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 * Privacy Policy


PRIVACY POLICY

Effective Date: July 1, 2023

Retail Services & Systems, Inc. and affiliated companies doing business under
Total Wine & More brands and associated brands (“Total Wine,” “we,” “our,” or
“us”) know that you care how information about you is used and shared, and we
appreciate your trust that we will do so carefully and sensibly. This Privacy
Policy lets you know what information we collect, how we may share that
information, and your choices regarding the sharing of your information. Please
note, our privacy practices are subject to the applicable laws of the places in
which we operate. You will see additional region-specific terms that only apply
to customers located in those geographic regions, or as required by applicable
laws.

You are subject to our Terms & Conditions, which govern your access to and use
of the Total Wine & More Sites (defined below). Click Terms & Conditions for
more information.


PRIVACY POLICY TABLE OF CONTENTS

 1.  Our privacy commitment
 2.  What our Privacy Policy covers
 3.  Acceptance of and changes to this Privacy Policy
 4.  Personal information we collect and use
 5.  How we collect personal information
 6.  Notice of cookies & clickstream technology, including opting out
 7.  How we use your Personal Information
 8.  Security of your personal information
 9.  How we disclose your personal information
 10. Your rights related to Personal Information held by us
 11. Additional notice to California residents
 12. Our response to requests
 13. Non-discrimination policy for exercising your privacy rights
 14. Notice of financial incentive
 15. Retention
 16. Updating your personal information
 17. E-mail & account registration
 18. Children’s and minor’s privacy
 19. Nevada privacy notice
 20. How to contact us




1. OUR PRIVACY COMMITMENT

We value the relationship we have with our customers and prospective customers,
and we are committed to protecting the confidentiality, accuracy, and integrity
of your Personal Information, meaning any information that identifies, relates
to, describes, is capable of being associated with, or could reasonably be
linked, directly or indirectly with a particular consumer or household. Personal
Information does not include deidentified or aggregate information, or public
information lawfully available from governmental records. We understand the
importance of keeping your Personal Information secure.




2. WHAT OUR PRIVACY POLICY COVERS

This Privacy Policy covers our customer-facing operations and applies to
Personal Information collected from and about prospective customers and
customers of businesses that operate retail liquor stores under Total Wine &
More brands and associated brands in various states, whether collected at a
retail location (a “Store”) or from the Total Wine & More website, webpages,
mobile site, and/or app (the “Sites”).

We may provide different or additional privacy notices in connection with
certain activities, programs, and offerings. We may also provide additional
“just-in-time” notices that may supplement or clarify our privacy practices or
provide you with additional choices regarding your personal information.
 California residents who are job applicants for work in any of our businesses
operating in the United States are subject to a different privacy policy
regarding the information collected during the application process and any
employment. See the Job applicant terms & conditions page for more information.

Our Sites may include links to websites and/or applications operated and
maintained by third parties. Please note that we have no control over the
privacy practices of websites or applications that we do not own. We encourage
you to review the privacy practices of those third parties.




3. ACCEPTANCE OF AND CHANGES TO THIS PRIVACY POLICY

As Total Wine continues to improve the services, products, and features we
provide, this Privacy Policy is subject to change. We reserve the right to amend
this Privacy Policy at any time by posting the amended policy on the Sites and
updating the Effective Date at the top of this page.

By using the Total Wine site and services, you signify your acceptance of this
Privacy Policy. If you do not agree with any position or statement herein, your
sole option is to discontinue use of the Store or Sites. Your continued use of
any portion of the Stores or Sites following notification or posting of such
changes constitutes your acceptance of those changes. If you have questions or
concerns about our specific policies, please send an e-mail
to privacy@totalwine.com




4. PERSONAL INFORMATION WE COLLECT ABOUT YOU

Total Wine collects your Personal Information (including individuals associated
with you, all of whom are referred to as “you” in this Privacy Policy) in its
normal course of business and over the course of your relationship with us.  We
may collect (and may have collected during the 12-month period prior to the
effective date of this Statement) the following categories of personal
information about you: 

