Effective and Last Modified: September 30, 2013

This policy (“Privacy Policy”) informs you of the policies of Penfold Communications and its subsidiary entities ( “Penfold”) concerning the collection, use and disclosure of personal information from this and other Penfold-related websites (“Website(s)”). Because we may gather certain types of information about our users and understand your privacy is important to you, we want to help you understand the terms and conditions surrounding the collection and use of that information. Even though we may need to collect information about you to provide some of the products and services we offer, you may not want us to disclose that information to others. Accordingly, what follows is a description of how we gather and use information about you ( “Your Information”). Please read this Privacy Policy carefully so that you understand what information we collect through our Websites, what we do with that information, and how to safeguard personal information you provide to us.

Please note that by visiting this Website you consent to the collection of Your Information by Penfold as set forth in this Privacy Policy.

1. Disclosure of Personal Information to Outside Parties

   Except as set forth in this policy, Penfold does not sell, trade, or rent your personal information to others. However, Penfold may provide aggregate statistics about our customers, traffic patterns, and related Website information to third-party vendors. Generally, these statistics will include no personally identifying information. Penfold may also release Your Information when we believe, in good faith, that such release is reasonably necessary to (i) comply with the law, (ii) enforce or apply the terms of our Terms of Use applicable to this Website, (iii) enforce contest, sweepstakes, promotions, and/or game rules, or (iv) protect the rights, property or safety of Penfold, our users, or others. Also, we may give some or all of Your Information to third-party vendors who assist us in fulfilling some of the functions of this Website. Finally, we may provide Your Information to third parties if you authorize us to do so.

2. Information We Collect and How We Use It

   1. Voluntary Information You Provide Us. If you contact us by email, complete our registration forms, surveys, or entry forms, subscribe to our services or newsletters or participate in any of our contests or sweepstakes, we will ask you for Your Information. The information we ask for in this context may include contact information (such as your name and email address) and/or demographic information (such as your zip code or age). Below you will find descriptions of how Penfold may use these types of information.

   2. Registration Data. Registration data is voluntary personal information provided directly by you in order to receive optional access to certain services or Website areas and which may include information such as your name, age, email address, zip code or telephone number. In addition, registration data may include preference information such as usernames, passwords, desired newsletters, etc.

   3. Surveys. Sometimes Penfold posts optional surveys in which we ask for Your Information. The choice is yours – you don’t have to answer surveys, but if you do, please understand that Penfold may use Your Information and that we may share Your Information with third parties.

   4. Contests and Promotions. Penfold may run contests, promotions and sweepstakes in which we ask for Your Information, which may include but is not limited to your name, email address, phone, and age, so we can determine if you're eligible for the contest and to notify you know if you win. Sometimes we request additional information such as your gender, marital status and income level.

   5. Special Offers. Penfold and its affiliated entities are able to provide to you special offers of products and services. When providing these offers, we need to gather Your Information, which may include but is not limited to your name, email address, age and phone. Your acceptance of these offers is completely voluntary, but if you do not correctly provide Your Information as required, you may not receive the product or service offered.

   6. Online Commerce Services. This Website may offer shopping and other online commerce services, which may be offered by Penfold or by a firm that operates a store under contract with us. If our Website offers such services, you will use a customer order form to request information, products, and services. The order form will ask you to give us contact information (e.g., name or email address), financial information (e.g., account or credit card numbers), and demographic information (e.g., zip code or age). We will use the financial information that you provide to bill you for products and services. By giving our Website your credit card and related personal information, you are authorizing our store to give that information to the merchant and credit card company in order to confirm and fulfill your order. We will use contact information from the order form to fulfill your orders. We may also use contact data to get in touch with you when necessary. We will not otherwise use or distribute your financial information without your prior approval.

   7. Information We Obtain From Other Sources. Where permitted by applicable law, we may collect information about you from other sources, including through interactive applications (mobile devices, third-party services and embedded audio or video players), from co-branded partners and websites (Twitter or Facebook pages) and from commercially available sources (e.g., data on aggregators and public databases).

   8. Combining Information. Please note that all of the information we collect about you may be combined, including to help us tailor our communications to you and to develop rich online content and services across the Penfold Websites.

3. Information Shared With Third Parties

   1. Information Sharing With Third Parties. Penfold may enter into a special relationship with another company that is not owned byPenfold to provide additional features on our Websites. These special relationships may include “powered by” partners, business partners, sponsors, and co-branded sites (referred to here as “co-branded pages”). You should look for a specific privacy statement on any such co-branded page. Any personal information that you provide when signing up at one of those co-branded pages may be shared with our third party partner. You should also check our partner’s website for information regarding its privacy policies. Additionally, the nature of some features of our Website may require that we share personal information about you with persons or companies outside of the Penfold corporate enterprise.

   2. Links to Other Sites. When you visit Penfold Websites, you may be linked to other outside sites. This includes links to sites operated by advertisers, sponsors, and partners that may use Penfold's logo as part of an agreement with Penfold. These other sites may send their own cookies to users, collect data, or solicit Your Information. These other sites may be developed by people over whom Penfold exercises no control and, as such, are not subject to the Penfold Privacy Policy. Penfold is not responsible for the privacy policies of these other sites, nor for the use of any of Your Information that these sites may collect.

   3. Sale of Our Company. Penfold may include any information we collect through this Website in our customer information database. This database is considered an asset owned by Penfold. As in any business venture, the sale of Penfold is always a possibility, either as an entire corporate entity or through an asset sale that may include our customer information database. Should another entity ever purchase or acquire Penfold or its assets, all information contained in our customer information database will be considered a transferred asset and become the property of the purchasing or acquiring entity.