Effective Date: January 1, 2020

Privacy Policy

C. Fuente Holdings, Inc. (“Arturo Fuente,” “we” or “us”) respects your privacy and is committed
to protecting it through our compliance with this policy.

Scope

This policy describes the types of information we may collect about you and how we handle andshare it. By interacting with us through our website, www.arturofuente.com (our “Website”), ourmobile application, our store, or our products and services, or when you call, email, or otherwise
communicate with us, you agree to this privacy policy.
This policy does not apply to information collected on any other website operated by us or any
third party, including our affiliates and subsidiaries. This policy also does not apply to yourinteractions with third parties or their websites or mobile applications that are linked to oraccessible from our Website or mobile application or that are operated by any parties unaffiliatedwith us, all of which are governed by the respective privacy policies of those third parties. This
policy also does not apply to our employment-related records.
This policy may change from time to time (see Changes to Our Privacy Policy, below). Your
continued use of this Website or our mobile application after we make changes is deemed to be
acceptance of those changes, so please check the policy periodically for updates.

Information We Collect

We collect, and have collected in the past twelve months, the following categories of personal
information to sell products to you, to buy products from you, to comply with legal requirements,
or otherwise to operate our Website, mobile application, and business:
Category
A. Identifiers.

ExamplesReal name, postal address, internet protocol address, email
address, or other similar identifiers.
B. PersonalName, telephone number, employment, or bank accountinformation
number, credit card number, debit card number, or any othercategories listed financial information. Some personal information included inin thethis category may overlap with other categories.
California
Customer
Records statute(Cal. Civ. Code§ 1798.80(e)).
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C. Commercial
information.

Records of personal property, products or services purchased,
obtained, or considered, or other purchasing or consuming
histories or tendencies.
Browsing history, search history, information on a consumer’sinteraction with a website, application, or advertisement.

D. Internet orother electronic
network
activity
information.
E. Professional Current or past employment information, such as name ofor employment- employer.
relatedinformation.
Our Website and mobile application are not intended for individuals under 21 years of age. No one
under age 21 may provide any personal information to us on the Website or mobile application.
We do not knowingly collect personal information from individuals under 21. If you are under 21,
do not use this Website or our mobile application, and do not provide us with any information
about yourself. If you believe we might have any information from or about someone under 21,
please contact us (see Contact Information, below). California residents under 16 years of age may
have additional rights regarding their personal information (see Your California Privacy Rights,
below).

Sources of Information

We collect the above categories of information directly from you when you provide it to us,
automatically as you use our Website or mobile application, and from third parties, such as ourbusiness partners.

Information You Provide

You may choose to provide us information when you use our Website or mobile application orinteract with us. For example, when you place an order with us, we may collect your payment card
information. When you fill out forms on our Website or mobile application or call or email us, wewill collect your contact information.

Information from Automatic Data Collection Technologies

As you use our Website or mobile application, we may use automatic data collection technologies,
such as cookies, to collect certain information about your equipment, browsing actions, andpatterns, including details of your visits to our Website or mobile application and information
about your computer and internet connection, including your IP address, operating system, andbrowser type. When you call us, or when we call you, we may collect your voice by recording thephone call.

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The information we collect automatically helps us improve our Website and mobile applicationand deliver a better and more personalized service, including by enabling us to:••••

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website or mobile
application according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website or mobile application.

The technologies we use for this automatic data collection may include:•••

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of yourcomputer. You may refuse to accept browser cookies by activating the appropriate setting
on your browser. However, if you select this setting you may be unable to access certain
parts of our Website or mobile application. Unless you have adjusted your browser setting
so that it will refuse cookies, our system will issue cookies when you direct your browser
to our Website or mobile application.
Flash Cookies. Certain features of our Website or mobile application may use local stored
objects (or Flash cookies) to collect and store information about your preferences andnavigation to, from, and on our Website or mobile application. Flash cookies are not
managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages of our Website or mobile application and our emails may containsmall electronic files known as web beacons (also referred to as clear gifs, pixel tags, andsingle-pixel gifs) that permit us, for example, to count users who have visited those pages
or opened an email and for other related website statistics (for example, recording the
popularity of certain website content and verifying system and server integrity).

