Privacy Policy

1. Who We Are

This Privacy Policy describes how [LEGAL ENTITY NAME, S.A. de C.V.], doing business as Tequila Hacienda Vieja ("Hacienda Vieja," "we," "us," or "our"), collects, uses, discloses, and protects personal information when you visit www.tequilahaciendavieja.com, our social media pages, or any other website, store, email, or service that links to this Privacy Policy (the "Services").

We are located at Heliodoro Bravo 370, 47180 Arandas, Jalisco, Mexico. [Our products are imported into the United States by [IMPORTER NAME], [City, State].]

This Privacy Policy applies to visitors and customers who reside in the United States. Residents of Mexico, Canada, and other countries should consult the privacy notice for their jurisdiction, available [here].

2. Legal Drinking Age Only

Our Services promote alcoholic beverages and are intended only for adults of legal drinking age, which in the United States is 21 years old. By entering the Services, you confirm that you are at least 21 years of age.

We use an age-verification page that asks for your full date of birth. We do not knowingly allow anyone under 21 to access the Services, create an account, subscribe to our communications, enter promotions, or make a purchase.

3. Personal Information We Collect

In the past 12 months, we have collected the following categories of personal information:

We do not collect sensitive personal information, as defined by applicable law, except for account login credentials used solely to provide your account.

4. How We Use Personal Information

We use personal information to:

• Verify that visitors and customers are of legal drinking age.
• Operate, maintain, and improve the Services.
• Process orders, payments, shipping, returns, and customer service requests, through authorized retailers or distributors where required by law.
• Send marketing emails or text messages when you have opted in, and show you advertising about our products.
• Run promotions, sweepstakes, or events, subject to their official rules.
• Detect and prevent fraud, underage purchases, and security incidents.
• Comply with alcohol beverage, tax, and other legal requirements, and protect our legal rights.

5. Cookies, Analytics, and Targeted Advertising

We and our service providers use cookies, pixels, and similar technologies to remember your age verification and preferences, analyze traffic, and measure and deliver advertising. These may include [Google Analytics, Meta Pixel, Klaviyo].

Some of these technologies allow third parties to collect information about your activity on our Services to show you ads on other websites. Under certain state laws, this may be considered a "sale" or "sharing" of personal information or "targeted advertising." You can opt out as described in Section 9.

We direct our advertising only to audiences that are reasonably expected to be at least 21 years of age.

6. How We Disclose Personal Information

We disclose personal information to:

• Service providers that act on our behalf, such as website hosting and e-commerce platforms, payment processors, shipping carriers, email and SMS platforms, analytics providers, and customer service tools.
• Authorized importers, distributors, and retailers in the United States, when needed to fulfill an order or a request in compliance with alcohol beverage laws.
• Advertising and marketing partners, to measure and deliver ads. This may be a "sale" or "sharing" under certain state laws.
• Government authorities and other parties, when required by law, subpoena, or court order, or to protect our rights, our customers, or the public
• A successor entity, in connection with a merger, acquisition, or sale of assets.

We do not sell personal information for money. We do not knowingly sell or share the personal information of anyone under 16 years of age.

7. Data Retention and Security

We keep personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy. Typically:

• Account information: until you close your account, plus [2] years.
• Order and transaction records: [5] years, to meet tax and accounting obligations.
• Marketing information: until you unsubscribe or [24] months after your last interaction.
• Age-verification cookies: [30] days

We use reasonable administrative, technical, and physical safeguards to protect personal information. No method of transmission or storage is completely secure.

8. Persons Under 21

The Services are not directed to, and we do not knowingly collect personal information from, anyone under 21 years of age. This includes children under 13, as protected by the Children's Online Privacy Protection Act (COPPA).

If we learn that we have collected personal information from someone under 21, we will delete it promptly. Parents or guardians who believe we have such information should contact us at the address in Section 12.

9. Your U.S. State Privacy Rights

Depending on your state of residence (including California, Colorado, Connecticut, Virginia, Texas, Oregon, and other states with comprehensive privacy laws), you may have the right to:

• Know and access the personal information we have collected about you, and receive a portable copy.
• Correct inaccurate personal information.
• Delete personal information we have collected from you, subject to legal exceptions.
• Opt out of the sale or sharing of personal information and of targeted advertising.
• Limit the use of sensitive personal information, where applicable. We do not use sensitive personal information for purposes that require this right.
• Not be discriminated against for exercising any of these rights.

How to submit a request. Use our Do Not Sell or Share My Personal Information page, email us at [privacy@tequilahaciendavieja.com], or call +52 33 1297 8540. We will verify your identity before acting on access, correction, or deletion requests. We will respond within 45 days, or as otherwise required by law.

Authorized agents. You may use an authorized agent to submit a request on your behalf. We may ask for proof of authorization and may ask you to verify your identity directly with us

Global Privacy Control. We treat a Global Privacy Control (GPC) signal from your browser as a valid request to opt out of the sale or sharing of your personal information for that browser or device

Appeals. If we deny your request, you may appeal by replying to our decision or emailing [privacy@tequilahaciendavieja.com] with the subject line "Privacy Appeal." If your appeal is denied, you may contact your state Attorney General.

10. Additional Information for California Residents

This section supplements this Privacy Policy under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA), and the California Online Privacy Protection Act (CalOPPA).

• The categories of personal information we collect, their sources, purposes, and recipients are described in Sections 3 through 6.
• In the past 12 months, we may have "sold" or "shared" identifiers, internet and device information, commercial information, and inferences with advertising partners, for cross-context behavioral advertising.
• Do Not Track. Apart from the GPC signal, we do not respond to browser "Do Not Track" signals.
• Shine the Light. California residents may request information about our disclosures of personal information to third parties for their direct marketing purposes by contacting us as described below.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version on this page and change the "Last Updated" date. If changes are material, we will provide additional notice as required by law.

12. Contact Us

[LEGAL ENTITY NAME, S.A. de C.V.] — Tequila Hacienda Vieja Heliodoro Bravo 370, 47180 Arandas, Jalisco, Mexico Email: [privacy@tequilahaciendavieja.com] Phone: +52 33 1297 8540