To access thedifferencebourbon.com (the “Website”) you must be of legal drinking age in the country where you reside. Please exit the Website immediately if you are not of a legal age for consuming alcoholic beverages in the country or territory in which you reside, or are in a country or territory where the access to the Website is not permitted. PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND YOUR CHOICES AND RIGHTS.  IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE WEBSITE. THE WEBSITE IS INTENDED FOR USERS LOCATED IN THE UNITED STATES. IT IS NOT INTENDED FOR USERS LOCATED IN OTHER COUNTRIES, INCLUDING THE EUROPEAN UNION AND THE EUROPEAN ECONOMIC AREA.

Introduction

The Difference™ Bourbon, (also referred to herein as “we,” “us,” and “our”) is committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business.  We also believe in transparency, and we are committed to informing you about how we treat the data we collect and process. When does this Policy apply?  This Privacy Policy (the “Policy”) describes our practices regarding the collection of personal information when you visit the The Difference™ Bourbon website (the “Website”). It does not apply to information collected from other sources.

What Information Do We Collect?

We collect the following information for the purposes described in the “How Do We Use and Share Your Information?” section of this Policy.

Category	Description
Contact Information	Depending on how you interact with us via the Website, we may collect your name, email address, and phone number.  We may also collect information about your communication preferences, including whether you would like to receive text messages and/or emails from us.
User Account Registration	We may disclose your information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
Automated Information	We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy.  We will only disclose your information in this context with your consent.
Your Communications	We may disclose information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws.  We may also share information in order to establish or exercise our legal rights or claims; to defend against a legal claim; and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our contracts.
Location Information	We may provide information about you to third parties that may offer products and services specifically requested by you.
Cookies and Similar Technologies	We may share information with our service providers that need access to information to provide operational or other support services on our behalf.  Among other things, service providers help us to administer the Website; support our provision of services requested by you; provide technical support; support our provision of promotions, sweepstakes, or contests, send communications to you; provide payment processing; and assist with other legitimate purposes permitted by law.
Contact Us	We may share your information with our insurers and other professional advisors, including attorneys and accountants, that need access to your information to provide operational or other support services on our behalf.

Cookies and Similar Technologies

First and Third-Party Cookies

A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” or “permanent” cookie). “Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain stored on your hard drive until they expire or are deleted by you. Local stored objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you’re visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.

Other Similar Technologies

In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as users navigate through and interact with a website:

• Web beacons: These are tiny graphics (sometimes called “clear GIFs” or “web pixels”) with unique identifiers that are used to understand browsing activity. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are rendered invisible on web pages when you open a page.
• Social Widgets: These are buttons or icons provided by third-party social media platforms that allow you to interact with social media services when you view a webpage or mobile app screen. These social widgets may collect browsing data, which may be received by the third party that provided the widget and are controlled by third parties.
• UTM Codes: These are strings that can appear in a URL (the “Uniform Resource Locator,” which is typically the https or https address entered to go to a webpage) when you move from one web page or website to another. The string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.

What Cookies and Similar Technologies Are in Use and Why Do We Use Them?

Google Marketing. We use Google’s marketing technologies, including DoubleClick, to track user activity on the Site and to serve personalized advertisements. Your browser is assigned a pseudonymous ID to track the ads that have been served to your browser and to identify those on which you’ve clicked. The cookies enable Google and its partners to select and display ads based on your browsing behavior. For more information on how Google uses this information, you can visit https://policies.google.com/technologies/ads, https://support.google.com/displayvideo/answer/7621162, and https://support.google.com/google-ads/answer/7548399?hl=en. To block certain ads served by Google, please visit https://support.google.com/ads/answer/2662922. Google’s Privacy Policy is available at: https://www.google.com/policies/privacy. Google Analytics. We use Google Analytics to collect and process statistical data about the number of people using the Site and to better understand how they find and use the Site. The data collected includes data related to your device/browser, your IP address, and on-site activities to measure and report statistics about user interactions on the Site. Any data collected is used in accordance with this Policy and Google’s privacy policy. You may learn more about Google Analytics by visiting https://www.google.com/policies/privacy/partners/ and https://support.google.com/analytics/answer/6004245. You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy at: https://www.google.com/policies/privacy. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the “Google Analytics opt-out browser add-on” page (located at https://support.google.com/analytics/answer/181881?hl=en).

