Blue Roan Coffee – Privacy Policy 

Last Revised: November 1, 2022

THIS Blue Roan Coffee PRIVACY POLICY (the “Privacy Policy”), discloses Blue Roan Coffee’s (“BRC”) privacy practices and describes the types of personal information that we collect, how we use it, how and when it may be shared, and the rights and choices you have with respect to your information. It also explains how we communicate with you and how you can make requests or submit inquiries to us about your information. Our goal is to help you understand how we use your information to improve our products, services, marketing, and interactions with you.

This Privacy Policy applies to information collected, used, and/or disclosed by BRC’s websites (e.g., www.blueroan.coffee), physical locations, mobile apps, and any other offerings that reference this Privacy Policy.  BRC is the controller and is responsible for Your personal information (“BRC”, “we”, “us” or “our”). If you do not agree with the terms set forth in this Privacy Statement, please discontinue use of our website immediately. 

The term “personal information,” as used in this Privacy Policy, shall mean any information that enables us to reasonably identify You, directly or indirectly, by reference to an identifier such as Your name, identification number, location data, online identifier or one or more factors specific to You. De-identified and or aggregated data which cannot reasonably identify, relate to, describe, or be capable of being associated with, or be linked, directly or indirectly, to an individual, household or device is not considered personal information.

This Privacy Policy will notify You of the following:

1. What personal information is collected from You, the sources from which such personal information is collected, how it is used and with whom it may be shared.
2. What choices are available to You regarding the use and retention of, and access to, Your personal information.
3. The security procedures in place to protect the misuse of Your personal information.

What personal information do we collect? 
As you use Our website or visit one of our stores, we may use different methods to collect personal information from and about You including:

• Personal Information You Give Us. 
  You may give us Your personal information including your name, contact details (e.g., your address, email, phone number), payment information, and/or other identifying information, by filling in forms or by corresponding with us by post, phone, email, chat, virtually, in-person, or otherwise. This includes personal information You provide when, for example: You ask us about or purchase our products or services; subscribe to our services or publications; request marketing to be sent to You; and/or give us feedback. In order to use certain functions of Our website, a user (You) may need to first sign up. During registration, You are required to give certain information (such as name, address, email addresses, payment information, etc.). This information may be used to display products/services on our website.
• Personal Information We Collect Automatically.
  We may use cookies, log files, web beacons, device identifiers, advertising identifiers and similar tracking technologies, including those from third-party service providers like Google Analytics, Google Tag Manager, HubSpot, and other cloud-based tools, to automatically collect Your preferences, performance data, and information about Your web usage when You visit our website and/or use the Services. For example, we may collect Your IP address, device and Internet service provider information, Web browser details and the address of any referring website. This may include collecting geolocation signals from Your IP address or device settings to determine Your location so that we may operate and personalize the Services for You. We may also collect information about Your online activity, such as purchases you make from us, how frequently you purchase from us, rewards/promotions associated with a purchase, products you place on your “Wishlist”, “Shopping Cart” or “My Bag” for future purchase, web pages viewed, and/or interactions between you and other users. Our Services are not designed to recognize or respond to “do not track” signals received from browsers. You can control the information collected by such tracking technologies or be alerted when cookies are sent by adjusting the settings on Your Internet browser or devices, but such adjustments may affect or disable certain functionality of the Services. You can learn more about Google Analytics and Your options for opting out of interest-based Google ads at https://adssettings.google.com. You can learn more about targeted ads and Your ability to opt out of receiving interest-based ads at aboutads.info and www.networkadvertising.org/choices.
• Device and Usage Information.
  We may collect information about your browser or device. This information may include the type of device you are using, your operating system, your browser, your internet service provider, your domain name, your internet protocol (“IP”) address, your device and mobile ad identifiers (e.g., Apple IDFA or Android AAID), the website that referred you to our website, the web pages of our website that you view (including the date and time you viewed them), the services or functionality you access or use (including the date and time of your access or use), and the subject of the ads you click or scroll over. To collect this information, we may use log files that record events in connection with your use of our services, as well as cookies and similar technologies, such as web beacons embedded in marketing emails to monitor the engagement of recipients.
• CCTV Information.
  Closed circuit video surveillance cameras (“CCTV”) may be installed at some of our retail locations to monitor building security and assist in crime prevention, detection, and investigation, and to ensure the health and safety of our staff and visitors to our facilities.
• Location Information.
  We may collect information about the location of your device, such as information that identifies your device’s precise location (for example, GPS latitude and longitude level) or its approximate location (e.g., less precise location estimated based on a browser or device’s IP address). We may also use location-based technology in our retail locations to collect information about the presence of your device, if your Bluetooth is turned on and your device settings allow for this. We collect this location information or derive it from your GPS, WiFi, Bluetooth or other device settings for purposes of enhancing or facilitating our services, such as to enable the functionality of our websites that provide you with information about stores near you, to enable you to remotely order and pay for our products and services, or so that you may have certain BRC products delivered to you by a third-party vendor. We may also use information about the location of the device you are using to help us understand how our websites and other services and functionality are being used, or to deliver more relevant advertising or personalized experiences for you, including tailored marketing offers or messages based on your location or related context such as the time of day or weather. If you want to opt out of the collection of this location information, please see the section below titled Your Choices.
• Information We Collect from Other Sources. 
  Some information we collect is from unaffiliated sources, including in some cases information that is publicly available, provided by or purchased from marketing business partners, or present on social media platforms.