 * Identifiers, such as name, alias, delivery address, delivery signature,
   postal address, phone number, email address, date of birth, age or age range,
   IP address, unique personal identifier, online identifier, and other similar
   unique identifiers, certain of which are described in the “Cookie Policy”
   below
 * Characteristics of protected classifications under California or federal law,
   such as age (over 40); gender identity or gender expression; marital status;
   military or veteran status; or disability information.
 * Commercial information, such as transaction history, purchase history or
   tendencies, last 4 digits of credit cards, &MORE Rewards or awards purchases,
   points, and benefit utilization, returns data, product delivery data, product
   or service ratings, product or service reviews, and email or mail subscriber
   status.
 * Internet or other similar network activity, such as search history and
   information about consumer’s interaction with an Internet website,
   application, or advertisement.
 * Geolocation Information, such as presence at a retail location, billing
   information, product delivery information, or “Preferred Store” election on
   website or application.
 * Audio or video footage collected using CCTV cameras, (only if you visit one
   of our premises that uses this technology) or Customer Service phone call
   recording.
 * Job applicant information, such as education, employment, or other
   professional information.  See the Job applicant terms & conditions page for
   more information.
 * Inferences drawn from Personal Information for purposes of creating a profile
   about a consumer reflecting the consumer’s preferences, characteristics,
   psychological trends, preferences, predispositions, behavior, and attitudes.
 * Sensitive Personal Information.  We may collect minimal sensitive personal
   information, as defined in the applicable state privacy laws, but only with
   your consent.  Such minimal sensitive personal information consists of
   account passwords used to access the Sites, which are encrypted and
   inaccessible to the Total Wine in the ordinary course of business. We do not
   use sensitive personal information for inferring characteristics about you.




5. HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect personal information about you from various sources.  For example, we
collect and obtain information:

 * Directly from you, such as when you visit our Sites, manually enter Personal
   Information into our Sites’ forms to place a delivery order or join the &MORE
   Rewards program, or when you post on-line to a social media account.
 * Indirectly from you. For example, from observing your actions on our Sites.
 * Affiliated Companies and Service Providers that process information for us,
   such as third-party social networking providers, tech or customer support,
   operations, web or data hosting, billing, credit card processing, accounting,
   security, marketing, or data management, validation, enhancement, or hygiene.
   For example, we get updated addresses from the National Change of Address
   (“NCOA”) service to ensure we have the correct contact information for our
   customers.
 * Consumer data resellers and renters, such as entities that compile Personal
   Information about prospective or current Total Wine customers for purposes of
   updating, verifying or deduplicating Personal Information, or prospecting new
   potential customers.
 * From publicly available sources. For example, online database searches.




6. NOTICE OF COOKIES & CLICKSTREAM TECHNOLOGY, INCLUDING OPTING OUT

As you navigate the Sites, we may also collect information about you using
common information-gathering tools, such as cookies and web beacons
(collectively “Website Navigational Information”). Website Navigational
Information includes standard information from your web browser (such as browser
type and browser language), your Internet Protocol (“IP”) address, and the
actions you take on the Sites (such as the web pages viewed and the links
clicked).


COOKIES

Like many companies, we use cookies on our Sites. Cookies are pieces of
information shared between your web browser and a website. Use of cookies
enables a faster and easier experience for the user.

There are different kinds of cookies with different functions:

 * Session cookies: These are only stored on your computer during your web
   session. They are automatically deleted when the browser is closed. They
   usually store an anonymous session ID allowing you to browse a website
   without having to log in to each page. They do not collect any information
   from your computer.
 * Persistent cookies: A persistent cookie is one stored as a file on your
   computer, and it remains there when you close your web browser. The cookie
   can be read by the website that created it when you visit that website again.
 * First-party cookies: The function of this type of cookie is to retain your
   preferences for a particular website for the entity that owns that website.
   They are stored and sent between Total Wine’s servers and your computer’s
   operating system. They are not used for anything other than for
   personalization as set by you. These cookies may be either Session or
   Persistent cookies.
 * Third-party cookies: The function of this type of cookie is to retain your
   interaction with a particular website for an entity that does not own that
   website. They are stored and sent between the Third-party’s server and your
   computer’s or device’s hard drive. These cookies are usually Persistent
   cookies.

