Website Terms of Use Acceptance of the Terms of Use These terms of use are entered into by and between you, the user (“You”) of this website and ZONIN1821, ZONIN USA, Inc. (postal address: 20807 Biscayne Blvd, Suite 320 Aventura, FL) as operator of this website (“Company“, “We” or “Us“). The following terms and conditions (“Terms of Use“), govern your access to and use of https://us.zoninprosecco.com/including any content, functionality and services offered on or through https://us.zoninprosecco.com/(“Website“). Please read the Terms of Use carefully before You start to use the Website. By using the Website, You accept and agree to be bound and abide by these Terms of Use and our Privacy Policy. If You do not agree to these Terms of Use or the Privacy Policy, You must not access or use the Website. This Website is intended for your use only if You are of legal age to purchase alcohol in the United States. If You do not meet this requirement, You should leave the Website immediately. Changes to the Terms of Use We may revise and update these Terms of Use from time to time in our sole discretion without notice. All changes are effective immediately when We post them, and apply to all access to and use of the Website thereafter. Your continued use of the Website following the posting of revised Terms of Use means that You accept and agree to the changes. Accessing the Website and Account Security We reserve the right to withdraw or amend this Website, and any service or material We provide on the Website, in our sole discretion without notice. We will not be liable if for any reason all or any part of the Website is unavailable at any time or for any period. From time to time, We may restrict access to some parts of the Website, or the entire Website, to users, including registered users. You are responsible for:

• Making all arrangements necessary for You to have access to the Website.
• Ensuring that all persons who access the Website through your internet connection are aware of these Terms of Use and comply with them.

To access the Website or some of the resources it offers, You may be asked to provide certain registration details or other information. It is a condition of your use of the Website that all the information You provide on the Website is correct, current and complete. You agree that all information You provide to register with this Website or otherwise, including but not limited to through the use of any interactive features on the Website, is governed by our Privacy Policy, and You consent to all actions We take with respect to your information consistent with our Privacy Policy. Intellectual Property Rights The Website and its entire contents, features and functionality (including but not limited to all information, software, text, displays, images, video and audio, and the design, selection and arrangement thereof), are owned by the Company, its licensors or other providers of such material and are protected by United States and international copyright, trademark, patent, trade secret and other intellectual property or proprietary rights laws. These Terms of Use permit You to use the Website for your personal, non-commercial use only. You are prohibited from reproducing, distributing, modifying, creating derivative works of, publicly displaying, publicly performing, republishing, downloading, storing or transmitting any of the material on our Website without Company’s permission. No right, title or interest in or to the Website or any content on the Website is transferred to You, and all rights not expressly granted are reserved by the Company. Any use of the Website not expressly permitted by these Terms of Use is a breach of these Terms of Use and may violate copyright, trademark and other laws. Prohibited Uses You may use the Website only for lawful purposes and in accordance with these Terms of Use. You warrant and agree that, while using the Website, You shall not upload, post or transmit to or distribute or otherwise publish through the Website any materials that: (a) are in breach of any part of these Terms of Use (b) restrict or inhibit any other user from using and enjoying the Website, (c) constitute or encourage conduct that would constitute a criminal offence or give rise to civil liability, or (d) contain a virus or other harmful component, advertising of any kind, or false or misleading indications of origin or statements of fact. You also warrant and agree that You shall not: (a) impersonate, or misrepresent your affiliation with any other person or entity; (b) upload, post, publish, transmit, reproduce, distribute or in any way exploit any information or other material obtained through the Website for commercial purposes (other than as expressly permitted by the provider of such information or other material); (c) engage in spamming or flooding; or (d) attempt to gain unauthorized access to other computer systems through the Website. Except as otherwise expressly permitted herein, You may not upload, post, publish, reproduce, transmit or distribute in any way any component of the Website itself or derivative works with respect thereto, as the Website is protected by copyright. Additionally, You agree not to:

• Show or forward the contents of this Website to persons under the legal age to purchase alcohol in the United States;
• Otherwise attempt to interfere with the proper working of the Website.

User Contributions The Website may contain message boards, chat rooms, personal web pages or profiles, forums, bulletin boards, or other interactive features (collectively, “Interactive Services“) that allow users to post, submit, publish, display or transmit to other users or other persons (hereinafter, “post“) content or materials (collectively, “User Contributions“) on or through the Website. All User Contributions must comply with these Terms of Use including the Content Standards set out below. Any User Contribution You post to the Website will be considered non-confidential and non-proprietary. By providing any User Contribution on the Website, You grant Us and our affiliates and service providers, and each of their and our respective licensees, successors and assigns the right to use, reproduce, modify, perform, display, distribute and otherwise disclose to third parties any such material for any purpose. You represent and warrant that You own or control all rights in and to the User Contributions and have the right to grant the license granted above to Us and our affiliates and service providers, and each of their and our respective licensees, successors and assigns. You understand and acknowledge that You are responsible for any User Contributions You submit or contribute, and You, not the Company, have fully responsibility for such content, including its legality, reliability, accuracy and appropriateness. We are not responsible, or liable to any third party, for the content or accuracy of any User Contributions posted by You or any other user of the Website. Monitoring and Enforcement; Termination We have the right to:

• Remove or refuse to post any User Contributions for any or no reason in our sole discretion.
• Take any action with respect to any User Contribution that We deem necessary or appropriate in our sole discretion, including if We believe that such User Contribution violates the Terms of Use, including the Content Standards, infringes any intellectual property right or other right of any person or entity, threatens the personal safety of users of the Website or the public or could create liability for the Company.
• Disclose your identity or other information about You to any third party who claims that material posted by You violates their rights, including their intellectual property rights or their right to privacy.
• Take appropriate legal action, including without limitation, referral to law enforcement, for any illegal or unauthorized use of the Website.
• Terminate or suspend your access to all or part of the Website for any or no reason, including without limitation, any violation of these Terms of Use.

