Effective as of May 1st, 2025

This Privacy Notice describes how Spindrift Beverage Co., Inc. and its affiliates Spindrift Sparkling Co., LLC and Spindrift Spiked Co., LLC (collectively, “Spindrift”, “we”, “us”, or “our”) may collect and process, store, disclose, share and use (collectively, “use”) personal information when you visit or access drinkspindrift.com or spindriftspiked.com (“Sites”) or when you otherwise interact with us either online, including on a digital property that is not a Site, or offline, such as during customer service sessions, when you engage in other activities that link to this Privacy Notice, when you request, order or purchase Spindrift products, when you participate in surveys, contests, sweepstakes and other marketing programs and campaigns, and when you register for or attend events (any such interaction an “Interaction”).  This Privacy Notice also describes rights you may have related to your personal information.

We may update this Privacy Notice from time to time.  We will post the updated version, and its effective date, on our Sites. We will announce any material changes to the Privacy Notice through an alert on our Sites and/or via email to you at the email address we have on file for you or otherwise in compliance with law. We may also provide other privacy notices on specific occasions when we are using your personal information in ways that differ from what we have described in this Privacy Notice so that you are aware of how and why we are using such information and what your rights are with respect to such use.

1. The personal information we and our service providers may collect about you and how it is collected

Information You May Provide to Us

During Interactions

• Contact, account, and search information, such as name, street addresses, ZIP code, phone numbers, and email addresses
• Demographic information, such as your birthday and gender identity
• Social media account information, if you interact with us on social media
• Account preferences
• Transaction and payment information, such as credit card numbers and purchase history, including product selections and sizes
• Information you otherwise provide to us via Interactions, including your feedback, thoughts, and responses to optional questions about your age, race, and ethnicity and photographs and other audiovisual materials that you choose to share with us through email, calls or social media posts)

As A Business Representative of a Supplier, Vendor, or Other Business Partner of Spindrift

• Business and contact information, such as company or organization name, corporate form, state or country of formation, industry, office locations, name, phone number, email address, and postal address of a contact person or representative, government identifier, and other information related to the business you represent, and any other information you choose to provide us, including through third-party portals and platforms
• Transaction, financial, and payment information to facilitate payments to you or from you
• The contents of any communications you have with us, such as requests, questions, and/or issues regarding our products, your orders, invoices or account, other feedback, and other topics you might raise
• Information related to your attendance or participation at an event or program, such as name, email address and phone number, and photographs and other audiovisual materials that you choose to share with us

Information We May Collect Through Automated Means

Usage Data

Usage data includes the dates and times you visit or access our Sites or engage in an Interaction with us, the features you use and the pages you visit, the type(s) of browser through which you visit or access our Sites or engage in an Interaction with us, the content you upload or post to our Sites or when you engage in an Interaction with us, error logs and other system activity, and the websites or applications through or from which you access our Sites or engage in an Interaction with us. We may also collect and analyze information about your transactions, including the type of product you requested or received, the date and time for which an order was placed or requested, and the amount charged.

Device Data

Device data includes your device’s IP address, information about your device’s hardware, the operating system on your device and the version of that operating system, your language preferences, unique device identifiers, advertising identifiers, and information about the mobile network you use.

Location Data

Location data includes general location information from your computer or mobile device such as the city and state in which your device is located based on its IP address. 

Note About Cookies and Similar Technologies

We, our service providers, and other entities (described in “How we may disclose information we collect” below) may use cookies, pixels and similar technologies (“Cookies”) to collect automatically collected information set forth above. Cookies are small text files sent automatically by your computer or device to us each time you visit our Sites. We may use session Cookies or persistent Cookies.  A persistent Cookie remains after you close your browser and may be accessed every time you visit our Site while a session Cookie disappears once you close your browser.  For information about the use of these technologies and the choices that may be available to you, please see the “Online advertising” and the ”Your rights and choices regarding your personal information” sections of this Privacy Notice. 

Information We May Collect From Others

We may collect information about you from other parties, including:

• Social Networks. If you access the Sites or otherwise engage with us through a third-party connection or log-in (e.g., through a social network), you may allow us to have access to and store certain information from your social network profile. This information may include your name, profile picture, your “likes,” and your list of friends, depending on your settings on such platforms. If you do not wish to have this information disclosed, do not use a social networking connection to access the Sites. For a description of how social networking sites handle your information, please refer to their privacy policies and terms of use, which may allow you to modify your privacy settings.
• Business Partners and Vendors. We use both business partners and vendors, such as payment processors, merchandise providers, survey providers and analytics providers, to perform services on our behalf.  Some of these partners may have access to information about you that we may or may not otherwise have (for example, where you sign up directly with that provider) and may disclose some or all of this information to us. 
• Other Individuals. Another individual, such as a family member, friend or colleague, may provide us with your information, such as contact information in connection with an order or a referral program. 

