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Privacy Policy

DIGITAL BEVERAGE GROUP WEBSITES PRIVACY POLICY


Updated as of December 19th, 2022


I. INTRODUCTION TO DIGITAL BEVERAGE GROUP WEBSITES PRIVACY POLICY


Digital Beverage Group (”DBG", “we”, “our” or “us”) recognizes that privacy is a concern for our customers and users of our Websites, so we have established the following privacy policy (this “Privacy Policy”) for our customers and users. This Privacy Policy describes how DBG will collect, use, share and store your Personal Information that we collect in connection with your use of our website, including but not limited to lastbottlewines.com, lastbubbles.com firstbottlewines.com, invino.com, the Last Bottle Wine app, WineBid, Global Storage Network, and any other website or app operated by entities within Digital Beverage Group, Inc. (collectively, the “Websites”).


For purposes of this Privacy Policy, “Personal Information” is information relating to an identified or identifiable individual. For purposes of this Privacy Policy, Personal Information does not include de-identified or aggregated information and, to the extent permitted by law, does not include publicly available information from government records.


This Privacy Policy does not apply to (i) Personal Information collected when you apply for a job with DBG, (ii) Personal Information collected from employees or contractors of DBG, and (iii) Personal Information collected within the business-to-business context.


This Privacy Policy forms part of our Terms and Conditions. Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in Terms and Conditions.


II. PERSONAL INFORMATION COLLECTED BY DBG


In order to provide you with the benefits of using our Websites, DBG collects certain information from you and your devices. By using the Websites or otherwise providing Personal Information to DBG, you consent to our collection, use, and sharing of the data described in this Privacy Policy.


Personal Information that You Provide to Us


We may collect certain types of Personal Information about you in a variety of ways, depending on your interactions with us, including:


Contact Information:  Contact Information includes information you provide when you purchase products on our Websites, subscribe to our mailing list, refer-a-friend, purchase gift cards, participate in surveys or contests, or inquire about our products. Examples include name, shipping address, e-mail address, phone numbers (home and mobile), and date of birth.


Account Login Information: Account login information includes information you provide when you register for an account on our Websites such as your name, e-mail address, mobile phone number, date of birth, and password used to create an account on our Websites.


Payment Information: Payment information includes name, billing address, credit and/or debit card number, CVV2, and expiration date.


Transactional History: Transactional history includes information such as your order number and products purchased.


Information Collected from Your Browser or Device


We may automatically collect your IP address or other unique identifier (“Device Identifier”) from the computer, mobile phone, tablet or other device (“Device”) you use to access the Websites. A Device Identifier is a number that is assigned to your Device when you access a website or its servers, and our computers identify your Device by its Device Identifier. We, and our third-party service providers and business partners may use a Device Identifier to, among other things, administer the Websites; help diagnose problems with our servers; analyze trends; and track users’ web page movements over time.


In addition, we may automatically gather and store certain information about your visit from your browser or Device, such as your mobile network information, device type and hardware model, browser type, operating system type, and  Internet Service Provider (ISP). We may collect this information through the use of server log files and other methods.


Information Collected Using Cookies and Other Tracking Technologies


We use certain technologies on the Websites to collect information about how the Websites are accessed and used (“Usage Information”).  Usage Information may include browser type, device type, operating system, application version, the page served, the time, the preceding page views and your use of features on the Websites. This information helps us keep our Websites fresh and interesting for our visitors and allows us to tailor content to a visitor's interests. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.


The technologies used on the Websites to collect Usage Information, including Device Identifiers, include but are not limited to: cookies (data files placed on a Device when it is used to visit the Websites), mobile analytics software and pixel tags (transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a web page or in an email, which indicates that a page or e-mail has been viewed). We, or our third-party service providers, may place cookies or similar files on your Device for security purposes, to facilitate site navigation,  to personalize your experience while visiting our Websites, and for marketing purposes.


Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. However, please be aware that some features of the Websites may not function properly or may be slower if you refuse cookies. In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests. If you block or delete cookies, not all of the tracking that we have described in this Privacy Policy will stop.


When you visit or log in to our website, cookies  and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address.  We (or service providers on our behalf) may then send communications and marketing to these email or home addresses.  You may opt out of receiving this advertising by visiting https://app.retention.com/optout.


Third Party Analytics Provider. We use Google Analytics to learn more about the types of users that visit the Websites and to help improve the Websites. For example, Google Analytics provides us with certain data regarding the demographics of the users that visit the Websites.  To provide this service, Google Analytics may collect certain information about you from your computer, including but not limited to: information regarding your visit (such as the pages you visit and the length of your visit), information about your device (such as your IP address), how you got to the website, and other information about you. You can learn more about Google Analytics and how it collects and processes data (including how to control the information sent to Google) by visiting: www.google.com/policies/privacy/partners/.  You can opt-out of Google Analytics, here: https://tools.google.com/dlpag...  (this requires you to install an add-on to your browser).


Do Not Track Disclosure. Certain web browsers may provide you an option for your browser to inform websites you visit that you do not wish to have your activities tracked by cookies or other persistent identifiers, commonly called “Do Not Track Signals.” The Websites currently do not respond to Do Not Track Signals.


