Privacy Policy Statement

The Pure Spirit

This privacy policy ("Privacy Policy") covers our treatment of personally identifiable information collected by or submitted to The Pure Spirit ("we," "us," or "our"), including information submitted via the Internet, by telephone, mail or otherwise. We understand and respect your desire for privacy and will make reasonable efforts to use personal information in accordance with this Privacy Policy. Because this Privacy Policy addresses our use of personally identifiable information, we suggest that you review this Privacy Policy carefully.

Please note that to the extent any portions of the following Privacy Policy are inconsistent with applicable law or regulations, or to the extent you provide your express consent for uses not specifically described below, then such laws or regulations, or your express consent, will govern our use of your personal information.

CONTACT INFORMATION

You may contact us at any address or number that we have provided to you, or, as a general matter, at the following:

The Pure Spirit
245 El Cajon Way
Los Gatos, CA 95032

info@thepurespirit.com

INFORMATION COLLECTION

Information Collection - General

Generally, it is our policy not to request or collect especially sensitive personal information, such as religious preferences, racial or ethnic background or other similar forms of data.

We collect personally identifiable information that you provide to us over the Internet (especially via our websites, generally located within our addresses under the domain www.thepurespirit.com (our "Sites")), by email, regular mail, or by phone, from third parties that give your information to us and through other legal means. For the purposes set forth in greater detail below, we may collect information in any of the following categories: your name, physical address, email address, phone numbers, date of birth, personal interests, information regarding your interest and use of our services, your occupation, background information relevant to your applications (if you submit any) and other information relevant to responding to your inquiries and providing services to our members and business partners. If you are a member or prospective member, we may also collect personal information about you or your family (e.g., names and ages of family members, travel preferences, etc.) that will help us provide a more complete membership experience (e.g., arranging proper accommodations, responding to meal requests, etc.). If you are a member, we may collect financial information from you, such as credit card numbers, billing addresses, expiration dates, and etc., in order to facilitate the billing and payment of your accounts. If a third party provides us your information, we generally take reasonable steps to establish that the third party had the authority to provide such information to us.

For information you submit to us, we attempt to notify you which categories of information are required and which are optional. If you do not wish to provide us information that we request, then you should not provide such information. However, please be aware that if you do not provide us with certain information that we require, then we may not be able to respond to your requests, process your applications, bill or pay you in accordance with your proposed contracts with us, or provide you complete services. If you have any concerns about the nature of the information we collect, you may contact us at the above address, or as set forth below.

Certain Other Forms of Information Collected on the Internet

Use Data
If you use our Sites, we may collect non-personally identifiable information about your use of the Sites (such as IP addresses, domains, browser type and version, and operating system) ("Use Data").

Cookies
A cookie is a small file stored on a user's computer that contains information about the user. We may use either session ID cookies and/or persistent cookies. For the session ID cookie, once a user closes the browser, the cookie simply terminates. A persistent cookie is a small text file stored on a user's hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions. By showing how and when you use our Sites, cookies help us see which areas are popular and which are not and help in targeting information based on your interests. Cookies also allow us to store the personal preferences that you set during each visit to our Sites, which in turn allows us to speed up your future activities at our Sites. Most browsers are initially set to accept cookies. You can set your browser to notify you when you have received a cookie, giving you the opportunity to decide whether to accept it. You have the option to reject our cookies and still use our Sites, but you may not be able to access or use some of the features we offer on our Sites (including certain members-only functions and functions with respect to our referral programs).

Log Files
Like most standard website servers, we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks.

Clear GIFs (Web Beacons/Web Bugs)
We employ a software technology called clear GIFs (a.k.a. Web Beacons/Web Bugs), which help us better manage content on our Site by informing us what content is effective. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of users. The main difference between the two is that clear GIFs are invisible on the page and are much smaller, about the size of the period at the end of this sentence. In addition, we may use clear GIFs in our HTML-based emails to let us know which emails have been opened by the recipients.

USE OF INFORMATION

Use to Fulfill Our Obligations and Your Requests

We will use your personal information to provide you with any information you request from us, including sales and marketing materials, and to address any communications that you may have initiated or authorized.

We will also use your information to fulfill our obligations to you pursuant to any contracts or agreements that you may enter into with us, or in connection with any of our programs, events or promotions in which you register or participate. As examples, please consider: If you are a prospective member, we use information you submit in connection with your application to process your application (which may include a background check), establish your account and activate your membership. If you are a member, we use your information to provide you services and administer your account, including as necessary to make travel arrangements and reservations and to bill you. If you are a participant in one of our sales or marketing programs, we will send you information relevant to your participation, such as marketing materials or announcements about upcoming events related to the program.

We may also use your information to provide assistance or support with respect to your use of our services or Sites, to troubleshoot problems and to resolve disputes that may arise. Further, we may use your information to improve our content, advertising or services, or to analyze trends or to customize the display or format of our marketing content or Sites.

From time to time, we may send you information about our services and offerings, and about certain products and services of selected third parties, in which we think you may be interested.

We will not use your information or send you information if you have notified us of your preference not to have your information so used, or not to receive such information, or when we are prohibited by law from doing so.