Note that by submitting someone else’s personal information to us, you represent that you are authorized to provide this information to us.

2. How we may use personal information about you

We may use your personal information as described in this Privacy Notice and for reasons compatible with this Privacy Notice. 

Your personal information may be used for the following purposes:

• Managing and completing your product orders
• Payment processing and account management, including managing your rewards account
• Providing customer support and responding to your questions, requests or comments, including contacting you regarding your account and to address concerns
• Marketing our products
• Operating, measuring the performance of, and improving our Sites, products, communications, marketing programs and campaigns, events and other offerings, including Interactions with you, and developing new ones
• Providing access to content that varies based on information collected from you, such as showing you nearby locations based on your general location
• Personalizing your advertising experience and customizing content based on what we think your interests and preferences are
• Innovating new products
• Contacting you with information and offers such as coupons, discounts and special promotions that may interest you or seeking your feedback, including via text and email and through surveys or questionnaires, and informing you about our products, marketing programs and campaigns, events and other offerings, including Interactions with you
• Monitoring and improving the security and safety of our Sites, products, communications, marketing programs and campaigns, events and other offerings, including Interactions with you
• Preventing, detecting, mitigating, and investigating fraud, security breaches or other potentially prohibited or illegal activities
• Resolving disputes, protecting ourselves, our users, and others, exercising our legal rights and enforcing any legal terms that govern use of our Sites, Interactions, products, communications, marketing programs and campaigns, events and other offerings
• Complying with laws, regulations, and other legal process and procedures
  With your consent or as otherwise disclosed at the time of collection
  

We may combine the information we collect through our Sites and Interactions with information we collect automatically or receive from other sources and use such combined information in accordance with this Privacy Notice. For example, your browsing activity may be tracked across different websites and different devices or apps, and we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop by requesting our advertising technology partners to match your browsing patterns, geo-location and device identifiers with your browser and devices.

3. How we may disclose information we collect

We may disclose your personal information to:

• Our service providers and vendors, whom we engage to help us run our business, including but not limited to our Sites and Interactions with you, and for all of the purposes described above and reasons consistent with them, such as:
  
  • payment processing providers
  • e-mail marketing and other communications providers
  • analytics providers
  • database hosting and storage providers
  • shipping providers
• Order recipients if you are not the recipient of an order you place

Additionally, we may disclose your personal information to third parties as required by law, as necessary in connection with our Sites, products, communications, marketing programs and campaigns, events, other offerings, and Interactions with you, or to the extent we have another business or commercial purposes for doing so, including to: 

• Other parties at your request or option, such as co-sponsors of a promotion that you opt-into and you are responsible for assessing the privacy practices of these entities
• Other parties as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, or property of the Sites, our products, events, consumers, employees or agents or Site users, to resolve disputes, or to comply with applicable laws or legal process, including responding to requests from public and government authorities
• Third parties that provide advertising, content, or other functionality, who may collect or receive certain information about you and/or your use of the Sites to provide ads (including targeted ads), content, or functionality, or to measure and analyze ad performance, on our Sites or other websites or platforms
• Others with your consent

If we are subject to a merger or acquisition with/by another company or sale of assets or bankruptcy matter, we may disclose information to them in connection with the transaction.  If such an event occurs, we will require that the new combined or acquiring entity follow this Privacy Notice with respect to your personal information.

4. Online advertising

We may allow third-party advertising technologies (e.g., ad networks and ad servers such as Google’s ad services, and others) on our Sites that use Cookies to deliver advertising to you on the Sites and other websites you visit and applications you use. The ads may be based on various factors such as the content of the page you visit or have visited, information you provide, your searches, and other information we and these third parties have collected about you. 

We and our vendors (including Google Analytics) may also use these technologies and the information collected by them for data analytics purposes. More information about Google’s analytics practices is available for review at google.com/policies/privacy/partners. 

We may also associate Cookies with de-identified data linked to or derived from data you have submitted to us (e.g., your email address) and disclose such information with to advertising partners and vendors in hashed, non-human-readable form to provide you with more relevant ads when you visit other websites and mobile applications.

The use of Cookies or other similar technologies that may be placed on devices you use to access our Sites by non-affiliated third parties is governed by the privacy policies of those third parties. 

For information about how to opt out of targeted advertising activities and control Cookies, see the “Your rights and choices regarding your personal information” section below.

5. Aggregated and de-identified information

We may also aggregate and/or de-identify information collected through our Sites and Interactions in such a way that the information cannot reasonably be linked to you or your device. We may use de-identified or aggregated data for any purpose, including for research and marketing purposes, and we may disclose such data to any third parties, including advertisers, promotional partners, sponsors, and others.

