Privacy Statement

Club Jarritos® knows that privacy is important to you. We don’t solicit from or knowingly gather information on anyone under the age of 13. Other information about how we gather and share data collected through this website is noted below.

Club Jarritos® has created this privacy statement (this “Privacy Statement”) in order to demonstrate its firm commitment to privacy. The following discloses Club Jarritos®’ information gathering, use and dissemination practices for the information collected through the site located at www.clubjarritos.com (the “Site”).

This Site is controlled and operated by Tipp Enterprises, Inc. (dba Novamex), Tipp Distributors, Inc. and its Affiliates from the United States, and is not intended to subject Tipp Enterprises, Inc. (dba Novamex), Tipp Distributors, Inc. and its Affiliates to the laws or jurisdiction of any state, country or territory other than that of the United States.

Other U.S. sites, from time to time, certain activities on U.S. sites might be governed by different privacy practices from those set forth below. We encourage you to check the privacy practices of each U.S. site you visit. This Privacy Statement does not govern our collection of information through any web site, or by any other means, other than through our Site; nor does this Privacy Statement govern the collection of information by third parties.

I. CLUB JARRITOS®’S COLLECTION OF INFORMATION

We gather two basic types of information through the Site: “Personally Identifiable Information” (or “PII”) and “Non-Personally Identifiable Information” (or “Non-PII”). Personally Identifiable Information is information that identifies you as an individual. Non-Personally Identifiable Information is aggregated information, demographic information, IP Address and any other information that does not reveal specific identifying information about you.

A. Personally Identifiable Information

We collect PII from you when you provide it to us while on the Site, such as: your name, address, telephone numbers and email address when you set up an account, enter a sweepstakes, redeem an award, sign up for newsletters, participate in a survey, contact customer service, or otherwise interact with this Site. The PII you provide to this Site may be combined with information you provide to Club Jarritos® on other U.S. sites, with demographic and other information that is publically available, or with other information about you that Club Jarritos® may otherwise obtain online or offline.

B. Non-Personally Identifiable Information

When you visit and interact with the Site, Club Jarritos® may collect Non-PII (for example, a catalog of the Site pages you visit). Non-PII is generally collected from cookies, referrers, IP addresses, environmental variables, pixel tags and similar technologies and information you voluntarily provide.

a. Cookies. Club Jarritos® and our service providers may use encrypted or non-encrypted cookies in connection with this Site. Cookies are pieces of information that a web site places in a file on your computer associated with your browser that may be used to deliver content specific to your interests and for other purposes, such as security and other account administrative functions, and which may track PII. This information is processed passively by your browser as you surf through this Site. Cookies do not cause damage to your computer system or files. If you do not want the information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of one particular cookie, or cookies from a particular web site, to your computer. For example, cookies allow you to easily log into the Site by remembering your email address.

b. Referrers; IP Addresses; Environmental Variables. Club Jarritos® and our service providers may also collect “referrers” information, IP addresses and various environmental variables.

- A “referrer “is information the Web browser passes along to our web servers that references the URL from which you came.

- The “IP address” is a number used by computers on the network to identify your computer so that data can be transmitted to you.

- “Environmental variables” include, among other things, the domain from which you access the Internet, the time you accessed this Site, type of Web browser and operating system or platform used, the Internet address of the web site you left to visit the Site, the names of the pages you visit while at the site, and the Internet address of the web site you then visit.

c. Pixel Tags. Club Jarritos® may also use the so-called “pixel-tags,” “web beacons,” “clear GIFS,” or similar means (collectively, “Pixel Tags”) in connection with some Site pages and HTML formatted email messages to, among other things, compile aggregate statistics about Site usage, response rates and the effectiveness of advertising campaigns. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to Site visitors and may be associated with cookies on the visitors’ hard drives. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can tell the sender whether and when the email has been opened.

d. Information You Voluntarily Provide. We may also collect demographic data, such as your date of birth, gender and zip code. When such data is not combined with any PII, such information is considered to be Non-PII, as it does not personally identify you or any other user. Additionally, we may aggregate PII in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using PII to display content according to your zip code. Such aggregate information is considered Non-PII for purposes of this Privacy Statement. This Site is not directed to individuals under the age of thirteen (13), and we request that such individuals not provide PII through this Site.