We do use third-party cookies on our Sites, as well as third party provided web
beacons (please see the section on Web Beacons below). These cookies are used by
us and our marketing partners to better understand your preferences and to
tailor and improve your experience on the site based on our impressions of your
interests.

More specifically, our Sites use Google Analytics and Adobe Site Catalyst, which
are web analytic tools provided by Google, Inc. and Adobe Inc., respectively.
These services use cookies to help our Sites analyze how users use the Sites.
The information generated by the cookies about your use of the Sites (including
your IP address) will be transmitted to and stored by these vendors on servers
in the United States. These vendors will use this information for the purpose of
evaluating your use of the Sites, compiling reports on Site activity, and
providing other services relating to Site activity and internet usage for Total
Wine. These vendors may also transfer this information to third parties where
required to do so by law, or where such third parties process the information
for the vendors for purposes of providing those services. These vendors will not
associate your IP address with any other data held by them. You may refuse the
use of cookies by selecting the appropriate settings on your browser. However,
if you do block the use of cookies, you will not be able to use the full
functionality of the Sites. By using the Sites, you consent to the processing of
data about you by Google and Adobe in the manner and for the purposes set out
above.

Along with the above noted uses, we use cookies for the following purposes:

 * Strictly necessary cookies: These cookies are essential to enable you to move
   around the Sites and use its features, such as accessing secure areas of the
   Sites. Without these cookies, services you have asked for, such as logging
   into your account and using a shopping cart, cannot be provided. You can set
   your browser to block or alert you about these cookies, but then some parts
   of the Sites will not work. These cookies do not store any personally
   identifiable information.
 * Functional cookies: These cookies allow our Sites to remember choices you
   make (such as your username, language, or the region you are in) and provide
   enhanced, more personal or customized features. For instance, the Sites need
   to remember your login details, so that you do not have to repeatedly sign
   into your account when using a particular device to access our Sites. The
   information these cookies collect is usually anonymized. They may be set by
   us or by third-party providers whose services we have added to our pages.
   They do not gather any information about you that could be used for
   advertising or remember where you have been on the Internet.
 * Performance & analytics cookies: These cookies collect information about how
   visitors use a Sites, such as which pages visitors go to most often, and if
   they get error messages from web pages. They also allow us to record and
   count the number of visitors to the Sites, all of which enables us to see how
   visitors use the Sites in order to improve the way that our Sites works.
   These cookies do not collect information that identifies a person, as all
   information these cookies collect is aggregated and anonymous.
 * Marketing & advertising cookies: Total Wine does not "sell" your personal
   information as the word "sell" is commonly understood. In other words, we are
   do not give your personal information to third parties in exchange for money.
   However, our Sites do use cookies that may be used by third parties to build
   a profile of your interests and show you relevant advertisements on other
   sites. These cookies may also be used to enable you to share pages and
   content that you find interesting on our Sites through third-party social
   networking and other websites. The cookies do not store directly personal
   information, but are based on uniquely identifying your browser and Internet
   device. If you do not allow these cookies, you will experience less targeted
   advertising and may not be able to share pages or content you find
   interesting through third-party social networking sites.
 * Please note: We embed videos or insert links to videos from YouTube on our
   Sites. As a result, when you visit a page with content embedded from or
   linked to YouTube, you may be presented with cookies from YouTube. If you opt
   out of advertising and marketing cookies here, YouTube may still utilize
   cookies for those embedded videos and links. You can control YouTube cookies
   by visiting https://policies.google.com/technologies/cookies

For information on all these categories of cookies, and for more information
generally on cookies please refer to aboutcookies.org
or https://consumer.ftc.gov/articles/how-protect-your-privacy-online


OPTING OUT OF COOKIES

There are various ways for you to manage cookies and other technologies.