Without limiting the foregoing, We have the right to fully cooperate with any law enforcement authorities or court order requesting or directing Us to disclose the identity or other information of anyone posting any materials on or through the Website. YOU WAIVE AND HOLD HARMLESS THE COMPANY AND ITS AFFILIATES, LICENSEES AND SERVICE PROVIDERS FROM ANY CLAIMS RESULTING FROM ANY ACTION TAKEN BY ANY OF THE FOREGOING PARTIES DURING OR AS A RESULT OF ITS INVESTIGATIONS AND FROM ANY ACTIONS TAKEN AS A CONSEQUENCE OF INVESTIGATIONS BY EITHER SUCH PARTIES OR LAW ENFORCEMENT AUTHORITIES. Because We cannot review all material before it is posted on the Website, to the extent permitted by law, We assume no liability for action or inaction regarding transmissions, communications or content provided by any user or third party. We have no liability or responsibility to anyone for performance or nonperformance of the activities described in this section. Content Standards These content standards apply to any and all User Contributions and use of Interactive Services. User Contributions must in their entirety comply with all applicable federal, state, local and international laws and regulations. Without limiting the foregoing, User Contributions must not:

• Contain any material which is defamatory, obscene, indecent, abusive, offensive, harassing, violent, hateful, inflammatory or otherwise objectionable, in Company’s sole discretion;
• Promote sexually explicit or pornographic material, violence, or discrimination based on race, sex, religion, nationality, disability, sexual orientation or age;
• Infringe any patent, trademark, trade secret, copyright or other intellectual property or other rights of any other person;
• Violate the legal rights (including the rights of publicity and privacy) of others or contain any material that could give rise to any civil or criminal liability under applicable laws or regulations or that otherwise may be in conflict with these Terms of Use and our Privacy Policy.
• Be likely to deceive any person;
• Promote any illegal activity, or advocate, promote or assist any unlawful act;
• Encourage or condone under-age drinking, drunk-driving, or excessive consumption of alcohol beverages;
• Impersonate any person, or misrepresent your identity or affiliation with any person or organization;
• Involve commercial activities or sales, such as contests, sweepstakes and other sales promotions, barter or advertising;
• Contain themes or images appealing to children, including Santa Claus;
• Depict anyone who appears to be or is younger than 21 years of age.

Reliance on Information Posted The information presented on or through the Website is made available solely for general information purposes. We do not warrant the accuracy, completeness or usefulness of this information. Any reliance You place on such information is strictly at your own risk. We disclaim all liability and responsibility arising from any reliance placed on such materials by You or any other visitor to the Website, or by anyone who may be informed of any of its contents. This Website may include content provided by third parties, including materials provided by other users, bloggers and third-party licensors, syndicators, aggregators and/or reporting services. All statements and/or opinions expressed in these materials, and all articles and responses to questions and other content, other than the content provided by the Company, are solely the opinions and the responsibility of the person or entity providing those materials. These materials do not necessarily reflect the opinion of the Company. We are not responsible, or liable to You or any third party, for the content or accuracy of any materials provided by any third parties. Links from the Website If the Website contains links to other sites and resources provided by third parties, these links are provided for your convenience only. This includes links contained in advertisements, including banner advertisements and sponsored links. We have no control over the contents of those sites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. If You decide to access any of the third party websites linked to this Website, You do so entirely at your own risk and subject to the terms and conditions of use for such websites. Geographic Restrictions We provide this Website for use only by persons located in the United States. We make no claims that the Website or any of its content is accessible or appropriate outside of the United States. Access to the Website may not be legal by certain persons or in certain countries. If You access the Website from outside the United States, You do so on your own initiative and are responsible for compliance with local laws. Disclaimer of Warranties YOU UNDERSTAND THAT YOUR USE OF THE WEBSITE, ITS CONTENT AND ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE IS AT YOUR OWN RISK. THE WEBSITE, ITS CONTENT AND ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS, WITHOUT ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. NEITHER THE COMPANY NOR ANY PERSON ASSOCIATED WITH THE COMPANY MAKES ANY WARRANTY OR REPRESENTATION WITH RESPECT TO THE COMPLETENESS, SECURITY, RELIABILITY, QUALITY, ACCURACY OR AVAILABILITY OF THE WEBSITE. WITHOUT LIMITING THE FOREGOING, NEITHER THE COMPANY NOR ANYONE ASSOCIATED WITH THE COMPANY REPRESENTS OR WARRANTS THAT THE WEBSITE, ITS CONTENT OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE WILL BE ACCURATE, RELIABLE, ERROR-FREE OR UNINTERRUPTED, THAT DEFECTS WILL BE CORRECTED, THAT OUR WEBSITE OR THE SERVER THAT MAKES IT AVAILABLE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS OR THAT THE WEBSITE OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE WILL OTHERWISE MEET YOUR NEEDS OR EXPECTATIONS. THE COMPANY HEREBY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS OR IMPLIED, STATUTORY OR OTHERWISE, INCLUDING BUT NOT LIMITED TO ANY WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT AND FITNESS FOR PARTICULAR PURPOSE. THE FOREGOING DOES NOT AFFECT ANY WARRANTIES WHICH CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW. Limitation on Liability IN NO EVENT WILL THE COMPANY, ITS AFFILIATES OR THEIR LICENSORS, SERVICE PROVIDERS, EMPLOYEES, AGENTS, OFFICERS OR DIRECTORS BE LIABLE FOR DAMAGES OF ANY KIND, UNDER ANY LEGAL THEORY, ARISING OUT OF OR IN CONNECTION WITH YOUR USE, OR INABILITY TO USE, THE WEBSITE, ANY WEBSITES LINKED TO IT, ANY CONTENT ON THE WEBSITE OR SUCH OTHER WEBSITES OR ANY SERVICES OR ITEMS OBTAINED THROUGH THE WEBSITE OR SUCH OTHER WEBSITES, INCLUDING ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, CONSEQUENTIAL OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO, PERSONAL INJURY, PAIN AND SUFFERING, EMOTIONAL DISTRESS, LOSS OF REVENUE, LOSS OF PROFITS, LOSS OF BUSINESS OR ANTICIPATED SAVINGS, LOSS OF USE, LOSS OF GOODWILL, LOSS OF DATA, AND WHETHER CAUSED BY TORT (INCLUDING NEGLIGENCE), BREACH OF CONTRACT OR OTHERWISE, EVEN IF FORESEEABLE. THE FOREGOING DOES NOT AFFECT ANY LIABILITY WHICH CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW. Indemnification You agree to defend, indemnify and hold harmless the Company, its affiliates, licensors and service providers, and its and their respective officers, directors, employees, contractors, agents, licensors, suppliers, successors and assigns from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses or fees (including reasonable attorneys’ fees) arising out of or relating to your violation of these Terms of Use or your use of the Website, including, but not limited to, your User Contributions, any use of the Website’s content, services and products other than as expressly authorized in these Terms of Use or your use of any information obtained from the Website. Governing Law and Jurisdiction All matters relating to the Website and these Terms of Use and any dispute or claim arising therefrom or related thereto (in each case, including non-contractual disputes or claims), shall be governed by and construed in accordance with the internal laws of the State of New York without giving effect to any choice or conflict of law provision or rule (whether of the State of New York or any other jurisdiction). Any legal suit, action or proceeding arising out of, or related to, these Terms of Use or the Website shall be instituted exclusively in the federal courts of the United States or the courts of the State of New York in each case located in the City of New York and County of New York. You waive any and all objections to the exercise of jurisdiction over You by such courts and to venue in such courts. Entire Agreement The Terms of Use and our Privacy Policy constitute the sole and entire agreement between You and Company with respect to the Website and supersede all prior and contemporaneous understandings, agreements, representations and warranties, both written and oral, with respect to the Website. Copyright and IP Agent for the United States If You believe that any use of intellectual property on the Website violates your copyright, please provide the following information, in writing, to the Copyright Agent named below:

