicks, and mouse-overs), information you have viewed and methods used to browse away from the page.
- We may also collect any phone number you use to call our customer service number (include call metadata, like date, time & length of a call), or the social media handle you use to connect with our customer service team. (We may record calls for training & performance purposes, to establish clear records, and for legal reasons. We'll always tell you beforehand if a call is being recorded.)

How we use your information

We use your personal information in different ways. We've set these out below, along with the types of personal information we use for each purpose, and the legal reason(s) (also known as the 'lawful basis' under GDPR) that permits this processing. We explain more about what each legal basis means below. We may process your personal information based one or more than one legal basis, depending on the specific ways we are using your personal information.

HOW WE USE THIS PERSONAL INFORMATION	TYPE OF PERSONAL INFORMATION	OUR LAWFUL BASES FOR PROCESSING
To perform our contract with you under our Terms of Use and manage our relationship with you, including: providing our service to you, fulfilling and arranging delivery of orders with our retail partners , arranging payments, administering your account with us, storing your personal information, providing information to you which you have requested,	Identity Contact Analytics Payment Interaction Location	Contract Legal Obligation
To register you as a new user who wants to use our Services.	Identity Contact Location	Contract
To promote our service to you and keep you updated with information about our services, including: delivering relevant content on topics we think may be of interest to you, letting you know about new products or services; and showing you online ads for our Service on social media platforms and other websites and apps . To ask you to leave a review, provide feedback or take a survey.	Identity Contact Analytics Interaction Automatically collected information	Consent Our legitimate interests
To enable you to enter a prize draw or competitions.	Identity Contact Analytics	Consent
To customise your experience and offer you relevant ads, content and recommendations including information about new promotions. For measuring, understanding and optimising the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.	Contact ·Account Analytics Automatically collected information	Our legitimate interests
To administer our Services and for internal operations, including bug fixes, troubleshooting, data analysis, testing, and survey purposes. To improve our Services to ensure that content is presented in the most effective manner for you and for your computer. We may also use aggregated information to help us plan and introduce new features. To keep you up to date about our Service including notifying you about changes to our Service, to our terms or privacy policy and sending you service updates (including security alerts, To keep our Services safe and secure, including taking steps to detect and prevent fraud.	Contact Interaction Automatically collected information	Our legitimate interests
To analyse our user base, Service and service usage, feature and content popularity, software and hardware quality, and market trends. To share aggregated and anonymised analytics with digital content partners and other organisations about how people use the Services. You cannot be identified from this information. We may also use this information to inform, refine and deliver our wider online marketing campaigns.	Identity Contact Analytics Interaction Automatically collected information	Our legitimate interests
In the event that we sell or buy any business or assets, disclose your data to a prospective seller or buyer, or in the event we are the subject of acquisition by a third party.	Information relating to transactions	Contract Legal obligation Our legitimate interests
To comply with any rights requests you make.	Contact information	Legal obligation

Where we receive your personal information from a third party, they will be a separate data controller of your personal information, and will have their own legal bases for processing.

Our promotional updates and communications

Where permitted in our legitimate interests (explained below) or with your prior consent if required by law, we may:

- - send you marketing and promotional updates about our products and services, by email and SMS, if you have opted-in to receiving these; or
  - use your personal information for marketing analysis.

You can object to further marketing at any time by selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you or by sending us an email to privacy@spiritsnetwork.com.

Lawful bases explained

GDPR requires controllers of personal data to check they have a lawful basis for their processing of personal information, and to explain which lawful bases they are using for specific uses of personal information. Lawful bases under GDPR include consent, legitimate interests (which need to be balanced with the individual's rights), performance of a contract and performance of the controller's legal obligations.

	Consent: We will process your personal information for promotional or marketing purposes where you have given us your express consent for us to do this, where required by law. This includes sending you updates and newsletters about new content or available products. You can adjust your preferences or withdraw your consent at any time by unsubscribing from marketing in our marketing emails or on the Site.
	Contract: We collect, store and process your personal information where it's necessary for performing a contract you have with us (such as our Terms of Use) or where you have asked us to take specific steps before entering into that contract.
	Legal obligation: We may need to process your personal information to comply with our legal obligations, including under applicable local, UK and EU law (including consumer protection and data protection Law), and/or any court orders.
	Legitimate interests: processing your personal information is sometimes necessary for us to do the following activities, in our own interest or sometimes in the interests of a third party, like digital content partners we work with. In each case, we balance our legitimate interests with your rights and interests. Our legitimate interests include: Gaining insights on how you use our Services. Delivering, developing and improving our Services. Enabling us to enhance, customise or modify our Services and communications. Growing our business and informing our marketing strategy. Keeping our records updated. Improving our Services and data security. Enforcing or applying our terms or other agreements with you, including recovering fees or other debt due to us. Providing you with our promotional updates and communications in certain cases where you have made purchases with us and have not opted-out at the time of purchase or any time since.

Who we may share your information with

We may give your information to:

- Any member of our group, which means our subsidiaries affiliate, and any parent company from time to time, who support our processing of personal information under this policy.
- Our partner and support businesses, including support services, retail partners, advertisers, as well as brand and content partners.

