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This Privacy Policy (“Policy”) describes how ASHOC Beverage, LLC d/b/a Accelerator Active Energy., its parent, affiliates, and subsidiaries (“Company”, “Accelerator”, “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes personal information described in this Policy, as well as the rights and choices individuals have regarding such personal information.

By using our Services (as defined below), you acknowledge that your personal information will be handled as described in this Policy. Your use of our Services and any dispute over privacy are subject to this Policy and our Terms of Use, available at https://drinkaccelerator.com, including their applicable terms governing limitations on damages and the resolution of disputes.

Except as otherwise noted below, this Policy applies to personal information of individuals whose personal information we collect both offline and online, including our vendor personnel, our ambassadors, users of our websites where this Policy is posted, including at drinkaccelerator.com, and any other websites we operate that display or include a link to this Policy (collectively, the “Services”).

Additional Notices. Depending on how you interact or engage with us, we may provide other privacy notices with additional details about our privacy practices. For example, this Policy does not apply to job applicants and candidates who apply for employment with us, or to employees in the context of our working relationship with them.

2. PERSONAL INFORMATION COLLECTED

We collect personal information directly from you, automatically through your use of the Services, and from third-party sources. To the extent permitted by applicable law, we may combine the information we collect from publicly available or third-party sources.

Personal Information Collected Directly. While the personal information we collect varies depending on how you interact with us, in general we may collect the following personal information directly from you:

  • Orders. When you order products using our Services we may collect your name, email address, physical address, phone number, payment details, and specific order details.

  • Ambassador/College Program. If you participate in our ambassador/college program, we may collect your name, email address, work or personal physical address, your photo, your clothing size(s), and videos or voice recordings you choose to provide us.

  • Interactions with Company. When you email, call, or otherwise communicate with us and with members of our team (including on social media), we may collect and maintain a record of your contact details, communications, and our responses. We may also maintain records communications and information that you post in chat sessions, forums, and in other areas of the Services, well as on our social media channels, and information you provide to us related to any customer support requests.

  • Surveys. If you respond to a survey, we may collect your name, email address, and your answers to the survey questions.

  • Sweepstakes/Competitions. If you participate in sweepstakes, competitions, or other promotional campaigns we host, we may collect your name, email address, physical address, phone number, social media username, and any other information you choose to provide in your entry.

  • Social Media. If you interact with us via social media, we may receive your social media username, contact information, and information contained in any messages you send us via the social media platform.

  • Events and other requests. We also collect personal information related to your participation in our events as well as other requests that you submit to us related to our Services. For example, if you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event. We may also collect information about your dietary restrictions if you attend our events, which may reveal health or religious information.

  • Business Information. To conduct our business, and assess and pursue potential business opportunities, we may collect and receive personal information about current, former, and prospective vendors, business partners, and agents, including name, company information, contact details, and communications records.

    Personal Information from Third Parties. We may collect personal information about you from third party sources, such as public databases, joint marketing partners, social media platforms or other third parties.

  • We may receive lead and prospect information from third parties about prospective customers that may be interested in our Services. We may also engage with third parties to enhance or update our customer information.

  • If you post information about us or engage with us on third party platforms, such as social media platforms, we may collect personal information about you from that third party platform. These third-party platforms and services control the information they collect and share about you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.

    Personal Information Collected Automatically. We may automatically collect personal information related to your use of our Services and interactions with us and others, including information we collect automatically (e.g., using cookies and pixel tags), as well as information we derive about you and your use of the Services. Such information includes:

  • Device and browsing information. We may use cookies, log files, pixel tags and other tracking technologies to automatically collect information when users access or use our Services, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information.

  • Activities and usage. We may also collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, time spent within the Services, files uploaded, and products and items you view.

  • Location information. We may collect or derive location information about you, such as through our store locator function or via your IP address. Further, with your permission, we may collect geolocation information from your device. You may turn off location data sharing through your device settings.

3. HOW WE MAY USE PERSONAL INFORMATION

  • Generally, we collect, use, disclose and otherwise process personal information for the following purposes:

  • Services and support. To provide and operate our Services, communicate with you about your orders and use of the Services, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you about the Services, and for similar service and support purposes.

  • Analytics and improvement. To better understand how users access and use the Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop services and features, and for internal quality control and training purposes.

  • Ambassador Program. To support your role as a Company ambassador. For example, to send you products, merchandise, and other promotional or marketing materials for you to use.

  • Investors. To provide you with press releases, product information, or other information requested about the company.

