Privacy Policy

OFF THE VINE PRIVACY POLICY

Last updated: June 1, 2026

This Privacy Policy describes how RVN Holdings dba Off The Vine ("Off The Vine", the "Site", "we", "us", or "our")

collects, uses, and discloses your personal information when you visit, use our services, make a purchase from

www.offthevine.co (the "Site"), or otherwise communicate with us regarding the Site (collectively, the "Services").

For purposes of this Privacy Policy, "you" and "your" means you as the user of the Services, whether you are a

customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy.

Please read this Privacy Policy carefully. By using and accessing any of the Services, you agree to the collection,

use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy,

please do not use or access any of the Services.

Age Restriction

Off The Vine products are intended only for adults twenty-one (21) years of age or older. By accessing, browsing,

using this Site, creating an account, or purchasing any products through the Site, you represent and warrant that

you are at least twenty-one (21) years old. If you are not at least twenty-one (21) years old, you may not access or

use the Site or purchase any products offered through the Site.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other

operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Site, update the "Last

updated" date, and take any other steps required by applicable law.

How We Collect and Use Your Personal Information

To provide the Services, we collect and have collected over the past 12 months personal information about you

from a variety of sources, as set out below. The information that we collect and use varies depending on how you

interact with us.

In addition to the specific uses set out below, we may use information we collect about you to communicate with

you, provide, improve, and maintain the Services, comply with any applicable legal obligations, enforce any

applicable terms of service, and protect or defend the Services, our rights, and the rights of our users or others.

What Personal Information We Collect

The types of personal information we obtain about you depend on how you interact with our Site and use our

Services. When we use the term "personal information", we are referring to information that identifies, relates to,

describes, or can be associated with you. The following sections describe the categories and specific types of

personal information we collect.

Information We Collect Directly from You

Information that you directly submit to us through our Services may include:

● Contact details including your name, address, phone number, and email address.

● Order information including your name, billing address, shipping address, payment confirmation, email address,

and phone number.● Account information including your username, password, security questions, and other information used for

account security purposes.

● Customer support information including the information you choose to include in communications with us, for

example, when sending a message through the Services.

● Age verification or compliance information where required to confirm eligibility to access or purchase

age-restricted products.

Some features of the Services may require you to directly provide us with certain information about yourself. You

may elect not to provide this information, but doing so may prevent you from using or accessing these features.

Information We Collect About Your Usage

We may also automatically collect certain information about your interaction with the Services ("Usage Data"). To

do this, we may use cookies, pixels, and similar technologies ("Cookies"). Usage Data may include information

about how you access and use our Site and your account, including device information, browser information,

information about your network connection, your IP address, and other information regarding your interaction with

the Services.

Information We Obtain from Third Parties

We may obtain information about you from third parties, including vendors and service providers who may collect

information on our behalf, such as:

● Companies who support our Site and Services, such as Shopify.

● Payment processors who collect payment information, such as credit or debit card information, billing address,

and related payment details, to process your payment, fulfill your orders, and provide you with products or

services you have requested.

● Shipping, fulfillment, age verification, fraud prevention, analytics, advertising, email, and SMS service providers.

● Third parties that automatically collect certain information when you visit our Site, open or click on emails we

send, or interact with our Services or advertisements, using online tracking technologies such as pixels, web

beacons, software developer kits, third-party libraries, and cookies.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. Also see the

section below, Third Party Websites and Links.

How We Use Your Personal Information

Providing Products and Services

We use your personal information to provide the Services in order to perform our contract with you, including to

process your payments, fulfill your orders, send notifications related to your account, purchases, returns,

exchanges, or other transactions, create, maintain, and otherwise manage your account, arrange for shipping,

facilitate returns and exchanges, verify age or eligibility where required, and provide other features and functionality

related to your account.

We may also enhance your shopping experience by enabling Shopify to match your account with other Shopify

services that you may choose to use. In this case, Shopify will process your information as set forth in its Privacy

Policy and Consumer Privacy Policy.

Marketing and AdvertisingWe may use your personal information for marketing and promotional purposes, such as to send marketing,

advertising, and promotional communications by email, text message, or postal mail, and to show you

advertisements for products or services. This may include using your personal information to better tailor the

Services and advertising on our Site and other websites.

