Last Changes to Privacy Policy: November 17, 2022

WhiskeyShelf LLC (collectively “WhiskeyShelf” or “we”, “us”, or “our”) is strongly committed to protecting the privacy of your personal information when you interact with the WhiskeyShelf.app website and mobile applications (“Sites”). This privacy policy (“Privacy Policy”) explains the kinds of information we may gather from your use of the Sites; why we gather your information; what we use your personal information for; when we might disclose your personal information; and how you can manage your personal information. We also include specific disclosures for residents of the European Economic Area, UK, and Switzerland, as well as California. This Privacy Policy applies to WhiskeyShelf’s websites, mobile applications, emails we send, as well as information we collect when you interact with us through our services and other websites.

By visiting the Sites, you are accepting the practices described in our Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use the Whiskey Shelf Site or mobile apps. We reserve the right to modify or amend the terms of our Privacy Policy from time to time without notice. Your continued use of the Sites and our affiliate websites following the posting of changes to these terms will mean you accept those changes. If we intend to apply the modifications or amendments to this Privacy Policy retroactively, we will provide you with notice of the modifications or amendments.

If you have any questions about this Privacy Policy or don’t see your concerns addressed here, you should contact us by email at support@whiskeyshelf.app.

What Information About Me Is Collected and Stored?

Information We Collect Automatically

When you interact with the Sites, certain information about your use of the Sites is automatically collected. Much of this information is collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device. Any or all activities with regard to collecting usage information may be performed on our behalf by third-parties (see Additional Information About Third Party Cookies below). This includes:

• Details of your visits to the Sites and information generated in the course of the use the Sites including, but not limited to, server data, search terms and results, server logs and other communication data, the resources that you access, and how you reached the Sites.
• Details regarding the device you use to access the Sites, including, where available, your IP address, operating system, and browser type.
• Information about how you interact with our ads, newsletters and email notifications, including whether you open or click links in any correspondence.

How We Use and Share Your Information? We may use the information we collect from you for the following purposes:

• To help us personalize and continually improve your experience on the Sites so we can provide you with the best service and grow our business.
• To communicate with you, including responding to your inquiries, fulfilling your requests, and sending you information about products, services, and promotional offers.
• To share your interests in obtaining or sharing certain products with users who have expressed the similar interests.
• To analyze website usage and enhance the operation of the Sites.
• To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal.
• To enable third parties to carry out technical, logistical or other functions on our behalf.

Sharing of Aggregated Data

We may create analyses using aggregated, de-identified data and share these analyses at our discretion to provide statistical “ratings” information and pricing information to our users, partners and other third parties about how our users collectively use the Sites and attributes about the items they are entering into the Sites. We may also use or share aggregated data (or other information, other than personal information) in any other manner that we deem appropriate or necessary. These third parties will not be able to relate this data to identifiable individuals.

Third-Party Agents

We engage third party service providers to perform functions on our behalf such as: hosting, content management, analytics, anti-scraping prevention, etc. Third Party Agents are restricted from using, selling, distributing or altering data in any way other than to provide the requested services to the Sites. Law Enforcement and Legal Process We may also use or disclose information about you if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Sites; (b) protect and defend our rights or property, the Sites or our users, and (c) act under emergency circumstances to protect our personal safety or the personal safety of our affiliates, agents, the users of the Sites, or the public.

Social Media Platforms

Where you choose to interact with us through social media, your interaction with these programs typically allows the third party to collect some information about you through cookies they place on your device and other tracking mechanisms. In some cases, the third party may recognize you through its cookies even when you do not interact with their application. Please visit the third parties’ respective privacy policies to better understand their data collection practices and controls they make available to you.

What Happens When I Link To or From Another Website?

The Sites may contain links to other websites operated by affiliates of WhiskeyShelf or third parties. Please be advised that the practices described in this Privacy Policy for WhiskeyShelf do not apply to information gathered through these other websites. These other websites may also send their own cookies to you, collect your data or solicit your personal information. We are not responsible for the actions and privacy policies of third parties and other websites. We encourage you to be aware of when you leave the Sites and read the privacy policies of each and every website that you visit.