Information from Third Parties

We may collect your information from our affiliates, acquired businesses, public sources, or otherindividuals, such as, for example, if a customer refers you to us or if someone purchases a productfor delivery to you. We also may collect information from business partners, such as data analytics
service providers.

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How We Use Your Information

To perform services, including maintaining or servicing accounts, providing customer
service, processing or fulfilling orders and transactions, verifying customer information,
processing payments, providing analytic services, or providing similar services on ourbehalf.
To present our Website or mobile application and their contents to you.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose, order, or transaction for which you provide the information.
To carry out our obligations and enforce our rights arising from any contracts or orders
entered into between you and us, including for billing and collection.
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To notify you about changes to any products or services we offer or provide.
To contact you about our own and third-parties’ goods and services that may be of interest
to you.
To allow you to participate in interactive features on our Website or mobile application.
To enhance our products, services, operations, Website, and mobile application, including
to conduct research and analytics, develop or acquire new products or services, and perform
market research and data analytics.
To perform accounting, auditing, billing, and collection activities.
To undertake internal research for technological development and demonstration.
To undertake activities to verify or maintain the quality or safety of a service or device thatis owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade,or enhance the service or device that is owned, manufactured, manufactured for, or
controlled by us.
To comply with legal and regulatory requirements.
To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal
activity and prosecute responsible parties.
To debug to identify and repair errors that impair existing intended functionality.
In any other way we may describe when you provide the information.
Short-term, transient use, provided that the personal information is not disclosed to anotherthird party and is not used to build a profile about a consumer or otherwise alter anindividual consumer’s experience outside the current interaction, including, but not limited
to, the contextual customization of ads shown as part of the same interaction.
To evaluate or conduct a merger, divesture, restructuring, reorganization, dissolution, orother sale or transfer of some or all of our assets, whether as a going concern or as part ofbankruptcy, liquidation, or similar proceeding, in which information held by us about you
is among the assets transferred or involved.
Auditing related to a current interaction with the consumer and concurrent transactions,
including, but not limited to, counting ad impressions to unique visitors, verifying
positioning and quality of ad impressions, and auditing compliance with this specificationand other standards.
For any other purpose with your consent or direction.

Disclosure of Information

We may disclose aggregated information about our users, and information that does not identify
any individual, without restriction.
We also may disclose information:••

To our subsidiaries and affiliates.
To our contractors, service providers, and other third parties we use to support our businessand provide services to us, such as, for example and without limitation, in areas of orderprocessing and fulfillment, shipping, information technology, marketing, customer service,data analytics, research and enhancement, fraud prevention, legal, accounting, compliance,and risk management.
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To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your implied or express consent or direction.
To a buyer or other successor in the event of a merger, divestiture, restructuring,
reorganization, dissolution, or other sale or transfer of some or all of our assets, whether asa going concern or as part of bankruptcy, liquidation, or similar proceeding, in which
information about you is among the assets involved or transferred.
To third parties to market their products or services to you.
To comply with any court order, law, regulation, or legal process, including to respond to
any subpoena or government or regulatory request.
To enforce or apply our terms of use and any other agreements, including for billing andcollection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safetyof us, our employees, our customers, or others. This includes, for example, exchanging
information with governmental agencies or other companies and organizations for fraud
protection and credit risk reduction.
In connection with an investigation of suspected or actual wrongful or unlawful activity.