Other Third-Party Technologies

Some third parties may use automated data collection technologies to collect information about you when you browse the Internet. The information they collect about your online browsing activities over time and across different websites and other online services may be associated with your personal information and used to provide you with targeted content. We do not control these third parties’ technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible party directly or consult their privacy policies.

Choices About Cookies

Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising. You may adjust your browser settings to opt out of accepting a “persistent” cookie and to only accept “session” cookies, but you will need to log in each time you want to enjoy the full functionality of the Site. Please be aware that, if you decline the use of cookies, you may not have access to the full benefits of the Site. In addition, adjusting the cookie settings on the Site may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your cookie settings on the Site. Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browsers: Google Chrome: https://support.google.com/chrome/answer/95647?hl=en Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences Internet Explorer: https://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac and https://support.apple.com/en-us/HT201265 To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website at: https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html. For more information on how to modify your browser settings to block or filter cookies, visit https://www.aboutcookies.org/ or https://www.cookiecentral.com/faq/. You may learn more about internet advertising practices and related consumer resources at https://www.aboutads.info/consumers/, https://www.networkadvertising.org/choices, and https://youronlinechoices.eu/.  

How Do We Use and Share Your Information?

How do we use the information described in this Policy? 

To the extent permitted by applicable law, we may use the information described above in order to:

• Operate and improve our business, services, and the Website;
• Provide you with services, products, content, customer service, and functionality;
• Honor our Terms of Use and contracts;
• Manage our relationship with you;
• Process and complete transactions;
• Improve our products and services and develop new products and services;
• Communicate with you and respond to your feedback, requests, questions, or inquiries;
• Maintain, manage, and improve our relationships with you;
• Ensure the privacy and security of our Website and our services;
• Detect fraud and prevent loss;
• Support and improve the Website, including evaluations of functionality and features;
• Improve our customer service;
• Maintain our databases and back-ups, including records of our communications with you;
• Promote our products and services;
• Contact you about other products and services;
• Analyze use of the Website and our services and prepare aggregate traffic information;
• Accomplish any other purpose related to and/or ancillary to any of the purposes and uses described in this Policy for which your information was provided to us;
• Accomplish another purpose described to you when you provide the information, for which you have consented, or for which we have a legal basis under law;
• Comply with federal, state, or local laws;
• Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, order, or summons by federal, state, or local authorities;
• Cooperate with law enforcement agencies;
• Exercise or defend legal rights or claims;
• Create, use, retain, or disclose de-identified or aggregated data; and
• Any other purpose with your consent.

 

How do we disclose or share the information described in this Policy? 

Where permitted by applicable law, we may share the information described above in the following contexts:

Category	Description
Affiliates	We may share your information with our subsidiaries and affiliates and with their respective officers, directors, employees, accountants, attorneys and agents.
Acquisitions and Similar Transactions	We may disclose your information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
Disclosures with Your Consent	We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy.  We will only disclose your information in this context with your consent.
Legal Obligations and Rights (Subpoenas, Court Orders, and Warrants)	We may disclose information in response to subpoenas, warrants, court orders or other legal processes, or to comply with relevant laws.  We may also share information in order to establish or exercise our legal rights or claims; to defend against a legal claim; and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our contracts.
Third Parties	We may provide information about you to third parties that may offer products and services specifically requested by you.
Service Providers	We may share information with our service providers that need access to information to provide operational or other support services on our behalf.  Among other things, service providers help us to administer the Website; support our provision of services requested by you; provide technical support; support our provision of promotions, sweepstakes, or contests, send communications to you; provide payment processing; and assist with other legitimate purposes permitted by law.
Professional Advisors	We may share your information with our insurers and other professional advisors, including attorneys and accountants, that need access to your information to provide operational or other support services on our behalf.
Deidentified or Aggregated Data	We may disclose aggregated information or de-identified information about our users that does not identify any specific individual, such as groupings of demographic data or customer preferences to potential advertisers, partners, affiliates, and other third parties.

How Long Do We Store Your Information?

We retain and use your information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services, and to enforce our agreements. We may delete your information if we believe it is incomplete, inaccurate, or that our continued storage of it is contrary to our objectives or legal obligations. When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it. To the extent permitted by law, we may retain and use anonymous, de-identified, or aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement.  