Change of Ownership or Corporate Organization

We may change ownership or corporate organization while providing the Sites and services. As a result, please be aware that we may transfer your information to another service that is affiliated with us or with which we have merged. Under such circumstances, WhiskeyShelf would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy, as it may be amended from time to time.

Transfer of Data

If you use the Sites outside of the United States, you understand that we may collect, process, and store information about you in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your country. Any such transfers will comply with safeguards as required by relevant law. By using the Sites, you consent to the collection, international transfer, storage, and processing of your data.

What Steps Are Taken To Keep Personal Information Secure?

We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Sites. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you. While we use these precautions to safeguard your personal information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

Governing Law

The Sites are published in the United States of America. We make every effort to protect the personal information of all users of the Sites. We attempt to comply with local data protection and consumer rights laws to the extent they may apply to the services.

How Do I Opt-Out or Correct Information About Me

You may always opt-out of receiving future e-mail messages and newsletters from WhiskeyShelf. We provide you with the opportunity to opt-out of receiving communications from us by modifying your notification settings at https://www.whiskeyshelf.app/ or in the Settings on the WhiskeyShelf app. We also give you access to a broad range of information about your account to permit you to correct or update personal information that you have previously provided to us in the settings of your WhiskyShelf app. You can also send us a message at support@whiskeyshelf.app.

Additional Information About Third Party Cookies

WhiskeyShelf relies on partners to provide many features of the Sites and services. In order to do this, we provide our partners with data about your use of the Sites and other websites.

We use cookies for the following purposes:

• Site Operations: Enabling features that are necessary for providing you the services on the Sites, such as identifying you as being signed in, remembering your preferences and recent searches, and the number of times you have been shown an advertisement.
• Analytics: Allowing us to understand how our services are being used, track site performance and make improvements.
• Personalized Advertising: Delivering tailored advertising based on your preferences or interests across services and devices and measuring the effectiveness of ads.

The personal information from the following users is not provided to our partners for the purposes of personalized advertising:

• Users in the EEA, UK, Switzerland and California;
• Users who are actively logged on to the Sites; and
• Users who only use our mobile app.

Below is a list of these partners with links to more information their use of your data and how to exercise your options regarding tracking.

Category Partner Further Information Analytics,

Personalized Google How Google uses information from sites or apps that use our services Advertising

Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the services may not be available, work, or work as designed. You can learn more about ad serving companies and the options available to limit their collection and use of your information by visiting the websites for the Network Advertising Initiative, the European Interactive Digital Advertising Initiative. Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device.

Please note that opting-out of advertising networks services does not mean that you will not receive advertising while using the Sites or on other websites, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. If you delete your cookies, you may also delete your opt-out preferences.

Users in the European Economic Area, UK and Switzerland

If you are a resident of the EEA, UK or Switzerland, the following information applies:

Purposes of processing and legal basis for processing: We process personal data in various ways depending upon your interaction with the Sites. We process personal data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide our services; and (3) as necessary for our legitimate interests in providing the Sites and our services where those interests do not override your fundamental rights and freedom related to data privacy.

Right to lodge a complaint: Users that reside in the EEA, UK or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.

Transfers: Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. We will ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described above.

Your Rights: Residents of the EEA, UK and Switzerland are entitled to rights with respect to the processing of your personal information, including rights to request erasure of personal information or object to our processing of personal information. In order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you. With respect to these rights, you should contact us by email at support@whiskeyshelf.app. We may have a reason under the law why we do not have to comply with your request, or may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Your California Privacy Rights

California Shine the Light Residents of the State of California have the right to request certain information regarding its disclosure of personal information to third parties for the third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please send an e-mail to support@whiskeyshelf.app

California Consumer Privacy Act The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to know/access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”

To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below. We do not engage in any disclosures that would be considered sales of data for California residents under the CCPA at this time.