Security and Fraud Prevention

We use your personal information to detect, investigate, or take action regarding possible fraudulent, illegal,

unauthorized, or malicious activity. If you choose to use the Services and register an account, you are responsible

for keeping your account credentials safe. We recommend that you do not share your username, password, or

other access details with anyone else. If you believe your account has been compromised, contact us immediately.

Communicating with You and Service Improvement

We use your personal information to provide customer support and improve our Services. This is in our legitimate

interests in order to be responsive to you, provide effective services, and maintain our business relationship with

you.

Cookies

Like many websites, we use Cookies on our Site. For specific information about the Cookies used in connection

with Shopify-powered stores, see Shopify's cookie documentation at https://www.shopify.com/legal/cookies.

We use Cookies to power and improve our Site and our Services, including to remember your actions and

preferences, run analytics, and better understand user interaction with the Services. We may also permit third

parties and service providers to use Cookies on our Site to better tailor services, products, and advertising on our

Site and other websites.

Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject

Cookies through your browser controls. Removing or blocking Cookies can negatively impact your user experience

and may cause some of the Services, including certain features and general functionality, to work incorrectly or no

longer be available. Blocking Cookies may not completely prevent how we share information with third parties such

as advertising partners.

Please note that while your browser may allow you to transmit a "do not track" signal, like many websites, our Site

is not designed to respond to such signals. To learn more about "do not track" signals, you can visit

http://www.allaboutdnt.com/.

How We Disclose Personal Information

In certain circumstances, we may disclose your personal information to third parties for contract fulfillment

purposes, legitimate purposes, and other reasons subject to this Privacy Policy. Such circumstances may include:

● With vendors or other third parties who perform services on our behalf, including IT management, payment

processing, data analytics, customer support, cloud storage, age verification, fraud prevention, fulfillment, and

shipping.

● With business and marketing partners to provide services and advertise to you. Our business and marketing

partners will use your information in accordance with their own privacy notices.

● When you direct, request, or otherwise consent to our disclosure of certain information to third parties, such as to

ship products to you or through your use of social media widgets or login integrations.

● With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful

business.● In connection with a business transaction such as a merger, financing, sale, acquisition, bankruptcy, or similar

transaction.

● To comply with applicable legal obligations, including responding to subpoenas, search warrants, government

requests, law enforcement requests, and similar requests.

● To enforce applicable terms of service and to protect or defend the Services, our rights, and the rights of our

users or others.

We have in the past 12 months disclosed the following categories of personal information about users for the

purposes set out above in this Privacy Policy:

● Identifiers, such as basic contact details and certain order and account information.

● Personal information categories listed in the California Customer Records statute, such as basic contact details

and certain order and account information.

● Commercial information, such as order information, shopping information, and customer support information.

● Internet or other similar network activity, such as Usage Data.

● Geolocation data, such as locations determined by an IP address or other technical measures.

Categories of recipients may include:

● Vendors and third parties who perform services on our behalf, such as internet service providers, payment

processors, age verification providers, fulfillment partners, customer support partners, and data analytics

providers.

● Business and marketing partners.

● Affiliates and related entities.

We do not use or disclose sensitive personal information without your consent or for the purposes of inferring

characteristics about you.

Third Party Websites and Links

Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites

not affiliated with or controlled by us, you should review their privacy and security policies and other terms and

conditions. We do not guarantee and are not responsible for the privacy or security practices of such sites,

including the accuracy, completeness, or reliability of information found on those sites.

Information you provide on public or semi-public venues, including information you share on third-party social

networking platforms, may be viewable by other users of the Services or users of those third-party platforms without

limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply endorsement of

the content on such platforms or of their owners or operators, except as disclosed on the Services.

Children's Data

The Services are not intended for use by anyone under twenty-one (21) years of age. We do not knowingly collect,

use, or disclose personal information from individuals under the age of twenty-one (21). If you believe that a person

under twenty-one has provided personal information to us, contact us immediately so we may investigate and

remove such information.

