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John Middleton Co.

Effective Date: December 5, 2008

We at John Middleton respect your concerns about privacy and value the relationship we have with you. This Privacy Statement describes the types of information we collect on johnmiddletonco.com, how we may use that information and with whom we may share it. Our Privacy Statement also describes the measures we take to protect the security of the information. We also tell you how you can reach us to answer any questions you may have about our online privacy practices.

Information We Collect

We collect certain aggregate and non-personal information when you visit this website. Aggregate and non-personal information does not relate to a single, identifiable visitor. It tells us things such as how many users visited our site and the pages accessed. By collecting this information, we learn how to best tailor this website to our visitors. We collect this information through “cookie” technology as explained below.

Cookies

Like many companies, we use “cookies” on this website. Cookies are bits of text that are placed on your computer’s hard drive when you visit certain websites. We use cookies to tell us, for example, whether you’ve visited us before or if you’re a new visitor and to help us identify site features in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a particular site.

The “help” portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Remember though, without cookies, you may not be able to take full advantage of all our website features.

We collect certain Personal Information about you, such as your name, mailing address and phone number when you call or mail an inquiry using the information provided on the website.  We collect such Personal Information to respond to and to track your inquiries.  Although the phone and mail information is not collected directly through or via the website, we also do not sell or otherwise disclose information about you, except as described herein.

Information We Share

We do not sell or otherwise disclose information about you, except as described here.  We may share that information with companies affiliated with John Middleton. We also may share that information with service providers we have retained to perform services on our behalf.  These service providers are required to use or disclose the information only as necessary to perform services on our behalf or to comply with legal requirements. In addition, we may disclose that information (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or connection with an investigation of suspected or actual illegal activity.

We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets.  Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use that information in a manner that is consistent with this Privacy Statement.

Links to Other Sites

We may provide links to other websites for your convenience and information. These sites operate independently from johnmiddletonco.com. These sites may have their own privacy statements in place, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are unaffiliated with John Middleton, we are not responsible for their content or any use of the sites.

How We Protect Your Information

We maintain administrative, technical and physical safeguards for this website to protect against unauthorized disclosure, use, alteration or destruction of the information you provide on the site.

Updates to Our Privacy Statement

This Privacy Statement may be updated periodically and without prior notice to you to reflect changes in our online information practices. We will post a prominent notice on this site to notify you of any significant changes to our Privacy Statement and indicate at the top of the statement when it was most recently updated.

How to Contact Us

If you have any questions or comments about this Privacy Statement, please contact us at:

    c/o Altria Client Services
    Corporate Communications
    P.O. Box 85088
    Richmond, VA 23285