Our Commitment to Privacy

We respect your concerns about privacy and value the relationship we have with you. We will not sell, lend, or distribute your private information in any way outside of the Cakebread family of companies (“Cakebread”) unless required by law. Our Privacy Policy describes the type of information that you may be asked to share and how we may use it. Additional information on our policies, as well as any request to opt out of data collection, can be requested by contacting us at privacy@cakebread.com.

We are based in California, and this policy incorporates protections for California residents provided under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA”). Since we care about your privacy, we provide the same rights to all of our customers whether or not they are California residents. As discussed further below under Legal Disclaimers, your use of this Site and our services are subject to California and United States law.

Summary of Rights

If you ever have any questions about how we use and store your personal information, you can submit those questions to us at privacy@cakebread.com. Below is a non-exhaustive summary of the rights you have in this policy. This summary is only for your convenience: it does not change the details, exceptions, and legal obligations that apply to these items set out in more detail below:

• We do not and will not sell to or share your data with any Third Parties for their marketing purposes, including cross-context behavioral advertising purposes. We share your personal information only with certain of our Service Providers to carry out our business with you, for the limited purpose of providing those services. We nevertheless give you the opportunity to control and opt out of the use of certain cookies on our site as discussed further below.
• You may request that we correct or delete the personal information you provided to us at any time by sending your request to privacy@cakebread.com or by phone at (800) 588-0298, and we will correct or delete it, and direct our Service Providers to do the same (unless there is a specific reason we need to keep it).
• You may opt out of receiving marketing e-mails or the use of your personal data by us for direct marketing purposes. To opt out of the use of your personal data for this purpose, contact us at privacy@cakebread.com or by phone at (800) 588-0298. Please note that by opting out of these marketing e-mails, you may miss out on special promotions and event notifications.
• Up to twice a year, you may request that we disclose certain information to you regarding our collection and use of your personal information over the past 12 months, by contacting us at (800) 588-0298 via email at privacy@cakebread.com.
• Although you cannot object to our sharing your information with our Service Providers, such as our shipping & fulfillment vendor and payment processing vendor to facilitate your transactions, be assured that our agreements with those providers clearly describe the purpose of disclosing your information, require that the provider keep your information confidential, and prohibit the provider from using your personal information for any other purposes.
• We use cookies to help us better understand the performance of our website and to inform us of ways we can enhance your online experience. You may manage your cookies, ‘Do Not Track,’ and similar technologies by accessing your browser’s preference/settings menu. Please be aware that if you opt to reject cookies, you may not be able to take full advantage of all of our website features.
• You have a right not to receive any discriminatory treatment by Cakebread for the exercise of the privacy rights conferred by the CCPA.

NOTICE OF COLLECTION

Who is Collecting Your Data

Cakebread controls the data that is collected on the Site. You can contact us any time at: privacy@cakebread.com or (800) 588-0298. Cakebread Cellars is part of the Cakebread family of companies that includes Cakebread Cellars and other related entities under the Cakebread name. Your information is limited to use within the Cakebread family of companies as described further herein. If you would like to further restrict the use of your information within any of the specific Cakebread family of companies, please contact us.

Categories of Information We Collect

We collect and store certain personal information about you at various points including purchases on the website, signing up for the wine club, completing forms inquiries, and purchasing or providing your information in the tasting room in order to provide you with products and services. As discussed further below, we are required to collect certain information from you such as your age and residence in order to sell and ship you wine legally. We also use this information and additional information we collect to customize our services to your preferences and provide you with products and services that we believe will appeal to you.

California defines certain categories of “personal information.” During the past 12 months, we have collected information that falls into these categories directly from you and your electronic devices, as well as from other publicly available sources, and it is disclosed in the following manners. Further, as discussed below, we provide you with the ability to manage your data collection and use via cookies on our website:

Identifiers and Additional Identifiers

• Examples of types of data in this category include: name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, telephone number, credit card number, debit card number.
• Data in this category is disclosed only to our Service Providers.
• Data in this category is not sold to Third Parties.

Characteristics of protected classifications under California or federal law:

• Examples of types of data in this category include: age, gender and marital status.
• Data in this category is disclosed only to our Service Providers.
• Data in this category is not sold to Third Parties.

Commercial information:

• Examples of types of data in this category include: records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Data in this category is disclosed only to our Service Providers.
• Data in this category is not sold to Third Parties.

Internet or other electronic network activity information:

• Examples of types of data in this category include: information regarding a consumer’s interaction with an Internet Website or advertisement.
• Data in this category is disclosed only to our Service Providers.
• Data in this category is not sold to or shared with Third Parties.

Geolocation data:

• Examples of types of data in this category include: location of your electronic device.
• Data in this category is disclosed only to our Service Providers and their use of this data is limited to the extent necessary to perform such services.
• Data in this category is not sold to Third Parties.

