This Privacy and Cookie Policy (“Policy”) describes how Uppal Brewers & Distillers (UBD) (“we”, “our”, “us”) collects, processes, stores, uses, shares, and protects your personal data when you access, browse, or interact with our website (the “Site”), or otherwise engage with us. This Policy also explains your rights regarding your personal data under Indian data protection laws, including:

• The Information Technology Act, 2000;
• The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011;
• The Digital Personal Data Protection Act, 2023 (“DPDPA”), where applicable.

We are committed to protecting your privacy and maintaining your trust.

1 Age Eligibility and Legal Drinking Age Requirement

Important Note:

This Site and our services are intended only for individuals who are of legal drinking age in their country of residence and the country from which they access the Site. In India, this is 18 years or older, although this may vary by state (e.g., 21 in some jurisdictions).

We do not knowingly collect or process personal data from any person who is under the legal drinking age. If we become aware that such data has been inadvertently collected, we will promptly delete it from our records.

By using our Site, you confirm that you meet the minimum age requirement and are legally permitted to consume alcohol.

2 What is Personal Data?

“Personal Data” refers to any information that relates to an identifiable natural person, whether directly or indirectly. It includes information such as:

• Name
• Email address
• Phone number
• IP address
• Date of birth
• Location data
• Device information
• Online activity

Personal data also includes “Sensitive Personal Data or Information (SPDI)” under Indian law, such as:

• Passwords
• Financial data (e.g., credit card details)
• Health conditions
• Biometric data
• Sexual orientation
• Any detail relating to these categories

We take additional precautions when handling SPDI, as required by law.

3 What Data We Collect

We collect data through the following methods:

1. Data You Provide to Us Directly:

This includes information you voluntarily submit via:

• Contact forms
• Newsletter sign-ups
• Feedback, survey, or contest entries
• Customer service queries
• Comments or reviews on the Site

Examples:

• Name, phone number, email ID
• Your message content
• Preferences for marketing

2. Data We may Collect Automatically:

When you visit the Site, we collect certain data automatically through cookies and analytics tools.

Examples:

• Browser type and version
• Device type (mobile/desktop)
• IP address and geographic location
• Pages visited and time spent on each
• Date and time of visit
• Clicks, scrolls, and other usage behaviour

This data helps us understand user behaviour and improve the functionality of the Site.

3. Data Collected from Third Parties:

We may also receive personal data about you from third-party sources such as:

• Social media platforms (if you interact with us there)
• Advertising partners (with your consent)
• Public databases or referrals

4 Why We Collect Your Personal Data (Purpose of Collection)

We collect and process your personal data for the following clearly defined and lawful purposes:

1. To Verify Your Age:

We ensure that only individuals of legal drinking age access alcohol-related content.

2. To Provide Services You Request

When you contact us, request information, or fill out a form, we use your data to fulfil your request.

3. To Improve Our Website and Services

Usage data helps us improve site navigation, content quality, and loading speed.

4. To Respond to Your Queries

If you ask us a question or lodge a complaint, we use your contact information to respond promptly and accurately.

5. To Send Marketing Communications (Only with Consent)

We may send you emails, SMS, or notifications about our brand updates, offers, and promotions only if you have opted in. You may opt out at any time.

6. To Comply with Indian Laws

We may process your data to comply with legal obligations under IT rules, tax laws, or court orders.

5 Legal Grounds for Processing Your Data

We rely on the following legal bases to process your data in compliance with Indian law:

• Consent (freely given, informed, specific, and revocable at any time);
• Performance of a contract (e.g., responding to queries);
• Compliance with a legal obligation (e.g., anti-fraud or record-keeping);
• Legitimate interest, where processing is necessary for business operations and doesn’t override your privacy rights (e.g., fraud prevention, analytics).

6 Data Sharing and Disclosure

We do not sell or rent your personal data to third parties.

However, we may share your data under the following conditions:

1. With Trusted Service Providers

Third-party vendors who help us run our website, marketing campaigns, analytics, or customer support. They are contractually obligated to protect your data and use it only for the purpose we specify.

2. With Government or Law Enforcement Authorities

We may disclose your data if required by legal process, court orders, or to comply with the law.

3. In Corporate Transactions

If we are involved in a merger, acquisition, restructuring, or sale, your data may be transferred to the successor entity.

7 International Data Transfers

UBD is based in India. However, some of our service providers or partners may be located outside India. In such cases:

• We ensure equivalent data protection safeguards are in place;
• We use Standard Contractual Clauses or similar measures, where applicable.

8 Use of Cookies and Similar Technologies

Cookies are small files placed on your device when you visit a website. They help us remember your preferences, understand usage patterns, and enhance user experience.

Types of Cookies We Use:

Managing Cookies:

You can accept or reject cookies using your browser settings. Disabling cookies may affect certain features of the Site.

For more details, visit: www.allaboutcookies.org

9 Data Retention

We retain your personal data for as long as:

• It is needed for the purposes outlined in this Policy;
• It is required by law (e.g., for tax records, legal claims);
• You have an ongoing relationship with us.

Once retention is no longer justified, we delete or anonymize your data in accordance with industry best practices.

10 Data Security

We implement technical and organizational safeguards to protect your data, including:

• Secure servers and firewalls;
• SSL encryption;
• Access controls;
• Staff confidentiality agreements.

However, no digital transmission is 100% secure. If you suspect a security issue, please contact us immediately (see Section 12).

11 Your Rights Under Indian Law

Under applicable data protection laws, you have the right to:

• Access your personal data;
• Correct inaccurate or outdated data;
• Withdraw consent at any time;
• Delete your data (where legally possible);
• Restrict processing, in certain cases;
• File a complaint with the Data Protection Board of India.

To exercise any of these rights, please contact our Grievance Officer.

12 Grievance Redressal and Contact Details

If you have any questions or concerns about these Conditions of Use or your experience on the Site, please contact us using the contact information provided on our “Contact Us” page. Any information you provide will be handled in accordance with our Privacy Policy.

13 Third-Party Links

Our Site may link to external websites for your convenience. These third-party sites operate independently and are governed by their own privacy policies. We are not responsible for their practices.

14 Updates to This Policy

This Policy may be updated from time to time to reflect changes in law or our business practices.
We will notify users of significant changes via:

• Website banners or notices;
• Email alerts (if applicable).

Please revisit this page regularly to stay informed.

15 Governing Law and Jurisdiction

This Policy is governed by the laws of India, and any disputes shall be subject to the exclusive jurisdiction of the courts in Delhi.