Last updated: 10.14.22

Aubre Winters Fitness, LLC and its affiliated subsidiaries and related entities (collectively hereinafter,
“Company”, “us”, “our” or “we”) respect your privacy and want you to be familiar with how we collect,
use, maintain, protect, and disclose your Personal Information (as defined below). This Privacy Policy
(“Privacy Policy”) explains how we or our Service Providers (as defined below) collect, store, use,
disclose, and otherwise process your Personal Information when you access and use of
www.aubrewinters.com (“Website”), any other websites, platforms, and social media platforms owned
or controlled by us, along with any content, functionality, and services offered through us (each a
“Property,” collectively “Properties”). Capitalized terms not otherwise defined shall have the same
meaning given to them in the Terms of Use.

By using any Property, you agree to the terms and conditions of this Privacy Policy and consent to the
collection and use of information by us as set forth herein. If you do not agree to any of the provisions
of this Privacy Policy, do not use the Properties.

Section 1 – Linked Sites and Service Providers.

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other
data collection, storage, and use practices of any third party operating any site or property to which any
Property contains a link, including, without limitation, Sutra.Fit, ActiveCampaign, LLC, Facebook,
Inc., Apple Inc., Google Inc., Microsoft Corp., any wireless carriers and any third party (each, a “Linked
Site”) or third parties who may provide services in connection with your access and use of the Properties
as further detailed herein (each, a “Service Provider”).

The inclusion of a link on any Property does not imply our endorsement of, or affiliation with, the Linked
Site. Please note that the Properties may include the ability to access and submit certain information
directly to third parties, such as Service Providers. This Privacy Policy does not apply to any Personal
Information submitted by you to third parties, including without limitation, those Linked Sites and
Service Providers. You agree to the terms and conditions and privacy policies of such Service Providers,
which may change from time to time without notice to you.

Sutra.Fit Terms and Policies: You understand and agree that our online studio and mobile app is powered by the Arketa platform and therefore your access and use of the online studio platform is governed by Sutra.Fit’s Terms of Service and Privacy Policy. If you do not agree to the foregoing policies, please do not use the online studio or mobile app Properties.

Section 2 – Children Under the Age of 13.

Our Properties are not intended for children under 13 years of age. No one under age 13 may provide
any information to or via the Properties. We do not knowingly collect personal information from
children under 13. If you are under 13, do not use or provide any information via the Properties or on or
through any of its features/register on the Properties, make any purchases through the Properties, use
interactive or public comment features of the Properties (if any), or provide any Personal Information
(as defined below) to us, including your name, address, telephone number, email address, or any screen
name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will take corrective action as required by
the Children’s Online Privacy Protection Act (“COPPA”). Parents may want to consider commercially available parental control protections to limit what minors can access online and/or monitor their minor children’s online activities.  

Examples include: www.netnanny.com; www.webwatcher.com and www.sentrypc.com.  We do not endorse these or other services and are not responsible for them.

Section 3 – Changes to this Privacy Policy.

We may change this Privacy Policy at any time. Please look at the “Last Updated” legend at the top of
this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become
effective when we make the revised Privacy Policy available on or through the Properties. Your use of
any Property following such changes means that you accept the revised Privacy Policy. In the event we
make a material change to this Privacy Policy, we will notify you via e-mail or otherwise by any
acceptable means under applicable law.

Section 4 – Information We Collect.

The information we collect falls into three general categories: (i) information you provide directly to us,
(ii) information collected automatically, and (iii) information we obtain from third parties. We process
this information in light of our legitimate interest in operating, providing, improving the Properties, and
giving you the best experience, and where it is necessary for us to provide services to you. Without it,
we may not be able to provide you with the requested services and features of the Properties.
You may provide us and our Service Providers with two types of information: (a) Personal Information
you knowingly choose to disclose that is collected on an individual basis, and (b) Personal Information
collected on an automatic basis as you use our Properties. “Personal Information” is information that
can be used to identify you (whether alone or in combination) such as your first and last name, email
address, zip code/post code, billing address, shipping address, phone number, age, date of birth, credit
card information, and social media handles.

