Win-It-Too LLC d/b/a Global Beer Network

www.globalbeer.com

Effective Date: May 11, 2026

This Privacy Policy (this “Policy”) describes the practices of Win-It-Too LLC, a limited liability company doing business as Global Beer Network (“Global Beer Network,” “we,” “us,” or “our”), with respect to the collection, use, disclosure, and protection of personal information that we obtain through our website located at www.globalbeer.com (the “Site”), our digital marketing campaigns, QR code-based promotional programs, and any other online services or platforms we operate that link to or display this Policy (collectively, the “Services”).

PLEASE READ THIS POLICY CAREFULLY. BY ACCESSING OR USING THE SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THIS POLICY. IF YOU DO NOT AGREE, PLEASE DISCONTINUE USE OF THE SERVICES IMMEDIATELY.

1. Scope and Applicability

This Policy applies to all visitors, users, and others who access or use the Services, regardless of the medium through which they access them. This Policy does not apply to information collected offline, through third-party websites or applications that we do not operate, or through our interactions with other businesses in a business-to-business capacity.

If you are a California resident, please also review Section 12 of this Policy for additional disclosures and rights applicable to you under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA/CPRA”).

If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, please also review Section 13 of this Policy for information regarding our compliance with applicable data protection laws, including the General Data Protection Regulation (“GDPR”) and UK GDPR.

2. Information We Collect

We collect personal information in several ways, depending on how you interact with our Services.

2.1 Information You Provide Directly

We collect information that you voluntarily submit to us, including:

• Contact and Inquiry Information. When you complete a contact form, request information, or otherwise communicate with us, we collect your name, email address, phone number, and the content of your communication.
• Email Sign-Up and Newsletter Subscriptions. When you subscribe to receive promotional emails, newsletters, or other marketing communications, we collect your email address and any preferences you provide.
• Promotional Program Participation. When you participate in sweepstakes, contests, loyalty programs, or other promotions—including those accessed via QR code—we may collect your name, date of birth (to verify legal drinking age), mailing address, email address, phone number, and any other information required to administer the promotion.
• Account Registration. If we offer account registration features, we collect your username, password, and any profile information you choose to provide.

2.2 Information Collected Automatically

When you visit or interact with the Site or engage with our digital campaigns, we and our third-party service providers collect certain information automatically using cookies, pixel tags, web beacons, and similar tracking technologies. This information includes:

• Usage and Log Data. Your IP address, browser type and version, operating system, referring URLs, pages viewed, links clicked, time and date of visit, and time spent on pages.
• Device Information. Your device type, unique device identifiers, mobile network information, and hardware model.
• Location Data. General geographic location inferred from your IP address. We do not collect precise GPS-based location information unless you affirmatively grant permission through a device prompt.
• QR Code and Campaign Interaction Data. When you scan a QR code associated with a Global Beer Network campaign or promotion, we may collect information about the time and location of the scan (at the city or postal code level), the device used, and your interaction with the campaign landing page or redemption flow.
• Cookie and Analytics Data. Information collected through cookies and similar technologies as further described in Section 5 below.

2.3 Information Collected from Third Parties

We may receive information about you from third-party sources, including:

• Analytics and Advertising Partners. Third-party analytics providers (such as Google Analytics) may share aggregated or pseudonymized data with us regarding your use of the Services.
• Social Media Platforms. If you interact with our content on social media platforms or use social login functionality, we may receive certain profile information from the relevant platform, subject to your privacy settings on that platform.
• Promotional Partners and Co-Sponsors. In connection with joint promotions or co-sponsored campaigns, we may receive information that you have submitted to or authorized our partners to share with us.

2.4 Aggregated and De-Identified Data

We may aggregate or de-identify personal information such that it can no longer reasonably be used to identify you. We use and share aggregated or de-identified data for any purpose and it is not subject to this Policy.