Our selected third parties may include:

- Brand and content partners so they may understand the sorts of people interested in their products and services.
- Organisations who process your personal information in order to provide a service to us. This includes third party suppliers, agents, sub-contractors and/or other who support the services we offer through the Services, including those:
- providing website and data hosting services,
- distributing any communications we send,
- supporting or updating marketing lists,
- facilitating feedback on our services, and
- providing IT support services.
- These organisations will only use your information to the extent necessary to perform their support functions.
- Retail partners who process your information in order to supply spirits or other prodcuts you order from them through our store.
- Online advertiser partners We may work with social media platforms and digital advertising platforms to show you advertising for our Service on other websites and social media platforms. For instance, if you show an interest or buy a product or subscription on our Site, we may advertise that or other products we think may be of interest and you may see them on other websites and on your Facebook or other social media feeds. To do this we will share information with our social medial and digital advertising partners about you, usually including your purchase, age, gender and interests for instance so they can better understand what you are interested in and so we can deliver ads to you which we think might be of interest.
- Analytics and search engine providers that assist us in the improvement and optimisation of our Services (this will not identify you as an individual). Interested. See our Cookies Policy for more information.

We will also share your personal information with third parties:

- If we sell or buy any business or assets, in which case we will disclose your personal information to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.
- If we or substantially all of our assets are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

Where we store your information

We transfer and store your personal information outside the United Kingdom ("UK") and/or European Economic Area ("EEA"), principally in the United States, which does not have equivalent Data Protection Law.

Where your information is transferred outside the UK or EEA, we will take steps to ensure your personal information is protected by appropriate legal safeguards, and that it is treated securely and in accordance with this privacy policy.

Payment processing

It is possible to make payments on the Services through our payment gateway provider. You will be providing credit or debit card information directly to payment gateway provider which operates a secure server to process payment details, encrypting your credit/debit card information and authorising payment. Information which you supply to our payment gateway provider is not within our control and is subject to the payment gateway provider's own privacy, terms and conditions.

How we protect your information

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, including using SSL encryption to secure our Services and protection your information in transit. We cannot guarantee the security of your data transmitted to the Services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Our Services may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

How long we keep your information

We keep personal information for:

- as long as you have an account with us or use our Services in order to meet our contractual obligations to you; and
- six years after that to identify any issues and resolve any legal proceedings.

We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

Age restrictions

Protecting the safety of children when they use the Internet is important to us.

Our Services are restricted to persons who are age 18 or older and of at least the legal drinking age in the jurisdiction where such persons are accessing or attempting to access our Services. By using the Services, you confirm to us that you meet this requirement.

Furthermore, we do not market to, and do not knowingly collect any personal information from or about a child under the age of 13. If we discover that we have inadvertently collected personal information from a child under 13 years of age, we will promptly take all reasonable measures to delete that personal information from our systems.

Your rights

You have the right under certain circumstances:

- to be provided with a copy of your personal information held by us;
- to request the correction or erasure of your personal information held by us;
- to request that we restrict the processing of your personal information (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal information, including the right to object to marketing (as mentioned in 'Our promotional updates and communications' section;
- to request that your provided personal information be moved to a third party; and
- to withdraw consent. Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time.

You may exercise the rights listed above at any time by contacting us at privacy@spiritsnetwork.com . You may also be able to opt-out of certain additional tracking and targeted advertising. For more information on how to opt-out, please visit:

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, if you are in the EU, please see the European Commision Data Protection.

The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal information, as well as deal with any complaints that you have about our processing of your personal information.

If you request that we stop processing some or all of your personal information or you withdraw (where applicable) your consent for our use or disclosure of your personal information for purposes set out in this Privacy Policy, we may not be able to provide you all of the services and customer support offered to our users and authorized under this Privacy Policy or the Terms of Use, (which Terms of Use shall still continue to apply). Upon your request, we will close your account and remove your personal information from view as soon as reasonably possible, based on your account activity and in accordance with applicable laws.

California Residents

For residents of California (as required by California law), to obtain a list of any personal information Spirits Network has disclosed about you to third parties for direct marketing purposes during the preceding calendar year, please send a written request to Spirits Network by email using privacy@spiritsnetwork.com.

Canada Residents

You have choices about how we use your personal information to communicate with you, to send you marketing information, and whether you want to update or remove your personal information.
You can see, review, and change most of your personal information by signing in to your account. Please update your personal information immediately if it changes or is inaccurate.
We will honor any statutory right you have to access, modify, or erase your personal information. Please contact us by following the instructions above.
We will attempt to address your request within thirty (30) days.
Where you have a statutory right to request access or to request the modification or erasure of your personal information, we can still withhold that access or decline to modify or erase your personal information in some cases in accordance with applicable laws.
For further inquires or requested actions please send a written request to Spirits Network by email using privacy@spiritsnetwork.com

Changes To This policy

Any changes we make to our privacy policy in future will be posted on this page. This policy was last updated on November 27,2021

Spirits Network UK Limited a company registered in England and Wales
5 New Street Square London, UK EC4A 3TW
Registered Company Number: 13651599
VAT Registration Number: GB 396 7587 20

Spirits Network, LLC a limited liability company incorporated in Delaware, USA
235 Park Ave South, 4th Floor, New York, NY 10003

NBTV Channels, LLC a limited liability company incorporated in Delaware, USA DBA as Spirits Network UK Limited and Spirits Network, LLC USA
235 Park Ave South, 4th Floor, New York, NY 10003