We will not sell or rent Your personal information to anyone. 

How We Process or Use Personal Information 
We may use Your personal information for one or more of the following purposes:

• For business and commercial purposes, including to provide the products and services you request
• To perform customer services functions
• For security and fraud prevention
• For marketing and promotional purposes
• To respond to You, regarding the reason You contacted us
• To monitor and protect the security of our information, systems and network
• For internal business intelligence purposes, to conduct research, product development and enhancement
• To inform You of changes made to our website and other services
• To ensure that content from our website is presented most effectively for You and Your computer
• To perform website analytics
• To display content based on Your interests
• To enable You to search information on our web site
• To assess Your needs and interests in order to better tailor offers and/or advertising
• To improve our website, goods, and/or services

We may use the information we collect about you in a variety of ways, including to: 

To Provide Our Services. We process certain personal information when you access or use our services, including to:

• Process your purchases of, or requests for, products and services
• Register and verify user accounts
• Support and improve our loyalty programs
• Deliver gift cards or e-gifts, and any associated personalized messages, in accordance with your instructions
• Facilitate the functionality of our websites and mobile applications, including payment-related functionality
• Customize experiences and personalization when you are in and around our stores, if you have given permission for location sharing

To Communicate With You. We process certain information in order to communicate with you in relation to your accounts, our services, our marketing, and your requests, including to:

• Communicate with you about orders, purchases, returns, services, accounts, programs, contests, and sweepstakes
• Respond to your customer service inquiries and requests for information
• Post your comments or statements on our websites
• Send you personalized promotions, content, and special offers
• Communicate with you about our brands, products, events, or other promotional purposes
• Implement your communications preferences, such as sharing information with BRC business partners so that they may email you about their promotions, products and initiatives
• Provide important product safety information and notice of product recalls

For Research, Development, and Improvement of Our Services. We want to ensure that our website and services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain personal information, including to:

• Maintain, improve, and analyze our websites, ads, and the products and services we offer
• Detect, prevent, or investigate suspicious activity and/or fraud

To Enforce Our Terms, Agreements, or Policies. To maintain a safe, secure, and trusted environment for you when you use our websites and other services, we use your personal information to ensure our terms, policies, and agreements with you and any third parties are enforced. 

To Comply with Applicable Laws. We may be required to process certain personal information under certain laws and regulations, such as tax laws, as well as to:

• Maintain appropriate records for internal administrative purposes
• Comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed

With Your Consent. We may process certain personal information in order to fulfill any other business or commercial purposes at your direction or with your consent. Sharing Your personal information We may use and/or share Your personal information with the parties set out below for the purposes set out in this policy:

• One or more member(s) of our group;
• Our professional advisors such as auditors, accountants and lawyers, etc.;
• Companies that provide services to help us with our business activities, such as data storage, maintenance services, database management, web analytics, and payment processing.