We consider information to be de-identified when we maintain and use the information only in de-identified form and have not attempted to re-identify the information, except to determine whether our de-identification processes satisfy the requirements of applicable law.   

6. How we safeguard your personal information

We have put in place appropriate security measures designed to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration.

7. Your rights and choices regarding your personal information

Marketing

You may opt out from receiving marketing communications from us at any time by using the unsubscribe function in the email you receive from us or contacting us as set forth under “How to contact us” below. Please note that it may take us some time, consistent with our legal obligations, to process your request. Even if you opt out from receiving marketing messages from us, you will continue to receive administrative messages from us, such as order confirmations, updates to our policies and practices, or other communications regarding our relationship or transactions with you. 

Privacy Rights

In addition to the other rights and choices described in this Privacy Notice, depending on your jurisdiction, you may have the right to make certain requests regarding your “personal information” or “personal data” (as such terms are defined under applicable law and collectively referred to as “personal information”). Your rights and our responses to requests vary based on your state of residency, and you may be in a jurisdiction where we are not obligated or are unable to fulfill a request. Specifically, you may have the right to ask us to:

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting, selling, or sharing your personal information; and the categories of third parties with whom we disclose personal information
• Provide you access to and/or a copy of certain personal information we hold about you
• Correct or update personal information we hold about you
• Delete certain personal information we have about you
• Provide you with information about the financial incentives that we offer to you, if any
  

Additional information for California residents is provided in “California Privacy” below.

If you want to exercise any of the rights listed above or would like more information regarding your rights, email us at privacy@drinkspindrit.com or write to us at 55 Chapel Street, Suite 401, Newton, MA 02458.  Please note that it may take time, consistent with our legal obligations, to process your request. 

You also have the right to not be discriminated against for exercising your rights as provided in applicable law. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide products and other services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

If your request is denied for any reason, you may have the right to appeal the denial, depending on applicable law. To submit an appeal, email us at privacy@drinkspindrift.com or write to us at 55 Chapel Street, Suite 401, Newton, MA 02458.  

Notice of right to opt out of sales of personal information and processing/sharing of personal information for targeted advertising purposes.

Depending on your jurisdiction, you may opt out of certain processing of your personal information, including for targeted advertising, under applicable law. As discussed in the “How we may disclose information we collect” section above, we may sometimes disclose information to unaffiliated third parties which may be considered a “sale” under applicable laws. In some cases, we may also provide personal information to third-party advertising providers for targeted advertising purposes. This disclosure may be considered a “sale” of personal information under applicable law or may be considered processing/sharing personal information for targeted advertising. 

If you would like to opt out of our online disclosure, such as through Cookies, of your personal information for purposes that could be considered “sales” for those third parties’ own commercial purposes or “sharing” or processing for purposes of targeted advertising, please select “Your Privacy Choices” in the footer of the website and follow the instructions. You must make this choice on each site on each browser/device you use to access the Sites. You must also renew this choice if you clear your Cookies or your browser is set to do that. You can also submit a request to opt out of the use of your email address and other personal information related to that email address for targeted advertising purposes and to the disclosure of such information to our marketing and business partners for such purposes or in a way that constitutes a sale by visiting this link. Depending on your jurisdiction, you may be permitted to designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of individuals under the age of 18 without legally-required affirmative authorization.

Please note that if you have a legally-recognized browser-based opt out preference signal (such as the Global Privacy Control) turned on via your device browser, we recognize such preference in accordance with applicable law.

Cookie Choices

To generally update your Cookies settings to notify you when a Cookie is being set or updated or to disable Cookies altogether, please consult your web browser settings. Please note that if you delete or choose not to accept Cookies from us, you may miss out on certain features of our Sites.  

To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.  

If you are interested in information about tailored browser advertising and how you can generally control Cookies from being put on your devices to deliver tailored advertising, visit the Network Advertising Initiative's Consumer Opt-Out link or the Digital Advertising Alliance’s Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. Please note that these opt-outs apply per browser and per device, so you will have to opt out for each device—and each browser on each device—through which you access our Sites. In addition, the opt-outs do not apply to advertisements in mobile applications.

You can also make choices about targeted advertising as set forth above in “Notice of Right to Opt Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes."

8. California Privacy

Privacy Disclosures.

This section supplements our Privacy Notice with additional information for California residents about our information collection and use practices as required by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”). 

In this section, the terms “personal information” has the meaning set forth in the CCPA.

The following provides information about our practices in the 12 months leading up to the effective date of this Notice in relation to the categories of personal information that we collected from California residents generally, the purposes for which we use the information, and the categories of other businesses to whom we disclose the information for business purposes.  

Opt Out Rights.

