Privacy Policy

Effective Date: September 1, 2026

Pronghorn Initiative Holdings, LLC ("Pronghorn," "we," "us," or "our") respects your privacy. This Privacy Policy applies to consumers ("consumers" or "You") who visit pronghorn.co (the "Site") or use Pronghorn services (collectively, our "Services"). It explains what information we collect, how we use and share it, and the choices and rights available to You.

By using the Site, You agree to the practices described in this Policy.

1. Who We Are and How to Reach Us

Pronghorn Initiative Holdings, LLC
6000 Avalon Boulevard, Suite 220
Alpharetta, Georgia 30009
United States

Email: admin@pronghorn.co
Phone: +1 (770) 284-4011

Pronghorn is a spirits industry growth platform. We invest in and support spirits brands, operate career development programming, and sell products through our online shop.

2. What This Policy Covers

This Policy applies to pronghorn.co and to information we collect through the Site.

This Policy does not cover certain third-party services that we link to or embed:

• Our job board (jobs.pronghorn.co) is hosted and operated by ForceBrands. Information You submit when browsing or applying for roles is collected by ForceBrands under its own privacy policy and terms, not by Pronghorn.
• Our online shop checkout is powered by BottleNexus. When You purchase a product, Your payment and order information is collected and processed by BottleNexus and its fulfillment partners under their own privacy policies.
• Brand websites. Pronghorn holds a position in a number of spirits brands, and separately operates Edmond's Honor Bourbon. Each brand's website is governed by its own privacy policy.
• Social media platforms and other third-party sites we link to.

We encourage You to read the privacy policy of any third-party service before providing information to it.

3. Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, we collect the following categories:

• Category A – Identifiers. Name, email address, postal address, telephone and mobile number, IP address, and online identifiers such as cookie IDs and device identifiers.
• Category B – Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Name, telephone number, and address.
• Category F – Internet or other electronic network activity information. Browsing history on the Site, pages viewed, links clicked, search activity, session recordings, and information about Your interaction with our advertisements.
• Category G – Geolocation data. General location inferred from IP address, such as city or region. We do not collect precise geolocation.
• Category I – Professional or employment-related information. Employer and company information.
• Category K – Inferences. Inferences drawn from the above to create a profile reflecting preferences and characteristics, used for analytics and advertising audiences.

Sources of personal information

• Directly from You. Through information we ask for when You or Your agents use our Services — for example, our "Join the Movement" newsletter signup, our general inquiry form, expressions of interest in Spirits Prep or other programming, and correspondence by email or phone.
• Directly and indirectly from You when visiting the Site. Usage details collected automatically in the course of Your interaction with our website, as described in Section 4.
• From third parties. From analytics and advertising providers, our marketing platform, and partners who refer You to the Site.

Information collected automatically

When You visit the Site, we and our service providers automatically collect IP address and general location derived from it; browser type, device type, operating system, and screen size; pages viewed, links clicked, time on page, scroll depth, and referring URL; date and time of visit; and session activity including mouse movement, clicks, and scrolling.

4. Cookies and Similar Technologies

A cookie is a small text file stored on Your device. We use cookies and similar technologies — including pixels, tags, and local storage — to operate the Site, measure performance, and support advertising. We use a Google Tag Manager container to deploy and manage these technologies.

Analytics and performance

Marketing and CRM

Advertising

Session replay notice. Microsoft Clarity records a reconstruction of Your session on the Site, including pages viewed, clicks, and scrolling, so we can improve the experience. Clarity is configured to mask text input fields. Please do not enter sensitive information into free-text fields on the Site.

5. Advertising, Analytics, and Your Advertising Choices

We use Google Analytics, including Google Analytics Advertising Features, Google Ads, the LinkedIn Insight Tag, and a third-party ad server operated by our media partner.

Specifically:

• We have enabled Google Analytics Advertising Features, which may include Remarketing with Google Analytics, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting, and integrated services that require Google Analytics to collect data via advertising cookies and identifiers.
• We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on Your past visits to the Site, and to report how our ad impressions, other uses of ad services, and interactions with those ad impressions and ad services relate to visits to the Site.
• We do not merge personally identifiable information with non-personally identifiable information collected through Google advertising products unless we have given You robust notice of, and obtained Your prior affirmative consent to, that merger.
• Data collected through these features is used to understand our audience and to deliver and measure advertising. It is not used to make decisions that produce legal or similarly significant effects.

