Evolve Brands Inc. t/a PURA Beverage Company
Effective Date: September 11, 2026

Summary: This Privacy Policy explains how Evolve Brands Inc. t/a PURA Beverage Company collects, uses, shares, and protects your personal information when you visit drinkpura.com, place an order, or interact with us, and the choices and rights you have under U.S. state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA).

1. Introduction & Who We Are

Evolve Brands Inc. t/a PURA Beverage Company ("PURA", "we", "us", or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy describes how we handle personal information collected through our website at drinkpura.com (the "Site"), our online store, customer support channels, marketing communications, and brand activations. It is incorporated into our Terms of Service. If you do not agree with this Policy, please do not use the Site.

2. Business & Contact Information

• Legal Entity: Evolve Brands Inc. t/a PURA Beverage Company
• Website: drinkpura.com
• Privacy Requests & Customer Service: customerservice@drinkpura.com

3. Information We Collect

We collect only the personal information that is necessary to run our store, fulfil your orders, communicate with you, and improve the Site.

Category	Types of Information Collected	Source / Method of Collection
Contact Data	Name, email address, phone number, general location.	Newsletter and SMS sign-ups, contact forms, promotional competitions, trade enquiries.
Order & Payment Data	Billing and shipping address, order history, products purchased, order value. Payment card details are collected and processed by Shopify and its payment gateways; we never receive or store your full card number.	Checkout on our Shopify-powered store.
Digital & Technical Data	IP address, browser type, device type, cookie identifiers, pages visited, referring site, approximate location derived from IP address.	Automated website tracking, Google Analytics, advertising pixels (e.g., Meta Pixel) where enabled.
Reviews & User-Generated Content (UGC)	Product reviews and ratings, social media handles, comments, tagged photographs, testimonials.	Our reviews platform, social media interactions (Instagram, Facebook, TikTok), direct submissions.
Customer Support Data	The content of your emails and messages to us, and any information you choose to include.	Email and social media messages.
Business Contact Data	Company name, job title, commercial contact information, distribution enquiries.	Trade, wholesale, retail stockist, or supplier communication.

We do not knowingly collect sensitive personal information (such as precise geolocation, government identifiers, health information, or account log-in credentials in combination with access codes) and we do not use or disclose personal information for purposes that would require a "limit the use of my sensitive personal information" right under California law.

4. How We Use Your Information

We use personal information for the following business and commercial purposes:

1. Orders and Fulfilment: To process payments, fulfil and ship orders, send order and shipping confirmations, handle returns, replacements and refunds, and provide customer service.
2. Marketing: With your consent, to send email and text-message updates, offers and news about PURA. You can opt out at any time (see Section 9).
3. Site Operation and Improvement: To operate, secure, analyse and improve the Site and our products, and to remember your preferences.
4. Advertising: To measure the effectiveness of our advertising and, where advertising cookies are enabled, to show you relevant PURA advertising on third-party platforms.
5. Reviews and Community: To display product reviews and user-generated content you have chosen to share.
6. Legal and Safety: To comply with applicable law, prevent fraud, enforce our Terms of Service, and protect the rights, property and safety of PURA, our customers and others.

5. Cookies & Tracking Technologies

The Site uses cookies and similar technologies to keep the store working, remember your preferences (including your cart and region), and analyse traffic.

• Essential Cookies: Required for fundamental Site operation, the shopping cart and checkout, and security.
• Analytical / Performance Cookies: Help us measure visitor engagement and traffic sources (e.g., Google Analytics, with IP anonymisation enabled).
• Marketing Cookies: Where enabled, allow us to present relevant brand updates and measure advertising effectiveness across third-party networks (e.g., Meta Pixel).

You can manage or disable cookies at any time through your browser settings. Disabling essential cookies may prevent the cart and checkout from working. We honor Global Privacy Control (GPC) signals as a request to opt out of the sharing of personal information for targeted advertising where required by applicable state law.

6. How We Share Your Information

We do not sell your personal information for money. We share personal information only as described below:

• Store & Payment Platform: Shopify, which hosts our online store, processes checkout and payments, and stores order data on our behalf (see Shopify's privacy policy for how it handles your information).
• Fulfilment & Delivery: Warehousing and fulfilment partners (including Amazon Multi-Channel Fulfillment) and shipping carriers, who receive your name, delivery address, phone number and order contents to deliver your order.
• Marketing & Communications: Email and SMS platforms (e.g., Klaviyo) that send our messages on our behalf.
• Reviews Platform: The service that collects and displays product reviews (e.g., Stamped).
• Analytics & Advertising Providers: Google Analytics and, where enabled, advertising platforms such as Meta. Under some state privacy laws the use of advertising cookies may be considered "sharing" or "targeted advertising"; you can opt out as described in Section 8.
• IT & Hosting Providers: Web hosting, content management, domain operations and security services.
• Legal & Regulatory Authorities: Where required by law, subpoena, court order, or to protect our rights, or in connection with a merger, acquisition or sale of assets.