• Your address, telephone number, and email address;
• A description of the copyrighted work that You claim has been infringed;
• A description of the alleged infringing activity and where the alleged infringing material is located;
• A statement by You that You have a good faith belief that the disputed use is not authorized by You, the copyright owner, its agent, or the law;
• An electronic or physical signature of the person authorized to act on behalf of the owner of the copyright interest; and
• A statement by You, made under the penalty of perjury, that the above information in your Notice is accurate and that You are the copyright owner or authorized to act on behalf of the copyright owner’s behalf.

  Copyright Agent Last Modified: January 2023

Privacy Policy Highlights of Privacy Statement Below are the Privacy Statement Highlights from ZONIN USA, Inc. and its affiliates within the ZONIN1821 family of brands. This Privacy Statement describes how ZONIN USA, Inc. brands (hereinafter” “We,” or “Us”) treat personal information on our websites, applications, and platforms in the United States. Please read the full Privacy Statement for full details explaining how We handle the information We collect from you.

Who we Are:	We are the largest subsidiary of ZONIN1821, a leading producer of premium wines. Details of ZONIN1821’s brands can be found here: https://www.zonin1821.com
Personal and other Information:	We will collect information about you (“Personal Information”) that may be used to identify, contact and locate you. In many cases, We collect the information directly from you. We may also collect information about how you interact with Us online via cookies and other automated means. We may also combine the information We collect from you with information obtained from other sources to help Us know Our customers better.
Uses:	We use your Personal Information to fulfill your requests for products, services and information, deliver marketing communications, send personalized content, including interest-based ads, administer promotions and sweepstakes and for other everyday business purposes, such as making back-ups and for legal compliance.
Disclosures:	Your Personal Information may be shared and/or disclosed: • to Us and Our affiliates who may use it only for the purposes listed in this Privacy Statement, including for their own marketing purposes, • to Our service providers who only use it to perform the services We have requested, or • when required to do so by law or in connection with the sale of Our business. We will never share your Personal Information with unaffiliated third parties for their own marketing unless you have given Us your consent.
Your Choices:	You can opt out of receiving marketing communications and interest-based ads.
Important Information:	Your Personal Information may be processed in other countries, but We will take all appropriate measures to protect the privacy and security of your Personal Information no matter where it is processed. Please see European Union and International Privacy Matters for more information on where your Personal Information may be processed. If you are a California Consumer, please see the California Privacy Rights section for more information about how to exercise your rights. How to Contact Us: marketing@1821fws.com

Privacy Statement Last Updated: January 2023 ZONIN USA, Inc is an affiliate of the ZONIN1821 family of brands (hereinafter “We” or “Us” or “Our”). We respect your right to privacy. We have developed this Privacy Statement to inform you how We handle the Personal Information you provide to Us. We may update this Privacy Statement from time to time. If We make any material changes to this Privacy Statement, We will notify you by sending a notice to the primary email address provided to Us or by posting the revised Privacy Statement on Our website.

