THE SIP SOCIAL PRIVACY POLICY

Last modified: September 7, 2022

INTRODUCTION
The Sip Social Co LLC (“THE SIP SOCIAL CO”, “we”, “us” or “our”) knows that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This policy describes the types of information we may collect from you or that you may provide when you visit the website www.thesipsocialco.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies to the information we collect:
· On this Website.
· In email, text, and other electronic messages between you and this Website.
It does not apply to information collected by:
· Us offline or through any other means, including on any other website operated by the Company or any third party; or
· Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Website.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Website. By accessing or using this Website, you agree to this privacypolicy. This policy may change from time to time (see “Changes to Our Privacy Policy” below). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) NOTICE
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any personal information (any terms defined in COPPA have the same meaning when used in this section) to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or provide any information about yourself to us, including your name, address,telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information
from or about a child under 16, please contact us at thesipsocialco@gmail.com.
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see “Your State Privacy Rights” below for more information.

COLLECTING AND USING YOUR PERSONAL INFORMATION
Personal Information
We collect several types of information from and about users of our Website, including information:
· By which you may be personally identified, such as name and email address and,
· About your internet connection, the equipment you use to access our Website, and usage
details (“Usage Data”)
We collect this information:
· Directly from you when you provide it to us.
· Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us
The information we collect on or through our Website may include:
· Information that you provide by filling in forms on our Website. This includes
information provided when you contact us or when you sign up for our membership or loyalty and rewards program found at www.thesipsocialco.com/loyalty (The Topper Rewards Program”).
· Records and copies of your correspondence (including email addresses), if you contact us.
· Details of transactions you carry out after contacting us through our Website and of the fulfillment of your service requests.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively,User Contributions). Your User Contributions are posted on and transmitted to others at your own risk. We cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection
technologies to collect certain information about your equipment, browsing actions, and patterns,
including but not limited to information such as your device's Internet Protocol address (e.g. IP
address), browser type, browser version, the pages of our Website that you visit, the time and
date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic
data.

When you access the Website by or through a mobile device, we may collect certain information
automatically, including, but not limited to, the type of mobile device you use, your mobile
device unique ID, the IP address of your mobile device, your mobile operating system, the type
of mobile Internet browser you use, unique device identifiers, and other diagnostic data.
The information we collect automatically may include Personal Information or we may maintain
it or associate it with Personal Information we collect in other ways or receive from third parties.
It helps us to improve our Website and to deliver a better and more personalized service,
including by enabling us to:
· Estimate our audience size and usage patterns.
· Store information about your preferences, allowing us to customize our Website
according to your individual interests.
· Speed up your searches.
· Recognize you when you return to our Website.

Tracking Technologies and Cookies
The technologies we use for this automatic data collection may include:
 Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your
computer. Learn more about cookies:  All About Cookies . You may refuse to accept
browser cookies by activating the appropriate setting on your browser. However, if you
select this setting, you may be unable to access certain parts of our Website. Unless you
have adjusted your browser setting so that it will refuse cookies, our system will issue
cookies when you direct your browser to our Website.
· Web Beacons. Pages of our Website and our emails may contain small electronic files
known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that
permit the Company, for example, to count users who have visited those pages or opened
an email and for other related website statistics (for example, recording the popularity of
certain website content and verifying system and server integrity).
· Flash Cookies. Certain features of our Website may use local stored objects (or Flash
cookies) to collect and store information about your preferences and navigation to, from,
and on our Website. Flash cookies are not managed by the same browser settings as are
used for browser cookies. For information about managing your privacy and security
settings for Flash cookies, see Choices About How We Use and Disclose Your
Information.
· Google Analytics (Google Inc.). Google Analytics is a web analysis service provided by
Google Inc. (“Google”). Google utilizes the data collected to track and examine the use
of this Website, prepare reports on its activities, and share them with other Google
services. Google may use the data collected to contextualize and personalize the ads of its
own advertising network. You can opt-out of having made your activity on the Service
available to Google Analytics by installing the Google Analytics opt-out browser add-on.

The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from
sharing information with Google Analytics about one’s visiting activity. For more
information on the privacy practices of Google, please visit the Google Privacy Terms
web page: https://policies.google.com/privacy.

These tracking technologies are necessary for the website to function and collect information for
analytics – We do not currently personalize your experience with targeted ads or sell your
Personal Information to third parties.

INTERACTIONS WITH SOCIAL NETWORKS AND PLATFORMS
Some content or applications on the Website are served by third parties, including application
providers such as the Facebook, TikTok, and Instagram social widgets. These third parties may
use cookies alone or in conjunction with web beacons or other tracking technologies to collect
information about you when you use our Website. The information they collect may be
associated with your Personal Information or they may collect information, including Personal
Information, about your online activities over time and across different websites and other online
services. They may use this information to provide you with interest-based (behavioral)
advertising or other targeted content.
We do not control these third parties; tracking technologies or how they may be used. If you have
any questions about an advertisement or other targeted content, you should contact the
responsible provider directly. For information about how you can opt-out of receiving targeted
advertising from many providers, see “Choices About How We Use and Disclose Your
Information” below.

LOYALTY REWARDS PROGRAM
Financial Incentive Notice: We offer consumers a loyalty program (the Topper Rewards
Program) that provides certain perks, such as rewards and exclusive offers. We may also provide
other programs, such as sweepstakes, contest, or other similar promotional campaigns
(collectively, the “Programs”). Through these program offerings, consumers may provide us with
some personal information (e.g., name, postal address, email address, phone number, birthday,
and other similar forms of personal information) when they opt-in to our programs. There is no
obligation to opt-in and consumers may opt-out. We offer these programs to, among other things,
enhance our relationship with customers. The value to our business, in the aggregate, of
consumers’ personal information depends on specific facts, such as whether and to what extent
they take advantage of any offerings. We do not calculate the value of the consumers’
information for our accounting statements. To the extent we would, however, such valuation
could be directly or reasonably related to the cost associated of acquiring or developing such
information.

 

You may opt-in to our programs by signing up in the manner invited for an individual program.
And you can opt-out of these programs at any time. To opt-out, please contact us by emailing us
at thesipsocialco@gmail.com .


USE OF YOUR PERSONAL INFORMATION
We use information that we collect about you or that you provide to us, including any Personal
Information:
· To present our Website and its contents to you.
· To provide you with information, products, or services that you request from us.
· To communicate with you about accounts, programs, contests, and sweepstakes.
· To fulfill any other purpose for which you provide it.
· To support and improve The Topper Rewards Program.
· To carry out our obligations and enforce our rights arising from any contracts entered into
between you and us, including for billing and collection.
· To notify you about changes to our Website or any products or services we offer or provide through it.
· In any other way we may describe when you provide the information.
· For any other purpose with your consent.
We may also use your information to contact you about our own services that may be of interest
to you and other marketing or promotional materials. If you do not want us to use your
information in this way, please contact us with your request at thesipsocialco@gmail.com . For
more information, see “Choices About How We Use and Disclose Your Information” below.

DISCLOSURE OF YOUR PERSONAL INFORMATION
We may disclose aggregated information about our users, and information that does not identify
any individual, without restriction.
We may disclose Personal Information that we collect, or you provide as described in this
privacy policy:
 To contractors, service providers, and other third parties we use to support our business.
· To a buyer or other successor in the event of a merger, divestiture, restructuring,
reorganization, dissolution, or other sale or transfer of some or all of The Sip Social Co
LLC's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar
proceeding, in which Personal Information held by The Sip Social Co LLC about our
Website users is among the assets transferred.
· To fulfill the purpose for which you provide it.
· For any other purpose disclosed by us when you provide the information.
· With your consent.

 

We may also disclose your Personal Information:

· To comply with any court order, law, or legal process, including to respond to any
government or regulatory request.
· To enforce or apply our agreements, including for billing and collection purposes.
· If we believe disclosure is necessary or appropriate to protect the rights, property, or
safety of The Sip Social Co LLC, our customers, or others. This includes exchanging
information with other companies and organizations for the purposes of fraud protection
and credit risk reduction.
The categories of Personal Information we may disclose include Personal Information (typically
an email address) and Usage Data.

