Privacy policy

Manulele Distillers, LLC
PO Box 227
Kunia, Hawaii 96759 USA

PRIVACY POLICY

This privacy policy (the “Privacy Policy”) sets forth a commitment and description of practices related to personal data privacy and security of Manulele Distillers, LLC and its successors, parents, subsidiaries, affiliates and related companies or other companies under a common control that we may have now or in the future operate (the “Company,” “we,” “our,” or “us”). The singular term “Website” includes all websites and all devices or applications that collect personal information from you that we may have now or in the future operate that link to this Privacy Policy, web pages within each such website, device or application, any equivalent, mirror, replacement, substitute, or backup website, device, or application and web pages that are associated with each such website, device, or application. By accessing the Website and providing us with personal information, you agree to be bound by this Privacy Policy.

In addition to this Privacy Policy, we have established Terms and Conditions that set forth the general rules and policies governing your use of the Website. A copy of the Terms and Conditions can be found at http://kohanarum.com/terms_and_conditions.html.

The Company is committed to protecting your personal data. We provide this Privacy Policy to explain the type of information we collect on the Website and how that information is used.

Please note: The laws and regulations in different countries impose different (and even conflicting) requirements on the Internet and data protection. The servers that make the Website available worldwide are located in the USA. All matters relating to the Website are governed by the laws of the State of Hawaii, in the USA. Please note that any information you provide will be transferred to the USA, and by using the Website or providing us your personal information, you authorize this transfer.

I. INFORMATION WE COLLECT

Registration Information
When you register with the Website, you can elect to provide us with contact information, such as your name, physical and electronic address, phone number, and other similar contact details to receive information and updates on our products and services, as well as those of our subsidiaries, affiliates, and parent companies and any of their related businesses as well as those of our third-party partners. Such information will not be used for marketing and promotion of such products and services unless you request to receive such information. We use return email addresses to answer the email that we receive, and we may use return email to send you other information. Such addresses are not used for any other purpose.

Polling Answers
When visiting the Website, you may be asked questions, the answers to which are collected on an aggregate basis (i.e., the answers will not be stored in a manner that identifies them with you personally).

Contest and Sweepstakes
Registration may be required to be eligible to enter online contests or sweepstakes. The Company may use the information you provide when registering to manage your entry, fulfill prizes, which may include disclosure to third-party entities that assist with such fulfillment, and for other marketing and promotional purposes related to the contests or sweepstakes as disclosed on the rules applicable to a particular contest or sweepstakes.

IP Addresses
In addition to information that you provide us voluntarily, the Company may collect aggregate information in the form of IP addresses. An IP address is a number that is automatically assigned to your computer whenever you are surfing the Web. Web servers, the computers that “serve up” web pages, automatically identify your computer by its IP address. When you request a page from the Website, our servers log your IP address and certain other

information, such as browser type, internet service provider (ISP), referring/exit pages, operating system, data/time stamp, and clickstream data. We do not link this automatically-collected data to any data that is personally identifiable to you. Although your Website session may be logged, the automatically-collected data will not reveal to us any personally identifiable information about you.

Cookies and Other Tracking Devices
Cookies and other user tracking devices (e.g., locally stored objects) may be stored in your computer’s hard drive when you visit the Website. These tracking devices may also be used to help us speed up your future activities or to improve your experience by remembering the information that you have already provided to us. We do not use these devices to retrieve information from your computer that was not voluntarily provided by you. The use of these devices is an industry standard. Some of our business partners may also use these devices to provide us with anonymous data and information regarding the use of the Website. At your option, you may block or delete tracking devices from your hard drive. However, by disabling such tracking devices, you may not have access to the entire set of features of the Website. For information on how to disable and manage such tracking devices, visit http:// www.aboutads.info/consumers/.

II. HOW WE USE AND SHARE THE INFORMATION COLLECTED

We may use information collected from you in the following ways:
We may use 3rd-party audience data along with Google Analytics Demographics and Interest Based information, for example, to assess trends amongst our consumers or to measure the amount of traffic to the Website. We may also share non-personal information with others, such as non-Manulele Distillers companies that provide services to Manulele Distillers and certain other third parties, in aggregate, anonymous form, which means that the information will not contain any personally identifiable information about you.

We may arrange for selected organizations to send you marketing and promotional information that may be of interest to you if you have elected to receive such information. In such circumstances, your personal information may be disclosed to these organizations who will agree to be bound by the terms of this privacy statement. We will obtain your permission before we send you any such communications.

Information that you post on or through the public areas of the Website (e.g., chat rooms, bulletin boards, and discussion groups) are generally accessible to, and may be collected and used by, others and may result in unsolicited messages or other contact from others. Users of the Website are encouraged to exercise caution when providing personal information about themselves in public or interactive areas.

In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personally identifiable information that you provide and other information concerning your relationship with us.

We may transfer your personal information to third parties under confidentiality obligations for the performance of services provided to us or in connection with the administration and support of the activities noted above (e.g., the administration of a marketing campaign).