1. What types of Personal Information do We collect and how do We collect it?

This Privacy Statement explains Our practices with regard to “Personal Information.” Personal Information is any information that can be used to identify, locate or contact you. We collect the following types of Personal Information:

• Contact Information that allows Us to communicate with you, such as your name, username, mailing address, telephone numbers, country of residence, email address or other addresses that allow Us to send you messages, and any other identifier that permits the physical or online contacting of a specific individual.
• Relationship Information that helps Us do business with you, such as your age, demographics and interests as well as your brand and marketing preferences.
• Transaction Information about how you interact with Us including your purchase history, customer account information.
• Usage Information about how you use Our websites and mobile applications and your location when you do so, to give Us a better idea of how you interact with Our brands and content.

In many cases, We collect Personal Information directly from you. We may ask you for Personal Information when you interact with Us, such as registering on Our websites, liking Us on social media, signing up to receive promotions or joining a wine club. We may also obtain additional information from third party data suppliers who enhance Our files and help Us better understand Our customers.

2. How do We use your Personal Information?

We use your Personal Information to:

• Fulfill your orders for products, services, and related activities, such as send you communications related to your order, respond to your inquiries, perform age verification, product and service delivery, customer service, account management, support and related training of Our personnel involved in such activities, and to provide other services related to your account;
• Develop Our relationship with you such as by delivering personalized content;
• Provide you with marketing communications and offers for products and services from Us and, in some cases, Our partners, including for offers targeted based on your interests or location;
• Administer market research, surveys and promotional events that you may voluntarily choose to join;
• Match it with other public and private data sources in order to enhance Our records, such as appending additional information to your profile, or the records of Our business partners. We also may work with other providers who also possess information about you in order to reach you through different methods and platforms, such as on a social media platform that you use; and
• Manage Our everyday business needs, such as payment processing and financial account management, product development, contract management, website administration, forum management, fulfillment, analytics, security and fraud prevention, corporate governance, reporting and legal compliance.

If We intend to use your Personal Information in a manner materially different than as set out in this Privacy Statement, We will provide you with information on that other purpose prior to that use.

3. When is your Personal Information disclosed to others?

We understand that you may not want Us to provide your Personal Information directly to third parties for their own marketing purposes without your consent. We limit Our sharing of your Personal Information as follows:

• We may share your Personal Information with, or otherwise make it available to, Our affiliates, who may only use your Personal Information in compliance with this Privacy Statement.
• We may share your Personal Information with Our service providers, who are instructed to only use your Personal Information in accordance with Our instructions.
• We may share your Personal Information with unaffiliated joint marketing partners, but only if you have given Us your consent.
• We may also disclose Personal Information where needed to affect the sale or transfer of business assets, in connection with a bankruptcy proceeding, to enforce Our rights, protect Our property, or protect the rights, property or safety of others, or as needed support external auditing, compliance and corporate governance functions. We may also disclose Personal Information when required to do so by law, such as in response to a subpoena, including to law enforcement agencies and courts in the countries where We operate.

Please note that We may also use and disclose information about you that is not personally identifiable i.e. Personal Information in an aggregate form that no longer identifies you.

4. Cookies and Other Data Collection Technologies

When you visit Our website, We collect certain Transaction Information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs, web beacons and more. Cookies When you visit Our website, We place cookies on your device. Cookies are small text files that websites send to your device or other Internet-connected devices to uniquely identify your browser or to store information or settings in your browser. Cookies allow Us to recognize you when you return. They also help Us provide a customized experience and enable Us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available. Flash Cookies We may use Flash Cookies (also known as Local Stored Objects) and similar technologies to personalize and enhance your online experience. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation. We use Flash cookies for security purposes and to help remember settings and preferences similar to browser cookies, but these are managed through a different interface than the one provided by your web browser. To manage Flash cookies, please see Adobe’s website at http://kb2.adobe.com/cps/526/52697ee8.html or visit www.adobe.com. Pixel Tags and Web Beacons Pixel tags and web beacons are tiny graphic images placed on website pages or in Our emails that allow Us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow Us to measure response to Our communications and improve Our web pages and promotions. Types of Data We Collect We collect many different types of information from cookies and other technologies. For example, We may collect information about the device you use to access Our website, your operating system type, browser type, referring domain, and other system settings, as well as the language your system uses and the country, state, zip code and time zone where your device is located. Our server logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to US and the website you visit after you leave Our site. In many cases, the information We collect using cookies and other tools is only used in an aggregated or non-identifiable way, without any reference to Personal Information. For example, We use information We collect about all website users to optimize Our websites and to understand website traffic patterns. In some cases, We do associate the information We collect using cookies and other technology with your Personal Information. This Privacy Statement governs how We use this information when We associate it with your Personal Information. Third Party Advertisers and Interest-Based Ads We may allow third parties to collect information about the users of Our website. Such third parties may collect Personal Data about your online activities over time and across different websites when you use Our website, also known as online behavioral advertising. We have relationships with Google and other third-party advertising companies to deliver interest-based advertisements, targeted to you based on your demographics, brand preferences, online behavior and similar factors. These companies may also perform tracking and reporting functions for Us on this website and other websites. These companies may place cookies on your device when you visit Our website or other websites so that they can display targeted advertisements to you. These companies do not collect Personal Information in this process, and We do not give any Personal Information to them as part of this process. However, this Privacy Statement does not cover the collection methods or use of the information collected by these companies. For more information about interest-based advertising, please visit the Digital Advertising Alliance (DAA) at www.aboutads.info/consumers. We comply with the Self-Regulatory Principles for Online Behavioral Advertising as administered by the DAA. To opt out of being targeted by some third party advertising companies, you may visit www.aboutads.info/choices . We may work with third parties that use algorithms to determine if you have interacted with Our services on multiple devices and to match such devices together. We may then display interest-based advertisements to you across your devices or otherwise use the combined data for purposes under this Privacy Statement. For example, if you exhibit certain behaviors on your desktop computer, We may serve interest-based advertisements to you on your smartphone based upon those behaviors if We have linked both of those devices to you. If you would like to opt-out of such cross device matching, please visit the Digital Advertising Alliance (DAA) at www.aboutads.info/consumers. While We do provide the ability to opt-out of certain targeting advertising as described in this Privacy Statement, We do not respond to “do not track” (a/k/a DNT) signals or similar mechanisms transmitted by web browsers. To learn more about browser tracking signals and Do Not Track please visit http://www.allaboutdnt.org/.