Information You Provide. You may provide us, and our third-party service providers, with Your Personal
Information through the Properties, for example:

Online Studio Account Registration: When you sign up for a free trial, subscription, or make any
other purchase in our online studio, you must create an account with your e-mail address and a
password and provide valid payment card information. Except for the name associated with
your card and information about the transaction (e.g., time of transaction, amount), payment
card information is collected directly by a third-party payment vendor and is not received or
stored by us. You may also create a username and upload an avatar to use for comments or
forums.

In-Person Classes or Events: When you sign up to attend classes, Walk Club, or other events, you
will need to provide your full name, e-mail address, phone number, and possibly your billing
address, credit card information.

Make a Purchase: When you make a purchase, you will need to provide certain Personal
Information for us to process and fulfill the order such as your name, billing and shipping
address, email address, phone number, and credit card information.

• Newsletter: When you sign up for any of our newsletters, you will need to provide your e-mail address and full name.
• Walk Club Ambassadorship: When you apply to become a Walk Club Ambassador, you will need to provide your name, e-mail, and certain general location information about where you are located.
• Messages, Communications, and Submissions: When you communicate with us or our third- party service providers by e-mail or through the Properties, you may provide us certain Personal
• Information, such as your name, e-mail address, and other information you may provide as part of your inquiry or message.
• Survey: If you participate in any survey, you may provide certain Personal Information as part of your response.
• Information We Collect Automatically. We and our Service Providers may collect certain Personal Information automatically when you access the Properties and other web analytics services. This information generally includes:
• Usage Data: When you use the Properties, we and our Service Providers may track and collect usage data and information about your interactions with the Properties such as the pages that you visit and links you click on, and the date and time the Properties on your device access our servers.
• Cookies, Web Beacons, and Log Data: Like most companies, when you visit or interact with the Properties, we and our Service Providers may use cookies and other tracking technologies for storing information, including pixels, web beacons, “clear GIFs,” local storage, and device identifiers to help provide, protect and improve the Properties.
  • An Internet Protocol (IP) address is a number that is automatically assigned to your device from which you are accessing the Property by your Internet Service Provider (ISP), and is identified and logged automatically in our server log files whenever you visit the Properties, along with the time of the visit and the activity on the Properties, browser type and operating system, device information, device event information, and the page you’ve viewed or engaged with before or after using the Properties. We and our Service Providers use IP addresses for purposes such as calculating Property usage levels, helping diagnose server problems, administering the Properties and determining your approximate geographic location.
  • “Cookies” are small pieces of information that a website attaches to your browser when you visit a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until deleted) to provide you with a more personal and interactive experience with the Website. When you visit a site, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each site can send its own cookie to your browser if your browser’s preferences allow it. We do not store Personal Information in any Cookies on your computer. Persistent Cookies can be removed by following your Internet browser’s directions within the help tab. However, in order to use certain aspects of the Properties, your web browser must accept Cookies, and therefore some aspects of the Properties may not work properly if you choose to disable Cookies.
  • We may also use Cookies, pixels, “Web Beacons” (which are usually small, transparent graphic images) and navigational data like Uniform Resource Locators (URLs to gather information regarding the date and time of your visit, the features and information for which you searched and viewed, or the e-mail you opened. This type of information is collected to make the Properties more useful to you and to tailor the experience with us to meet your interests and needs.