Your controls

• Google Analytics: opt out using the Google Analytics Opt-out Browser Add-on at Google's opt-out download page
• Google personalized advertising: manage or opt out at Google Ads Settings
• LinkedIn: opt out of targeted advertising at LinkedIn's advertising opt-out settings
• Industry opt-outs: Network Advertising Initiative at the NAI opt-out tool and Digital Advertising Alliance at the DAA opt-out tool
• Browser controls: most browsers let You block or delete cookies through their settings. Blocking cookies may affect how the Site functions.
• Global Privacy Control: where required by law, we honor opt-out preference signals such as Global Privacy Control (GPC) transmitted by Your browser.
• Do Not Track: there is no common industry standard for responding to "Do Not Track" browser signals, and we do not currently respond to them other than as described above for GPC.

6. Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided — for example, to provide services requested or offered by our organization.
• To provide You with email alerts and other notices concerning our Services, or updates to the Services.
• To improve our Services to You.
• To market our Services to You, including by delivering and measuring advertising and showing Pronghorn advertisements to people who have previously visited the Site.
• For testing, research, analysis, and product and service development.
• To administer and improve our career development programming.
• To verify that visitors are of legal drinking age where required.
• As necessary or appropriate to protect the rights, property, or safety of us, our clients, or others, and to detect and prevent fraud, abuse, and security incidents.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulation, including alcohol beverage advertising and marketing regulations.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information, or use the personal information we collected for materially different, unrelated, or incompatible purposes, without providing You notice.

7. Sharing Personal Information

We disclose personal information to the following categories of recipients:

• Service providers. Vendors who perform services for us, including our website platform (Webflow), marketing and CRM platform (HubSpot), analytics providers (Google, Microsoft), e-commerce provider (BottleNexus), job board provider (ForceBrands), and our advertising agency and ad server.
• Advertising partners. Google, LinkedIn, and our ad server, in connection with the advertising activities described in Sections 4 and 5.
• Legal and safety. Where we believe disclosure is required by law, regulation, legal process, or governmental request, or is necessary to protect the rights, property, or safety of Pronghorn, our users, or others.
• Business transfers. In connection with a merger, acquisition, financing, reorganization, or sale of assets.
• At Your direction. When You ask us to share information or otherwise consent.

We do not sell Your personal information for money. However, our use of advertising cookies and tags as described in Sections 4 and 5 may constitute a "sale" or "sharing" of personal information for cross-context behavioral advertising under certain state privacy laws. You may opt out using the controls in Section 5, by enabling Global Privacy Control in Your browser, or by contacting us at admin@pronghorn.co.

We do not knowingly sell or share the personal information of consumers under 16 years of age.

8. Email and Text Message Communications

Email. When You sign up for our newsletter or otherwise provide Your email address, You consent to receive marketing and informational emails from Pronghorn. You can unsubscribe at any time using the unsubscribe link in any message, or by emailing admin@pronghorn.co. We may still send You transactional or administrative messages related to Your requests or purchases.

Text messages. If You provide Your mobile number and affirmatively consent to receive text messages from Pronghorn, we may send You marketing and informational messages. Message frequency may vary. Message and data rates may apply. Reply STOP to any message to opt out, or HELP for help. Consent to receive text messages is not a condition of any purchase.

We do not sell or share mobile numbers, SMS consent, or message data with third parties or affiliates for their own marketing or promotional purposes. We may share this information only with service providers, such as carriers and messaging platforms, solely to operate our messaging program.

9. Your Rights and Choices — California Residents

The California Consumer Privacy Act, as amended ("CCPA"), provides California residents with specific rights regarding their personal information. This section describes those rights and explains how to exercise them.

Access to specific information and data portability rights

You have the right to request that we disclose certain information to You about our collection and use of Your personal information over the past 12 months. Once we receive and confirm Your verifiable consumer request, we will disclose to You:

• The categories of personal information we collected about You.
• The categories of sources from which the personal information was collected.
• Our business or commercial purpose for collecting, selling, or sharing that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about You (also called a data portability request).