Our service providers are contractually required to use personal information only to provide services to us and to protect it appropriately.

7. Information Security & Data Retention

We maintain appropriate technical and organizational measures to safeguard personal information against loss, unauthorized access, destruction, or disclosure. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, tax, accounting and reporting requirements, resolve disputes and enforce our agreements. Order records are typically retained for the period required by tax law; marketing data is retained until you unsubscribe or your account becomes inactive.

8. Your Privacy Rights Under U.S. State Law

Depending on where you live, you may have some or all of the following rights under state privacy laws such as the California Consumer Privacy Act (CCPA/CPRA) and the consumer privacy acts of Virginia, Colorado, Connecticut, Utah, Texas, Oregon and other states:

• Right to Know / Access: Request confirmation of whether we process your personal information, and receive a copy of the personal information we hold about you, including the categories collected, the sources, the purposes, and the categories of third parties it was disclosed to.
• Right to Delete: Request that we delete personal information we have collected from you, subject to legal exceptions (for example, records we must keep to complete a transaction or comply with tax law).
• Right to Correct: Request correction of inaccurate personal information.
• Right to Portability: Receive your personal information in a portable and, where feasible, readily usable format.
• Right to Opt Out of Sale, Sharing or Targeted Advertising: We do not sell personal information. To opt out of the sharing of personal information for cross-context behavioral / targeted advertising, disable marketing cookies in your browser, enable Global Privacy Control, or email us.
• Right to Non-Discrimination: We will not deny you goods or services, charge different prices, or provide a different level of service because you exercised your privacy rights.
• Right to Appeal: If we decline your request, you may appeal by replying to our decision; we will respond in writing with the reasons.

How to exercise your rights: Email customerservice@drinkpura.com with the subject line "Privacy Request". We will verify your identity by matching the details you provide against the information we hold (for example, the email address on your orders) and will respond within 45 days, extendable once by a further 45 days where reasonably necessary. You may designate an authorized agent to make a request on your behalf; we may require proof of the agent's authorization and verification of your identity.

Notice at collection for California residents: The categories of personal information we collect, the purposes and the categories of recipients are described in Sections 3, 4 and 6. We have not sold personal information in the preceding 12 months. We may have "shared" identifiers and internet activity information with advertising platforms for cross-context behavioral advertising where advertising cookies were enabled. We do not knowingly sell or share the personal information of consumers under 16 years of age.

9. Email & Text Message Marketing

• Email: Every marketing email includes an "Unsubscribe" link. You can also withdraw consent by emailing us. Transactional emails (order and shipping confirmations) are sent regardless of marketing preferences.
• SMS: If you opt in to text messages, you consent to receive recurring automated promotional and transactional messages at the number provided. Consent is not a condition of purchase; message and data rates may apply. Reply STOP to any message to opt out, or HELP for help.

10. Children's Privacy

The Site is intended for adults. Our kids' range is marketed to parents and caregivers, not to children. We do not knowingly collect personal information from children under 13 (or under 16 for the purposes of sale or sharing). If you believe a child has provided us with personal information, contact us and we will delete it.

11. International Visitors & Data Transfers

The Site and our online store are operated for customers in the United States. Personal information is processed in the United States and may be processed by our service providers in other countries where they operate, under contracts requiring appropriate protection. If you visit from South Africa or elsewhere, the region-specific privacy policy shown on this page for your region applies.

12. Do Not Track

Some browsers offer a "Do Not Track" setting. There is no industry standard for responding to these signals, so the Site does not respond to them; however, we do honor Global Privacy Control signals as described in Section 5.

13. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our legal obligations, business operations, or digital services. Updates will be posted on this page with a revised effective date; material changes will be highlighted on the Site or notified by email where required.

14. How to Contact Us

For questions about this Policy, or to exercise your privacy rights, please contact us:

• Email: customerservice@drinkpura.com (subject line "Privacy Request")
• Entity: Evolve Brands Inc. t/a PURA Beverage Company