Privacy Policy

CATALYST BEVERAGE CO. PRIVACY POLICY

Last modified: September 4, 2024

California Privacy Rights Notice

INTRODUCTION

Catalyst Beverage Co. (here­inafter ​“Catalyst”) and its brands, affil­i­ates, sub­sidiaries, com­pa­nies and/​or their relat­ed brands (col­lec­tive­ly referred to here as ​“we,” ​“our,”) cre­at­ed this Pri­va­cy Pol­i­cy to inform our web­site users, club mem­bers, event registrants/​participants, newsletter/​information recip­i­ents, pro­mo­tion, con­test, sweep­stakes or cam­paign par­tic­i­pants, online com­mu­ni­ty par­tic­i­pants, those who cor­re­spond with us via SMS (text mes­sage), those who pur­chase or inquire about our prod­ucts and ser­vices and oth­ers (col­lec­tive­ly referred to as ​“you”) about our prac­tices regard­ing col­lec­tion, use and dis­clo­sure of per­son­al­ly iden­ti­fi­able infor­ma­tion (“per­son­al information”) that you pro­vide to us or we col­lect from you. All ref­er­ences to our ​“web­site” in this Pri­va­cy Pol­i­cy include any of our affil­i­at­ed sites linked to our web­site as well as any of our affil­i­at­ed mobile applications.

This Privacy Policy does not apply to information collected by any third party (other than our affiliates, subsidiaries, and data service providers), including through any application or content (including advertising), whether or not such is linked to, or accessible from or on, our websites or apps.

YOUR CAL­I­FOR­NIA PRI­VA­CY RIGHTS

California state law confers certain rights relating to the personal information of its residents. If you are a Cal­i­for­nia res­i­dent, please see our Cal­i­for­nia Pri­va­cy Rights Notice.

YOUR CONSENT

Please review this Privacy Policy periodically. You should read this entire Privacy Policy before submitting information, including personal information, to us in any form. Whenever you submit personal information to us, whether online or offline, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy.

All personal information may be used for the purposes stated in this Privacy Policy. We may make full use of all information that is de-identified, aggregated, or otherwise not in a personally identifiable form.

NO DATA COLLECTED FROM MINORS UNDER THE AGE OF 18

We comply with the requirements of the Children’s Online Privacy Protection Act (“COPPA”) and other applicable privacy laws. We do not knowingly collect personal information from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided personal information to us except as permitted by applicable law, please contact us using any of the methods described in this Privacy Policy, and we will delete that personal information from our systems. We do not knowingly sell or share for cross-context behavioral advertising the personal information of consumers under the age of 18.

INFOR­MA­TION COL­LEC­TION AND USE

We may collect per­son­al information (includ­ing, with­out lim­i­ta­tion, age, birth­date, address, email address, IP address, phone num­ber, social media account infor­ma­tion, geo­graph­ic loca­tion, and commercial information) from you both online and offline. Any personal information we collect will be used as indicated in this Privacy Policy.

Offline, we may receive information from you through telephone, written correspondence, or other communication methods, and in person, including at our wineries, tasting rooms, or retail locations.  Online, we may receive infor­ma­tion through our web­site, an affil­i­at­ed site, a brand page on a com­mu­ni­ty web­site or social media site or through sim­i­lar online avenues, email, and via mobile phone appli­ca­tions or SMS (text mes­sage) cor­re­spon­dence. In many cas­es, such infor­ma­tion will be col­lect­ed direct­ly from you, such as through a trans­ac­tion or inquiry (includ­ing via a tele­phone call or SMS cor­re­spon­dence) or your sub­mis­sion of a form, reg­is­tra­tion or com­mu­ni­ca­tion to us. Infor­ma­tion may also be gath­ered from third-par­ty sources (includ­ing with­out lim­i­ta­tion, our third-par­ty ser­vice providers (such as mar­ket­ing and ful­fill­ment com­pa­nies), opt-in lists, con­sumer report­ing agen­cies, oth­er com­pa­nies and refer­rals) and through your activ­i­ties and inter­ac­tions with us, includ­ing, with­out lim­i­ta­tion, your online activ­i­ty on our web­site and social media pages. We may com­bine data col­lect­ed from these dis­parate sources unless we tell you oth­er­wise. Any of your per­son­al information or oth­er infor­ma­tion gath­ered by one of our brands may be shared with and used by any of our oth­er brands in accor­dance with this Pri­va­cy Policy. To see a complete list of what we collect and how we use this data, please see Annex 1 below.