Sharing of Information

For the purposes described above and to the extent permitted by law and regulations, we may share your personal identification information with the following categories of entities:

• Third parties that perform information processing on our behalf, such as companies that manage our membership-wide emails, that conduct surveys for member satisfaction, that perform background checks, that help us send information regarding companies, products or services in which we believe you may be interested, or that provide analyses of use of our services or Sites.
• Third parties that perform on our behalf, or that help us perform, our contractual obligations to you.
• Our corporate affiliates and other entities that operate websites for The Pure Spirit
• In response to a request by law enforcement or other governmental personnel or court order or subpoena; if we are under a legal obligation to do so; to protect the integrity of our company if we believe that a user has committed unlawful or otherwise harmful acts; to protect our interests in connection with a legal proceeding; in emergency situations to protect health or safety; if we believe such disclosure is in your vital interest; or if we obtained your information from public sources.
• On rare occasions,third parties with whom we have advertising or promotional relationships(provided that we are not otherwise restricted from making such disclosures).
• In connection with any merger or consolidation with, or sale of substantially all of our assets to, an affiliated entity or third party, provided that such party agrees to comply with our Privacy Policy or you are given a choice if such party would like to use such information in a manner materially different from that disclosed in our Privacy Policy.

Use of Use Data and other Internet-Based Information

We use aggregated (i.e., non-personally identifiable) Use Data for purposes of site administration and to compile information about usage of our Sites and services. We may share aggregated information (which does not contain your personally identifiable information) with third parties, such as advertisers and marketing partners.

We may combine personally identifiable information with Use Data to help us serve you better in connection with your use of our services or Sites, and to respond to your requests for technical assistance (e.g., we may record which web browser you use in order to help respond to your questions with difficulties using our Sites).

International Transfer of Information - Residents of the European Union

Please note that in order to fulfill our obligations with respect to your information and in accordance with the purposes outlined above, we may need to transfer your information internationally, including by transferring information to the United States or other countries. Such transfers will be subject to the terms of this Privacy Policy. If you are a resident of the European Union, then, notwithstanding anything to the contrary in other provisions of this Privacy Policy, unless we have your express consent for other uses, our policy is not to use your information other than as is necessary to respond to your inquiries or requests for information, to process your application for membership (if you submit one), to service your membership and account (if you are a member), to provide you information relevant to your membership and account, and to administer any other contract or agreement we may have with you.

SECURITY

We have taken appropriate technical and organizational measures to help prevent unauthorized access, maintain data security, and to make proper use of the information that we collect; however, no transmission of data over the Internet is guaranteed to be completely secure and we cannot guarantee the security of any information you provide to us. For example, third parties may unlawfully intercept or access transmissions or private communications. Therefore, although we use industry standard practices to protect your privacy, we do not promise or guarantee, and you should not expect, that your personally identifiable information or communications with us will always remain private.

MODIFYING OR DELETING PERSONAL INFORMATION

We intend to keep your information accurate and up to date. You have the opportunity to review and correct any of your information that we may have, or to restrict the uses we make of your information.

In order to review or correct your information that we have on file, please take the following steps:

• Contact us via email at info@thepurespirit.com
• Give us your name and email address, together with any information that might help us more effectively serve or communicate with you
• Let us know how we can help you - if you would like to review your information, etc.
• Let us know the most convenient way for us to communicate with you (email, phone, etc.)

If you request that certain information be amended, we will use reasonable efforts to accommodate your request in a timely manner. If you are a member or otherwise have established a contractual relationship with us, there is certain information that we must maintain in order to properly service your account. We retain certain information in our sole discretion that we need to process your information in order to fulfill your requests and our contracts with you, to maintain our records in accordance with industry practices, to resolve disputes, to troubleshoot problems, to enforce this Privacy Policy, or for other valid business reasons; it is not our policy to retain more information for longer than is necessary. Please note that we will not remove your non-personally identifiable Use Data from our aggregated files. Furthermore, please be aware that even if you request that your information be removed from our systems, such information may never be completely removed due to technical and legal constraints, including backup and disaster recovery systems, as well as the need to keep some information to track and record your requests.

NOTIFICATION OF CHANGES TO THIS PRIVACY POLICY

We may, at our sole discretion, revise this Privacy Policy at any time in a manner consistent with applicable law and regulations. When we revise this Privacy Policy, we will incorporate the revisions into this Privacy Policy and will revise the "last updated" date at the top of this web page. Please check this Privacy Policy periodically for the most current version of our Privacy Policy to confirm your continued agreement with its terms, which will be inferred by your continued association with us following any such modifications.

MINORS

Our Sites and services are not directed toward individuals under eighteen years old ("Minors") nor do we knowingly collect information from Minors.

LINKS

Our Sites may contain links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our Site and to read the privacy statements of each and every website that collects personally identifiable information.

ADDITIONAL CONTACT INFORMATION

If you have any questions or comments regarding our Privacy Policy, please contact us at the addresses or phone numbers listed above. If you have any technical questions or comments regarding the website itself, you make direct your inquiries to info@thepurespirit.com.

Effective date of this policy: November 1, 2007.