Privacy Policy

1. Introduction

The Pursuit of Bella, Inc. ("Company," "we," "us," or "our") operates www.thepursuitofbella.com (the "Site"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our Site.

We are committed to protecting your privacy. Please read this policy carefully. If you disagree with its terms, please discontinue use of the Site.

2. Information We Collect

2.1 Information You Provide Voluntarily

We may collect personal information that you voluntarily provide when you:

• Submit our age verification form
• Register for an account or mailing list
• Contact us via email or contact forms
• Participate in promotions, contests, or surveys

This may include: name, email address, date of birth (for age verification), phone number, postal address, and any other information you choose to provide.

2.2 Information Collected Automatically — Analytics

Vercel Analytics (Cookieless). This Site uses Vercel Analytics, a privacy-first, cookieless analytics service. Vercel Analytics does not use cookies, does not track individual users across sessions, and does not collect personally identifiable information. It derives aggregate, anonymized metrics — such as page views, referral sources, and general geographic region (country/region level) — from HTTP request data.

Specifically, Vercel Analytics does NOT:

• Set or read browser cookies
• Store a persistent unique identifier on your device
• Track your browsing activity across other websites
• Build personal profiles or behavioral histories
• Share individual-level data with third parties

https://vercel.com/legal/privacy-policy.

2.3 Log Data

Our servers may automatically collect standard log data when you visit the Site, including your IP address (which may be truncated or hashed), browser type, operating system, referring URL, and pages visited. This data is used for security monitoring and operational purposes and is not linked to your personal identity.

3. How We Use Your Information

We use the information we collect to:

• Verify that visitors are of legal drinking age
• Respond to your inquiries and provide customer support
• Send promotional communications (with your consent, where required)
• Analyze aggregate Site traffic and usage trends via Vercel Analytics
• Comply with legal obligations
• Maintain the security and integrity of our Site

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

4. Cookies and Tracking Technologies

Our analytics provider (Vercel Analytics) is cookieless and does not place tracking cookies on your device. However, we may use limited functional or session cookies for the following purposes:

• Age gate session management (to remember that you have verified your age during a session)

These functional cookies do not track you across other websites and expire at the end of your browser session unless otherwise noted. You may configure your browser to refuse cookies; however, some Site features may not function properly as a result.

5. Sharing of Information

We may share your information with:

• Service providers: Third-party vendors who assist us in operating the Site (hosting, email delivery, etc.), bound by confidentiality obligations and permitted to use your data only for services provided to us
• Legal compliance: When required by law, regulation, subpoena, or court order, or to protect our legal rights
• Business transfers: In connection with a merger, acquisition, or sale of assets, with appropriate confidentiality protections

We do not share your personal information with advertisers or data brokers.

6. Age Verification & COPPA

This Site is strictly for adults of legal drinking age. We do not knowingly collect personal information from individuals under the age of 21 (United States) or the applicable legal drinking age in other jurisdictions. If we learn that we have inadvertently collected information from a minor, we will promptly delete it. If you believe we may have collected information from a minor, please contact us at legal@bella-tequila.com.

7. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable law. Age verification session data is retained for the duration of your browser session only. Marketing contact information is retained until you unsubscribe or request deletion.

8. Your Rights & Choices

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your personal information (subject to legal exceptions)
• Opt-out: Unsubscribe from marketing communications at any time
• Data portability: Receive your data in a portable format (where applicable)

CALIFORNIA RESIDENTS: See Section 9 below. EEA/UK RESIDENTS: See Section 10 below. You may also have the right to object to processing and to lodge a complaint with a supervisory authority.

To exercise these rights, contact us at: legal@bella-tequila.com — Attention: Privacy

9. California Privacy Rights (CCPA/CPRA)

This section applies to residents of California and supplements the rest of this Privacy Policy. It is provided pursuant to the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020 (collectively, "CCPA/CPRA").

9.1 Categories of Personal Information Collected (Past 12 Months)

We have collected the following categories of personal information from or about California consumers:

• Identifiers: Name, email address, IP address (truncated/hashed), postal address, phone number.
• Internet or Other Electronic Network Activity: Aggregated, anonymized page-view data and referral sources derived from HTTP requests via Vercel Analytics (not linked to any individual).
• Geolocation Data: Country/region level only, derived from anonymized analytics. We do not collect precise geolocation.
• Commercial Information: Records of products or services you request or purchase, where applicable.

We do not collect: Social Security numbers, financial account information, biometric data, health/medical information, or the contents of private communications.

9.2 Business and Commercial Purposes for Collection

We collect the above categories of personal information for the following business or commercial purposes:

• Age verification to comply with applicable alcohol regulations
• Responding to consumer inquiries and providing customer support
• Sending promotional communications where consent has been obtained
• Analyzing aggregate Site usage to improve our services
• Security monitoring and fraud prevention
• Complying with applicable legal obligations

9.3 Sale or Sharing of Personal Information

We do not sell your personal information. We also do not "share" personal information for cross-context behavioral advertising as defined under the CPRA. Because we do not sell or share personal information, we do not offer a "Do Not Sell or Share My Personal Information" opt-out link. If our practices change, we will update this Policy and provide the required opt-out mechanism.

9.4 Retention Periods

We retain each category of personal information only as long as reasonably necessary for the purpose for which it was collected, or as required by law. Age verification data is session-only. Contact and marketing data is retained until you opt out or request deletion. Log data is retained for up to 90 days for security purposes.