RETENTION OF YOUR PERSONAL INFORMATION
We will retain your Personal Information only for as long as is necessary for the purposes set out
in this Privacy Policy. We will retain and use your Personal Information to the extent necessary
to comply with our legal obligations (for example, if we are required to retain your data to
comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
THE SIP SOCIAL CO will also retain Usage Data for internal analysis purposes. Usage Data is
generally retained for a shorter period of time, except when this data is used to strengthen the
security or to improve the functionality of our Website, or we are legally obligated to retain this
data for longer time periods.

 

TRANSFER OF YOUR PERSONAL INFORMATION
Your information, including Personal Information, is processed at THE SIP SOCIAL CO’s
operating offices and in any other places where the parties involved in the processing are located.
It means that this information may be transferred to — and maintained on — computers located
outside of your state, province, country or other governmental jurisdiction where the data
protection laws may differ than those from your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents
your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that your data is treated securely
and in accordance with this Privacy Policy and no transfer of your Personal Information will take
place to an organization or a country unless there are adequate controls in place including the
security of your data and other Personal Information.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the Personal Information you provide to us. We
have created mechanisms to provide you with the following control over your information:
· Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note  hat some parts of this site may then be inaccessible or not function properly.
· Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to
thesipsocialco@gmail.com.
· Promotional Offers from the Company. If you do not wish to have your email address or contact information used by the Company to promote our own goods and services, you can opt-out by sending us an email with your request to thesipsocialco@gmail.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to the Company as a result of a product purchase, product service experience or other
transactions.
· Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers target-audience preferences, you can opt-out by sending us an email with your request to thesipsocialco@gmail.com. For this opt-out to function, you may need to have your browser set to accept all browser cookies.
We do not control third parties; collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt-out of receiving targeted ads from members of the Network Advertising Initiative (NAI) on the NAI's website.
Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah may have additional Personal Information rights and choices. Please see “Your State Privacy Rights” below for more information.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
You can request access to, correct, or delete any Personal Information or User Contributions by sending us an email with your request to thesipsocialco@gmail.com.
We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If we delete your User Contributions from the Website, copies of your User Contributions may
remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Residents of certain states, such as California, Nevada, Colorado, Virginia, and Utah may have additional Personal Information rights and choices. Please see Your State Privacy Rights for more information.

YOUR STATE PRIVACY RIGHTS

State consumer privacy laws may provide their residents with additional rights regarding our use
of their Personal Information.

California Residents
If you are a California resident, you may exercise certain rights under the California Consumer
Privacy Act (“CCPA”) related to your Personal Information. We adopt this section to comply
with the CCPA and any terms defined in the CCPA have the same meaning when used in this
section. We collect information that identifies, relates to, describes, references, is reasonably capable of
being associated with, or could reasonably be linked, directly or indirectly, with a particular
consumer, household, or device (i.e. Personal Information as defined under the CCPA). This
does not include:

 Publicly available information from government records.
 Deidentified or aggregated consumer information.
 Information excluded from the CCPA's scope. For example, health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical
trial data, or other qualifying research data; or, Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act
(FIPA), and the Driver's Privacy Protection Act of 1994.

The Personal Information we collect, and sources for that information, are described above under
“Collecting and Using Your Personal Information.” It includes the following categories:
 Personal identifiers, such as name, contact information, email address, photos you send
us, and other unique or online identifiers;
 Customer records, such as payment information and other financial account information
you provide to us to pay for a purchase;
 Commercial and transactional information, such as products and services purchased; and
 Any inferences that are drawn from the information above.

We obtain the categories of Personal Information listed above directly from you. For example,
from forms you complete or products and services you purchase.

Use of Information. California residents have the right to “opt-out” of the sale of their Personal
Information to third parties. We do not sell Personal Information. We may use, or disclose the Personal Information we collect for one or more of the following purposes:

 To fulfill or meet the reason you provided the information. For example, if you share
your name and contact information to request a price quote or ask a question about our
products or services, we will use that Personal Information to respond to your inquiry.
 To provide and improve our products and services.
 To process your requests, purchases, transactions, payments, rewards, and prevent
transactional fraud.
 To provide you with support and to respond to your inquiries, including to investigating
and addressing your concerns and monitoring and improving our responses.
 To help maintain the safety, security, and integrity of our products and services,
databases and other technology assets, and business.
 To respond to law enforcement requests and as required by applicable law, court order, or
governmental regulations.
 As described to you when collecting your Personal Information or as otherwise set forth
in the CCPA.
 We will not collect additional categories of Personal Information or use the Personal
Information we collected for materially different, unrelated, or incompatible purposes
without providing you notice.