BROWSER SETTINGS

Through your browser settings, you can disable all the above-listed cookies (and
other tracking tools) or request to be prompted before accepting cookies from
the Sites and other websites you visit. These browser settings may also permit
you to delete cookies you already have. Please consult your web browser’s ‘Help’
documentation or visit aboutcookies.org or
https://consumer.ftc.gov/articles/how-protect-your-privacy-online for more
information about how to turn cookies on and off for your browser. If you use
different browsers and computers, you will need to adjust the appropriate cookie
settings for each browser and computer. Certain parts of the Sites may function
differently, and you may not be able to use some portions of our Sites if you
choose to disable cookies entirely.

You may also opt out by broadcasting an Opt-Out Preference Signal, such as the
Global Privacy Control (“GPC”) (on the browsers and/or browser extensions that
support such a signal). To download and use a browser supporting the GPC browser
signal, click here https://globalprivacycontrol.org/orgs. If you choose to use
the GPC signal, you will need to turn it on for each supported browser or
browser extension you use.

COOKIE BANNER

When you first accessed the Sites, a cookie banner at the bottom of the screen
allowed you to access user-enabled privacy controls through a OneTrust
preference center.  Such controls allowed you to opt-out of marketing &
advertising cookies, as described above. 

THIRD-PARTY EXTENSIONS

There are several browser extensions that allow you to manage cookies and
personalize your browsing experience. Since these extensions are made by third
party providers, Total Wine does not control these features and cannot provide
technical support for these products.

TARGETED ADVERTISING COOKIES

You may opt-out of advertising cookies from companies who are members of the
Network Advertising Initiative (“NAI”) or who subscribe to the Digital
Advertising Alliance’s (“DAA”) Self-Regulatory Principles for Online Behavioral
Advertising. Please visit the Network Advertising Initiative Consumer Opt-Out
Page or the Digital Advertising Alliance Opt-Out Page to opt out directly from
providers who participate in those programs.


WEB BEACONS

The Sites may also use web beacons (including web beacons supplied or provided
by third parties) alone or in conjunction with cookies to compile information
about users’ usage of the Sites and interaction with e-mails from Total Wine.
Web beacons are transparent electronic images that can recognize certain types
of information on your computer, such as cookies, when you view a particular
Site tied to the web beacon, and a description of a Site tied to the web beacon.
We use web beacons to operate and improve the Sites and e-mail communications.
We may use information from web beacons in combination with other data we have
about our customers to provide you with information about Total Wine and our
services. We will conduct this review on an anonymous basis.


IP ADDRESSES

When you visit our Sites, Total Wine collects your Internet Protocol (“IP”)
addresses to track and aggregate non-Personal Information. For example, Total
Wine uses IP addresses to monitor the regions from which users navigate the
Sites. IP addresses will be stored in such a way so that you cannot be
identified from the IP address. In addition, Total Wine uses your IP address to
get an approximate location so we can find a store closest to you. We do this
for both your convenience, as well as for legal compliance reasons.




7. HOW WE USE YOUR PERSONAL INFORMATION

We collect and use your Personal Information for various purposes, including:

 * Consumer Transactions, such as processing a purchase or fulfilling an order,
   as well as creating, maintaining, customizing, and securing your account with
   us.
 * Customer Service and Relationship Management, such as addressing a customer
   complaint, applying &MORE Rewards points to a transaction.
 * Customer Experience, such as improving website offerings and interface,
   identifying and repairing errors in our Sites’ functionality, testing,
   research, analysis, and product development, including to develop and improve
   our Sites, products, and Services.
 * Marketing and Advertising, such as providing promotions that are interesting
   to you based on your purchasing and viewing history, ad customization that
   does not involve or contribute to profiling, and managing promotions and
   contests.
 * Merchandising, such as determining and improving product assortment based on
   your purchasing history.
 * Analytics, such as information about Site performance relative to your
   computer or device, hosting our Sites, and managing databases.
 * Security and Compliance, such maintaining the safety, security, and integrity
   of our Sites, products and Services, databases and other technology assets
   and our business, including preventing fraud, detecting security breaches,
   and prosecuting violators, and responding to law enforcement requests and
   meeting requirements of applicable law, court order, or governmental
   regulations.