We may use the information we collect from you to:

• Respond to or follow up on your comments, inquiries, or requests;
• Communicate with you about your account or the use of our websites;
• Pro­vide prod­ucts or ser­vices that you have ordered or to process your order trans­ac­tions and con­tact you regard­ing your order;
• Invite and help you to par­tic­i­pate in online and offline events, activ­i­ties, and/​or clubs;
• Improve the quality of our website, services, and products and tailor them to your preferences;
• Send pro­mo­tion­al com­mu­ni­ca­tions or offers (unless you have request­ed that we do not send such com­mu­ni­ca­tions);
• Per­mit you to par­tic­i­pate in and to oth­er­wise admin­is­ter sweep­stakes, pro­mo­tions, cam­paigns, and con­tests;
• And as oth­er­wise spec­i­fied in this Pri­va­cy Pol­i­cy and/​or at the point of per­son­al information collection.

 

In addition to promotional communications or offers you have opted in to receive or have not opted out from receiving, we may use your con­tact infor­ma­tion to tell you about oth­er prod­ucts and ser­vices (includ­ing those of our oth­er brands, affil­i­ates, and com­pa­nies) that we believe might be of inter­est. If at any time you do not want com­mu­ni­ca­tions from us for pro­mo­tion­al pur­pos­es, you can opt out by following the instructions provided in those communications or sending an email to the email address listed on the brand website.  

This opt-out does not apply to information provided to us as a result of a product purchase, product service experience, or other similar transaction. In addition, we may use your information for compliance with our company policies and procedures, for accounting and financial purposes, and as otherwise described above. If you do not provide this information, we may not be able to fulfill the applicable purpose of collection, such as to respond to your queries or provide our website to you.

How We Disclose Your Personal Information.

The personal information you provide is held by Catalyst or an agent of Catalyst and may be used by our affiliates, partners, agents, or licensees. Your information will not be sold, shared, exchanged, or otherwise distributed to unaffiliated third parties except to the extent required by law or as outlined below.

Our business partners. We use mar­ket­ing and adver­tis­ing part­ners and we share cook­ies, IP address­es, and device iden­ti­fiers with them for a business purpose so that they can help us pro­mote our services. We may share your personal information with them for general business administration purposes and other purposes described herein.

Agents/Service Providers. We may dis­close per­son­al information you pro­vide to any of our oth­er brands and to ser­vice providers that we use to sup­port our busi­ness and oper­a­tions (e.g., deliv­ery ser­vices, finan­cial insti­tu­tions, ful­fill­ment ser­vices, tech­ni­cal sup­port, adver­tis­ing, pub­lic rela­tions, media and mar­ket­ing ser­vices, sweep­stakes, pro­mo­tions, cam­paigns and con­test-relat­ed ser­vices, e‑commerce and oth­er web-relat­ed ser­vices such as web host­ing and web mon­i­tor­ing ser­vices and event-relat­ed ser­vices such as online and offline data cap­ture) who have agreed to keep the infor­ma­tion con­fi­den­tial and use it only to pro­vide the applic­a­ble service(s). In some cas­es, we work with oth­er com­pa­nies who help to gath­er infor­ma­tion from you or help us to com­mu­ni­cate with you.