5. Your Choices

You can always limit certain information you provide to Us. You can also limit the communications that We send to you. To opt-out of emails, simply click the link labeled “unsubscribe” at the bottom of any email We send you. Please note that even if you opt-out of promotional messages, We may still need to contact you with important transactional information about your account. For example, even if you opt-out of emails, We may still send you order confirmations and shipping notices. You can exercise certain choices with respect to interest-based ads as set forth above in the “Third Party Advertisers and Interest-Based Ads” section. You may request that We delete your Personal Information from Our active records. We will make reasonable efforts to honor such requests, provided that, We may retain archived information and are unable to remove your Personal Information from the records of any third parties with whom the information has previously been shared in compliance with this Policy Statement. Please contact Us with any such requests.

6. Access, Correction, and Other

We respect your right to access and correct your Personal Information. If you have an online account, you can log into your account at any time to access and update the information you have provided to Us. If you need assistance updating your Personal Information, please contact Us.

7. Information Security and Retention

We take all appropriate technical and organizational measures to protect the confidentiality and security of your Personal Information. We have implemented an information security program that contains administrative, technical and physical controls that are reasonably designed to safeguard your Personal Information. For example, We use industry-standard encryption technology to secure Personal Information consisting of credit card numbers and other payment information when it is being collected and transmitted over the Internet as well as firewalls, site monitoring and intrusion detection software. We retain your Personal Information for as long as your account is active, or as long as needed for the business purposes described in this Privacy Statement, in accordance with applicable legal standards. Other recipients of your Personal Information who have been provided with such information in compliance with this Privacy Statement may retain your data for longer periods to fulfil the purpose for which your Personal Information was shared with them, or for their own compliance, dispute resolution, enforcement, or record management purposes.

8. European Union and International Privacy Matters

This section describes the additional commitments that apply to your Personal Information if you are located in the European Union and your data is processed by Brand outside the European Union, or if your data is processed by a Brand established in the European Union:

• We will use your Personal Information as described in this Privacy Statement as necessary (i) for the performance of any contract between you and Us, where you have made a purchase, including in order to process your payment, make a delivery, respond to any customer service requests, (ii) with your consent where required by law, for instance to send you marketing communications or administer surveys and other promotional events, (iii) to comply with Our legal obligations, notably in terms of payment processing, financial account management, fraud prevention, legal compliance, and (iv) to further Our legitimate interests including Our legitimate interest in better serving you and improving Our services, improving Our communication with you, and ensuring the accuracy of the information We hold about you.
• Where Our processing of your Personal Information listed above is not based on your consent or Our legitimate interests (i.e. is necessary for the performance of a contract or required to fulfil Our legal obligations), failure to provide any of the requested Personal Information may result in Us being unable to process your order or respond to your request, and certain features of Our website and/or application may not be available.
• We will seek your consent to use and process your Personal Information when required to do so by applicable law. In such case, you may withdraw such consent at any time by contacting Us or opting out where applicable.
• We may conduct profiling activities based on your interests and your browsing on Our web sites to better serve you and provide you with targeted marketing information on Our products in accordance with your tastes. You may opt out at any time when receiving such information. We respect your right to restrict or object to the processing of your Personal Information, as well as your right to data erasure and portability. To exercise these rights, please contact Us. You also have the right to lodge a complaint with the competent supervisory authority.
• We will always protect the privacy and security of your Personal Information in accordance with this Privacy Statement as well as with any applicable laws, regardless of where it is processed or stored.
• We will keep your data as long as required by applicable law for the purpose for which the data was collected.
• The categories of data recipients include, but are not limited to Our marketing departments and relevant services providers (not namely mentioned) depending on the purposes of the data processing.

Such recipients of your Personal Information may be located outside of the EU. Therefore, where We transfer your Personal Information to a country that may not present an adequate level of protection according to EU law, We may rely on contracts based on the European Commission’s standard contractual clauses. If you would like more information on these contracts, please contact Us.

9. Rights of California Users

If you are a California user, you have certain rights with respect to the collection, use, transfer, and processing of your “Personal Information”, as defined by the California Consumer Privacy Act (CCPA). We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others. To exercise any of the rights below, please contact Us via the contact information below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. Collection of Personal Information When California Consumers access the ZONIN1821 websites, purchase ZONIN1821 products, visit one of Our physical locations, participate in our marketing research, seek employment with ZONIN1821, or become a ZONIN1821 employee, We may collect the following Personal Information. Personal Information / Identifiers

• Name
• Address
• Email Address
• Telephone number
• Date of Birth
• Social Security number

Other Personal Information (Financial Information)

• Credit Card Number
• Routing and bank account number

Characteristics of protected classifications

• National Origin
• Gender
• Race
• Ethnicity
• Disability
• Age
• Marital Status

Employment Information

• Title
• Employment History
• Salary
• Performance Review
• Resume
• 401k Contributions
• Background Checks