3. How We Use Your Information

We use the information we collect for the following purposes:

• To Operate and Provide the Services. To maintain and administer the Site, respond to your inquiries, process promotional entries, deliver requested information, and fulfill our contractual obligations to you.
• To Send Marketing Communications. To send you promotional emails, newsletters, and other marketing materials about Global Beer Network’s products, events, and campaigns, subject to your consent where required by applicable law and your right to opt out at any time.
• To Administer Promotions and Campaigns. To verify your eligibility to participate in promotions (including age verification where required), select winners, and fulfill prizes or rewards.
• To Improve the Services. To analyze usage patterns, conduct research and analytics, troubleshoot technical issues, and enhance the functionality and user experience of the Services.
• To Personalize Your Experience. To deliver content, advertisements, and promotional offers that are relevant to your interests based on your prior interactions with the Services or our campaigns.
• To Communicate with You. To send transactional and administrative messages, including confirmations, updates, and security alerts.
• To Comply with Legal Obligations. To comply with applicable laws, regulations, and legal processes, including responding to lawful requests from governmental and regulatory authorities.
• To Protect Our Rights and Interests. To enforce our Terms of Use and other agreements, prevent fraud and abuse, and protect the security and integrity of the Services.
• For Other Purposes with Your Consent. For any other purpose disclosed to you at the time of collection, or for any purpose for which you have provided your consent.

4. Legal Bases for Processing (EEA, UK, and Switzerland)

If you are located in the EEA, UK, or Switzerland, we process your personal information on the following legal bases:

• Contractual Necessity. Processing that is necessary to perform our contract with you, including to respond to inquiries and deliver requested Services.
• Legitimate Interests. Processing that is necessary for our legitimate business interests, including improving the Services, preventing fraud, and sending direct marketing communications where permitted by applicable law, provided that such interests are not overridden by your fundamental rights and freedoms.
• Consent. Processing based on your express consent, including where required for certain cookies or marketing communications. You may withdraw your consent at any time without affecting the lawfulness of prior processing.
• Legal Obligation. Processing that is necessary to comply with our legal obligations.

5. Cookies and Tracking Technologies

5.1 Types of Cookies We Use

We use the following categories of cookies and similar tracking technologies on the Site:

• Strictly Necessary Cookies. These cookies are essential to the operation of the Site and cannot be disabled without impairing the functionality of the Services. They are typically set in response to your actions, such as setting privacy preferences, logging in, or completing forms.
• Performance and Analytics Cookies. These cookies allow us to measure and analyze how visitors use the Site, including which pages are most visited, how long visitors spend on pages, and where visitors arrive from. We use this information to improve the Services. We currently use Google Analytics for this purpose.
• Functional Cookies. These cookies enable enhanced functionality and personalization, such as remembering your preferences and settings between sessions.
• Marketing and Targeting Cookies. These cookies are used to deliver advertisements that are relevant to you and your interests. They may also be used to limit the frequency with which you see an advertisement and to measure the effectiveness of advertising campaigns. They are typically placed by advertising networks with our permission.

5.2 Third-Party Cookies

Third parties, including analytics providers and advertising networks, may set cookies when you visit our Site. These third parties’ use of cookies is subject to their own privacy policies, not ours. We encourage you to review the privacy policies of any third-party services we use, including Google’s Privacy Policy, available at https://policies.google.com/privacy.

From time to time, we may also deploy advertising, conversion tracking, and measurement technologies offered by third-party platforms, including the Meta Pixel and related business tools (operated by Meta Platforms, Inc.) and Google Ads conversion tracking and remarketing tags (operated by Google LLC). When in use, these technologies allow us to measure the effectiveness of our advertising campaigns, optimize ad delivery, and present advertisements to users who have previously visited the Site or interacted with our digital campaigns, including on third-party platforms such as Facebook, Instagram, and Google. These third parties may collect or receive information from the Site and other sources to provide measurement services and target ads, and their use of your information is governed by their own privacy policies, available at https://www.facebook.com/policies/cookies/ and https://policies.google.com/technologies/ads. Where required by applicable law, we will obtain your consent before deploying such technologies, and you may adjust your preferences using the cookie controls described in Section 5.3 or the opt-out mechanisms made available by the relevant third party.

5.3 Your Cookie Choices

Most web browsers are set to accept cookies by default. You can set your browser to refuse all or some cookies or to alert you when cookies are being set. However, if you disable or refuse cookies, please note that some parts of the Services may not function properly. Where required by applicable law, we obtain your consent before placing non-essential cookies.

To opt out of Google Analytics tracking, you may use the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout.

We do not currently respond to “Do Not Track” signals from web browsers because no uniform standard for such signals has been established. If a standard is established and we are required to comply, we will update this Policy accordingly.