Third parties. We may share your personal information with social media platforms such as Facebook and Instagram and with Google Analytics to serve you advertisements on our behalf and to provide analytics services. Depending on your place of residence, the circumstances, and the contractual obligations in place, this sharing may be considered a “sale” or “sharing,” and you may have the right to request that we stop such sharing as set forth in this Privacy Policy. For more information on this type of sharing and how you may opt out, see the “Third Party Advertising and Analytics Disclaimers” section below.

Legal matters. We may also dis­close per­son­al information to third par­ties (includ­ing, with­out lim­i­ta­tion, gov­ern­men­tal agen­cies) if required to do so by law, reg­u­la­tion or court order; to respond to gov­ern­men­tal and/​or law enforce­ment requests; to iden­ti­fy, con­tact or bring legal action against some­one who may be caus­ing injury to or inter­fer­ing with our (or oth­ers’) rights or prop­er­ty; to sup­port any actu­al or threat­ened claim, defense or dec­la­ra­tion in a case or before any juris­dic­tion­al and/​or admin­is­tra­tive author­i­ty, arbi­tra­tion or medi­a­tion pan­el; or in con­nec­tion with dis­ci­pli­nary actions/​investigations. Like­wise, we may dis­close per­son­al information to third par­ties in con­nec­tion with the sale, assign­ment or oth­er trans­fer of the busi­ness of our web­site or the sale, assign­ment, merg­er, reor­ga­ni­za­tion or oth­er trans­fer of any of our brands or companies.

We (includ­ing any of our brands) may use your user-gen­er­at­ed con­tent you choose sub­mit to us includ­ing by dis­play­ing it on our sites and includ­ing for our pro­mo­tion­al purposes.

Business transfers. Where permitted by law, we may transfer your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries, or other assets.

How We Use Cookies and Other Technology.

As you use our web­site, some infor­ma­tion can be ​“pas­sive­ly” col­lect­ed using var­i­ous tech­nolo­gies, such as cook­ies, web bea­cons, and nav­i­ga­tion­al and loca­tion data col­lec­tion. Your Inter­net brows­er auto­mat­i­cal­ly trans­mits some of this infor­ma­tion, such as the URL of the web­site you just vis­it­ed and the Inter­net Pro­to­col (IP) address and brows­er ver­sion cur­rent­ly being used by your com­put­er. Such tech­nolo­gies help us to keep track of your inter­ac­tions with our web­site and pro­vide you with a more cus­tomized experience.

As is the case with many web­sites, our web­site may use cook­ies and oth­er auto­mat­ed infor­ma­tion col­lec­tion means. Cook­ies are infor­ma­tion about you from our web­site that is stored on your brows­er or hard dri­ve. Cook­ies save you time because you do not need to man­u­al­ly re-enter the infor­ma­tion stored on your hard dri­ve. Cook­ies also help us opti­mize and upgrade our web­site by show­ing when and how users use our web­site. You can set your brows­er to noti­fy you when a cook­ie is sent or refuse cook­ies alto­geth­er, but cer­tain fea­tures of our web­site might not work with­out cookies.

Our web­site may also use IP address­es for the same pur­pos­es iden­ti­fied above, as well as to ana­lyze trends, admin­is­ter our web­site, track users’ move­ments and online activ­i­ty, and gath­er demo­graph­ic infor­ma­tion for aggre­gate use.

We may use web bea­cons on our web­site to access and set cook­ies and oth­er­wise help us to bet­ter under­stand how users are mov­ing through our web­site. Infor­ma­tion pro­vid­ed by the web bea­con includes the computer’s IP address, the type of brows­er being used, and the time that the web bea­con was viewed. We may also use web bea­cons in emails and newslet­ters so that we know when such com­mu­ni­ca­tions have been opened and to oth­er­wise help us tai­lor our com­mu­ni­ca­tions to indi­vid­ual users.

Third Party Advertising and Analytics Disclaimers.

We and/or third parties including advertising companies, social networking sites, and service providers on our behalf, use cookies, web beacons, and other similar technology to collect information for the purposes described in this Privacy Policy including advertising, analytics, online behavioral marketing, monitoring performance, and improvement of our online services (traffic, errors, page load time, popular pages, etc.).

