At Invintory Wines Incorporated ("Invintory Wines", "us", "we", or "our") we are committed to maintaining the accuracy, confidentiality and security of your personal information. We have developed this Privacy Policy to describe our privacy policies and practices and how we collect, use and disclose the personal information of those individuals who visit our website (which includes use of our mobile application). We have developed other documents that describe our privacy policies and practices with respect to our employees and with respect to our customers, suppliers and other parties with whom we interact.
If you are unsure of which Privacy Policy applies to you, please contact our Privacy Officer for more information.

Privacy Policy Effective for Canada

It is Invintory Wines's policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and/or an individual's right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada's federal and Ontario's provincial privacy laws, as applicable.This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. If you are unsure if or how this Privacy Policy applies to you, please contact our Privacy Officer for more information.

What is Personal Information?

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than the person's business title or business contact information when used or disclosed for the purpose of business communications.

What Personal Information Do We Collect?

You can visit our website without telling us who you are or revealing any information about yourself, including your email address. Our web server may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page that is viewed by that IP address and what country you are from. We use this information to monitor our website's performance (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our website.

We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes:

• contact and identification information, such as your name, location, address, telephone number and email address

• demographic information;

• information about your tastes, habits, and preferences, for example, information about your wine collection;

• product and service related information concerning the products and services that we provide to, or receive from, you; and

• business relationship information, including information related to your agreements, preferences, advisors and decision-makers, feed-back and information requested by or provided to you.

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning. We may also collect information related to our media, investor and public relations activities and information related to our interactions with financial and other analysts and advisors.As a general rule, Invintory Wines collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).From time to time, we may use the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

In addition, we collect the personal information that you submit to our website that you choose to provide by:

• using the "contact us" portion of this website;

• applying for a position with Invintory Wines through this website; or

• by corresponding with a representative of Invintory Wines via email using the hyperlinks created for that purpose.

Where you request information from us, we may use the email address that you provide to send you information about offers on products and services that we believe may be of interest to you. If you have asked us to put you on an email mailing list to provide you with certain information on a regular basis, or if we send you information about our offers on products and services by email, you may ask us to remove you from the list at any time (using the unsubscribe instructions provided with each email and on the site where you signed up).

Children's Privacy

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children without verification of parental consent, we take steps to remove that information from our servers.

How Do We Use Cookies?

When you visit the website, we place a "cookie" on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. Cookies act as identification cards and allow our website to identify you and to record your passwords and preferences. Cookies allows us to track your visit to the website so that we can better understand your use of our website so that we can customize and tailor the website to better meet your needs. Examples of cookies we use include session cookies, preference cookies, and security cookies.Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (1) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (2) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you will not be able to access a number of web pages found on the website.

What about Links to other Websites?

Our website may contain links to other websites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. Invintory Wines is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information

Why Do We Collect, Use, and Disclose Personal Information?

The personal information collected is used and disclosed for our business purposes, including for those purposes explained in this policy.

Invintory Wines collects personal information to enable us to manage, maintain, and develop our business and operations, including:

• to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested (for example, we will use your personal information to establish your identity and location so that we may perform our obligations or exercise our rights under agreements you have entered into with us);

• to notify you about changes to our services;

• to provide customer support;

• to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;

• to be able to review the products and services that we provide to you so that we may understand your requirements for our products and services and so that we may work to improve our products and services;

• to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;

• to be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);

• to protect us against error, fraud, theft and damage to our goods and property;

• to enable us to comply with applicable law or regulatory requirements; and

• any other reasonable purpose to which you consent.

Your personal information is shared with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with establishing, maintaining and managing our relationship with you. In addition, personal information may be disclosed or transferred to another party in the event of a change in ownership of, or a grant of a security interest in, all or a part of Invintory Wines.For example, Google, Firebase, Amplitude, and our other affiliates and service providers may provide certain information technology and data processing services to us from time to time so that we may operate our business, and as result, your personal information may be collected, used, processed, stored or disclosed in the United States of America and Canada.

When do we Disclose Your Personal Information?

We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including: third parties that provide services to us or on our behalf; third parties that assist Invintory Wines in the provision of services to you; and third parties whose services we use to conduct our business.In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of Invintory Wines through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

Further, your personal information may be disclosed

• as permitted or required by applicable law or regulatory requirements

• to comply with valid legal processes such as search warrants, subpoenas or court orders;

• as part of Invintory Wines's regular reporting activities to its parent and affiliated companies;

• to protect the rights and property of Invintory Wines;

• during emergency situations or where necessary to protect the safety of a person or group of persons;

• where the personal information is publicly available; or

• with your consent.

Your Consent is Important to Us

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.By using our website, we assume that you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

Choice/Opt-Out

You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer using the contact information set out below. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide products or services to, or acquire products or services from, you. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

How is Your Personal Information Protected?

Invintory Wines endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while this website strives to protect your personal information, we cannot warrant the security of any information you transmit to us, and you do so at your own risk. Once this website receives your transmission, we make commercially reasonable efforts to ensure its security on our systems.The security of your personal information is important to us, please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control

Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Access to Your Personal Information

You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact our Privacy Officer using the contact information set out below. Please note that any such communication must be in writing.When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer.Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.

Inquiries or Concerns?

If you have any questions or concerns about our Privacy Policy please contact our privacy officer at [email protected].  We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

Revisions to this Privacy Policy

Invintory Wines from time to time may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website https://invintorywines.com/privacy-policy and we encourage you to refer back to it on a regular basis.

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word "including" is used, it shall mean "including without limitation".This Privacy Policy does not create or confer upon any individual any rights, or impose upon Invintory Wines any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada's federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.