8. SECURITY OF YOUR PERSONAL INFORMATION

Whether you are shopping on our Sites or in our Stores, we use reasonable
security measures to protect the confidentiality of personal information under
our control and appropriately limit access to it. The Total Wine Sites use
Transport Layer Security (“TLS”) or equivalent encryption technologies to
protect your personal information during data transport, including your name,
address, and credit card number. However, no security controls are failproof,
and Total Wine cannot completely ensure or warrant the security of your personal
information. We therefore urge you to always use caution when transmitting
information over the Internet.

When you create an account on TotalWine.com you are required to establish a
password that must be at least 8 characters, contain one letter, one number, and
one special character. Your password may not contain your first name or last
name. You are solely responsible for maintaining the secrecy of your password
and account information. We strongly recommend that you do not share this
information with others. You have the ability to purchase on our Sites without
creating an account; however, you will need to reenter your personal information
each time you use our Sites to make a purchase.




9. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We do not disclose any Personal Information about you to others except as stated
in this Privacy Policy, as otherwise permitted by law, or authorized by you.
This Privacy Policy does not apply to privacy practices of third parties that we
do not own or control, including but not limited to any third-party websites,
services, applications, or online resources to which the Sites may link, embed,
reference, or otherwise provide access. We are not responsible for the privacy
practices or the content of such third-party sites. Please contact these third
parties directly for information regarding their privacy practices. However, we
only allow our service providers to handle your personal information if we are
satisfied with the appropriate measures taken to protect your personal
information. We also impose contractual obligations on service providers,
contractors, and third parties to ensure they can only use your personal
information to provide services to us and to you.

We may disclose your Personal Information to the following categories of other
parties for a business purpose or commercial purpose, as those terms are defined
in state privacy laws:

 * Our affiliates, employees, and authorized agents;
 * Service providers for our businesses, as described further below;
 * Third parties to whom you or your agents authorize us to disclose your
   Personal Information in connection with products or services we provide to
   you, as described further below;
 * Government regulators or law enforcement, where required;
 * Our legal advisors and other parties when required by law or pursuant to
   legal process; and
 * To any entity involved in the purchase or sale of our businesses, as
   described further below.


SERVICE PROVIDERS

We use third-party service providers to enhance your consumer experience. This
may include, for instance, providers who assist us with tech or customer
support, operations, web or data hosting, billing, credit card processing,
accounting, security, marketing, data management, validation, enhancement or
hygiene, or otherwise help us to provide, develop, maintain and improve our
services. These companies may use information about your visits to our Sites to
help process delivery orders and/or provide personalized recommendations and
advertisements about our goods and services on our Sites or other websites.
Because service providers we use may be located in the United States, your
Personal Information may be processed and stored inside the United States; and
the U.S. government, courts, or law enforcement or regulatory agencies may be
able to obtain disclosure of your Personal Information under U.S. laws.


THIRD PARTIES

Some areas in our Sites may be offered to you in association with affiliated or
non-affiliated third parties, such as co-promotional partners, dedicated
producers of drinks, or co-sponsors of events you may want to attend. Such
co-branded areas may require you to disclose Personal Information to the third
party. The co-branded areas will identify the third party; however, the third
party’s privacy policy will apply to how they treat your Personal Information.
We recommend you review the privacy policy of these third parties. If you elect
to register for events or products with these third parties you will be
providing your Personal Information to both us and the third party.

Parts of the Sites use YouTube API Services to provide access to Total Wine’s
YouTube channel. You acknowledge and agree to be bound by the YouTube Terms of
Service (https://www.youtube.com/t/terms) and Google’s Privacy Policy
(https://policies.google.com/privacy) when engaging YouTube content and services
through the Sites. You may manage your YouTube API data by visiting Google’s
security settings page at:  .

To provide advertisements and content that are more relevant to you, we and our
advertising and content providers may collect Personal Information when you use
our Sites (such as the IP address of your device, the identifier on your mobile
device, or cookies stored on your device), and may share the information we
collect with third parties.  Please see our Cookie Policy for more information.