You may opt out of behavioral remarketing as follows:

Google Analytics and Facebook Pixel. We use Google Analytics and Facebook Pixel to understand how our website, services, and products perform, how you use them, and to serve you with ads on third-party websites and social networking sites like Facebook. To learn more about how Google processes your data, please visit https://www.google.com/policies/privacy/. To opt out of Google Analytics please visit https://tools.google.com/dlpage/gaoptout. To learn more about how Facebook uses your data, please visit https://www.facebook.com/policy.php.

Advertising and Remarketing Services. We use remarketing services to inform, optimize and serve ads on third-party websites such as Facebook to you based on your use of our website and social media. To understand more about Facebook advertising and manage your preferences, please visit https://www.facebook.com/about/ads.  Login to Facebook and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app) for more information. For more information about targeted advertising and to opt out of collection of information and ad targeting from third-party websites, including Facebook and Google, please visit http://www.aboutads.info/choices. If you choose to opt out, you will continue to receive advertisements, but they will not be tailored to your interests.

Depending on your place of residence, the circumstances, and the contractual obligations in place, the above use of your information may be considered a “sale” or “sharing,” and you may have the right to request that we stop such sharing as set forth in this Privacy Policy. You may opt out of this sharing by filling out our online form available here. Please also see the “Opt-out Preference Signals” section and Annex 1 in our California Privacy Rights Act Notice, below.

Digital Advertising Alliance. You can also opt out from companies like Google, Instagram, Pinterest, Facebook and other participating companies through the Digital Advertising Alliance in the USA: http://www.aboutads.info/choices.

Retention of Personal Information.

We will retain your personal information (collected through offline and online methods) for as long as it is necessary for the purposes described in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

SECU­RI­TY

We take commercially reasonable technical, administrative, and physical security measures to pro­tect per­son­al information from loss, mis­use and unau­tho­rized access, dis­clo­sure, alter­ation or destruc­tion, whether in trans­mis­sion or stor­age includ­ing by pseu­do­nymiz­ing and/​or encrypt­ing data in cer­tain cas­es. However, we can­not guar­an­tee com­plete secu­ri­ty because no method of transmission over the Internet or method of electronic storage is 100% secure. Any infor­ma­tion that you pro­vide to us is done so entire­ly at your own risk. More­over, you are respon­si­ble for main­tain­ing the con­fi­den­tial­i­ty of any username and pass­word you use. If you have reason to believe that your interaction with us is no longer secure, please contact us at privacy@DrinkCatalyst.com.

Links to Other Websites.

Our website may contain links to third-party websites or services that are not controlled by us. This Privacy Policy only applies to information collected by us. We have no control over third-party websites or apps. Unless otherwise indicated, once you have left the website, all use of information you provide is governed by the privacy policy of the other website’s operators. Catalyst Beverage Co. is not responsible for any transactions that occur between you and a third-party website or social media account.

 

IT’S YOUR CHOICE: CON­TACT PREF­ER­ENCES AND OPT-OUT

We want to keep in touch with you in ways that you find to be ben­e­fi­cial. If you don’t want us to use your con­tact infor­ma­tion to com­mu­ni­cate with you for pro­mo­tion­al pur­pos­es, please tell us that when you pro­vide your con­tact infor­ma­tion. If you decide at a lat­er time you do not want to receive pro­mo­tion­al com­mu­ni­ca­tions, you can com­mu­ni­cate this to us by fol­low­ing the instruc­tions in the com­mu­ni­ca­tions that we may send you. You can also com­mu­ni­cate with by email­ing the email address listed on the brand page(s) where you signed up to receive communications or made a purchase requesting to be opt­ed out of such com­mu­ni­ca­tions. Keep in mind that these pref­er­ences regard­ing pro­mo­tion­al con­tacts do not mean that we might not con­tact you for oth­er rea­sons, such as those relat­ed to an order you placed, an inquiry you made, a newslet­ter to which you may have sub­scribed, a mem­ber­ship you under­took, an event for which you reg­is­tered, or a legal­ly required notice.