We will only transfer Your personal information to trusted third parties who provide sufficient guarantees in respect of the technical and organizational security measures governing the processing to be carried out and who can demonstrate a commitment to compliance with those measures. We do not allow our third-party service providers to use Your personal information for their own purposes and only permit them to process Your personal information for specified purposes and in accordance with our instructions. We may also disclose Your personal information to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose Your personal information to the prospective seller or buyer of such business or assets;
• if we are under a duty to disclose or share Your personal information in order to comply with any legal obligation, any request from law enforcement or governmental organizations, to defend a legal claim, or in order to enforce or apply our terms of service and other agreements; or to protect the rights, property, or safety of BRC, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

In the event that a third party improperly uses, shares, and/or displays Your personal information, we shall not be liable and You must seek remedies from that third party. Under no circumstances shall we be held liable for any damages or claims arising out of a third party’s improper use of Your personal information. We are headquartered in the United States of America. Your personal information will be accessed by us or transferred to us in the US and will be accessed by our US-based employees. If You are visiting our website from outside the US, be aware that Your personal information will be transferred to, stored, and processed in the US where our servers are located, and our central database is operated. By using our web site, You consent to this transfer and storage of Your personal information. 

How We May Allow Others to Collect Your Information 
When you use our websites, we may allow third parties to collect device and usage information and location information across your different devices through mobile software development kits, cookies, web beacons and other similar technologies. These third parties collect this information for the following purposes and for other purposes consistent with their own privacy policies: 

• To Display Ads for Products or Services – We allow some advertising companies to collect this information in order to display ads that are more relevant to you across your different devices and on our own and others’ websites and mobile apps. Please see the Your Choices section of this Statement for more information about opting out of targeted advertising and controlling the use of cookies, web beacons and other similar technologies. 
• To Understand the Use of Our Services – We allow certain service providers to collect this information to help us understand how our websites are used and to assist us in improving the content and operation of our online properties (e.g., compiling analytics and measuring user engagement with a particular website or feature through A/B testing). These service providers collect aggregate statistical usage data that is not matched or linked to any individual user. 
• To Make the Services of Other Companies Work on Our Websites – We allow companies to use cookies, web beacons, and other similar technologies to enhance the operations of particular services and functionality of our websites and mobile applications. 
• To Link Your Activity on Our Websites to Your Social Networks – We have added certain features to our websites that allow social networks (such as Facebook, Pinterest, Instagram, TikTok and Twitter) to track the activities of their members or collect certain information when they use our website or mobile applications. These features may include technologies called “plug-ins” and “widgets.” Plug-ins create a direct link between two websites, and widgets are interactive mini-programs that provide other companies’ services on our websites. If you are concerned about the way a social network is tracking your activity, please contact the social network or review its privacy policy. For example, you can review Facebook’s data-use policy at https://www.facebook.com/about/privacy/. 

How We Protect Your Information 
BRC protects your information using technical, physical, and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your information. When you transmit highly sensitive information (such as a credit card number) through our website, we encrypt the transmission of that information using the Secure Sockets Layer (SSL) protocol. However, no security system is perfect, and due to the inherent nature of the Internet, we cannot guarantee that data, including personal information, is absolutely safe from intrusion or other unauthorized access by others. You are responsible for protecting your password(s) and maintaining the security of your devices. 

Retention and Disposal of Your Information 
BRC stores personal information as needed to accomplish the purposes identified in this Privacy Statement and to meet legal requirements, including record retention, resolving disputes, and enforcing our agreements. Our retention of your personal information is governed by applicable law. This storage period may extend beyond the term of your relationship with BRC. The personal information that you provide us is stored and processed on servers owned by BRC and other companies in the United States, Canada or elsewhere around the world, including locations outside of the country or jurisdiction where you are located. Regardless of the company or person who processes your information and where it is processed, we will take steps to transfer and protect your information through appropriate safeguards in accordance with applicable data protection laws and this Privacy Statement. When personal information is no longer needed, or in any event, after legal authority to retain it has expired, personal information will be destroyed, in accordance with local law and pursuant to procedures established in relation to the relevant Blue Roan Coffee system or process. 

Children’s Privacy CHILDREN 
Our websites are intended for business use only. We do not knowingly collect or solicit Personal Information from anyone under the age of 18. If You are under 18, please do not attempt to register for the Sites or send any Personal Information about Yourself to us. 