How Do We Protect Your Information?

We have put security measures in place to protect the personal information that you share with us from being accidentally lost, used, altered, disclosed, or accessed in an unauthorized manner. From time to time, we review our security procedures to consider appropriate new technologies and methods. While our security measures seek to protect the personal information in our possession, no security system is perfect, and no data transmission is 100% secure. As a result, while we strive to protect your information, we cannot guarantee or warrant the security of any information transmitted to or from the Website.  Your use of the Website is at your own risk.  We cannot guarantee that your data will remain secure in all circumstances. The safety and security of your personal information also depends on you.  Where you use a password to access parts of the Website, you are responsible for keeping the username and password confidential.  Do not share your username and/or password with anyone. If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.  

Your Rights and Choices Regarding Personal Information

Please use the “Contact Us” details provided at the end of this Policy to exercise your rights and choices under this Policy. We honor such requests when we are required to do so under applicable law. Accuracy and Updating Your Information. Our goal is to keep your information accurate, current, and complete. If any of the information you have provided to us changes, please let us know via the “Contact Us” details at the end of this Policy.  For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information.  If you have created a user account for the Website, you may access, review, and make changes to your registration information by following the instructions on the Website. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal information that you provide to us. Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy. Cookies.  You may be able to set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.  If you disable or refuse cookies, please note that some parts of the website may then be inaccessible or not function properly. California Shine the Light. Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response.  As part of the California Online Privacy Protection Act, all users of our App may make any changes to their information at any time by contacting us at [email protected] Nevada Residents. You may submit a verified request to us at [email protected] to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request. We will respond to your request in accordance with Nevada law.  

Third-Party Sites and Services

This Policy only applies to the Website, and it does not apply to any third-party websites or applications. The Website may contain links to, and media or other content from, third parties.  These links are to external websites and third parties that have their own privacy policies and with which we may have no relationship.  Because of the dynamic media capabilities of the Internet, it may not be clear to you which links are to external, third-party websites.  If you click on an embedded third-party link, you will be redirected away from the Website to the external third-party website.  You can check the URL to confirm that you have left the Website. We cannot and do not (1) guarantee the adequacy of the privacy or security practices employed by or the content and media provided by any third parties or their websites, (2) control third parties’ independent collection or use or your information, or (3) endorse any third-party information, products, services or websites that may be reached through embedded links on the Website. Some third parties may use automated data collection technologies to collect information about you when you browse the Internet. The information they collect about your online browsing activities over time and across different websites and other online services may be associated with your personal information and used to provide you with targeted content. We do not control these third parties’ technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible party directly or consult their privacy policies. Any information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use.  If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website. Your use of Google Pay or Apple Pay is subject to the terms and conditions, including the privacy policies, of Google and Apple, respectively.  

Children’s Online Privacy Protection Act

The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet.  Our Website and services are not directed to children under 18, nor is information knowingly collected from children under the age of 18.  No one under the age of 18 may access, browse, or use the Website or provide any information to or on the Website.  If you are under 18, please do not use or provide any information on the Website (including, for example, your name, telephone number, email address, or username).  If we learn that we have collected or received personal information from a child under the age of 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 18, please contact us via the “Contact Us” details provided at the end of this Policy. For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.  

Updates and Changes to This Policy

We reserve the right, at any time and without notice, to add to, change, update, or modify this Policy to reflect any changes to how we treat your information or in response to changes in law. Should this Policy change, we will post all changes to this Policy on this page. Any such changes, updates, or modifications will be effective immediately upon posting on the Website. The date on which this Policy was last modified is identified at the beginning of this Policy. You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Website, and from time to time, so that you are aware of any changes. Your continued use of the Website after the “Last Updated” date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your information according to the terms of the then-current Policy.  If you do not agree with this Policy and our practices, you should not use the Website.  

Contact Us

For more information, if you have any questions or concerns regarding this Policy, or if you want to opt-out from receiving future promotional correspondence from us, correspondence from our affiliated companies, and withdraw your consent to sharing your personally identifiable information with others, you may contact us using the information below.  In Writing: 3415 W. Lake Mary Blvd., Box 950370, Lake Mary, FL 32746 By Email: [email protected]