Notice at Collection Regarding the Categories of Personal Information Collected You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. The categories we use to describe the information are those enumerated in the CCPA.

Our practices regarding disclosure of your Personal Information are described below:

Personal Identifiers:

• We collect your email, name, city, state and zip code that you live in, as well as your email address when you create an account or complete a transaction. If you create an account, you will also be asked to create a username, and we will assign one or more unique identifiers to your profile. We use this information to provide the Sites, respond to your requests, and send information about products, services, and promotional offers to you.
• We collect your purchasing information such as date purchased, location purchased from and purchase cost for items.
• We collect your social media handle and basic account information when you interact with our Sites through social media.
• You may submit payment information to us through our website, which may include your credit card number, when you complete a transaction. This information is transmitted directly to our payment card processor, and we do not store it.
• We collect your IP address automatically when you use our Sites. We use this information to identify you, gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and serve targeted advertisements based on your online activities.
• We collect your device id automatically when you use our Sites. We use this information to monitor your use and the effectiveness of our Sites, to identify you, and to prevent fraud.

Commercial Information: When you engage in transactions with us, we create records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies. We use this information to measure the effectiveness of our Sites and to provide you with targeted information, advertisements and offers.

Internet or Other Electronic Network Activity Information: We collect information about your browsing history, search history, and interactions with websites, and/or applications advertisements automatically when you utilize our Sites. We use this information to gauge online activity on our website, measure the effectiveness of online services, applications, and tools.

Geolocation Data: As described above, we collect your IP address automatically when you use our Sites. We may be able to determine your general location based on the IP address. We do not collect your precise location (e.g., your GPS coordinates). We do collect the precise location from stores where you have purchased items entered into the Sites.

We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected, as described in the How We Use and Share Your Information section above.

Right to Know About Personal Information Disclosed or Sold

You have the right to request that we disclose to you the Personal Information we disclose or sell. We may share purchase information, inventory data or your zip code/general location with other users or Service Providers, which are companies that we engage for business purposes to conduct activities on our behalf. Service Providers are restricted from using Personal Information for any purpose that is not related to our engagement. The categories of Service Providers with whom we share information and the services they provide are described in our Privacy Policy above in the section titled “Third-Party Agents.”

To “sell” information means to disclose it to a company for monetary or other benefit. A company may be considered a third party either because the purpose of sharing is not an enumerated business purpose under California law, or because our contract does not restrict them from using Personal Information for other purposes. We do not engage in any disclosures that would be considered sales of data for California residents under the CCPA at this time.

Right to Know/Access Information You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. You may submit such a request as described below. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request.

Right to Request Deletion of Information You have the right to request in certain circumstances that we delete Personal Information that we have collected directly from you. Some Personal Information is required for you to use the Sites. You may submit such a request as described below. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

How to Submit a Request You may submit a request to exercise your rights to know/access or delete your Personal Information or Account through one of two means:

• By emailing us at support@whiskeyshelf.app
• By requesting to delete your account from the Update Profile page on the Whiskey Shelf Mobile app.

Verification Procedures in order to process your request to delete your Account or delete Personal Information  we collect, disclose, or sell, we must verify your request. We do this by asking you to:

• send us an email from the email address associated with your account; or
• confirm your request using the email address associated with the account stated in the request.

Authorized Agent You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require the authorized agent to provide proof that you have authorized them to act on your behalf.

Changes to This Policy We may make changes to this Privacy Policy from time to time. We will post any changes, and such changes will become effective when they are posted. Your continued use of the Sites following the posting of any changes will mean you accept those changes.

We recommend that you read this Privacy Policy each time you use the Sites in case you missed our notice of changes to the Privacy Policy. We will never materially change our policies and practices to make them less protective of customer information we have previously collected without your express consent.

Updated February 13, 2023