This Privacy Policy applies to the Pearl Vodka Site at http://www.pearlvodka.com/home.html home page, the splash page, Pearl News, Find Pearl Near You, Pearl Flavors and Recipes, Press Coverage, Product Specifications, Luxco Importer, Reviews and Ratings, Recipes, Contact US, Request Imagery, Distributors, Club Restaurants and Stores, Featured Recipe and all other pages under the same top level domain name, and all content thereon (the "Site"). The Pearl Vodka Site is provided to you by Luxco, ("Luxco" or "we"). Luxco is the exclusive U.S. licensee of the Pearl Vodka brand of products.

COLLECTING INFORMATION:

Personally Identifiable Information
This Site requests and collects certain personally identifiable information such as name, address, phone number and e-mail address through various means, such as Site registration, surveys, questions, comments and communications to and from the Site.

Non-Personally Identifiable Information
We also collect certain non-personally identifiable information at our Site, such as annual income, and buying preferences, also known as demographic or profile data, though this information is optional.

Information of Children
The Children’s Online Privacy Protection Act (COPPA) requires that we ask for the birth date of each Site user before we can allow that user to access this Site. Please enter the date carefully. If you are under legal age to purchase beverage alcohol in your jurisdiction, you should not submit any information about yourself on this Site. We do not knowingly collect personal information from anyone under the legal age to purchase beverage alcohol.

Cookies:
"Cookies" are pieces of information that are placed on an individual's computer hard drive to enable the individual to more easily communicate and interact with the Site. We may use cookies to customize your experience on the Site. We may also use cookies to record how many times a user has visited our Site and what pages the user has accessed. You may, however, disallow receiving cookies at any time through your web browser. It is not our intention to use cookies to retrieve information that is unrelated to our Site or your interaction with our Site.

IP Address
We may collect your IP (Internet Protocol) address to help diagnose problems with our server, and to administer our Site. An IP address is a number that is assigned to your computer when you use the Internet. This information does not contain any personally identifiable information about you. Your IP address is also used to help identify you during a particular session and to gather broad demographic data.

How Collected Information is Used:
Luxco and its affiliates use personally identifiable and non-personally identifiable information collected through this Site to learn more about how visitors use the Site and to measure areas of interest. This allows Luxco to build features and functionality that will enhance your experience. We also use the registration process to filter out those users who are ineligible to access the Site due to age or non-compliance with our Terms and Conditions of Use. See Terms and Conditions. Your information may also be used when you register to use the Site or use services on the Site, to send you e-mails about new features and services on the Site, Site updates, information about the Pearl Vodka products, or to send you e-mails from selected third party product or service providers. We might also use this information to respond to your e-mails, comments and opinions, provide customer support, enforce our Terms and Conditions of Use or other similar matters. In certain instances you will have an opportunity to limit these uses at the time the information is collected. You also may limit the information that we send to you by following the instructions in Choice/Opt-out below. We may use the information we gather along with information obtained from other sources, including third parties. You understand and agree that we cannot control the type or frequency of information sent to you by third parties or the procedures for discontinuing information from third parties.

With respect to non-personally identifiable information, we may use this data to improve our Site and to send you information that may be of interest to you. We may also share this information with others, such as advertisers interested in advertising on the Site, in aggregate, anonymous form, which means that the information will not contain any personally identifiable information about you or any other person. This information may also be used to evaluate what portions of the Site are more popular than others, determine where visitors came from, and where they go, and how long visitors stay on a particular page, or the Site in general.

Sharing of Information:
Luxco may share your personally identifiable information with business partners that we believe may provide offers that may be of interest to you. In certain instances you will have an opportunity to limit this sharing at the time the information is collected. You also may limit this sharing by following the instructions in Choice/Opt-out below.

Certain services available on the Site may be provided by third parties. For example, if you choose to purchase products or services from the Site, the information you provide in connection with such purchase may be used by an authorized vendor to fulfill that order. Your provision of information to these third parties will be governed by the privacy practices of that third party; please check for the privacy policy link on the page on which you are requested to provide information.

In order to make the Site more enjoyable for visitors, Luxco constantly strives to learn how users use the Site. Information concerning your use of the Site and related services may be made available to one or more third parties, such as a data processor, fulfillment agency, or advertising agency, for these purposes.

Luxco may transfer, sell or assign information concerning your use of this Site, including without limitation, personally identifiable information that you provide and other information concerning your use of the Site, to third parties, as a result of the sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation of Luxco.

Luxco may also disclose user information in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may have breached our Terms and Conditions of Use, or who may be causing injury to or interference with (either intentionally or unintentionally) Luxco's rights or property, other Site users, or anyone else who could be harmed by such activities. Second, we may disclose user information to law enforcement personnel and agencies when requested to do so or as required by law.

Security:
We take security very seriously. We provide for the secure transmission of your information from your PC to our servers by using encryption software. However, due to the open communication nature of the Internet, we cannot guarantee that communications between you and us, and us and you, will be free from unauthorized access by third parties.

Consent to Processing:
By providing any personal information to this Site, you fully understand and unambiguously consent to the transfer of such personal information to, and the collection and processing of such personal information in, the United States and other countries or territories.

Links:
This Site may contain links or references to other web sites outside of our control. Each of these third party web sites may have a privacy policy different from that of Luxco. For example, you might click on a link or banner ad that will take you off our site. These links and banners may take you to sites of advertisers, sponsors and co-branding partners. Please review the privacy policies of these sites. Luxco is not responsible for any actions or policies of such third parties. These other sites may send their own cookies to users, collect data or solicit personal information. You should review the applicable private policies of these third party sites before providing personally identifiable information. Please be aware that we have no control over these sites, that our privacy policy does not apply to these sites, and that we are not responsible for any actions or policies of such third parties.

Access:
If you would like to review and/or update the information that you have provided to the Site, please send an e-mail to it@davidsherman.com requesting such access or change.

Choice/Opt-out:
You may choose to have your name taken off of Luxco's e-mail list, the Pearl After Hours Club list, or have Luxco not provide your information to others in the future by (1) sending an e-mail to unsubscribe@luxco.com with the subject line "Unsubscribe to Luxco" or "Unsubscribe to Partners," or by (2) following instructions as provided in any e-mail message from Luxco.

Use of Site:
The Site may only be used or otherwise accessed by you if you are of legal age to purchase beverage alcohol in the jurisdiction in which you reside. See Terms and Conditions. If we receive notice, or reasonably believe, that someone under legal purchasing age has provided us with personal information, we will make reasonable efforts to remove such personal information from our database.

Your Acceptance of this Policy:
By using this Site, you signify your acceptance of our Privacy Policy. If you do not agree to this policy, please do not use our Site. We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time so visitors are encouraged to review this policy from time to time. Your continued use of our Site following the posting of changes to these terms means you accept these changes.

Luxco
5050 Kemper Avenue
St. Louis , Missouri 63139, U.S.A.
Last updated: April 2005