6. How We Share Your Information

We do not sell, rent, or trade your personal information to unaffiliated third parties for their own marketing purposes. We may share your information in the following circumstances:

• Service Providers. We share information with vendors, contractors, and other service providers who perform services on our behalf, including website hosting, email delivery, analytics, payment processing, and promotion administration. These parties are contractually obligated to use your information only as directed by us and to maintain appropriate security standards.
• Promotional and Campaign Partners. In connection with co-sponsored promotions, events, or campaigns, we may share your information with the co-sponsor or partner as disclosed at the time you enter such promotion or program.
• Corporate Transactions. We may disclose or transfer your information in connection with a merger, acquisition, reorganization, sale of all or substantially all of our assets, or similar corporate transaction. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.
• Legal Requirements and Enforcement. We may disclose your information if we believe disclosure is required or permitted by law, including to comply with a subpoena, court order, or governmental request; to enforce our Terms of Use; to protect the rights, property, or safety of Global Beer Network, our users, or others; or to investigate or prevent fraud or other illegal activity.
• With Your Consent. We may share your information for any other purpose with your prior consent.

7. QR Code and Digital Campaign Programs

Global Beer Network uses QR codes and digital landing pages in connection with promotions, point-of-sale programs, and other marketing campaigns. When you scan a QR code or engage with a digital campaign associated with Global Beer Network:

• You may be directed to a campaign-specific landing page where you may be asked to submit contact information, participate in a promotion, or provide information to redeem an offer or prize.
• We may collect the data described in Section 2.2 automatically, including the time and approximate geographic location of the scan, device information, and your interactions with the landing page.
• Promotional programs accessed via QR code or digital campaigns may be subject to additional terms and conditions, which will be made available at the point of entry. Those additional terms are incorporated by reference into this Policy.
• Age Verification. Because our products involve alcohol, certain promotions require you to affirmatively confirm that you are of legal drinking age in your jurisdiction before participating. We do not knowingly collect personal information from individuals who are under the legal drinking age.

8. Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process the information and whether we can achieve those purposes through other means; and applicable legal requirements.

When personal information is no longer required, we will securely delete or anonymize it in accordance with our data retention policies. In certain circumstances, we may retain de-identified data indefinitely.

9. Data Security

We implement and maintain reasonable and appropriate administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These measures include, as appropriate, encryption of data in transit using Secure Socket Layer (SSL) technology, access controls, and regular security assessments.

However, no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security. In the event of a data breach that is required to be reported under applicable law, we will notify affected individuals in accordance with such law.

You are responsible for maintaining the confidentiality of any password you use to access the Services and for any activities that occur under your account. If you believe your account or personal information has been compromised, please contact us immediately using the contact information in Section 15.

10. Children’s Privacy

The Services are not intended for, and we do not knowingly collect personal information from, individuals who are under the legal drinking age in their jurisdiction, or, in any event, from individuals under eighteen (18) years of age. If we learn that we have inadvertently collected personal information from a minor, we will take prompt steps to delete such information from our records. If you believe that we may have collected information from a minor, please contact us immediately using the contact information in Section 15.

11. Your Choices and Rights (General)

Depending on your jurisdiction and the nature of your relationship with us, you may have some or all of the following rights with respect to your personal information:

• Opt-Out of Marketing Communications. You may opt out of receiving promotional emails from us by clicking the “Unsubscribe” link included in any marketing email, or by contacting us as described in Section 15. Please note that you may still receive transactional or administrative emails from us even after opting out of marketing communications.
• Access and Correction. You may request access to the personal information we hold about you and ask us to correct inaccuracies.
• Deletion. You may request deletion of your personal information, subject to certain exceptions (such as information we are required to retain for legal or business purposes).
• Restriction and Objection. You may request that we restrict processing of your personal information, or object to certain processing activities, including processing for direct marketing purposes.
• Portability. Where applicable, you may request that we provide your personal information in a structured, commonly used, and machine-readable format so that you may transfer it to another controller.

To exercise any of these rights, please contact us using the information in Section 15. We will respond to your request within the time period required by applicable law. We may need to verify your identity before fulfilling your request and reserve the right to deny requests that are unfounded, excessive, or repetitive, or that would require disproportionate effort.

12. Additional Rights for California Residents (CCPA/CPRA)

This Section 12 applies solely to individuals who are residents of California and supplements the other provisions of this Policy. Capitalized terms used in this Section have the meanings ascribed to them under the CCPA/CPRA.