We may disclose your personal information if permitted by law or required to do so by law or where we believe such action is necessary in order to protect or defend our interests or the interests of our customers or users of the Website.

Our policies and procedures limit access to personal information to those with a business reason to know such information. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. However, due to the open communication nature of the Internet, we cannot represent, warrant, or guarantee that communications between you and us, or personal information stored on our servers, will be free from unauthorized access by third parties, loss, misuse, or alterations. THE COMPANY DISCLAIMS ANY AND ALL LIABILITY FOR UNAUTHORIZED ACCESS OR USE, OR COMPROMISE OF YOUR PERSONAL INFORMATION SUBMITTED THROUGH THE WEBSITE. USERS ARE HEREBY ADVISED THAT THEY SUBMIT SUCH PERSONAL INFORMATION AT THEIR OWN RISK.

III. WIRELESS MARKETING SERVICES

We may provide you with the opportunity to register for special promotions, services, news, programming and information delivered via text messaging and other wireless devices (e.g., SMS), such as mobile phones (the “Mobile Services”) and, in the event we do so, users are required to provide their consent to receive such information, either by registering on the Website or via their wireless device (or both). We may require you to consent again in a subsequent confirmation message. Such services and promotional opportunities may be provided by our third-party affiliates and service providers.

The information requested as part of the online registration process may include your wireless telephone number and your carrier’s name. Additional information may be requested for specific promotions, such as a user’s preferences regarding goods or services, choice of events, or other similar survey information. Depending on the promotion, we may also collect an email address or other contact information, and, depending on the information collected, you may also be required to confirm your agreement to this Privacy Policy and the Terms and Conditions.

We will only use information you provide in connection with the Mobile Services to transmit your text message(s) or as otherwise described in this Privacy Policy and the Terms and Conditions unless we provide advance notice of any other use. Nonetheless, we reserve the right at all times to disclose any information as necessary to satisfy any law, regulation or governmental request, to avoid liability, or to protect our rights or property.

IV. THIRD-PARTY SITES

The Website may contain links or references to other websites outside of our control. Please be aware that this Privacy Policy does not apply to these sites. Additionally, the Website may include functionality that allows integration with third-party sites, such as Twitter, Facebook, or other social networks. We may allow you to share information, rich media, and other content, including your information, with such third-party sites, and you may be permitted to export information concerning your use of the Website to such third- party sites. Some of those third-party services may provide us with your information to enhance and personalize your use of the Website. If you submit your credentials (e.g., username and password) for a third-party website or service during your registration for the Website or in connection with updating your user profile, we may receive your information from such third-party website or service. The Company encourages you to read the privacy statements and terms and conditions of linked or referenced sites you enter. These third-party websites may send their own cookies and other tracking devices to you, log your IP address, and otherwise collect data or solicit personal information. THE COMPANY DOES NOT CONTROL AND IS NOT RESPONSIBLE FOR WHAT THIRD PARTIES DO IN CONNECTION WITH THEIR WEBSITES, OR HOW THEY HANDLE YOUR PERSONAL INFORMATION. PLEASE EXERCISE CAUTION AND CONSULT THE PRIVACY POLICIES POSTED ON EACH THIRD-PARTY WEBSITE FOR FURTHER INFORMATION.

V. ACCESS TO, MODIFICATION OF, AND CORRECTION OF YOUR PERSONALLY IDENTIFIABLE INFORMATION

You may request that we provide you the information we hold about you, update your information, or ask us to remove your information, or to correct any inaccuracies in such personal data by sending an email to info@kohanarum.com. We will use reasonable efforts to deal with your request within a reasonable time.

VI. REFERRAL SERVICE

The Website may include a referral service that allows you to tell a friend about the Website or certain content on the Website by submitting your friend’s name and email address to us. We will automatically send your friend a one-time email inviting him or her to visit the Website. The Company stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. Your friend may contact us at info@kohanarum.com to request that we remove this information from our database.

VII. YOUR CALIFORNIA PRIVACY RIGHTS

Residents of the State of California have the right to request from certain businesses with whom the California resident has an established business relationship a list of all third parties to which the business, during the immediately preceding calendar year, has disclosed certain personally identifiable information for direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To obtain this information, you should send a request to info@kohanarum.com with the subject heading “California Privacy Rights.” In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California Privacy Rights requirements and only information on covered sharing will be included in our response.

VIII. REVISIONS TO OUR PRIVACY POLICY

We reserve the right to change the Privacy Policy at any time. Please review the contents of the Privacy Policy frequently, as the Company may amend them from time to time to reflect changes in its services and its policies relating to data privacy. Amendments will become effective when posted on the Website. The Company will not provide you with a notice of any change in the Privacy Policy. It is your responsibility to monitor and review any updates to the Privacy Policy. Your continued use of the Website, or online services provided by the Company, after such posting will be deemed your acceptance of these changes to the Privacy Policy.