As explained in “How we may disclose information we collect” above, we sometimes disclose information to unaffiliated third parties we collaborate with or that provide offers that we think may be of value to you. This disclosure of information may be considered a “sale” under the CCPA. We also provide personal information to third-party advertising providers for targeted advertising purposes, so that we can provide you with more relevant and tailored ads regarding our Sites and Interactions, or use analytics partners to assist us in analyzing use of our Sites, Interactions and user/customer base. The disclosure of your personal information to these third parties to assist us in providing these services may be considered a “sale” of personal information under the CCPA, or, the “sharing” of your personal information for purposes of “cross-context behavioral advertising.”

We have sold or shared the following categories of personal information over the last 12 months  to advertising partners and advertisers: identifiers and internet network and device activity data.

If you would like to opt out of our online disclosure, such as through Cookies, of your personal information for purposes that could be considered “sales” for those third parties’ own commercial purposes, or “sharing” for purposes of targeted advertising, please select “Your Privacy Choices” in the footer of the website and follow the instructions . You must make this choice on each site on each browser/device you use to access the Sites. You must also renew this choice if you clear your Cookies or your browser is set to do that. You can also submit a request to opt out of the use of your email address and other personal information related to that email address for targeted advertising purposes and to the disclosure of such information to our marketing and business partners for such purposes or in a way that constitutes a sale by visiting this link. You can designate an authorized agent to submit such requests on your behalf. Please note that we do not knowingly sell the personal information of individuals under the age of 18 without legally-required affirmative authorization.

Please note that if you have a legally recognized browser-based opt out preference signal (such as Global Privacy Control) turned on via your device browser, we recognize such preference in accordance with applicable law.

Notice Concerning Do Not Track.

We do not currently recognize or respond to browser-initiated “Do Not Track” signals. Learn more about Do Not Track. Please note that Do Not Track is a different privacy mechanism than the user “preference signal” referenced in “Your rights and choices regarding your personal information” above, which is a browser-based control that indicates whether you would like to opt out of the sale or processing of your information for targeted ads, under applicable laws. 

Retention.

We retain your information as long as we determine is necessary to provide the Sites and Interactions and to fulfill the transactions you have requested, and for other necessary purposes such as complying with our legal obligations, resolving disputes, enforcing our agreements, and for fraud prevention and related security purposes. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. For example, we retain your email address as an authentication credential (where applicable) as long as you have an account with us and an additional period of time after that for our legitimate interests and for our fraud and legal compliance purposes. If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. We may delete or de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable law. We may retain cached or archived copies of your information.

Notice of Financial Incentive.

We may offer opportunities to receive certain benefits, such as discounts, promotional entries or other similar incentives that may require providing personal information, such as in responding to surveys or providing feedback (each, an “Incentive Program”). Depending on the Incentive Program you participate in, you may provide personal information such as your name, email address, and phone number. Such opportunities may be considered a financial incentive under applicable law. Your participation in an Incentive Program is voluntary, and when you participate, you agree to the terms of the Incentive Program, and, depending on the Incentive Program, you may withdraw from your participation in the Incentive Program by following the instructions provided when you sign up for the Incentive Program or by contacting us as described in “How to contact us” below. Any monetary value derived from the reward, discount, or incentive is a reasonable approximation of the monetary value of participating in the Incentive Program. This estimate is based on multiple factors including any revenue generated related to the Incentive Program, any expenses incurred by us to operate the Incentive Program and/or any improve our Sites and Interactions based on information obtained from the Incentive Program. 

9. Our policy on children’s information

Individuals under the age of 18 (or age of 21 where indicated) are not allowed to purchase products or engage in an Interaction with us. If you are aware that a person under the age of 18 is making or has made a purchase or is engaging or has engaged in an Interaction with us, please contact us. If we find out we have personal information about a person known to us as under the age of 18 or reasonably believed by us to be under the age of 18, we will delete it.

10. Links to other websites and services

The Sites, Interactions and our products, communications, programs, campaigns, events and other offerings may include or involve links to other websites that are not operated by us. We have no control over how these websites may collect or use your information and no responsibility for the practices, policies and security measures implemented on these websites. Read the privacy notices on those other websites before you submit your information through them. 

11. Users outside of the United States

Please note that Spindrift is located in the United States and provides our products, communications, programs, campaigns, events and other offerings, and processes your data, in the United States. In addition, Spindrift may subcontract the processing of your data to, or otherwise disclose your data to, service providers and trusted business partners in countries other than your country of residence, including the United States, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of our products, communications, programs, campaigns, events and other offerings to you, the processing of transactions, and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage, or use.

12. How to contact us

If you have any questions or concerns about our use of your personal information, contact us:

Via Mail at:

55 Chapel St.
Suite 401
Newton, MA 02458

Via Email at: privacy@drinkspindrift.com

Via Phone at: 617-391-0356