We may disclose these categories of Personal Information to third party affiliates and service
providers to fulfill our business purposes.

Submit a CCPA Rights Request. If you are a California resident, the CCPA gives you the right to
request that we disclose the Personal Information we have collected about you, the categories of
sources from which your Personal Information was collected, our purpose for collection, and the
categories of Personal Information we disclose and to whom. California residents also have the
right to request that we delete their Personal Information, subject to certain exceptions. You may
make CCPA requests or exercise these rights at no charge up to twice every 12 months.
California residents are requested to retain copies of any literature issued in relation to the
provision of our products and services.

If you are a California resident and wish to exercise your rights under the CCPA, you may
submit a request by email at thesipsocialco@gmail.com. In order to protect our customers’
Personal Information, and as required under the CCPA, we will verify your identity 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 request, or where necessary to process
your request. If we are unable to adequately verify a request, we will notify the requester. You
may submit a request on your own behalf, or you may designate an authorized agent to make a
request on your behalf. Authorized agents will be required to provide proof of their
authorization, and we may also require that the relevant individual directly verify their identity
and the authority of the authorized agent.

We will confirm receipt of your request within ten (10) business days. We endeavor to
substantively respond to a verifiable consumer request within forty-five (45) days of its receipt.
If we require more time (up to another 45 days), we will inform you of the reason and extension
period in writing. We do not charge a fee to process or respond to your verifiable consumer
request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the
request warrants a fee, we will tell you why we made that decision and provide you with a cost
estimate before completing your request.

The CCPA grants California residents the right not to receive discriminatory treatment for
exercising their privacy rights. We respect your privacy rights and we do not discriminate against
individuals for exercising their rights. 

California’s ‘Shine the Light’ Law. Under California’s “Shine the Light” law, a California
resident with whom we have an established relationship has the right to request information
about our disclosure of Personal Information to affiliated companies or third parties for their
direct marketing purposes, within the immediately preceding calendar year, subject to certain
exceptions. To exercise this right, please contact us by emailing us at thesipsocialco@gmail.com,
Subject: Privacy Team: Shine the Light.

Nevada Residents
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes
Chapter 603A may submit a request to this designated email address: thesipsocialco@gmail.com .
However, please know we do not currently sell data triggering that statute's opt-out requirements.

Colorado, Connecticut, Virginia, and Utah Residents
Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:
· Confirm whether we process their Personal Information.
· Access and delete certain Personal Information.
· Data portability.
· Opt-out of personal data processing for targeted advertising and sales (if applicable).
Colorado, Connecticut, and Virginia also provide their state residents with rights to:
· Correct inaccuracies in their Personal Information, taking into account the information
nature and processing purpose.
· Opt-out of profiling in furtherance of decisions that produce legal or similarly significant
effects.
To exercise any of these rights please by sending us an email stating your request to
thesipsocialco@gmail.com .

DATA SECURITY
We have implemented measures designed to secure your Personal Information from accidental
loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the
transmission of information via the internet is not completely secure. Although we do our best to
protect your Personal Information, we cannot guarantee the security of your Personal
Information transmitted to our Website. Any transmission of Personal Information is at your own
risk. We are not responsible for circumvention of any privacy settings or security measures
contained on the Website.

 

CHANGES TO OUR PRIVACY POLICY
It is our policy to post any changes we make to our privacy policy on this page. If we make
material changes to how we treat our users Personal Information, we will notify you by email.
The date the privacy policy was last revised is identified at the top of the page. You are
responsible for ensuring we have an up-to-date active and deliverable email address for you, and
for periodically visiting our Website and this privacy policy to check for any changes.

CONTACT INFORMATION
To ask questions or comment about this privacy policy and our privacy practices, contact us at:
thesipsocialco@gmail.com.