Inferences:

• Examples of types of data in this category include: inferences drawn from any of the information above to create a profile about a consumer.
• Data in this category is not disclosed or sold.

We obtain the categories of personal information listed above from the following categories of sources:

• Our customers, through direct interactions and form;
• Our website, through passive collection of information about your interaction with the site, including page clicks, time spent, or other automatically collected meta-data; and
• Internet cookies.
• We do not collect biometric information, sensory data, professional or employment-related information (other than from our employees or job applicants), or non-public education information.

Why Cakebread Collects Your Information

We collect your information to manage our relationship with you and send you communications, including the following:

ORDERS

In order for you to place orders, make purchases, complete transactions, interact with us or have access to certain features of the Site, we may require you to register or provide certain personal information. This information may include, but is not limited to, your name, contact information, email address, age or date of birth, payment information, shipment address and other information, or a username and password. In addition, our website collects certain information as part of the technology we use to run our website. This technical information may also include personal information about you. This information will be handled just like all other personal information we collect.

PURCHASE AND RECIPIENT INFORMATION

When making purchases through the Site, we may also require you to provide a credit card, billing address and gift message and that you provide information about a recipient or potential recipient of a gift or a purchase you make through the Site.

CONTACTING YOU

We may send communications about events or promotional offers including marketing communications to an email address or through other contact information provided by you on behalf of Cakebread. If you would like to opt out of our use of your information for marketing purposes, or to be removed from our email list, you may contact us at privacy@cakebread.com, or you may click on the “manage my subscription” link at the bottom of the email to manage your email preferences. Even if you opt out, we may still send emails to you concerning specific transactions or other non-marketing related messages. If you opt into text messages, you can text STOP to 20826 to stop receiving text messages.

WINE CLUB MEMBERSHIPS AND ONLINE PURCHASES

If you choose to make a purchase or join a wine club, we may collect information such as your name, address, phone number, date of birth, and credit or debit card information. We use this information to process your order, communicate with you about our products and promotions, and collect feedback on your experience on this site. If you create an Account on the Site, you can manage your information in the My Account section when you log in at https://www.cakebread.com/.

AGE VERIFICATION

You must be of legal age to use the Site or to purchase any alcoholic beverage. If you wish to purchase any alcohol containing beverage from us, you may be required to provide personal information sufficient to verify that you are over 21 years of age. If you do not provide information to verify that you are of legal age, we cannot provide any services to you. We also cannot ship any product to you if you do not provide an address at which a person over the legal age is available to receive the product. We do not knowingly collect nor do we sell or share personal information from individuals under 21, nor do we direct any of our content to individuals under 21.

OTHER WEBSITE FEATURES

We offer visitors to our website various features for their information and enjoyment, which we may change from time to time. To the extent you participate in any sweepstakes, promotions or contests through the Site, any personal information provided by you may be used in accordance with separate or different terms and conditions under the applicable rules of such sweepstakes, promotion or contest, which may differ from this Privacy Policy.

INFORMATION COLLECTED AUTOMATICALLY

We may at times review certain information by automated means when you visit our website, such as how many users visited our site and the pages accessed. By collecting this information, we learn how to best tailor our website to you, our valued guest.

NON-PERSONAL INFORMATION

We may collect non-personal or de-identified information from you including, but not limited to, demographic data or operating system. Unless otherwise required by applicable law, we may use and share this information, which does not personally identify you, for any purpose, including sharing with our third-party partners, affiliates, agents or service providers for various administrative, analytical and marketing purposes. Additionally, we may use your IP address, browser type, and/or your Internet Service Provider (“IT Information”) to help diagnose problems with our server, to detect fraud, and to administer the Site. We may also use your IT Information to assist in attempting to identify you when we feel it is necessary to enforce compliance with this Privacy Policy or the Terms of Use or to protect the Site, our systems, affiliates, information, employees, business partners, service providers, users, customers, or others or as may be required by law enforcement.

USER NAME AND PASSWORD

You are responsible for maintaining the confidentiality of your username and password, if applicable to this Site. You shall be responsible for all uses of your username and password, whether or not authorized by you. You agree to immediately notify us of any unauthorized use of your username or password.

SERVICE PROVIDERS

We are required to provide your information to certain of our Third Party vendors in order to store your data, process orders, payments and shipments, and execute e-mail campaigns as discussed below. Our service providers are not permitted to use your information for their own marketing purposes, unless they have an independent relationship to you and have obtained your information from another source. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without first providing you notice.

How Long We Keep Your Information

We will retain your information for as long as your account is active or as necessary to provide you services and to maintain a record of your transactions for financial reporting and compliance purposes. If you wish to cancel your account, please contact us at privacy@cakebread.com. We will keep your order history on file indefinitely so that we can always provide you with information on what you ordered previously unless you ask us to delete it.