Correction rights

You have the right to request that we correct inaccurate personal information we maintain about You, taking into account the nature of the information and the purposes of processing it.

Deletion request rights

You have the right to request that we delete any of Your personal information we collected from You and retained, subject to certain exceptions. Once we receive and confirm Your verifiable consumer request, we will delete (and direct our service providers to delete) Your personal information from our records, unless an exception applies.

We may deny Your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or perform a contract with You.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

Right to opt out of sale or sharing

You have the right to opt out of the sale or sharing of Your personal information for cross-context behavioral advertising. See Section 7 and the controls in Section 5.

Exercising access, correction, data portability, and deletion rights

To exercise the rights described above, please submit a verifiable consumer request to us at admin@pronghorn.co or +1 (770) 284-4011.

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable consumer request related to Your personal information. You may also make a verifiable consumer request on behalf of Your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify You are the person about whom we collected personal information, or an authorized representative.
• Describe Your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to Your request or provide You with personal information if we cannot verify Your identity or authority to make the request and confirm the personal information relates to You. Making a verifiable consumer request does not require You to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response timing and format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform You of the reason and extension period in writing. We will deliver our written response by mail or electronically, at Your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format that is readily useable and should allow You to transmit the information from one entity to another without hindrance.

We do not charge a fee to process or respond to Your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will tell You why we made that decision and provide You with a cost estimate before completing Your request.

Non-discrimination

We will not discriminate against You for exercising any of Your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny You use of our Services.
• Provide You a different level or quality of Services.
• Charge You different prices or rates for Services, including through the granting of discounts or other benefits, or by imposing penalties.

10. Residents of Other U.S. States

Residents of states including Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia may have rights under their state privacy laws similar to those described in Section 9, including the right to access, correct, and delete personal information, the right to opt out of targeted advertising and the sale of personal information, and the right to appeal a denial of a request. To exercise these rights, or to appeal a decision, contact us at admin@pronghorn.co.

11. European Residents

If You are a resident of the European Economic Area (EEA) or the United Kingdom, You have certain rights under the General Data Protection Regulation (GDPR). These include the right to access, correct, update, or request deletion of Your personal information. You also have the right to object to the processing of Your personal information, ask us to restrict the processing of Your personal information, or request portability of Your personal information. Where we rely on consent, You have the right to withdraw that consent at any time. To exercise these rights, please contact us at admin@pronghorn.co.

You have the right to complain to a data protection authority about our collection and use of Your personal information. For more information, please contact Your local data protection authority.

12. Data Retention

We keep personal information for as long as needed for the purposes described in this Policy, including to provide our Services, communicate with You, and meet our legal, tax, and regulatory obligations. Contacts in our marketing database are retained until You unsubscribe or ask us to delete Your information. Analytics data is retained according to the retention settings of the relevant analytics platform.

13. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information. No method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

14. Age Restrictions

The Site is intended for adults of legal drinking age. You must be 21 years of age or older to use this Site, to purchase products through our shop, or to sign up for our communications.

The Site is not directed to children. We do not knowingly collect personal information from anyone under 21. If You believe a person under 21 has provided us with personal information, contact us at admin@pronghorn.co and we will delete it.

Drink Responsibly. 21+

15. Third-Party Links and Services

The Site contains links to and embedded content from third-party websites and services, including our job board, our shop, brand websites, and social media platforms. We are not responsible for the privacy practices or content of those third parties. Their collection and use of Your information is governed by their own policies.

16. Changes to Our Privacy Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. The date this Policy was last updated is identified at the top of this page. If we make material changes, we will provide additional notice as required by law. You are responsible for periodically visiting the Site and this Privacy Policy to check for any changes. Your continued use of the Site after an update means You accept the revised Policy.

17. Contact Information

If You have any questions or comments about this Privacy Policy, the ways in which we collect and use Your personal information, Your choices and rights regarding such use, or wish to exercise Your rights, please contact us:

Pronghorn Initiative Holdings, LLC
Email: admin@pronghorn.co
Phone: +1 (770) 284-4011
Mail: 6000 Avalon Boulevard, Suite 220, Alpharetta, GA 30009