SMS MES­SAG­ING OPT-OUT

If you have par­tic­i­pat­ed in our gen­er­al SMS cor­re­spon­dence cam­paign, you may opt-out by tex­ting ​“STOP” to the short code pro­vid­ed in that mes­sage. Text ​”HELP” to the code for help. Mes­sage and data rates may apply.

HOW TO CON­TACT US FOR MORE INFORMATION

If you have any ques­tions about this Pri­va­cy Pol­i­cy or our infor­ma­tion prac­tices, please con­tact us by calling or calling our toll-free number at (888) 887-9141 or by email­ing privacy@​DrinkCatalyst.​com

CHANGES TO THIS PRI­VA­CY POLICY

This Pri­va­cy Pol­i­cy may be revised from time to time for any rea­son. If this Pri­va­cy Pol­i­cy changes, the revised pol­i­cy will include a new effec­tive date, and we will noti­fy you of such changes by post­ing the revised pol­i­cy on this page, which will be considered effective immediately. Any such changes will auto­mat­i­cal­ly apply to all uses of our web­site and col­lec­tion and use of your per­son­al information by us, on or after such effec­tive date (until such time as this Pri­va­cy Pol­i­cy is sub­se­quent­ly revised). If you don’t want us to use your per­son­al information accord­ing to the new pol­i­cy, don’t sub­mit your per­son­al information or vis­it our web­site. Be sure to check the Pri­va­cy Pol­i­cy when­ev­er you sub­mit per­son­al information or use our web­site.

CALIFORNIA CONSUMERS ONLY: YOUR CALIFORNIA PRIVACY RIGHTS

Last Modified: September 4, 2024

This California Privacy Rights Notice (“Notice”) provides additional information to California residents whose personal information is collected by us pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). If you are not a California resident, this Notice does not apply to you. Please visit our Privacy Policy for more information. Any capitalized terms undefined in this Notice have the same definition as the Privacy Policy.

The purpose of this Notice is to inform our web­site users, wine club mem­bers, event registrants/​participants, newsletter/​information recip­i­ents, pro­mo­tion, con­test, sweep­stakes or cam­paign par­tic­i­pants, online com­mu­ni­ty par­tic­i­pants, those who cor­re­spond with us via SMS (text mes­sage), those who pur­chase or inquire about our prod­ucts and ser­vices and other California residents from whom we may collect personal information, about our practices regarding the collection, use and disclosure of their personal information and certain rights under California law. This notice applies to both offline and online collection of personal information and applies to Catalyst Beverage Co. and our affiliates and brands.

RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, DISCLOSED OR SOLD AND SHARED

Information collected. In the preceding 12 months, we have collected the categories of personal information about California consumers as described in Annex 1 below.

Retention of Personal Information. We retain your personal information for as long as needed to fulfill the purposes outlined in the Privacy Policy and this Notice or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include our ongoing relationship with you and any financial or legal obligation to which we are subject.

Business-to-Business Information. If you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship, we collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating that business relationship. We use that information for internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship. We do not disclose that information outside our business relationship without your consent.

Information sold or shared. We have not sold any personal information to third parties for a business or commercial purpose in the preceding 12 months. Certain network activity, device information, and commercial information may be collected by third parties such as Google Analytics and Meta via cookies and pixels placed on our website which may constitute “sharing” under the CPRA. For details and how to opt out of this sharing, please see the “RIGHT TO OPT OUT OF SALE OR SHARING OF PERSONAL INFORMATION” section, below.

Information disclosed for Business Purposes. We have disclosed the following categories of personal information to third parties in the preceding 12 months:

• Personal Identifiers (such as first and last name, address, email address, telephone number, and other contact information)
• Commercial Information (such as billing information, address, or credit card number)
• Internet/Network Activity (such as domain name and browsing history)

For details regarding the categories of third parties to whom we have disclosed personal information, please see Annex 1 below.