Your Rights to Access, Delete, or Correct Your Data

If you ask, we will provide you with a copy of your account data or delete your account at your request, subject to verifying your identity as discussed below. Up to twice a year, you may ask us whether we are collecting, storing, using, disclosing or selling your personal information, what categories and/or specific pieces of personal information of yours we are collecting and storing, the categories of sources from which our personal information is collected, the business or commercial purpose for collecting your personal information, and whom we may have shared your information with and the categories of that information shared.

Such “requests to know” can be sent by contacting us at privacy@cakebread.com, or by phone at (800) 588-0298. We will work diligently to respond to your requests and will provide you with a free response within 45 days.

If you would like us to delete or correct your data, please contact us at privacy@cakebread.com or (800) 588-0298. Depending on the nature of the data that you request we delete or correct, we may require you provide two or more data points that match the information in our file. Note that even if you request deletion, we may continue to retain and use information as may be authorized or necessary under California Law. While you have the right to request that we delete or correct the personal information you.

provide to us and we will not discriminate against you for exercising any rights that you have, we may no longer be able to sell you any alcohol-containing beverages if you ask us to delete your information showing you are of legal age or are in a location where it is legal for us to sell to you, and you may need to make other arrangements to verify your age and location to facilitate transactions. If you have an active membership in any of our wine clubs, we cannot delete the information necessary to process your membership transactions.

We will verify your identity for purposes of such a request to delete, correct or access. If you have an account on the Site, we will verify your request for information through your account. If you do not have an account, we will verify your request depending on the nature of the request. If you request to know the categories of information, we will request that you provide two pieces of information that match our records, which may vary depending on the information we have on file. If you request to know specific pieces of information, we will require additional verification to match three pieces of information on file, as well as a signed declaration via mail sent to Cakebread Cellars P.O. Box 216, Rutherford California, 94573. If you would like to designate an authorized agent to make such a request on your behalf you may do so by providing us with written permission of such authorization, or your agent must provide proof of a power of attorney.

In order to ensure protection of your information from fraudulent requests, we require you provide us with additional information to verify your identity should you wish to access or delete your data. For your protection, in the event the requisite verification is not satisfied, we may deny the request for access to your account data or to delete your account.

Protecting Your Information

We make every effort to ensure that any data that we store about you is kept behind a secure firewall and is not accessible to the public in any way. Your personal information is collected and stored in a secure area for your protection. Any credit card information that we collect from you is tokenized and only available to process your orders via our service providers.

We protect user data offline as well by restricting access to information to only those employees (for example, a Customer Care representative) who need the information to perform a specific job. All employees are kept up to date on our security and privacy practices and are aware of the importance of keeping customer data secure and safe at all times. We also outsource certain of our data processing operations to third parties as discussed below, and we have agreements with those service providers that require them to maintain security over your information.

Although we use our best efforts to protect the security of your information and our system, and we have agreements in place with our service providers requiring them to do the same, no transmission via the internet or storage of data can be guaranteed to be 100% secure. As a result of this and other factors beyond our control, we cannot guarantee the security of the information that you transmit to or through our Site. Therefore, you assume that risk by using the Site.

If you have any questions about the security of our Site, please feel free to contact us at privacy@cakebread.com.

How We Share Your Information With Third Parties

We value your privacy, and we will never sell or rent any personal information to any Third Party for that Third Party’s marketing purposes unless we are given explicit and affirmative authority to do so by you. The Cakebread family of companies, of which Cakebread Cellars is a part, will never sell or rent your personal information.

We work with Service Providers, who may be considered “Third Parties,” to assist us in fulfilling our sales and services to you and to process your data, including shipping companies, data hosts, credit card processors, and email management companies to host our databases, ship orders, process credit cards, or bill you for goods and services. We require all Service Providers and Third Parties to keep any information they receive confidential, maintain the privacy of all our customers, and to use any information provided to only provide services on behalf of Cakebread and the customer. We have in the past and may continue to disclose for business purposes your personal information with these Service Providers and Third Parties as set forth in the table above.

From time to time, we may also employ other Service Providers or Third Parties to perform services, to maintain and operate the Site, and to maintain certain features on the Site. To such parties, we may disclose non-personal information such as traffic patterns and website usage data, but in no event will we disclose any personal information. Third parties may also acquire browsing data or other information about your activity on the Site through cookies, as discussed below.

We also may employ Service Providers or Third Parties to analyze our sales data for internal purposes, in which case we may disclose information to such parties such as the wines purchased, the location of shipments, and the frequency of purchases. We additionally may enlist a Service Provider or Third Party to assist with marketing and sending member emails, in which case we will provide these third party vendors only with member email addresses. Again, we require all such Service Providers or Third Parties to keep any information they receive confidential, maintain the privacy of all our customers, and to use any information provided for services on our and your behalf.