Commercial Information

• Purchase history

Internet or other electronic network activity information

• Browsing history
• Search history
• Information regarding a consumer’s interaction with an Internet Web site, application, or advertisement
• Internet Protocol address
• Device ID
• Cookies
• Beacons
• Pixel Tags
• Mobile Ad Identifiers

Location Data The foregoing pieces of Personal Information may have been collected about Our consumers in the past 12 months: Sources from which Personal Information is Collected We collect your identifiers, other personal information (financial information), characteristics of protected classifications, and employment information from you directly. We may also collect your identifiers from third party data suppliers. Certain pieces of employment information and other personal information (medical/health) are generated by Us when you become an employee. We collect your commercial information by keeping a log of your transactions. We collect your internet or other electronic network activity information and location data from your interactions with Our website. We also collect certain identifiers, characteristics of protected classifications, and commercial information from third party data suppliers. Business or Commercial Purposes for which Personal Information is Collected Your Personal Information is used for the following purposes:

• Fulfill your orders for products or services and for related activities, such as send you communications related to your order, respond to your inquiries, perform age verification, product and service delivery, customer service, account management, support and related training of Our personnel involved in such activities, and to provide other services related to your account;
• Develop Our relationship with you such as by delivering personalized content;
• Provide you with marketing communications and offers for products and services from Us and, in some cases, Our partners, including for offers targeted based on your interests or location;
• Administer market research, surveys and promotional events that you may voluntarily choose to join;
• Match your Personal Information with other public and private data sources in order to enhance Our records, such as appending additional information to your profile, or the records of Our business partners. We also may work with other providers who also possess information about you in order to reach you through different methods and platforms, such as on a social media platform that you use; and
• Manage Our everyday business needs, such as payment processing and financial account management, product development, contract management, website administration, forum management, fulfillment, analytics, security and fraud prevention, corporate governance, reporting and legal compliance.
• Provide you with customer support and respond to your communications.
• Reserve tours or rooms at one of Our properties.
• Send you transactional or administrative communications as well as certain service-related announcements.
• Run website analytics to evaluate performance.
• Fulfill Our responsibilities as an employer.

Third Party Data ZONIN1821 shares your Personal Information with affiliates, analytics and service providers, benefits providers, transactions processors, unaffiliated joint marketing partners, and law enforcement (if necessary). In the preceding 12 months, We have not sold Personal Information about consumers nor minors. In the preceding 12 months, We have disclosed the following Personal Information about consumers for business purposes:

• We disclose this Personal Information to Our service providers to allow them to perform services on behalf of ZONIN1821 such as maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, providing employee benefits, fulfilling our responsibilities as an employer, and processing payments.
  • Identifiers,
  • Characteristics of protected classifications,
  • Other Personal Information (Financial Information),
  • Other Personal Information (Medical/Health),
  • Employment Information, and
  • Commercial Information.
• We disclose this Personal Information to service providers to assist ZONIN1821 by providing advertising, marketing, and analytics services. (more information located in the “Cookies and Other Data Collection Technologies” section above).
  • Internet or other electronic network activity information.
  • Identifiers
  • Location data
• We disclose this Personal Information to detect security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
  • Identifiers
  • Other Personal Information (Financial Information)
  • Commercial Information
• We share with or allow third parties to conduct auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
  • Internet or other electronic network activity information.

Individual Rights You have the right to request that ZONIN1821 disclose the Personal Information it collects, uses, and discloses about you to third parties over the previous 12 months. There are two types of Right to Know requests you can make:

• 1. Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
  • a. Categories of Personal Information We collected;
  • b. Categories of sources from which We collected Personal Information;
  • c. Business purpose for collecting or selling that Personal Information;
  • d. Categories of third parties with whom We share or sell Personal Information; and
  • Categories of Personal Information We disclosed for a business purpose, and for each category of Personal Information disclosed, the categories of third parties to whom received that particular category.
• 2. Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
  • a. Specific pieces of Personal Information collected about you.

ZONIN1821 does not sell any Personal Information of California consumers. This information will be provided to you free of charge, unless ZONIN1821 determines that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period. Right of Deletion You have the right to request that ZONIN1821 and Our service providers delete any Personal Information about yourself, which ZONIN1821 has collected from you upon receipt of a verifiable request. This right is subject to the same exceptions as for Right to Know requests. Submitting and Verifying Requests You may submit a request via email at marketing@1821fws.com. ZONIN1821 provides California Consumers with the ability to submit requests through our request website, our telephone number, and our email address. ZONIN1821 must verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request. To verify a California Consumer’s identity, we may request up to three pieces of Personal Information about you when you make a request to compare against our records. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. ZONIN1821 reserves the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent. Authorized Agent You may choose a person or business entity registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, ZONIN1821 requires that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with ZONIN1821 representative. Failure to do so may result in ZONIN1821 denying your request. Right to Equal Service ZONIN1821 will not discriminate against you because you exercised any of your rights, including, but not limited to, by:

• Denying goods or services to you.
• Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
• Providing a different level or quality of goods or services to you.
• Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

10. Personal Information of People Under the Legal Age

We do not intend to collect Personal Information from any individuals under the legal purchase age, or to market alcoholic beverages to anyone under the legal purchase age. Please do not provide Us with your Personal Information if you are not of legal age to purchase alcohol in the jurisdiction in which you reside and (if different) in the jurisdiction in which you are interacting with Us. If We receive notice or believe that someone under the legal purchase age has provided Us with Personal Information, We will use reasonable efforts to remove such Personal Information from Our files, or to flag such Personal Information and (to the extent permitted by law) retain it for the sole purpose of ensuring that it is no longer used.