CONSUMERS UNDER 18 YEARS OLD 
As of the effective date of this policy, we do not have actual knowledge that we sell CCPA PI of consumers under 18 years of age. If we learn that we have collected CCPA PI from a child under age 18, we will delete that information as quickly as possible and will not sell it. Please refer to the section on CHILDREN for more information. 

Marketing 
Unless You ask us not to, we may contact You via email in the future to tell You about specials, new products or services, or changes to this Privacy Policy. We will generally ask for Your consent to receive marketing communications in line with the applicable law when You first provide Your personal information. 

How Long Do We Keep Your Personal Information? 
We will store Your personal information in a form which permits us to identify You, for no longer than is necessary for the purpose for which the personal information is processed. We may use Your personal information as necessary to provide the Services, to comply with our legal obligations, to resolve disputes, and to enforce our agreements and rights, or if it is not technically and reasonably feasible to remove it. Otherwise, we will make best efforts to delete Your personal information within a reasonable timeframe upon written request by You to us. You can request the deletion of Your personal information by contacting us in writing using the contact information set forth in the “Contact Us” section below. 

Your Rights 
You may opt out of any future contacts from us at any time. In certain circumstances, You can do the following at any time by contacting us using the Contact Us page on our website:

• Right of Access – See the sources from which we have collected Your personal information, what personal information we have or have disclosed about You, if any, covering a minimum period of 12 months, and the business or commercial purpose of the collection of such personal information.
• Right to Rectification – Change/correct any information we have about You.
• Right to Erasure – Have us delete any personal information we have about You.
• Right to Object – Express any concern You have about our use of Your personal information.
• Right to Data Portability – Have us transmit any personal information directly to another organization, in certain circumstances.
• Right to Lodge a Complaint – Lodge a complaint with a competent data protection authority.

Your Choices 
You have control over your promotional communications preferences, mobile application functionality, cookie settings, interest-based advertising preferences, Flash cookies, and more. 

Promotional Communication Choices. 
You can opt out of receiving promotional emails and mailings by informing us of your preference at the time you sign up for a BRC account, by modifying your promotional preferences online in your account’s profile management section, or by following the “unsubscribe” instructions in the promotional emails we send you. Similarly, you may opt in to receive text messages, telephone calls and mailings. Please note that if you opt out of receiving promotional communications from us, we may still send you transactional communications, including emails about your BRC accounts/purchases. 

Security 
We take precautions and make best efforts to protect Your information. When You submit sensitive information via our website, Your information is protected both online and offline. Wherever we collect sensitive information (such as credit card data), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of Your web browser, or looking for “https” at the beginning of the address of the web page. While we use encryption to protect sensitive information transmitted online, we also protect Your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to such personally identifiable information. The computers and servers in which we store personally identifiable information are kept in a secure environment. 

Texas Privacy Protection Act (TXPPA): 
If  You are a Texas resident, the TXPPA grants You with rights regarding Your personal information. BRC affords everyone the same rights, regardless of location. As a result of our alignment with the General Data Protection Regulation (GDPR), most of the obligations of TXPPA have been covered in previous sections: “What personal information do we collect?”, “How do we process personal information?”, “Sharing Your personal information”, and “Your rights”. If You would like to exercise any of Your other rights, please visit “Your rights” for more information. If a representative and/or agent You designate is requesting rights on Your behalf, we will require proof of authorization. This may include needing You to verify Your identity directly with BRC. BRC has disclosed the following categories of information under the TXPPA in the past 12 months:

• Identifier Information, such as email addresses, internet protocol addresses, and name
• Geolocation data

Links 
This website may contain links to other websites maintained by third parties. Please be aware that under no circumstances shall we be held responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our website and to read the privacy statements of any other site that collects personal information. 

Updates 
This Statement went into effect on the “Last Revised” date noted near the top of this page. We may update this Statement from time to time. We will notify you of any modifications to this Statement that might materially affect your rights or the way that we use or disclose your personal information prior to the change becoming effective by means of a message on this website. We encourage you to look for updates and changes to this Statement by checking the “Last Revised” date when you access our website 

Contact us 
If You have any questions or concerns regarding this Privacy Policy, please contact us using the Contact Us page on our website, or by emailing us at [email protected]