Cookies

Our Site uses cookies to speed navigation, keep track of items, and provide you with custom-tailored content. We and our service providers also use cookies to make the site function, remember some of the information you’ve given us so you don’t have to re-enter it each time you visit the Site, and to process transactions. By showing us how and when you use the Site, cookies also help us see which areas are popular and which are not. Many improvements and updates to the Site are based on data such as total number of visitors and pages viewed.

We employ settings intended to manage the cookies we use so they do not allow us or other parties to collect personally identifiable information about your online activities over

time and across different Websites. We offer you the ability to manage the cookies that you accept on your device. While you cannot opt out of cookies that are necessary to make the site function, you have the choice to reject performance or targeting cookies upon entering our website. Most browsers are initially set to accept cookies. You may also manage how your browser handles cookies and related technologies by adjusting your browser’s security and privacy settings. Refer to instructions related to your browser to learn about privacy and security settings that are available to you.

This Site uses Google Analytics, a web analytics service provided by Google. Google Analytics uses cookies to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google. Google will use this information only for our evaluation of your use of the website, compiling reports on website activity, and providing other services relating to website activity and internet usage for us. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

This Site uses Meta cookies with the Limited Data Use setting employed. With this setting, Meta acts as a Service Provider to us. Nevertheless, the Site allows you to opt out of the use of such cookies in the Do Not Share or Sell My Information settings.

“Do Not Track” Signals

Some browsers have incorporated “do not track” features to enable users to make privacy and security choices. By using these settings, your browser may send a signal to a website not to collect tracking information. The Site does not change its behavior if a “do not track” signal is received, but as discussed above, you may opt out of the use of technical or tracking cookies upon entering our website.

Links to Other Websites

We may occasionally provide links to third party websites on the Site. We add these links to provide further information and enjoyment of your experience on the Site. We try to review the websites we link to, however; we are not responsible and have no control over the content, privacy practices, policies or information collection practices of these sites. These websites may use their own cookies or solicit personally identifiable information from you. Please read the privacy policy/terms and conditions of any website you visit before providing them with personal information.

Data of Minors

The Site is not directed at children and cannot be accessed by persons who do not verify that they are of legal drinking age. As a result, we will not knowingly collect information from minors of any age in the U.S., including those under 16, with or without consent from their parents or guardians.

Protecting the privacy of children is very important to us. If we learn that we collected the personal information of a minor, we will take steps to delete the information as soon as possible. If you believe we have inadvertently collected the personal information of your minor child, please contact us at privacy@cakebread.com.

Legal Disclaimers

This privacy policy explains how the Cakebread family of companies, including Cakebread Cellars, collects, uses and safeguards information you provide to us on this Site, at the Winery, or that you have otherwise given us which personally identifies you, as well as general, non-personal information that is automatically collected from our Site. The terms “the Winery,” “Site,” “us” or “we” refer to the Cakebread family of companies, including Cakebread Cellars, and this website. The terms “you,” “your” or “customer” refer to the user or viewer of this Site or customer of the Winery. Please read this privacy policy carefully. If you do not agree to our practices, please do not register, subscribe, create an account, make purchases or otherwise interact with this Site. By visiting and using the features on the Site (including mailing list sign up, wine club sign up, event registration, and other Site features), or by providing us with your personal information, you agree to this privacy policy.

In addition to the use of your personal information for our business purposes, and subject to our not otherwise sharing or selling your data to Third Parties except as set forth above, we reserve the right to disclose your personally identifiable information as allowed or required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Site.

This Site may contain links to other sites. We are not responsible for the privacy practices of other sites. We encourage our users to be aware when they leave our Site and to read the privacy statements of each site that collects personally identifiable information. This privacy policy applies solely to information collected by this Site.

We are based in California, and this policy incorporates protections for California residents provided under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CCPA”). Since we care about your privacy, we provide the same rights to all of our customers whether or not they are California residents. Your use of this Site and our services are subject to California and United States law. Residents of the European Union may have certain additional rights, including the ability to request corrections to your personal data, which we will recognize if you contact us at privacy@cakebread.com.

Privacy Policies Update

We reserve the right to modify this privacy statement at any time. We may periodically revise this privacy policy without notifying you of the changes, but it will be up to you to check periodically for updates to our policies. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes. If we have your email address, we will notify you in the event we make any changes that substantially affect your rights to your personal data, specifically, if we intend to change

our policy that we do not sell your personal information to or share such information with any third party.

Contact Us

If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you, please contact us by emailing us at cellars@cakebread.com or by writing to us at Cakebread Cellars, P.O. Box 216, Rutherford, California 94573, or call us at (800) 588-0298.