11. Privacy Policies of Third Parties

This Privacy Statement only addresses the use and disclosure of information by Us. Other websites that may be accessible through this website have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion. If you interact with Us on social media platforms, such as Facebook or Instagram, those interactions are also governed by the terms and privacy policies of the social medial platform providers.  

12. Forums and Other Public Areas

Our websites may provide forums and other areas where you can communicate with others and publicly post information, such as reviews. Prior to posting in these areas, please read the Terms of Use carefully. All the information you post can be seen by anyone with Internet access, and any Personal Information you include in your posting may be read, collected, and used by others. For example, if you post your email address, you may receive unsolicited messages from others. Please use caution when posting any Personal Information in the public areas.

13. How to Contact Us

Please contact Us if you have any questions or comments about Our privacy practices or this Privacy Statement. You can always reach Us online at marketing@1821fws.com    Cookies Policy When required by applicable law, our website uses cookies and similar technologies (“cookies”). This Cookies Policy (the “Policy”) describes how Zonin® Prosecco, is committed to respecting your privacy regarding its use of cookies on its websites, applications, pages on social media etc. (the “Digital Media”). Before using our Digital Media, please read carefully this Cookie Policy (including the Privacy Policy). If you do not agree to this Cookies Policy or the Privacy Policy, do not use our Digital Media.    We reserve the right to make changes to this Cookies Policy or the Privacy Policy at any time. Such change should occur in a near future to take into account the e-Privacy Regulation provisions which is currently debated at the EU Parliament level. The purpose of this Policy is to reflect the rules which are applied now by ZONIN1821 until the e-Privacy Regulation is definitively applicable. We will notify you of such changes to this Cookies Policy or the Privacy Policy. You are thus invited to regularly read this Cookies Policy or the Privacy Policy to make sure you are aware of any change and how your Personal Data may be used.    What is a cookie? Cookies are small text files or pieces of information that are stored on your computer or mobile device (such as a smartphone or tablet) when you visit our Digital Media. A cookie will usually contain the name of the website/application from which the cookie has come from, the duration of the cookie (i.e. how long the cookie will remain on your device), and a value, which is usually a randomly generated unique number.    Why do we use cookies?   We use cookies to make our Digital Media easier to use and to better tailor our Digital Media and our products to your interests and needs. Cookies can do this because our Digital Media can read and write these files, enabling them to recognize you and remember important information that will make your use of our Digital Media more convenient (for example by remembering preference settings). Cookies may also be used to help speed up your future activities and experience on our Digital Media. We also use cookies to compile anonymous, aggregated statistics that allow us to understand how users use our Digital Media and to help us improve the structure and content of our Digital Media.   What are the different types of cookies we use? The types of cookies that we may use can be either session or persistent, or first party or third party cookies. Persistent cookies are used to save your login information and remember your settings for future logins to our Digital Media. A persistent cookie is a cookie stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the Digital Media that created it when you visit it again.  Session ID cookies are used to enable certain features of our Digital Media and services, to better understand how you interact with our Digital Media and to monitor aggregate usage and web traffic routing. Unlike persistent cookies, session cookies are deleted from your computer when you close your browser. They usually store an anonymous session identifier on your computer allowing you to browse a website / application (for example) without having to log in to each page.   First party cookies are our own cookies, which we use to improve your experience. They are associated with a user’s Personal Data. No third party has access to the information we collect through our own cookies.   Third party cookies are cookies placed on our Digital Media by third parties to provide their services, including advertising cookies. They set cookies (third party cookies) on your device on our behalf when you visit our Digital Media to allow them to deliver the services they are providing. You will find more information about these cookies in their privacy policies.   You will find below a list of the different types of cookies we use on our Digital Media. To the extent information collected through cookies constitutes Personal Data, the provisions in the Privacy Policy apply in addition to this Cookie Policy.   Essential Cookies Essential cookies are first party cookies which are strictly necessary for our Digital Media to work and to use its services and features.  Without these cookies, our Digital Media will not perform as smoothly for you as we would like it to and we may not be able to provide the Digital Media or certain services or features thereof you request. We also use technical cookies which allow our Digital Media to remember choices you make (such as your user name, language or the region you are in) for customization and personalization purposes. These cookies do not gather any information about you that will be used for advertising purposes or to remember your browsing history on the internet. 

Who is placing the cookie ?	Type	Description/purpose
ZONIN1821	Persistent cookie	Cookie Policy Visibility Cookies: With your permission to enter our site, ZONIN1821 installs a cookie on your computer which indicates whether or not you have been informed of the use of cookies through a banner notice being displayed, and then whether you have indicated your consent to the use of cookies by continuing to use the website/application or service, so that the banner will not continue to show every time you visit a page.
ZONIN1821	Persistent cookie	Device Identifier Cookie: ZONIN1821 installs a cookie on your computer which identifies you and tells the Website/application that you are logged in.
ZONIN1821	Persistent cookie	User Local Cookie: ZONIN1821 installs a cookie which is used to remember local specific selections made by you such as language preferences.
Google Tag Manager	Persistent cookie	Streamlines the process of creating tags to send user interaction data to Google Analytics.

These cookies are necessary to the operation of our Digital Media, are considered as non-privacy intrusive cookies improving internet experience and therefore they do not necessitate consent and you cannot opt-out to their use. Social Media Plug-in Cookies We use buttons to enable sharing of pages with social networking sites. These buttons may place a third-party cookie on your device, which could gather usage information. Our Digital Media uses the following social media cookies:

Who is placing the cookie	Type	Description/purpose
Facebook	Persistent cookie	Facebook Social Media Button: Cookies are used to facilitate the sharing of content of our Digital Media on Facebook.
Instagram	Persistent cookie	Instagram Social Media Button: Cookies are used to facilitate the sharing of content of our Digital Media on Twitter.