• Geographic Location Information: If you use any location-enabled products or services, you may be sending us location information (e.g. IP address). When you use a location-enabled service, we may collect and process information about your precise geographical location, such as GPS signals sent by a mobile device. We and our Service Providers and partners may use your device’s physical location to provide you with personalized location-based services, content and advertisements. In some instances, you may be permitted to allow or deny such uses of your device’s location, but if you choose to deny such uses, we may not be able to provide you with the applicable personalized services and content.
• Device Information: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, device type (Windows or Macintosh), screen resolution, operating system version, Internet browser type and version and the type and version of the Property that you are using. We and our Service Providers may also collect a unique device identifier assigned by us or our Service Providers to the device from which you are accessing the Property and other transactional information for the device that we and our Service Providers may use to serve content and advertisements to the device.
• Software Development Kits (“SDK(s)”): We may use third parties including our business partners and Service Providers who use mobile SDKs to collect information and information related to how mobile devices interact with the Properties. An SDK is computer code that app developers can include in their apps to enable ads to be shown, data to be collected and related services and functionality to be implemented. A mobile SDK is in effect the mobile app version of a pixel tag or beacon. We may use this technology, for instance, to analyze how you interact with content and advertisements and to enable analytics or other features through mobile devices.
• Aggregated Information: We may aggregate Personal Information so that the end-product does not personally identify you or any other user of the Property, for example, by using Personal Information to calculate the percentage of our users who access a particular article. Information From Third Parties. We may engage third parties, such as Google Analytics, Shopify, Sutra.Fit, and ActiveCampaign, to provide analytics about the use of our Properties, assist with our payment processing, data processing and management, account management, hosting, customer and technical support, management, fulfillment, and shipment for orders, and other services which we use to personalize your experience. These Service Providers may use cookies, web beacons, pixels, embedded scripts, and other technologies to automatically collect information about your use of the Website, such as your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. Additionally, we or our Service Providers may work with advertising networks and programmatic exchanges to allow us to serve you ads. These third-party ad networks and exchange providers may use third-party cookies, pixels, or similar technologies to collect information, including your device identifier, IP address, or identifier for advertising. The information these third parties collect may be used to help us in providing you with more relevant advertising that we serve on or off the Properties, and as described above. Third-party cookies are covered by the third parties’ privacy policy. If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit the Network Advertising Initiative at www.networkadvertising.org or the Digital Advertising Alliance at www.aboutads.info.

The Properties may use social media plug-ins (e.g., the Facebook “Like” button, “Share to Instagram”
button) to enable you to easily share information with others. When you visit the Properties, the
operator of the social plug-in can place a cookie on your computer or other electronic device that
enables that operator to recognize individuals who have previously visited our Properties. If you are
logged into the social media website (e.g., Facebook, Twitter) while browsing on our Properties, the
social media plug-in allows that social media website to receive information that you have visited our
Properties. The social media plug-in also allows the social media website to share information about
your activities on our Properties with other users of their social media website. These sharing settings
are managed by the social media website and governed by its privacy policy. We recommend that you
review the privacy policies of each of these websites, apps, or services before connecting your accounts
or sharing any Personal Information.

Section 5 – How We Use Your Information.

We and our Service Providers may use your Personal Information for a range of legitimate business
purposes, including the following:
– To fulfill orders, process payments, arrange for shipping, and communicate with you about your
membership, purchases, or order.
– To provide you access to our online studio, platform, and services and respond to your
inquiries.
– To send you administrative information, including information regarding your account, updates
to the Properties, and changes to our Terms of Use and Privacy Policy.
– To communicate with you for customer service, or to answer your requests.
– To send you newsletters and marketing communications (including, without limitation, by our
Service Providers that send direct e-mail and other types of advertising to those whose email
addresses we have collected).
– To personalize your experience with the Properties by presenting content, products, and offers
tailored to you.
– To provide, improve, test, monitor, and develop the Properties, including, without limitation, to
provide you access to the Properties, identify usage trends, determine the effectiveness of
promotional campaigns, test new products, services, and features, as well as diagnose and fix
technology problems in connection with current products, services, and features.
– For our business purposes, such as fraud prevention, data analysis, audits, developing new
products, enhancing the Properties, improving our services, and identifying usage trends.
– To administer a sweepstakes, contest, survey, and other promotions. Some of these activities
have additional rules, which could contain additional information about how we use and
disclose your Personal Information, so we suggest that you read these rules carefully; in the
event of a conflict between such rules and this Privacy Policy, such rules will govern.
– As we believe to be necessary or appropriate: (a) under applicable law, including laws outside
your country of residence; (b) to comply with legal process; (c) to respond to requests from
public or government authorities, including public or government authorities outside your
country of residence; (d) to enforce our Terms of Use and Privacy Policy; (e) to protect our
operations; (f) to protect our rights, privacy, safety or property, or that of you or others; or (g) to
allow us to pursue available remedies or limit the damages that we may sustain.
– We may combine Personal Information that you submit on or through the Property with
information that we collect from and about you from other online and offline sources, including from our own websites and web properties (including apps, widgets and players) and third party
sources.