Third-Party Use of Information

Some content or applications, including advertisements, on the Website or our mobile application
are served by third-parties, including social media platforms, advertisers, ad networks and servers,
content providers, and application providers. These third parties may use cookies alone or in
conjunction with web beacons or other tracking technologies to collect information about you
when you use our Website or mobile application. The information they collect may be associatedwith your personal information or they may collect information, including personal information,
about your online activities over time and across different websites and other online services. Theymay use this information to provide you with interest-based (behavioral) advertising or othertargeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you haveany questions about an advertisement or other targeted content, you should contact the responsible
third party directly.

Accessing and Changing Your Information

You can review and request changes to your information by emailing us at the email address statedbelow (see Contact Information, below) to request access or a change to any personal information
you have provided to us.
We strive to accommodate reasonable requests where feasible. However, we may notaccommodate a request to access or change information if we believe the request or compliancewith the request would violate any law or legal requirement, infringe on any or our legal rights or
obligations, if we cannot verify the authenticity of the request or the identity or authorization of
the person making the request, if we suspect fraud or other wrongdoing, if compliance would cause
Page 5 of 9the information to be incorrect, if compliance would pose an undue burden or expense, if
compliance would jeopardize the security, integrity, or availability of any information, orotherwise in our discretion.

Nevada Consumers

We do not sell personal information for monetary consideration. However, Nevada law gives
Nevada consumers the right to ask a company that operates a website for commercial purposes not
to sell their personal information for monetary consideration to another party for the other party tolicense or sell the information to additional parties. This right may apply even if personal
information is not currently being sold. If you are a Nevada consumer who wishes to exercise aright to ask us not to sell your personal information, please email us at the email address identified
below (see Contact Information, below). We reserve the right to take reasonable measures to verify
the authenticity of the request and the identity of the consumer making the request.

Your California Privacy Rights

This portion of the Privacy Policy, “Your California Privacy Rights,” applies only to individuals
who live in California. We adopt this notice to comply with the California Consumer Privacy Act
of 2018 (the “CCPA”) and other California laws identified below. Terms defined in the CCPA
have the same meaning when used in this portion of the privacy policy.

Types of Personal Information Collected, Sources of Collection, Purposes, andCategories of Third Parties

The categories of personal information collected from California consumers, the sources ofcollection, the business and commercial purposes for which the information will be used, and thecategories of third parties to whom we disclose the information are disclosed in the above sectionsof this privacy policy.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve months, we have disclosed the following categories of personal
information for a business purpose to other entities:
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Identifiers.
California Customer Records personal information categories.
Commercial information.
Internet or other similar network activity.
Professional or employment-related information.

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“Sales” (as defined by the CCPA) of Personal Information

We do not sell your information for payment. However, the CCPA defines “sale” more broadly
to include, for example, certain communications of information to a third party for “other valuable
consideration.” In the preceding twelve months, we have shared the following categories of
personal information with other entities in such a way that the sharing may be deemed a “sale”
under the CCPA, even though we do not sell your information for payment or discount:
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Identifiers.
California Customer Records personal information categories.
Commercial information.
Internet or other similar network activity.
Professional or employment-related information.

Your Rights

Access to Information: You can ask us to disclose to you the following information if we receivea verifiable consumer request (see Exercising Your Rights, below):
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Categories of personal information we have collected about you.
Specific pieces of personal information we have collected about you.
Categories of sources from which the personal information is collected.
Business or commercial purpose for collecting or selling personal information.
Categories of third parties with whom we share personal information.
Categories of personal information we “sold” (as defined in the CCPA) about you and thecategories of third parties to whom the information was “sold,” by category or categories
of personal information for each category of third parties to whom the personal information
was “sold.”Categories of personal information we disclosed about you for a business purpose.

When you make this request, the information provided may be limited to personal information wecollected about you in the twelve months preceding our receipt of the verifiable request. We are
not obligated to provide this information to you more than twice in any twelve-month period.
We may deny access requests for business-to-business personal information because until January
1, 2021, the CCPA exempts from some of its requirements personal information reflecting awritten or verbal business-to-business communication or transaction.
Deletion Rights: You can ask us to delete any of your personal information we collected fromyou, if we receive a verifiable consumer request (see Exercising Your Rights, below). There are
exceptions to this right under the CCPA. For example, we are not required to delete yourinformation if we need it to provide a product you ordered or comply with a legal obligation.