III. HOW WE USE THE INFORMATION WE COLLECT


We may use the Personal Information we collect from you for a variety of purposes such as to:


- Respond to your inquiries, questions and requests;


- Process your orders;


- Provide and deliver the products that you purchased;


- Send information such as offers, updates or news regarding the Websites and our products;


- Send promotional, marketing and advertising communications that we believe may be of interest to you;


- Contact you regarding certain programs or offerings that you may have registered for;


- Communicate with you about your account and activities on the Websites and, in our discretion, changes to any DBG policy or notice;


- Authenticate your access to parts of the Websites that you are authorized to access;


- Manage and operate the refer-a-friend program;


- Operate, improve, maintain, administer and provide the Websites;


- Manage our business, including performing accounting, auditing, and other internal functions;


- Evaluate and improve our products, conduct research and perform analysis, learn more about our users and customers, and enhance the customer experience, including to better optimize and target our marketing;


- Comply with applicable laws and regulatory requirements, or as requested by government or regulatory authorities;


- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity;


- Protect and defend the rights or property of DBG; and


- For purposes disclosed at the time you provide your Personal Information or otherwise with your consent.


IV. HOW WE SHARE INFORMATION


We may also share your Personal Information as disclosed at the time you provide your information, as set forth in this Privacy Policy and in the following circumstances:


Third Parties Providing Services On Our Behalf: We may share your Personal Information with third parties that perform functions on our behalf, such as service providers and vendors that host or operate our Websites, process payments, ship our products, analyze data, store data on our behalf, or for other processing needs.


Our Affiliates: We may share your Personal Information with other entities and our affiliates primarily for business and operational purposes.


Business Transfers: In the event that DBG is involved in a bankruptcy, merger, acquisition, reorganization, sale of assets or any other business combination transaction (regardless of structure), your information may be sold or transferred as part of that transaction.


Legal Disclosure: We may transfer and disclose your information to third parties to comply with a legal obligation; when we believe in good faith that the law or a governmental authority permits or requires it; to verify or enforce our Terms and Conditions or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect our rights or property or security of third parties, visitors to our Websites or the public.


We may also share non-Personal Information, such as anonymous information or aggregate data, with third parties for any purpose.


V. OPTING-OUT


You may receive email communications from DBG and other entities within Digital Beverage Group, Inc., including communications regarding the Websites, marketing, or promotions, and/or other topics. We may use the information you provide to us to contact you, including email address, address, and/or phone number.  You may also opt-out of promotional email communications by clicking on a link provided in the promotional email message. After opting-out, you will no longer receive marketing or promotional communications but will continue to receive other non-marketing-related messages, such as emails relating to your orders, your account, or your use of the Websites.


VI. YOUR CALIFORNIA PRIVACY RIGHTS; ACCESS, CORRECTION, AND DELETION OF YOUR PERSONAL INFORMATION


For California Residents: If you are a California resident, you may request, once per calendar year, certain information regarding our disclosure of your Personal Information to third parties for their own direct marketing purposes. To make such a request, you may contact us at: [email protected]


Please provide adequate details regarding your request. We may ask you for additional information to verify your identity. Please note, we have not made any disclosures of Personal Information to third parties for their own direct marketing purposes in the last twelve months.


Access, Correction, and Deletion of Your Personal Information: If you would like to access, delete or correct certain Personal Information that we may have collected about you, please log into your account via the Websites.


Deleting Your Account: When you terminate your account, we delete your purchase history, profile, and any information you have provided in your profile (including your name, email, password, billing information, and shipping addresses). Account deletion is permanent, and you will be unable to log back in after it has been completed. If your account has been terminated for a breach of our Terms & Conditions, you will be prohibited from creating a new account. If you would like to delete your account for any reason, you can do so by contacting us at [email protected]. Please include your name and log-in email, with subject line "Last Bottle Wines Account Deletion". We will respond to your email within ten business days to confirm that your account has been successfully deleted.


VII. UNDERAGE PERSONS


The Websites is not directed to individuals under the age of 21. DBG does not knowingly collect, use or disclose Personal Information from anyone under 21 years of age. We do not allow anyone under the age of 21 to register for an account on our Websites.


VIII. SECURITY OF YOUR INFORMATION


We take information security seriously and implement administrative, technical, and physical safeguards to help protect your Personal Information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Websites and provide us with your information at your own risk.


IX. OTHER SITES


The Websites may include links to other websites that we do not own or operate. We do not control, recommend or endorse and are not responsible for these sites or their content, products, services, or privacy policies or practices. These other sites may send their own cookies to your Device, they may independently collect data or solicit Personal Information and may or may not have their own published privacy policies. We encourage you to become familiar with the  privacy policies and terms of use for these sites before sharing your personal information with them.


X. CONSENT TO PROCESSING AND TRANSFER OF INFORMATION


DBG is located in the United States and our Websites are operated in and governed by the laws of the United States. Our Websites are not directed to individuals located outside of the United States. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect may be transferred to and processed in the United States. By using the Websites, or providing us with any Personal Information, you (a) acknowledge that the Websites are subject to the laws of the United States, (b) consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen, and (c) waive any claims that may arise under those laws.


XI. UPDATES TO PRIVACY POLICY


We may update this Privacy Policy from time to time to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.


XII. CONTACT US


If you have any comments or questions regarding this Privacy Policy, please contact us at [email protected].

If you have any questions about the security of our website, please feel free to contact us at [email protected].