II. CLUB JARRITOS®’S USE OF INFORMATION

A. Personally Identifiable Information

PII is used by us to respond to your requests, to process your transactions, for administrative purposes, and to process rewards and prizes. We may also use PII for internal business purposes, such as analyzing and managing our businesses, for example, to study the effectiveness of advertising campaigns, improving our website or our products, to tailor the Site experience and content based on your past activities on the Site, and to gauge customer satisfaction. In addition, we may also use PII to send you information about Club Jarritos®’s promotions, to send invitations to you to participate in special programs, to re-contact you if we have not heard from you in a while and, occasionally, to send you advertising/promotional material from some of our affiliates, advertising and strategic partners. You may opt-out from receiving certain future electronic marketing communications (see the “Opt-Out/Choice” section below).

B. Non-Personally Identifiable Information

Because Non-PII does not personally identify you, we may use such information for any purpose. For example, we may use this information for Club Jarritos®’s internal use such as to enhance web site security, to detect broad demographic trends, to assist Tipp Enterprises, Inc. (dba Novamex), Tipp Distributors, Inc. and its Affiliates in providing content tailored to your interests, and to otherwise enhance your experience on this Site. This information may also be shared with third parties on an aggregate and non-personally identifiable basis. Please note we may link Non-PII to PII about you that we have previously collected. Such combined information will be treated as PII as long as it is so combined.

III. DISCLOSURE OF INFORMATION TO THIRD PARTIES

A. Strategic Partners

From time to time, we may enter into a special relationship with another company that is not owned by or affiliated with Club Jarritos®. We may share your name, email address and zip code with such third-party strategic partners; however, we will provide you with the opportunity to either opt into or opt out of such sharing when you set up an account and when you log in after we add a new strategic partner. Because these third parties will use your PII in accordance with their own privacy practices, you should check their web sites for information regarding their privacy practices.

B. Service Providers

We may use third party service providers to help us operate our business and this Site or administer activities on our behalf, such as companies for order fulfillment, delivery, and sweepstakes administration. We may share your PII with these third parties for those limited purposes. For instance, if you participate in a sweepstakes, game, or loyalty program resulting in a prize or reward, we will share your PII with our games management and merchandise fulfillment agencies.

C. Other Disclosures

We may also share your PII: (i) as permitted by law, (ii) in the event of a transfer of ownership, assets or a bankruptcy of Tipp Enterprises, Inc. (dba Novamex), Tipp Distributors, Inc. and its Affiliates, (iii) where we determine that disclosure of specific information is necessary to comply with the request of a law enforcement or regulatory agency, or (iv) to protect the interests or safety of Club Jarritos® or other visitors to this Site.

IV. LINKS AND THIRD PARTIES’ PRIVACY PRACTICES

This Site may contain links to other sites which are not operated by Club Jarritos®. CLUB JARRITOS® IS NOT RESPONSIBLE FOR THE PRIVACY PRACTICES OR THE CONTENT OF SUCH OTHER WEB SITES. Club Jarritos® recommends that you review the privacy policy of third party web sites arrived at from links on this Site. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.

V. SECURITY

This Site has security measures in place to help protect against the loss, misuse and alteration of the PII under its control. Club Jarritos® employs security measures consistent with standard industry practice to help protect against public access to personal and account activity information collected on and used by Club Jarritos® at this Site. For instance, all access to our databases that contain PII is logged for security purposes and access is limited to individuals with a business need to have access. Certain specific activities are protected using a secure communications encryption technology called SSL. SSL (stands for Secure Sockets Layer) is a method for hiding information to prevent others from intercepting and reading data sent between the client (your computer) and the server (this Site). All PII and account activity are also protected through the use of user names and passwords. In order to help maintain the security of your information, you should protect the confidentiality of your user name and password. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. As a result, although we strive to protect your PII, we cannot ensure or warrant the security of any information you transmit to us through or in connection with this Site or that is stored by us. You acknowledge and agree that any information you transmit through the Site is so transmitted at your own risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with ‘Contacting Club Jarritos®,’ below (note that physical mail notification will delay the time it takes for us to respond to the problem).