Requests to Know. You or your designated authorized agent have the right to request that we disclose to you the following regarding the personal information we collect about you:

• Categories of personal information collected;
• Sources of personal information collected;
• The business or commercial purpose for collecting or selling/sharing personal information;
• The categories of third parties with whom we share/sell personal information; and
• The specific pieces of personal information we have collected about you over the last 12 months.

 

You also have a right to know if we have sold or disclosed your personal information for a business purpose over the past 12 months and, if so, the categories of personal information sold or disclosed and the categories of third parties to whom the personal information was sold or disclosed, along with the business or commercial purpose for which the personal information was sold or disclosed.

To make a request for any of the information set forth above (a “Request to Know”), please submit a request pursuant to the instructions below. You may only make a Request to Know twice within a 12-month period. We will acknowledge your Request to Know within 10 days and will attempt to respond substantively within 45-90 days.

The Request to Know must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. You may be asked to provide additional proof of identification so that we can verify your identity and validate the request. If we cannot verify your identity, we may decline to honor your request.

You or your designated authorized agent can make a Request to Know the personal information we have about you by filling out our online form available here or calling us at 1-800-400-6628.

RIGHT TO KNOW ABOUT SENSITIVE PERSONAL INFORMATION COLLECTED

We collect and use your sensitive personal information as described in Annex 1 below.

We do not collect or process sensitive personal information for the purpose of inferring characteristics.

RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION

You or your designated authorized agent have the right to request deletion of your personal information collected or maintained by us (“Request to Delete”), subject to certain exceptions permitted by law.

To make a Request to Delete, please submit a request pursuant to the instructions below. We will acknowledge your Request to Delete within 10 days and will attempt to respond substantively within 45-90 days.

The Request to Delete must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. You may be asked to provide additional proof of identification so that we can verify your identity and validate the request. If we cannot verify your identity, we may decline to honor your request. Additionally, as permitted by law, if the information requested to be deleted is necessary for us to maintain, we will not be able to comply with your request. We will notify you if this is the case.

You or your designated authorized agent can make a Request to Delete the personal information we have about you by filling out our online form available here or calling us at 1-800-400-6628.

We will retain correspondence, documents and information related to any Request to Know, Request to Delete, or Request to Opt Out for 24 months as required by law.

RIGHT TO OPT OUT OF SALE OR SHARING OF PERSONAL INFORMATION

You have the right to opt out of the sale or sharing, as defined by the CPRA, of your personal information. We do not and will not sell your personal information. As explained in Annex 1 below, we share your data with third parties such as social networking sites and advertising companies in order to serve you with ads tailored to your preferences across various platforms.

Opt-out Form. You may opt out of the sharing of your personal information by filling out our online form available here.

Opt-out Preference Signals. We honor opt-out preference signals that you enable (i.e., Global Privacy Control). Opt-out preference signals are plug-ins available in certain browsers that signal to websites you visit of your preferences to opt out of the sale and sharing of certain personal information. You can learn more here: https://globalprivacycontrol.org/. If you have enabled an opt-out preference signal device from your browser, we will not sell or share your personal information without first seeking your explicit consent. Adjusting your settings to enable Global Privacy Control will only opt out of any sharing activity on the browser and device you are using. We may continue to collect and share personal information about you with other third parties, including to continue providing services to you where sharing of your personal information is for purposes other than targeted advertising and is permitted by law. Our website does not respond to Do Not Track signals because there are no common, industry accepted “do not track” standards and systems.

This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third parties to learn about their privacy practices.

Cookies. As explained in our “How We Use Cookies and Other Technology” section, you can opt out of cookies using your brokers. Please note:

• Opt-outs are device- and browser-based. You must opt out on each device and each browser where you want your choice to apply.
• Opt-outs may be stored via cookies. If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.
• We may still share your personal information with our services providers that help us perform functions that are necessary for our business such as vendors that host our website, credit card processors and analytics processors. These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.
• You may still receive ads from us that are not tailored to your interests.