12.1 Categories of Personal Information Collected

In the preceding twelve (12) months, we have collected the following categories of Personal Information from California consumers:

• Identifiers, such as real name, email address, IP address, and unique device identifiers.
• Commercial Information, such as promotion participation records and redemption history.
• Internet or Other Electronic Network Activity Information, such as browsing history on the Site, interaction with digital campaigns, and QR code scan data.
• Geolocation Data (city or postal code level only, derived from IP address).
• Inferences drawn from any of the above categories to create a profile about your preferences and interactions with the Services.

12.2 Sources, Purposes, and Disclosures

We collect Personal Information from the categories of sources described in Section 2 of this Policy. We collect, use, and disclose Personal Information for the business and commercial purposes described in Sections 3 and 6 of this Policy.

12.3 Sale and Sharing of Personal Information

We do not sell Personal Information as that term is traditionally understood. To the extent that our use of certain advertising or analytics cookies could constitute a “share” of Personal Information under the CCPA/CPRA for purposes of cross-context behavioral advertising, California residents have the right to opt out of such sharing by using the cookie management options described in Section 5.3 of this Policy.

We do not have actual knowledge that we sell or share Personal Information of consumers under sixteen (16) years of age.

12.4 Your CCPA/CPRA Rights

Subject to certain exceptions, California residents have the following rights:

• Right to Know. The right to request disclosure of the categories and specific pieces of Personal Information we have collected about you, the categories of sources from which we collected it, the business or commercial purposes for collecting or sharing it, and the categories of third parties to whom we disclose it.
• Right to Delete. The right to request deletion of Personal Information we have collected from you, subject to certain exceptions.
• Right to Correct. The right to request correction of inaccurate Personal Information we maintain about you.
• Right to Opt-Out of Sale/Sharing. The right to direct us not to sell or share your Personal Information for cross-context behavioral advertising purposes.
• Right to Limit Use of Sensitive Personal Information. To the extent we collect Sensitive Personal Information, as defined under the CPRA, you have the right to direct us to limit our use and disclosure of such information to the uses permitted by law.
• Right to Non-Discrimination. The right not to receive discriminatory treatment for exercising any of your CCPA/CPRA rights.

To exercise your rights under the CCPA/CPRA, you or an authorized agent acting on your behalf may submit a verifiable consumer request by contacting us as described in Section 15. We will respond to a verifiable consumer request within forty-five (45) days of receipt, with a possible one-time extension of an additional forty-five (45) days where necessary.

13. Additional Rights for EEA, UK, and Swiss Residents (GDPR / UK GDPR)

If you are located in the EEA, UK, or Switzerland, in addition to the rights described in Section 11, you have the right to lodge a complaint with the competent data protection supervisory authority in your jurisdiction. Contact details for supervisory authorities within the EU are available at https://edpb.europa.eu/about-edpb/about-edpb/members_en. For UK residents, the relevant authority is the Information Commissioner’s Office (https://ico.org.uk).

Win-It-Too LLC is the data controller with respect to personal information processed under this Policy. Our contact information is set forth in Section 15 below. We do not currently have a designated EU or UK representative, but are in the process of evaluating our obligations in this regard.

Where we transfer personal information from the EEA, UK, or Switzerland to countries that have not been deemed to provide an adequate level of data protection, we will implement appropriate safeguards in accordance with applicable law, which may include standard contractual clauses approved by the European Commission or the UK Information Commissioner’s Office.

14. Third-Party Links and Services

The Services may contain links to third-party websites, services, or platforms that are not owned or controlled by Global Beer Network. This Policy does not apply to those third-party services, and we are not responsible for the privacy practices of any third party. We encourage you to review the privacy policies of any third-party services you access through links on our Site or through our campaigns.

15. Contact Information

If you have any questions, concerns, or requests regarding this Policy or our privacy practices, please contact us at:

Win-It-Too LLC d/b/a Global Beer Network

Attn: Privacy Compliance

Email: privacy@globalbeer.com

Website: www.globalbeer.com

We will endeavor to respond to all requests within a reasonable time and within any timeframe required by applicable law.

16. Changes to This Policy

We reserve the right to update or modify this Policy at any time and from time to time. If we make material changes to this Policy, we will provide notice by posting an updated Policy on the Site and revising the “Effective Date” at the top of this page, and, where required by applicable law, by providing additional notice (such as by sending you an email). We encourage you to review this Policy periodically to stay informed about our privacy practices.

Your continued use of the Services following the posting of changes to this Policy will constitute your acceptance of those changes, to the extent permitted by applicable law.

© 2026 Win-It-Too LLC d/b/a Global Beer Network. All rights reserved.