VI. ADVERTISING-RELATED VENDORS

Please note that our online and email advertising-related vendors may use cookies and Pixel Tags in connection with the Site to help manage our online and email advertising campaigns and strengthen the effectiveness of such campaigns. For example, if a vendor has placed a unique cookie on your computer, the vendor may use Pixel Tags to recognize the cookie during your visit to the Site and to learn which online advertisements of Club Jarritos® may have brought you to our Site and the vendor may provide us with such non-PII for our use. Please note we may link such non-PII provided to us by our vendors to PII about you that we have previously collected. Such combined information will be treated as PII hereunder as long as it is so combined.

VII. OTHER INFORMATION

Club Jarritos® does not represent or warrant that this Site or any part thereof is appropriate or available for use in any particular jurisdiction other than the United States. Those who choose to access this Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules, and regulations. You are also subject to United States export controls in connection with your use of this Site and/or Site-related services, and are responsible for any violations of such controls, including without limitation any United States embargoes or other federal rules and regulations restricting exports. We may limit this Site’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time in our sole discretion.

VIII. OPT-OUT/CHOICE

This site provides you with the opportunity to opt-out of receiving marketing communications from Club Jarritos®. If you opt-out, Club Jarritos® will not send you future marketing communications related to Club Jarritos®. Club Jarritos® also gives you convenient methods for unsubscribing from electronic marketing communications so as not to receive such electronic marketing communications either from Tipp Enterprises, Inc. (dba Novamex), Tipp Distributors, Inc. and its Affiliates or Club Jarritos® databases. However, regardless of your opt-out preferences, Club Jarritos® may still at times need to send emails for administrative reasons.

To exercise your opt-out rights:

• You may click on the opt-out link on the bottom of any marketing email from Club Jarritos® and make choices as to what marketing communications from Club Jarritos® you wish to receive;

• You may send mail to the following postal address (please specify clearly what electronic marketing communications you are opting-out from):

Club Jarritos® Headquarters

PO Box 181629

Dallas, TX 75218-8629

Please note that changes may not be effective immediately. We will endeavor to comply with your request as soon as reasonably practicable.

IX. UPDATES TO THIS PRIVACY STATEMENT

Club Jarritos® reserves the right to make changes in this Privacy Statement. You can determine when this Privacy Statement was last revised by referring to the “LAST UPDATED” legend at the top of this page. Any changes to our Privacy Statement will become effective upon our posting of the revised Privacy Statement on this Site. We encourage you to check this page regularly since your continued use of this Site following any changes to this Privacy Statement will be deemed to constitute your acceptance of such change.

X. REVIEWING/CORRECTING/UPDATING YOUR INFORMATION

To review, correct, update or otherwise modify information you have previously provided:

You may contact customer care at 1-866-252-2020.

You may send mail to the following postal address:

Club Jarritos®

Website Customer Care

PO Box 181629

Dallas, TX 75218-8629

Please note that changes may not be effective immediately. Further, please note that we may need to retain certain information for record keeping purposes, and there may also be residual information that will remain within our databases and other records. We also reserve the right, from time to time, to re-contact former users of the Site. Finally, we are not responsible for removing information from or updating information in the databases of third parties with whom we have already shared your PII.

XI. CONTACTING CLUB JARRITOS®

If you have any questions about this Privacy Statement or the practices of this Site, you may contact:

PO Box 181629

Dallas, TX 75218-8629

Telephone # 1-866-252-2020

www.clubjarritos.com