Additional Options to Opt Out of Sale or Sharing.

In addition to the above options to opt out of the sale or sharing of your information under the CPRA as described above, you have controls and choices with respect to collection and use of your information by third parties. These are summarized for you below. We do not control or maintain opt-out mechanisms for third-party companies and are not responsible for their operation.

Advertising Opt Out. You can opt out of sharing your information with third-party companies engaged in targeted advertising including social networking sites such as Google and Facebook using the following tools: For websites: http://optout.aboutads.info/?c=2&lang=EN. For mobile apps: http://www.aboutads.info/appchoices.

Google Opt Out. If you would like to opt out of Google Analytics and Ads, you can. If you are on the web, you can opt out of Google Analytics by installing Google’s Opt Out browser add on: https://tools.google.com/dlpage/gaoptout, and you can opt out of interest-based Google ads using https://adssettings.google.com/u/0/authenticated.

Facebook Ad Preferences. To understand more about Facebook advertising and manage your preferences, please visit https://www.facebook.com/about/ads. Login to Facebook and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app) for more information.

RIGHT TO CORRECT

You or your designated authorized agent have the right to request that we correct in our records inaccurate information about you. To make a request to correct inaccurate information about you (a “Request to Correct”), please submit a request pursuant to the instructions below. We will acknowledge your Request to Correct within 10 days and will attempt to respond substantively within 45-90 days.

The Request to Correct must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. You may be asked to provide additional proof of identification so that we can verify your identity and validate the request. If we cannot verify your identity, we may decline to honor your request.

You or your designated authorized agent can make a Request to Correct the personal information we have about you by filling out our online form available here or calling us at 1-800-400-6628.

We will retain correspondence, documents, and information related to any Request to Correct for 24 months as required by law.

OTHER CALIFORNIA PRIVACY RIGHTS

Shine the Light Disclosure Information. Although we don’t disclose to any third parties for direct marketing purposes any of your personal information, you are entitled to receive the following disclosure. If you are a resident of California, you can request a notice identifying the categories of personal information, as defined by California Civil Code Section 1798.83, we share with our affiliates and/or third parties for their direct marketing purposes and the contact information for such affiliates and/or third parties. Please submit your request to Privacy@DrinkCatalyst.com.

Right to Non-Discrimination. If you choose to exercise any of the rights detailed in this Notice, we will not discriminate against you in any way as a result of that exercise, including by offering you different pricing or products or by providing you with a different level of quality of products.

Notice of Financial Incentive. We may offer you certain programs, benefits, or other offerings related to the collection or retention of personal information that may be deemed a “financial incentive” under the CCPA that can result in different prices, rates, or quality levels. Consumers who elect to participate in financial incentive programs (such as reward programs, limited-time promotions, sweepstakes, or contests) may be asked to provide personal information such as your name, email address, physical address, and/or phone number. We may also collect commercial information such as credit card number and payment information (in limited circumstances), details of transactions that you carry out through our services, including products purchased or considered, and wine club information from consumers who elect to participate in a rewards program. Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your personal information 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.

 