9.5 Your California Privacy Rights

California residents have the following rights under CCPA/CPRA:

• Right to Know: You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collection, and the categories of third parties with whom we share it.
• Right to Delete: You may request deletion of personal information we have collected from you, subject to certain exceptions (e.g., information necessary to complete a transaction or comply with a legal obligation).
• Right to Correct: You may request correction of inaccurate personal information we maintain about you.
• Right to Opt-Out of Sale/Sharing: As noted above, we do not sell or share personal information. No opt-out is currently required.
• Right to Limit Use of Sensitive Personal Information: We do not use sensitive personal information (as defined under CPRA) for purposes other than those permitted by law without your consent.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights. We will not deny you goods or services, charge different prices, or provide a different quality of service because you exercised your privacy rights.

9.6 How to Submit a California Privacy Rights Request

California residents may submit a verifiable consumer request by:

legal@bella-tequila.com with the subject line "California Privacy Request"

• Writing to: The Pursuit of Bella, Inc., 8 The Green, Ste R, Dover, DE 19901

We will respond to verifiable consumer requests within 45 days of receipt, with one permitted 45-day extension where reasonably necessary. We may need to verify your identity before processing your request and will use information you provide for verification only. Authorized agents may submit requests on your behalf with proper written authorization.

9.7 Financial Incentives

We do not currently offer financial incentives, price differences, or service differences in exchange for the collection, retention, or sale of personal information.

10. EEA, UK & Swiss Residents — GDPR Notice

This section applies to individuals located in the European Economic Area (EEA), the United Kingdom (UK), or Switzerland (collectively, "Europe") and supplements the rest of this Privacy Policy. It is provided pursuant to the EU General Data Protection Regulation (GDPR) (EU) 2016/679, the UK GDPR, and the Swiss Federal Act on Data Protection (nFADP).

10.1 Data Controller

The data controller responsible for your personal information is:

If you have questions about how we process your data, please contact us at the address above.

10.2 Legal Bases for Processing

We process your personal information only where we have a lawful basis to do so. The legal bases we rely on include:

• Consent (Art. 6(1)(a) GDPR): We rely on your consent to send marketing communications. You may withdraw your consent at any time by unsubscribing or contacting us.
• Contractual Necessity (Art. 6(1)(b) GDPR): Where you have requested a product or service from us, we process your information as necessary to fulfil that request.
• Legal Obligation (Art. 6(1)(c) GDPR): We process certain data to comply with applicable laws and regulations, including alcohol retail regulations requiring age verification.
• Legitimate Interests (Art. 6(1)(f) GDPR): We rely on our legitimate interests to operate and improve our Site, maintain security, prevent fraud, and respond to your inquiries, where those interests are not overridden by your rights and interests.

10.3 International Data Transfers

We are based in the United States. If you are located in Europe, your personal information will be transferred to, stored, and processed in the United States, which may not provide the same level of data protection as your home jurisdiction.

Where we transfer personal data from the EEA, UK, or Switzerland to the United States, we rely on appropriate safeguards, which may include:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• The UK International Data Transfer Agreement (IDTA) or UK Addendum to SCCs, as applicable
• The Swiss SCCs or equivalent mechanisms under Swiss law

You may request a copy of the applicable transfer safeguards by contacting us at legal@bella-tequila.com.

10.4 Your Rights Under GDPR

Subject to applicable law and certain exceptions, individuals in Europe have the following rights:

• Right of Access (Art. 15): You may request a copy of the personal data we hold about you and information about how it is processed.
• Right to Rectification (Art. 16): You may request that we correct inaccurate or incomplete personal data.
• Right to Erasure / 'Right to be Forgotten' (Art. 17): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent (and there is no other legal basis).
• Right to Restriction of Processing (Art. 18): You may request that we restrict how we process your personal data in certain circumstances (e.g., while a dispute is being resolved).
• Right to Data Portability (Art. 20): Where processing is based on consent or contract, you may receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller.
• Right to Object (Art. 21): Where processing is based on legitimate interests, you may object to processing at any time on grounds relating to your particular situation. You have an absolute right to object to processing for direct marketing purposes.
• Rights Related to Automated Decision-Making (Art. 22): We do not make decisions based solely on automated processing that produce legal or similarly significant effects on individuals.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing before withdrawal.

10.5 How to Exercise Your Rights

To exercise any of the rights described above, please contact us at:

Email: legal@bella-tequila.com — Subject line: "GDPR Rights Request"

Post: The Pursuit of Bella, Inc., 8 The Green, Ste R, Dover, DE 19901

We will respond to your request within 30 days of receipt. In complex cases, we may extend this period by an additional two months and will notify you accordingly. We will not charge a fee for responding to your request unless it is manifestly unfounded or excessive.

We may need to verify your identity before processing your request. We will use the minimum information necessary to verify identity and will not retain it for any other purpose.

10.6 Right to Lodge a Complaint

If you are located in the EEA and believe that we have not complied with applicable data protection laws, you have the right to lodge a complaint with your local supervisory authority. A list of EEA supervisory authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

If you are located in the UK, you may lodge a complaint with the Information Commissioner's Office (ICO) at https://ico.org.uk/.

If you are located in Switzerland, you may lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC) at https://www.edoeb.admin.ch/.

We would, however, welcome the opportunity to address your concerns before you contact a supervisory authority, and encourage you to contact us first.

10.7 Retention

We retain personal data for as long as necessary to fulfil the purposes described in this Policy, including to satisfy legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the nature and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data, and applicable legal requirements.

11. Security

We implement commercially reasonable technical and organizational measures to protect your personal information. However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security and disclaim liability for unauthorized access or disclosure beyond our reasonable control.

12. Third-Party Links

This Site may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Policy

We reserve the right to update this Privacy Policy at any time. We will post the revised policy with a new effective date. Your continued use of the Site after changes are posted constitutes acceptance of the updated policy. For material changes, we will provide more prominent notice as required by applicable law.

14. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact: