Effective Date: January 1st, 2020

PILOTO 151 and our affiliates (the “Company”, “PILOTO 151”, “we”, “us” or “our”) are committed to maintaining your trust by protecting your Personal Information. This Privacy Policy, and our website’s Terms of Use, describes the types of information we collect, and how we collect, use, share and protect that information in connection with the use of our website, applications, as well as any offline products, programs, and services. The information PILOTO 151 collects, and how that information is used, depends on how you use our services.

Please make sure to read this document carefully to help you make informed decisions about your relationship with us.

1. Introduction

This Privacy Policy describes our practices for collecting using, maintaining, and disclosing Personal Information that we collect from you or that you provide to us when you visit our website (our “Site“), acquire a membership with PILOTO 151 (“Membership”), buy any of our retail items (“Products”), or when you use any of the services made available by us (collectively referred to as the “Services”).

While providing our Services to businesses and other organizations who enter into a contract with us (our “Partners”), we may receive information related to the Partners’ consumers, and other third parties.  Our use of information on behalf of our Partners is governed by our contract with that Partner and our Partners’ own privacy policies.  By accessing or using our Services, our Partners have signified that they have read, understood and agreed to our collection, use and disclosure of your personal data (through them) as described in our Privacy Policy. We are not responsible for the privacy policies or privacy practices of our Partners or other third parties.

2. Information We Collect and How We Collect It

We collect information that you provide to us directly, or that your employer, or host provides to us, about your devices and their location, and your use of our Services, including through cookies, pixels, web beacons, logs, and other Internet technologies.

Personal Information under this Privacy Policy means data that relates to you and can — either on its own or in combination with other information — identify you as an individual. Personal Information does not include data that has been aggregated or made anonymous such that you can no longer be identified using any means reasonably available to us. We may also collect and/or generate anonymized and aggregated information from your use of the Services. We use anonymized and aggregated information in various ways, including to measure your interest in and use of portions or features of the Services. Anonymized or aggregated information is not Personal Information.

Depending on the Services you use and your relationship with us, we may collect the following categories of information:

**PERSONAL INFORMATION WE COLLECT NON-PERSONAL INFORMATION WE COLLECT INFORMATION COLLECTED FROM SOURCES OTHER THAN YOU

3. How Do We Use This Information

Your Personal Information is used for internal purposes only and is never sold or shared with anyone outside of PILOTO 151. We will only collect or use your Personal Information where we are satisfied that we have an appropriate legal basis to do so.

4. How Is Your Information Shared

PILOTO 151 treats personal data confidentiality. We may disclose your Personal Information in limited circumstances to the PILOTO 151 Companies and our service providers only for the purposes outlined below:

**PILOTO 151 COMPANIES VENDORS AND SERVICE PROVIDERS OTHER PARTIES IN CONNECTION WITH A CORPORATE TRANSACTION WHEN REQUIRED BY LAW SOCIAL MEDIA

5. How Do We Protect Your Information

6. Publicly Posted Information and Public Forums

Our sites may make member networks, chat rooms, forums, and/or other groups available to the users. This Privacy Policy shall not apply to any information or comments you post to the public areas of the sites, or on social media and other public forums. Anyone can read, collect, or use your postings on a network or forum or in a chat room or group and, we cannot be responsible for any unauthorized third party’s use of information that you disclose online.

7. Third Parties and Links to Third-Party Sites

This Privacy Policy applies only to our Services. Our sites may contain advertisements or links to other websites not operated or controlled by us (“Third Party Sites”), including social media websites and services. The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third-Party Sites and not by this Privacy Policy even if you access those sites through the Services. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact those sites directly for information on their privacy practices and policies.

8. Choices About How We Collect, Use, and Share Your Information

MARKETING COMMUNICATIONS

We provide a means to unsubscribe in our marketing-related email communications. Note that we will continue to send transaction-related emails regarding products or services that you have requested following an unsubscribe. PILOTO 151 may also need to send you certain communications regarding operation and administration of the Services, including communications regarding updates to this Policy and emergency alerts, and you will not be able to opt out of those communications.

9. Cookie Usage

Cookies are small data files placed on the hard drive of your computer. These cookies are used to collect information about how you interact with our website (www.piloto151.com) and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our visitors both on this website and other media.

You can change your browser configuration to refuse all cookies or indicate when a cookie is being sent. Please note that, if you choose to block all cookies you may not be able to access all or part of our site and may be unable to use those services or engage in activities that require the placement of cookies.

10. Your Rights

We value your rights to your data. Subject to certain exceptions provided by law, you may have the right to (i) request confirmation of whether we store, use or share any of your Personal Information; (ii) request an electronic copy of your Personal Information to be sent to you, or another organization; (iii) withdraw your agreement to the processing of your Personal Information; (v) seek correction of inaccurate, untrue or incomplete Personal Information.

If you would like to exercise any of these rights, please contact us at the e-mail addresses set out in the Contacting Us section below. We will process such requests in accordance with applicable laws. Although you are encouraged to contact us if you would like to exercise your rights, some of these rights are only available in certain circumstances and so we may not be required to comply with every request.

11. Opting Out

You have the right to opt-out of certain uses and disclosures of your Personal Information, as set out in this Policy, and in specific circumstances.

**OPTING-OUT OF MARKETING COMMUNICATIONS COLLABORATION

12. California Privacy Rights

If you are a California resident, you may opt out of having your Personal Information disclosed to third parties for direct marketing purposes by emailing us at: info@piloto151.com. ****

13. Children

Our Services are intended for users who are 18 years of age and older. PILOTO 151 does not knowingly collect Personal Information from anyone under the age of 13. If you are under the age of 13, you are not permitted to submit any Personal Information to us. If you believe we might have any information from or about an individual under 13, please contact us at info@piloto151.com. If we become aware that a person under 13 years old has provided us with Personal Information, we will delete such information from our files.

14. Changes

This Privacy Policy may be updated from time to time. When updated, we will amend the “Last Updated” date above and post the new Privacy Policy online. We encourage you to review this Policy periodically to remain informed of how we use and protect your information, and to be aware of any policy changes Any changes to this Policy take effect immediately after being posted. Your continued relationship with us after the posting or notice of any amended Policy shall constitute your agreement to be bound by any such changes.

15. Contacting Us

If you have any questions, comments, requests, or concerns regarding our Privacy Policy, please contact our Privacy Representative at info@piloto151.com.