Annex 1

Category	Examples	Collected From	Purposes	Disclosed to	Sold or Shared
Identifiers Commercial Information	Birthdate, name, age gender, email address, mailing address, telephone number, social media handle and images. Credit card number and payment information, in limited circumstances, details of transactions that you carry out through our services, including products purchased or considered, wine club information.	You, through a transaction, interaction, inquiry, or other communication with us. Third-party sources including third-party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals. Our third-party providers are bound by confidentiality obligations and are restricted to only using the data to provide our business with applicable services.	To respond to or follow up on your comments, inquiries, or requests and communicate with you about your account, our services, and products that may be of interest; To process transactions, contact you regarding your order, and deliver products to you; To improve our products, services, and website and to develop new products and services; To send promotional communication or offers to you (unless you have requested that we do not); For marketing, research, legal, and other business purposes; To comply with our policies, procedures, and financial and legal obligations.	Business partners and service providers who perform functions on our behalf (e.g., hosting or operating our services, processing credit card payments, sending marketing communications, carrying out contests and sweepstakes, special offers, or promotions, processing job applications, data analysis, website and app metrics and analytics, providing fraud detection services, and other business support services) who have agreed to keep the information confidential and use it only to provide the applicable services; Third-party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics, targeted advertising, or behavior remarketing, as explained in our Privacy Policy; Third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests.	N
Audio/visual information	Video recordings of you when you visit one of our locations or call recordings when you call for customer service.	You, through a transaction, interaction, inquiry, or other communication with us.	For legal and other business purposes; To comply with our policies, procedures, and financial and legal obligations.	Consultants, service providers, and contractors that we use to support our business and operations (e.g. providing security or fraud detection services) who have agreed to keep the information confidential and use it only to provide the applicable services; and Other parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests.	N
Network activity Device information Geolocation data	IP address, your device identifier, domain name, browsers you used to access our website and services, webpages viewed, time spent on webpages, links clicked, search terms used, usage patterns, transactions entered into and site-navigation patterns. We may also collect general geolocation data from your device with your consent in accordance with applicable law. If you do not consent to collection of this information, certain services such as personalized location-based services and content will not function properly. You can stop our collection of location data at any time by changing the preferences on your mobile device.	Your online activities and interactions with us, including on our social media channels or through our third-party sources. Third-party sources including third-party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals. Our third-party providers are bound by confidentiality obligations and are restricted to only using the data to provide our business with applicable services.	To analyze and track usage of our services and products including our website and social media accounts; To provide location-based services and content; To improve our website, services, and products, and tailor them to your preferences; To send promotional communications or offers (unless you have requested that we not send such communications); and For other marketing, research, legal, and other business purposes.	Business partners and service providers that we use to support our business and operations; Third-party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics, targeted advertising, or behavior remarketing, as explained in our Privacy Policy; Third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests.	N
Network activity Device information Commercial information	IP address, your device identifier, domain name, browsers you used to access our website and services, webpages viewed, time spent on webpages, links clicked, search terms used, usage patterns, transactions entered into and site-navigation patterns. Commercial information limited to products purchased, viewed, or considered.	Your online activities and interactions with us, including on our social media channels or through our third-party sources. Third-party sources via cookies and pixels placed on our website. Depending on the circumstances and the contractual obligations in place, this sharing may be considered a “sale” or “sharing” under the CCPA and you may have the right to request that we stop such sharing as set forth above. Please see the section in the Notice above titled “Opt-out Preference Signals.”	To analyze and track usage of our services and products including our website and social media accounts; To serve you personalized ads or customized offers to improve your shopping experiences on our website or elsewhere; and For other marketing, research, legal, and other business purposes.	Third-party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics, targeted advertising, or behavior remarketing, as explained in our Privacy Policy. .	Y
Sensitive personal information	Certain personal information we collect may be considered sensitive personal information under the CCPA, including: account or debit/credit card information for billing and transactional purposes; driver’s license or other identification card numbers for identity verification purposes; and geolocation data as discussed above. We only use and disclose sensitive personal information as necessary in connection with the performance of services, provision of products, and in accordance with the law. We do not collect your sensitive personal information to infer characteristics about you.	You, through a transaction, interaction, inquiry, or other communication with us. Your online activities and interactions with us, including on our social media channels or through our third-party sources.	To process transactions, contact you regarding your order, and deliver products to you; To provide location-based services and content; To authenticate your account credentials and identify you, as necessary to log you in and/or ensure the security of your account; To comply with our policies, procedures, and financial and legal obligations; For legal and other business purposes that do not involve inferring characteristics about you.		N
Business-to-business information	We collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating that business relationship.	From you, as a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship.	For internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship.	We do not disclose this information outside our business relationship without your consent.	N