  • Marketing and advertising. For marketing and advertising purposes. For example, to send you information about our products, such as offers, promotions, newsletters, and other marketing content, as well as any other information that you sign up to receive. We also may use certain information we collect to manage and improve our advertising campaigns so that we can better reach people with relevant content.

  • Planning and managing events. For event planning and management, including registration, attendance, connecting you with other event attendees, and contacting you about relevant events and Services.

  • Research and surveys. To administer surveys and questionnaires, such as for market research or member satisfaction purposes.

  • Sweepstakes/competitions. To administer sweepstakes, competitions, and other promotional campaigns, including selecting winners and issuing prizes.

  • Security and protection of rights. To protect the Services and our business operations; to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party.

  • Compliance and legal process. To comply with the law and our legal obligations, to respond to legal process and related to legal proceedings.

  • General business and operational support. To consider and implement business transactions such as financings, and related to the administration of our general business, accounting, auditing, compliance, record keeping, and legal functions.

4. DISCLOSURES OF PERSONAL INFORMATION

    • We may disclose the personal information we collect for the purposes described above and as follows:

    • Vendors and service providers. We may disclose personal information we collect to our service providers, processors, and others who perform functions on our behalf. These may include, for example, event management agencies, catering suppliers, shippers and distributors, IT service providers, analytics providers, consultants, auditors, and legal counsel.

    • Our affiliates. We may disclose personal information we collect to our affiliates or subsidiaries who will use and disclose this personal information in accordance with this Policy.

    • Third party platforms, providers, and networks. We may disclose or make available personal information to third party platforms and providers that we use to provide or make available certain features or portions of the Services, or as necessary to respond to your requests. We may also make available certain personal information to third parties in support of our marketing, analytics, advertising, and campaign management.

    • At your request. We may disclose information to others when requested, explicitly or implicitly, by a customer.

    • In support of business transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. We may also share certain personal information as necessary prior to the completion of such a transaction or corporate transactions such as financings or restructurings, to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for a transaction.

    • Compliance and legal obligations. We may also disclose personal information to third parties to comply with our legal and compliance obligations and to respond to legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. This may include regulators, government entities, and law enforcement as required by law or legal process. In addition, it may include certain disclosures that we are required to make under applicable laws, such as the names of sweepstakes and contest winners.

    • Security and protection of rights. We may disclose personal information where we believe doing so is necessary to protect the Services, our rights and property, or the rights and safety of others. For example, we may disclose personal information in order to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety or legal rights of any person or third party,[ or (iii) enforce, and detect, investigate and take action in response to violations of, our Terms of Service. We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.

    • Aggregate and Deidentified Information. Notwithstanding anything else in this Policy, we may use, disclose, and otherwise process aggregate and deidentified information related to our business and the Services with third parties for quality control, analytics, research, development, and other purposes.

    • Other Disclosures. We may disclose personal information in other ways not described above, but when required will notify you by updating this Policy, and, if necessary, obtain your consent.

    5. COOKIES AND OTHER TRACKING MECHANISMS

    We and our third-party service providers may use cookies, pixels, local storage objects, log files, APIs, and other mechanisms to automatically collect information browsing, activity, device and similar information within our Services and to target advertising and content. We use this information to, for example, analyze and understand how users access, use and interact with others through our Services, as well to identify and resolve bugs and errors in our Services and to assess secure, protect, optimize and improve the performance of our Services. You have certain choices about our use of cookies and tracking within the Services, as described in this section.

    Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within Service.

    Pixel tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, help us manage content and compile usage statistics. We may also use these in HTML e-mails we send, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

    Local storage objects. Local storage is a web storage mechanism that allows us to store data on a browser that persists even after the browser window is closed. Local storage may be used by our web servers to cache certain information in order enable faster loading of pages and content when you return to our websites. You can clear data stored in local storage through your browser. Please consult your browser help menu for more information.

    Third-Party Analytics and Tools. We may use third party tools, such as Google Analytics, which are operated by third party companies. These third-party analytics companies may collect usage data (using cookies, pixels and similar tools) about our Services in order to provide us with reports and metrics that help us to evaluate usage of our Services and improve performance and user experiences. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at.

    Cross-device Tracking. We and our third-party providers may use the information that we collect about you within our Services and on other third-party sites and services to help us and these third parties to identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.).

    Third-Party Advertising. We may work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“third-party ad companies”) to personalize content and display advertising within our Services, as well as to manage our advertising on third-party sites, mobile apps and online services. We may share certain information with these third-party ad companies, and we and them may use cookies, pixels tags, and other tools to collect usage and browsing information within our Services, as well as on third-party sites, apps, and services, such as IP address, location information, device ID, cookie and advertising IDs, and other identifiers, as well as browsing information. We and these third-party ad companies can use this information to provide you more relevant ads and content within our Services and on third-party sites and apps, and to evaluate the success of such ads and content.

    Custom Lists and Matching. We may share or make available certain customer list information (such as your name, email address and other contact information) with third parties (i) so that we can better target ads and content to you across third party sites, platforms and services, and (ii) in some cases, these third parties may help us to enhance our customer lists with additional demographic or other information, so we can better target our advertising and marketing campaigns.

    6. YOUR PRIVACY CHOICES

    We may make available several ways that you can manage your privacy choices and submit privacy requests related to your personal information. These include:

    • Cookie Settings. To prevent cookies from tracking your activity on our Site or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The "Help" portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Site who disable cookies will be able to browse the Site, but some features may not function.

    • Industry Ad Choice Programs. You can also control how participating third- party ad companies use the information that they collect about your visits to our Site, and those of third parties, in order to display more relevant targeted advertising to you. When you are in the U.S., you can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at aboutads.info/choices (Digital Advertising Alliance). Opting out of participating third party ad networks does not opt you out of being served advertising. You may continue to receive generic or "contextual" ads on our Site. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.

    • Marketing Communications. You can opt out of receiving marketing emails from us by using the unsubscribe feature in any such email we send you. You can also log in to your account and change your marketing/communications preferences.

    For more information about our privacy practices and your privacy choices, you may contact us at drinkaccelerator.com.

    7. CHILDREN/MINORS

    Our Services are not designed for children, and we do not knowingly collect personal information from children under the age of 18. If you are a parent or legal guardian and you believe we have collected your child’s information in violation of applicable law, please contact us at drinkaccelerator.com.

    8. SECURITY

    We have implemented safeguards that are intended to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

    9. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

    This section of the Policy provides additional information for California residents and describes our information practices pursuant to the California Consumer Privacy Act 2018, as amended by the California Privacy Rights Act 2020 and any subsequent amendments, and its implementing regulations (the “CCPA”). Depending on how you interact or engage with us, we may provide you with other privacy notices with additional details about our privacy practices.

    This section applies to “personal information” as defined in the CCPA, whether collected online or offline. This section does not address or apply to our handling of personal information that is exempt under the CCPA. Company is committed to maintaining and using deidentified information in compliance with the CCPA.

    Personal Information We Collect. Depending on how you use the Services, we may collect (and may have collected in the prior 12 months) the following categories of personal information:

    • Identifiers. Such as name, alias, email, phone number, billing and shipping address, unique personal identifier, online identifier, IP address, account name, or other similar identifiers.

    • Customer Records. Such as your account information and customer records that contain personal information, such as name, account name, other characteristics or descriptions, email, address, phone number, and other contact information, communications preferences, billing and payment information, customer service and support tickets and records, and other information you provide in order to use our Services.

    • Commercial Information. Such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

    • Internet or Other Electronic Network Activity Information. Such as browsing history, clickstream data, search history, and information regarding interactions with our Site, mobile application, advertisements, or emails, including other usage data related to your use of any of our Services or other online services.

    • Geolocation Data. Such as location information about a particular individual or device.

    • Audio, Electronic, Visual, or Similar Information. Such as information collected via call recordings if you are interacting with us in a customer service capacity or if you call us on a recorded line, recorded meetings and webinars, videos, photographs, user profile images, and security camera footage to secure our offices and premises.

    • Inferences. Such as inferences drawn from any of the information described in this section about a consumer including inferences reflecting the consumer’s preferences, characteristics, behaviors, attitudes, abilities, and aptitudes.

    • Sensitive Personal Information. In limited circumstances, we may collect health information (dietary requirements in connection with your attendance at an event) or religious information (based on your dietary requirements).

    Sources of Personal Information. We generally collect personal information from the following categories of sources:

    • Directly or indirectly from you;
    • Our affiliates and subsidiaries;
    • Our business partners;
    • Social networks;
    • Operating systems and platforms; and
    • Our vendors and service providers.

    Purposes for Collecting and Disclosing Personal Information. As described in the “How We May Use Personal Information” section above, in general, we collect and otherwise process the personal information we collect for the following business or commercial purposes:

    • Services and support;
    • Analytics and improvement;
    • Ambassador/college program;
    • Marketing and advertising;
    • Planning and managing events;
    • Research and surveys;
    • Sweepstakes/competitions;
    • Security and protection of rights;
    • Compliance and legal process; and

    • General business and operational support.

    Sensitive Personal Information. Notwithstanding the purposes described above, we do not collect, use, or disclose “sensitive personal information” beyond the purposes authorized by the CCPA.

    Retention of Personal Information. We retain your personal information for as long as needed or permitted, based on the reason we obtained it (consistent with applicable law). When deciding how long to keep your personal information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period before we can delete them) or whether we have taken any legal positions (e.g., issued any legal holds or otherwise need to preserve the information). Rather than delete your data, we may also deidentify it by removing identifying details. Where we have committed to maintaining and using personal information in a deidentified form, we agree not to reidentify deidentified data except as permitted by applicable law.

      Disclosure of Personal Information to Third Parties and Other Recipients. The categories of personal information we have disclosed for a business purpose in the preceding 12 months may include: identifiers, customer records, Internet or other electronic network activity information, geolocation data, audio, video, and other electronic data, inferences. The categories of third parties and other recipients to whom we may disclose personal information for a business purpose may include: affiliates, subsidiaries, and business partners, vendors and service providers, acquirers of business assets, advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, and social networks.

      Sales and Sharing of Personal Information. The CCPA defines "sale" as disclosing or making available personal information to a third-party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third-party for purposes of cross-contextual behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” the following categories of personal information due to our use of advertising and analytics tools on our websites: identifiers, and Internet or other electronic network activity information. We may disclose these categories to third-party advertising networks, analytics providers, and social networks for purposes of marketing and advertising. We do not sell or share personal information about individuals we know are under the age of 18.

      Your CCPA Rights. The CCPA provides California residents with certain rights regarding their personal information. In general, California residents, including our business customers’ and vendors’ employees, agents or representatives who reside in California, have the following rights with respect to their personal information, subject to certain exceptions:

      1.  Right to Know/Access. With respect to the personal information we have collected about you, you have the right to request:
        • The categories or personal information we collected about you;

        • The categories of sources from which the personal information is

        • collected;

        • Our business or commercial purposes for collecting, selling, or sharing

        • personal information;

        • The categories of third parties to whom we have disclosed personal

        • information; and
        • A copy of the specific pieces of personal information we have collected about you.

       

        1. Right to Correct. You have the right to request that we correct inaccurate personal information.

        2. Right to Delete. You have the right to request we delete your personal information.

        3. Right to Opt-Out of Sales and Sharing. You have the right to opt-out of “sales” and “sharing” of your personal information, and to opt-out of the use of your personal information for “targeted advertising” as those terms are defined under the CCPA. To exercise these rights, please use the Do Not Sell or Share My Personal Information/Your Privacy Choices link at the bottom of our website.

          You also have the right to opt-out of “sales” and “sharing” of your personal information using an opt-out preference signal. If our site detects that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control”—or GPC— signal, we will opt that browser or device out of the use of cookies or other tools on our site that result in a “sale” or “sharing” of your personal information. If you come to our site from a different device or from a different browser on the same device, or if you clear your cookies, you will need to opt-out again, or use an opt-out preference signal, for that browser and/or device as well.

        4. Right to Limit Use. We do not engage in uses or disclosures of “sensitive personal information” that would trigger the right to limit use of sensitive personal information under the CCPA.

        5. Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

        Exercising Your CCPA Rights. If you are a California resident and would like to exercise your CCPA rights, you may do so via any of the methods described below:

        • Email us at privacy@drinkaccelerator.com

        Verification. Before responding to your request, we must first verify your identity using the personal information you recently provided to us. You must provide us with your full name and email address. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

        Authorized Agents. You may designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

        Rights Under California Shine the Light Law. Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year for information about any relevant third-party sharing in the prior calendar year. To submit a “Shine the Light” request, email us at drinkaccelerator.com, and include in your request a current California address and your attestation that you are a California resident.

        10. CHANGES TO THIS POLICY

        This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any updates to this Policy on this page. If we make material changes to how we collect, use, or disclose the personal information we have previously collected about you, we will endeavor to provide you prior notice, such as by posting prominent notice on our website or within the Services.

        11. CONTACT US

        If you have questions about this Policy or our privacy practices, you may contact us at privacy@drinkaccelerator.com