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We may deny deletion requests for business-to-business personal information because until
January 1, 2021, the CCPA exempts from some of its requirements personal information reflecting
a written or verbal business-to-business communication or transaction.
Exercising Your Rights: To exercise your access or deletion rights described above, please see
the contact information at the end of this policy.
We cannot accommodate your request if we cannot reasonably verify your identity or authority tomake the request and confirm the personal information relates to you.
Personal Information Sales Opt-Out and Opt-In Rights: We do not sell your information
for payment. However, the CCPA defines “sale” to include certain transfers of information even
without monetary consideration. You have the right to direct us not to “sell” (as defined by theCCPA) your personal information. This is the “right to opt-out.” To exercise your right to opt-out,click “Do Not Sell My Personal Information” located at the bottom of this page or our homepage.
We do not sell the personal information of consumers we actually know are under 16 years of age,unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is
at least 13 but not yet 16 years of age or the parent or guardian of a consumer under 13 years ofage. Consumers who opt-in to personal information sales may opt-out of future sales at any timeby clicking “Do Not Sell My Personal Information” located at the bottom of this page or our
homepage.
Once you have opted out of the sale of your personal information, we will wait at least twelve
months before asking you to reauthorize personal information sales. However, you may change
your mind and opt back in to personal information sales at any time by emailing us at the email
address stated below (see Contact Information, below).
You do not need to create an account with us to exercise your right to opt-out. We will use personal
information provided in an opt-out request only to review and comply with the request.
Non-Discrimination: If you exercise any of your CCPA rights, we will not discriminate against
you, which means that, unless permitted by the CCPA, we will not:••••Deny you goods or services.
Charge you different prices or rates for goods or services, including through the use of
discounts or other benefits or imposing penalties.
Provide you with a different level or quality of goods or services.
Suggest that you will receive a different price or rate for goods or services or a different
level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result indifferent prices or rates or level or quality of goods or services. Any CCPA-permitted financial
incentive we offer will reasonably relate to your personal information’s value to us and contain
written terms that describe the program’s material aspects. Participation in a financial incentive
program requires your prior opt-in consent, which you may revoke at any time.
Page 8 of 9Other California Privacy Rights

Subject to certain limitations, California's “Shine the Light” law (Civil Code Section § 1798.83)
permits California residents who have an established business relationship with us to request
certain information regarding our disclosure of personal information to third parties for their direct
marketing purposes during the immediately preceding calendar year. To make such a request, you
may email us at the email address stated below (see Contact Information, below). We are notobligated to comply with a request from the same customer more than once during the course of
any calendar year. We are exempt from the Shine the Light law if we have fewer than twenty fulltime or part-time employees.
The California Online Privacy Protection Act requires us to inform you how we respond to web
browser “do not track” signals or other mechanisms that provide consumers the ability to exercise
choice regarding the collection of personally identifiable information about an individual
consumer’s online activities over time and across third-party websites or online services, if weengage in that collection. As there is no industry or legal standard for recognizing or honoring “donot track” requests, we don’t respond to them at this time.

Data Security

We have implemented measures designed to safeguard your personal information from accidental
loss and unauthorized access, use, alteration, and disclosure. However, the transmission of
information over the internet is not completely secure. We cannot guarantee the security of yourpersonal information. Any transmission of personal information is at your own risk.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. The date theprivacy policy was last revised is identified at the top of the page. You are responsible for
periodically visiting our Website or mobile application and this privacy policy to check for any
changes.

Contact Information

You may contact us in the following ways:•••

Call us at 1-813-241-1907;
Email us at support@arturofuente.com;
Mail the request to us at The Fuente Companies, 1310 N. 22nd St., Tampa, FL 33605,
Attention: Website Administrator.

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