TRIALTO WINE GROUP LTD

PRIVACY STATEMENT (OCTOBER 2019)

1.WHAT KIND OF INFORMATION DO WE COLLECT FROM YOU WHEN YOU VISIT OUR SITE(s)?

When you visit either www.trialto.com or www.trialtorewards.ca, our stats package from Google collects some basic information about your browser. Examples are things like what type of browser and operating system are you using; how long did you stay on our site; what pages did you look at. This helps us understand how visitors browse our site so that we can make their experience better.

When you join our Rewards Club or sign up for our Newsletter, we also collect personal information about you such as your name, address, postal code, phone number or any other information that you agree to share with us. In general, we collect only the personal information that we reasonably require for the purposes of serving our members.

2.We do not share your information

Under no circumstances will we share any information that we collect with any third parties or web sites except as follows. We may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf. Some of our operations, such as advertising and promotions, may be managed and run by our Canadian and US service providers (“Service Providers”). As a result, your personal information may be collected, used, processed, stored or disclosed in the United States and that may potentially be accessible to law enforcement and national security authorities of that jurisdiction. These Service Providers may have access to your personal information on a confidential basis to the extent necessary to perform their functions. In no event will these companies have the right to use your personal information for any reason other than to provide you or us with those specific services, except as may be permitted by law. Information provided by you will be used by TRIALTO WINE GROUP LTD. and its Service Providers to learn about the experiences of our customers so that we may enhance our programs and improve our level of service. All the information you give us is completely private and used solely for our Rewards Club or Newsletter purposes. If you give us permission to send you marketing emails, then we use your email for that purpose, but never does that email get sold or distributed to any other web site or list.

3.SAFEGUARDING PERSONAL INFORMATION

We protect customer personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information. For example, we use up-to-date technological protections such as firewalls and passwords

We retain customer personal information only as long as is reasonable to fulfill the purposes for which the information was collected or for legal or business purposes.

We render customer personal information non-identifying, or destroy records containing personal information once the information is no longer needed. We use appropriate security measures when destroying customer personal information, including shredding paper records and permanently deleting electronic records.

4.IP ADDRESSES, COOKIES, THIRD PARTY LINKS

In general, you can visit our Trialto Wine Group websites without telling us who you are or providing us with any information. However, we may collect the IP (Internet protocol) addresses of all users of our Apps or visitors to our Sites and other related information such as page requests, browser type, operating system and average time spent on our Apps or Sites. We use this information to monitor and improve our Apps and Sites.

Trialto Wine Group Ltd. and our Service Providers use various technologies to collect and store information when you visit our Sites or use one of our Apps or services. This may include sending one or more cookies, java scripts, web beacons or anonymous identifiers to your device (“cookies”). A cookie is a small text file that our Sites can place on your computer’s hard drive. Using cookies, we may collect information about your computer, including your IP address, operating system and browser type, for system administration and in order to create reports. We may also collect information on your use of our Sites such as the time that the current visit occurred, whether the visitor has been to the site before, what site referred the visitor to the web page and your usage patterns on our Sites including the time you spend on our Sites and which parts of our Sites you are visiting. This is statistical data about our users’ browsing actions and patterns. We do not collect personally identifiable information about you, including your name, address, phone number or email address using cookies. To the extent that you provide us with personally identifiable information, whether by creating a user account on our Sites or through our Apps, this data is kept separate from and not merged with the data automatically collected by cookies.

We do not knowingly collect personal information from minors under the age of 18. If you believe we have inadvertently collected such information, please contact us immediately so we can obtain parental consent or remove the information.

Trialto Wine Group Ltd. provides links to third party websites as a convenience to the user. The inclusion of any link does not imply Trialto’s’ endorsement of any other company, its websites, or its products and/or services. These linked websites have separate and independent privacy policies, which we recommend that you read carefully. We have no control over such websites and therefore have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose and otherwise treat your personal information.

5.OPT-OUT.

If you have chosen to opt into our Rewards Club or Newsletter or to receive any marketing emails and decide to opt out, we have a simple unsubscribe form that will let you get off our email list. Also, under the member area, you will find a simple form to unsubscribe.

6.CONSUMER INQUIRIES AND PRIVACY.

If you have any questions about your privacy, or want to make changes to your profile, or get off our marketing list, simply send us an email to support@trialtorewards.ca