Section 6 – How Your Personal Information May Be Disclosed to Third Parties.
Your Personal Information may be disclosed:
– With Your Consent: We will disclose your Personal Information for those purposes in which you
have agreed that we may do so, including for such purposes outlined in this Privacy Policy.
– Service Providers: We use a variety of Service Providers to provide services to us or to our users
on our behalf, such as hosting, data analysis, payment processing, order fulfillment,
infrastructure provision, IT services, customer service, email delivery, credit card processing,
auditing and other similar services to enable them to provide such services. For example, we use
Shopify to host and power our online store, Sutra.Fit to power our online studio, and
ActiveCampaign to assist us with our email communications. These Service Providers have
access to your information solely to perform these tasks on our behalf in accordance with our
instructions and to the extent necessary to provide their services to us.
– Aggregated Data or Anonymous Information: We may also share anonymous information in the
form of aggregated information (information about our users that we render in such a way that
it no longer identifies or references an individual user) and other pseudononimized information
for regulatory compliance, industry and market analysis, demographic profiling, marketing and
advertising, and other business purposes.
– Compliance with Laws: We may disclose your Personal Information to courts, law enforcement
agencies, and governmental authorities (a) to comply with applicable law, including laws outside
your country of residence; (b) to comply with legal process; (c) to respond to requests from
public or government authorities, including public or government authorities outside your
country of residence; (d) to enforce our Terms of Use; (e) to protect our operations; (f) to
protect our rights, privacy, safety or property, or that of you or others; or (g) to allow us to
pursue available remedies or limit the damages that we may sustain.
– Change of Control: We may also share your Personal Information as part of a sale, merger or
change in control of Company, or in preparation for any of these events. Any other entity that
buys us or part of our business will have the right to continue to use your data, but only in the
manner set out in this Privacy Policy unless you agree otherwise.

Retention Period. Your Personal Information may be stored as long as it is required for the purposes
identified when you provided the information for such specific purposes or for any new purposes
identified by us and consented to by you, and for any appropriate time thereafter including a sufficient
time following to permit you to ask any questions regarding its use, after which point it will be archived
only for so long as reasonably necessary for the purposes set out above, in accordance with applicable
laws.

Sensitive Information. Do not send us or disclose any sensitive Personal Information (e.g., social security
numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs,
health, criminal background or trade union membership) on or through the Properties or otherwise to
us.

Section 7 – Choice and Access.

Data Security. We and our Service Providers have implemented measures designed to secure your
Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.
Notwithstanding, the safety and security of your information also depends on you. Where we or any of
our Service Providers have given you (or where you have chosen) a password for access to certain parts
of our Properties, including our online studio, you are responsible for keeping this password
confidential. We ask you not to share your password with anyone and urge you to be careful about
giving out Personal Information in public areas of the Properties like message boards and comments
sections. The information you share in public areas may be viewed by any user of the Properties.
We restrict access of Personal Information to authorized personnel of Company, and Service Providers
and agents who need to know that information in order to operate, monitor, and deliver our services,
fulfill orders, and administer the Properties. Personal Information will only be disclosed to those vendors
and Service Providers of Company for the purpose of administering our Properties and completing
transactions taking place thereon in accordance with the uses as outlined herein.