To opt out of being tracked by the Facebook and Instagram Social Media Button on all the websites you visit, go to the General Account Settings of your Facebook and Instagram accounts, locate and click the opt-out link.  Analytics Cookies Our Digital Media may also use Google Analytics cookies. These third-party cookies collect information about how you use and move around our Digital Media. For example, these will keep track of what pages are most visited, Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, to administer the Digital Media, to track users’ movements around our Digital Media and to gather demographic information about our user base as a whole. To opt out of being tracked by Google Analytics cookies on all the websites you visit, go to http://tools.google.com/dlpage/gaoptout. Marketing and profiling cookies We work with third-party advertising companies to serve ads while you are visiting our Digital Media and permit these companies to place and access their own cookies on your device in the course of serving advertisements on our Digital Media. These companies may use information obtained through their cookie (which does not include your name, address, e-mail address or telephone number) about your visits to our and other websites/applications, in combination with non-personally identifiable information about your purchases and interests from other online sites in order to provide advertisements about goods and services of interest to you.  Flash cookies We also use Flash Cookies (also known as Local Stored Objects) and similar technologies to personalize and enhance your online experience. You can learn how to manage Flash Cookies by visiting the following website: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager06.html. Please note that rejecting Flash cookies is likely to mean that our Digital Media will not operate properly and accordingly you will not be able to take full advantage of the Digital Media. How long are cookies stored?  Cookies will have a maximum retention period after being placed on the user’s terminal as required by applicable law.  How to control cookies on our Digital Media?  Except for cookies which qualify as essential, the cookies described above will be installed on your computer only if you continue your browsing after having read the banner appearing on the home page.  You can also control how your browser uses cookies and your browser’s ‘Help’ function should be able to tell you how to do this.  Please note that depending on the cookies you disable, you may not be able to view content or use other features of our Digital Media and may find that parts of our Digital Media either do not function at all or behave unexpectedly. If you use different devices to view and access our Digital Media (e.g. your computer, smartphone, tablet etc.) you will need to ensure that each browser on each device is adjusted to suit your cookie preferences. How to contact us ?  If you have any questions, comments, or concerns about your our use of cookies please contact marketing@1821fws.com Last Update: January 2023

Interest-Based Ads

We use your browsing history and other non-personal information collected on this website and third party sites to display interest-based advertising that we believe is relevant to you. We may also share your browsing history from our website and non-personal information with third parties to provide such relevant ads. They may combine this information with other data sources in order to tailor ads to you. If you would like to know more about how we use and share your information, please see our privacy policy. We comply with the Self-Regulatory Principles for Online Behavioral Advertising set forth by the Digital Advertising Alliance (DAA). You can opt out of interest-based advertising from third party providers who follow the DAA principles at www.aboutads.info/choices. Responsibility Responsibility Statement The Zonin Prosecco (ZP) and all companies within the ZONIN1821 group have a longstanding tradition of promoting responsible drinking. Responsibility is of a particular importance given the sensitive products we deal with. Our products are for most people associated with pleasure, enjoyment and socializing, but can have quite the opposite effect when not handled responsibly. Thus, all our marketing activities are conducted with care for the consumer. As a company we also have a responsibility for how we act in relation to the world around us and the society we live in. We strive to always act in a way that shows that we deserve the confidence and appreciation of our stakeholders, no matter who or where they are. Through a broad spectrum of initiatives, often in partnership with outside organizations, including industry associations, regulators, public authorities and representatives, we as well as our affiliates are deeply committed to promoting responsible drinking and discouraging misuse of our products. User Generated Content Policy As a consequence of our commitment to promoting responsible drinking, we hope you understand that we expect that users will not post any comments, photos, videos and other types of content (“Post”) which:

• Feature any people who are or appear to be under the legal drinking age, including featuring any people who are associated with drinking, who are not, or who do not appear to be, over legal drinking age;
• Is made by someone under the legal drinking age;
• Encourages underage purchase or drinking of alcoholic beverages or illegal, irresponsible or immoderate drinking;
• Promotes over-consumption or condemns or criticizes in any way anyone who chooses not to drink alcohol;
• Portrays irresponsible drinking in a positive light or associates drinking with driving, operating any kind of machinery or engaging in any kind of dangerous activity;
• Implies alcoholic beverages have any physical, psychological, intellectual benefits or contributes to sexual success; 
• Glorifies the alcohol strength, relatively high alcohol content or intoxicating effect of a drink;
• Mentions drinking alcohol in relation to any kind of illegal, antisocial, dangerous, aggressive or violent behavior;
• Feature copyrighted logos, products or characters other than our brands;
• Contains offensive language or gestures; or could be seen as offensive on the basis of gender, race, sexual orientation, religion, or culture; or is a personal attack on another user, individual or company.

Should your Post not comply with the above we reserve the right to remove it.  We believe responsible drinking is consistent with the maintenance of a balanced and positive lifestyle for most adults who choose to drink. For this reason, we would like to recommend the following reading: Distilled Spirits Council of the United States DISCUS, the spirits EUROPE Guidelines for the Development of Responsible Marketing Communications and ZONIN1821 commitments.  WEBSITE FOOTER ©2023. ZONIN USA, Inc. Aventura, FL. All Rights Reserved. The site is protected by reCAPCHA and the Google Privacy Policy and Terms of Service.  NEWSLETTER SIGNUP FORM:  ZONE-IN ON THE MOMENTS THAT MATTER MOST Stay updated on all that’s happening with Zonin Prosecco. You’ll get special access to the latest news, promotions, events and surprises first! Top of Form Enter your email address to Zone-InTM on our Insider List Bottom of FormBottom of Form