As of the effective date of this Privacy Policy, we do not have actual knowledge that we "share" or "sell" personal

information of individuals under 16 years of age, as those terms are defined in applicable law.Security and Retention of Your Information

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee "perfect

security." In addition, any information you send to us may not be secure while in transit. We recommend that you do

not use insecure channels to communicate sensitive or confidential information to us.

How long we retain your personal information depends on different factors, such as whether we need the

information to maintain your account, provide the Services, comply with legal obligations, resolve disputes, prevent

fraud, verify compliance, or enforce applicable contracts and policies.

Your Rights

Depending on where you live, you may have some or all of the rights listed below in relation to your personal

information. These rights are not absolute, may apply only in certain circumstances, and in certain cases we may

decline your request as permitted by law.

● Right to Access / Know: You may have a right to request access to personal information that we hold about you,

including details relating to the ways in which we use and share your information.

● Right to Delete: You may have a right to request that we delete personal information we maintain about you.

● Right to Correct: You may have a right to request that we correct inaccurate personal information we maintain

about you.

● Right of Portability: You may have a right to receive a copy of the personal information we hold about you and

request that we transfer it to a third party, in certain circumstances and with certain exceptions.

● Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal

information.

● Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right

to withdraw this consent.

● Appeal: You may have a right to appeal our decision if we decline to process your request. You can do so by

replying directly to our denial.

● Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving

these at any time by using the unsubscribe option displayed in our emails. If you opt out, we may still send

non-promotional emails, such as those about your account or orders.

You may exercise any of these rights where indicated on our Site or by contacting us using the contact details

provided below.

We will not discriminate against you for exercising any of these rights. We may need to collect information from you

to verify your identity, such as your email address, account information, or order information, before providing a

substantive response to the request. In accordance with applicable laws, you may designate an authorized agent to

make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we may

require proof that you authorized the agent to act on your behalf, and we may need you to verify your identity

directly with us. We will respond to your request in a timely manner as required under applicable law.

California Privacy Rights

If you are a California resident, you may have additional rights under the California Consumer Privacy Act, as

amended by the California Privacy Rights Act, and other applicable California privacy laws. These may include the

right to know what personal information we collect, use, disclose, sell, or share, the right to request deletion orcorrection of personal information, the right to opt out of certain sharing or selling of personal information, and the

right to limit the use and disclosure of sensitive personal information where applicable.

We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you. To

submit a California privacy request, contact us using the information listed in the Contact section below.

Complaints

If you have complaints about how we process your personal information, please contact us using the contact details

provided below. If you are not satisfied with our response to your complaint, depending on where you live, you may

have the right to appeal our decision by contacting us using the contact details set out below or lodge your

complaint with your local data protection authority.

SMS and Mobile Data Privacy

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All the

above categories exclude text messaging originator opt-in data and consent. This information will not be shared

with any third parties except as necessary to provide SMS services, comply with law, or fulfill the purposes for

which the information was provided.

If you opt in to receive SMS messages from Off The Vine, message frequency may vary. Message and data rates

may apply. You may opt out at any time by following the instructions provided in our text messages.

Hemp-Derived Cannabinoid Products

Off The Vine offers hemp-derived cannabinoid products, including but not limited to THCA, Delta-9 THC, CBD, and

other hemp-derived compounds. Product availability may vary by jurisdiction.

Customers are solely responsible for determining whether the purchase, shipment, possession, or use of any

product purchased from Off The Vine is lawful in their state, county, city, or other jurisdiction before placing an

order. Nothing contained on this Site should be construed as legal advice.

Statements made regarding products sold on this Site have not been evaluated by the United States Food and

Drug Administration. Products are not intended to diagnose, treat, cure, or prevent any disease.

International Users

Please note that we may transfer, store, and process your personal information outside the country you live in. Your

personal information may also be processed by staff, third-party service providers, and partners in these countries.

If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms such as the

European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the relevant

competent authority of the United Kingdom, as relevant, unless the data transfer is to a country that has been

determined to provide an adequate level of protection.

Contact

Should you have any questions about our privacy practices, this Privacy Policy, or wish to exercise any privacy

rights available to you, contact us using the information below:

RVN Holdings dba Off The Vine

1401 21st St, Suite R

Sacramento, CA 95811Phone: 818-305-5709

Email: cs@offthevine.co

Website: www.offthevine.co