Unfortunately, the transmission of information via the internet is not completely secure. Although we
do our best to protect your personal information, we cannot guarantee the security of your Personal
Information transmitted to our Properties. We cannot guarantee that unauthorized third parties will not
gain access to your Personal Information; therefore, any transmission of Personal Information is at your
own risk. We are not responsible for circumvention of any privacy settings or security measures in
connection with the Properties.

Your choices regarding our use and disclosure of your Personal Information. In some jurisdictions,
including the European Economic Area (EEA), you may exercise certain rights to access, request copies
of, change or correct, request our deletion or transfer, object to or reject certain processing of your
Personal Information. You may, of course, decline to share certain Personal Information with us. In such
circumstances we may not be able to provide to you some of the features and functionality found on the
Properties. Note that your information will be transferred outside the EEA, including to the United
States.

Opting Out. We give you many choices regarding our use and disclosure of your Personal Information
for marketing purposes. You may opt-out from:

Newsletters and Communications: To opt out of receiving our online newsletter, please click the
unsubscribe link at the bottom of the email. You may also unsubscribe by contacting
community@aubrewinters.com, contact@sutra.fit or via the online form submission here.

Please note that, if you opt-out as described above, we may not be able to remove your Personal
Information from the databases of unaffiliated third parties with which we have already shared your
Personal Information as of the date that we process your opt-out request. Please also note that, if you
do opt-out from receiving marketing-related messages from us, we may still send administrative
messages to you, such as related to pending orders, returns, or refunds.

Opt Out of Google Analytics. To opt out of Google Analytics, you may install the Google Analytics Opt-
Out Browser found at https://tools.google.com/dlpage/gaoptout. To opt out of Google Analytics for
display advertising or customize Google display network ads, you can visit the Google Ads Settings page
found at https://adssettings.google.com/authenticated.

Opt Out of Facebook Ads. To opt out of Facebook ad retargeting and re-marketing, you may do so by
adjusting your settings at https://www.facebook.com/about/ads.
The options described above must be set on each of your devices in order to apply. Not all companies
that serve interest-based ads participate in the ad industry opt-out programs described above, so even after opting-out, you may still receive some cookies and interest-based ads from other companies.

“Do Not Track” Signals. Note that your browser settings may allow you to automatically transmit a “Do
Not Track” signal to sites and online services you visit. There is no consensus among industry
participants as to what “Do Not Track” means in this context. Like many websites and online services,
we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser.

To learn more about cookies and any “Do Not Track” features, please visit
http://www.allaboutcookies.org/ and http://www.allaboutdnt.com. If you choose to decline cookies,
then some or all of the features, functionality and promotions available through the Property that may
not be available to you. If you do not want information collected through the use of cookies, there is a
procedure on most devices through which the Properties are accessed that allows you to decline the use of cookies.

Adobe Flash LSOs. If your device stores Flash LSOs, and if you do not want Flash LSOs stored on your
device through which you access the Property, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained using the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your device without you being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Property or our
content. We expect our Service Providers and technology suppliers to honor any decision by you to
restrict or limit Flash LSOs, but we cannot guarantee that they will do so.

Mobile Device Settings. On your mobile device, enable the “Limit Ad Tracking” setting in your iOS
phone’s settings, or the setting to “Opt out of Ads Personalization” in your Android phone’s settings. To
opt-out of location tracking when using our Properties, you can use the settings of your device. You can disable mobile analytics and bug reporting through these same settings as well.

For more information about analytics and advertising cookies and how you can opt out, you can visit
the Network Advertising Initiative’s opt-out page found at http://optout.networkadvertising.org/?c=1 ,
the Digital Advertising Alliance’s opt-out page found at http://optout.aboutads.info/?c=2&lang=EN,
EDAA’s Your Online Choices page found at http://www.youronlinechoices.com/ or via AppChoices
mobile app, available at https://www.youradchoices.com/appchoices, which lets you opt-out of
interest-based ads in mobile apps.

Section 8 – Privacy Notice for California Residents.
This Privacy Notice for California Residents supplements the information contained in this Privacy Policy
and applies solely to external contacts who reside in the State of California. We adopt this notice to

comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA
have the same meaning when used in this Notice.

Information We Collect and Disclose

The chart below provides additional information about the categories of Personal Information we
collect, the reason we collect it, and the categories of third parties with whom we may share the
information. Note that we do not necessarily collect all types of information that fall within a certain
category.

Category of Personal Information	Reason for Collecting  and/or Sharing	Categories of Third Parties	Collected or Disclosed in past 12 months
Common identifiers This includes a name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, and other similar identifiers.	–        Provide access to our Properties. –        Process and fulfill your order. –        Administer promotions, offers, sweepstakes or giveaways. –        Providing you customer service, and respond to your requests. –        Sending you information about our products or services. –        Personalizing our products and services. –        Our legitimate business purposes.	Service Providers	Collected and disclosed
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).  This includes, among other things, a name, signature, address, telephone number, passport number, and driver’s license or state identification card number.  Note that this category of information overlaps to some extent with the “Common Identifiers” category.	Not applicable.	Not applicable.	Not collected or disclosed.
Protected classification characteristics under California or federal law. This includes:  Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	–        Respond to your communications. –        Publishing your comments and/or reviews. –        Personalizing our products and services. Our legitimate business purposes.	Not applicable.	Collected; Not Disclosed.
Commercial information.  This includes: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Process and fulfill your order. Administer promotions, offers, sweepstakes or giveaways. Providing you with customer service, and respond to your requests. Personalizing our products and services. Our legitimate business purposes.	Service Providers	Collected and disclosed
Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	Not applicable.	Not applicable.	Not collected or disclosed.
Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Not applicable.	Not applicable.	Not collected or disclosed.
Geolocation data.  Physical location or movements.	Not applicable.	Not applicable.	Not collected or disclosed.
Sensory data.  Audio, electronic, visual, thermal, olfactory, or similar information.	Not applicable.	Not applicable.	Not collected or disclosed.
Professional or employment-related information.  Current or past job history or performance evaluations.	–        Processing any job applicant.	Not applicable.	Collected; Not disclosed.
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).   Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	Not applicable.	Not applicable.	Not collected or disclosed.
Inferences drawn from other personal information.  Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Not applicable.	Not applicable.	Not collected or disclosed.

We use your Personal Information in accordance with the Section “How We Use Your Information”
above. We will not collect additional categories of personal information or use the personal information
we collected for materially different, unrelated, or incompatible purposes without providing you notice.
In the preceding twelve (12) months, we have not sold Personal Information.

Your Rights and Choices: The CCPA provides California residents with specific rights regarding their
Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

The Right to Know	You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity: –       The specific pieces of information we have collected about you; –       The categories of Personal Information we have collected about you; –       The categories of sources of the Personal Information; –       The categories of Personal Information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; –       The categories of Personal Information we have sold and the categories of third parties to whom the information was sold; and –       The business or commercial purposes for collecting or selling the Personal Information
The Right to Request Deletion	You have the right to request the deletion of Personal Information we have collected from you, subject to certain exceptions.
The Right to Opt Out of Personal Information Sales	You have the right to request the deletion of Personal Information we have collected about you to third parties now or in the future.
The Right to Non-Discrimination	You have the right not to receive discriminatory treatment for exercising these rights.  In particular, we may not: –       Deny you goods or services; –       Charge you different prices for goods and services or impose penalties; –       Provide you with a different level or quality of service; or –       Threaten you with any of the above. However, please note that if the exercise of these rights limits our ability to process Personal Information, we may no longer be able to provide you our products and services or engage with you in the same manner.
“Shine the Light”	California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

California residents who wish to request further information about our compliance with this law or have
questions or concerns about our privacy practices, may do so at the following:
– Email community@aubrewinters.com; or
– Via the online form submission here

We will only act on your request if it is “verifiable.” To verify your identity, we will collect basic personal
information about you to match with our records. Next, you will receive a written confirmation that
your request was received, as well as information about additional steps that may be required to
confirm your identity and verify appropriate contact information.

You may make a request to disclose or delete using an “authorized agent.” Please include with your
request a signed document stating that the agent is authorized to act on your behalf. We will then
respond by providing information as to (i) how you can verify your identity, and (ii) confirm that the
agent is authorized to act on your behalf.

If you have only provided Personal Information as a result of browsing our Website (i.e., you did not
complete any forms or send us any emails or other communications) we will be unable to provide
information about the specific Personal Information we hold about you. Please refer to the table above
for information about our general data handling practices.
Please note that you may make data requests no more than twice in a 12-month period.

We will try to respond to verifiable requests within 45 days. If we require more time, we will inform you
of the reason and extension period in a written response. Any disclosures we provide will only cover the
12-month period preceding the receipt of your request. The response we provide will also explain the
reasons we cannot comply with a request, if applicable.

Section 9 – General Data Protection Regulation

.
If you are a data subject in the EEA, you have the right to access, rectify, or erase any personal data
Company has collected about you. You also have the right to data portability and the right to restrict or
object to Company’s processing of personal data it has collected about you. You may withdraw your
consent at any time for any data processing Company does based on consent you have provided to it. To
exercise any of these rights, community@aubrewinters.com or via the online form submission here and specify which right you intend to exercise. Please include your name, address, and e-mail address, with “Legal” in the subject line in your request. We will try to comply with your request as soon as reasonably practicable. Company will respond to your request within 30 days.

Company may require additional information from you to allow Company to confirm your identity.
Please note that Company may store information as necessary to fulfill the purposes for which it was
collected, and may continue to retain and use the information even after a data subject request for
purposes of Company’s legitimate interests, including to comply with its legal obligations, resolve
disputes, prevent fraud, and enforce its agreements. Personal Information collected within the
European Union and Switzerland may be transferred and processed by third parties located in a country
outside of the European Union and Switzerland. In such instances, Company will ensure that the
transfer of your personal data is carried out in accordance with applicable privacy laws. If you have any
issues with Company’s compliance, you have the right to lodge a complaint with an EEA supervisory
authority.

Section 10 – Release.

TO THE FULLEST EXTENT PERMITTED BY LAW, YOU HEREBY RELEASE COMPANY AND EACH OF THE
OTHER COMPANY PARTIES (DEFINED BELOW) FROM ANY CLAIMS OR DAMAGES OF ANY KIND OR
NATURE, KNOWN OR UNKNOWN, SUSPECTED OR UNSUSPECTED, DISCLOSED OR UNDISCLOSED,
RELATING TO THE DATA COLLECTION, STORAGE, USE, AND SHARING OF YOUR OR ANY THIRD PARTY’S PERSONAL INFORMATION OR ANONYMOUS INFORMATION BY ANY SERVICE PROVIDER. YOU AGREE, UNDERSTAND AND INTEND THAT THIS ASSUMPTION OF RISK AND RELEASE IS BINDING UPON YOU AND YOUR HEIRS, EXECUTORS, AGENTS, ADMINISTRATORS AND ASSIGNS IN PERPETUITY.

Section 11 – Governing Law.
You understand that we may process, transfer, and store your information in the United States and
elsewhere as permitted by law. The Properties are controlled and operated from the United States;
accordingly, this Privacy Policy, and our collection, use and disclosure of your Personal Information is
governed by U.S. law, and the Properties are not intended to subject us to the laws or jurisdiction of any
state, country, or territory other than that of the United States.

Contact Us. Questions regarding the Properties, Privacy Policy, or the Terms of Use should be directed
as follows: community@aubrewinters.com.