SOCIAL MEDIA, REVIEWS, AND USER GENERATED CONTENT

Any personally identifiable information you submit on a social media website,
such as Facebook or Twitter, bulletin board, blog, chat room, or any other
public forum on our Sites can be read, collected, or used by other users of
these forums, who could be used to send you unsolicited messages. We recommend
that you do not provide your name, e-mail address, or any other personal
information in public forums on this Sites. Please note that if you choose to do
so, it is at your own risk and you accept full responsibility for those posts
and any consequences that may arise.


SALE OF ASSETS

As we continue to develop our businesses, we might sell or buy assets. In such
transactions, user information, including Personal Information, generally is one
of the transferred business assets. Also, if either Total Wine itself or
substantially all of Total Wine assets were acquired, your Personal Information
may be one of the transferred assets. Therefore, we may disclose and/or transfer
your Personal Information to a third-party purchaser in these circumstances,
which could include a merger, divestiture, restructuring, reorganization,
dissolution, or other sale or transfer of some or all our assets.


OTHER LEGALLY REQUIRED DISCLOSURES

Total Wine preserves the right to disclose without your prior permission any
Personal Information about you or your use of this Sites if Total Wine has a
good faith belief that such action is necessary to: (a) protect and defend the
rights, property, or safety of Total Wine, employees, other users of this Sites,
or the public; (b) enforce the terms and conditions that apply to use of this
Sites; (c) respond to a legally valid request from a competent governmental
authority; or (d) respond to claims that any content violates the rights of
third parties. We may also disclose Personal Information as we deem necessary to
satisfy any applicable law, regulation, legal process, or governmental request.




10. YOUR RIGHTS RELATED TO PERSONAL INFORMATION HELD BY US

Please note that your rights listed below may vary depending on your state of
residence. If you are a resident of California, Colorado, Connecticut, or
Virginia, the following rights apply to you unless a specific state is
mentioned. You may exercise your rights through Total Wine’s Privacy Portal.

Right to Know Collected Personal Information

You have the right to know, and request disclosure of:

 * The categories of Personal Information we have collected about you, including
   sensitive personal information;
 * The categories of sources from which the Personal Information is collected;
 * Our business or commercial purpose for collecting, selling, or sharing
   Personal Information;
 * The categories of third parties to whom we disclose Personal Information, if
   any; and
 * The specific pieces of Personal Information we have collected about you.

Please note that we are not required to:

 * Retain any personal information about you that was collected for a single
   one-time transaction if, in the ordinary course of business, that information
   about you is not retained;
 * Reidentify or otherwise link any data that, in the ordinary course of
   business, is not maintained in a manner that would be considered personal
   information; or
 * Provide the Personal Information to you free of charge at a greater frequency
   than is required by the state laws where you reside. For example, Virginia
   residents may make two requests over 12 months, while Connecticut and
   Colorado residents may make one request over 12 months.

Right to Know Disclosed, Sold, or Shared Personal Information In connection with
any Personal Information we may sell, share, or disclose to a third party for a
business purpose, you have the right to know:
 * The categories of Personal Information about you that we sold or shared and
   the categories of third parties to whom the Personal Information was sold or
   shared; and
 * The categories of Personal Information that we disclosed about you for a
   business purpose and the categories of persons to whom the Personal
   Information was disclosed for a business purpose.

Right to Opt-Out of Sale or Sharing You have the right to opt-out of the sale of
your Personal Information or sharing of your Personal Information. If you
exercise your right to opt-out of the sale or sharing of your Personal
Information, we will refrain from selling or sharing your Personal Information,
unless you subsequently provide express authorization for the sale or sharing of
your Personal Information. Right to Limit Use of Sensitive Personal Information

In California, you have the right to limit the use and disclosure of your
sensitive personal information to the use which is necessary to:

 * Perform the services or provide the goods reasonably expected by an average
   consumer who requests those goods or services;
 * To perform the services in the “How we use your Personal Information” section
   above; and
 * As authorized by further regulation.

In Colorado, Connecticut, or Virginia, you have the right to opt-in to the use
of sensitive personal information, which Total Wine will provide before or at
the time of collection of such information.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request
from you, we will:

 * Delete your personal information from our records; and
 * Direct any service providers or contractors to delete your personal
   information from their records.
 * Direct third parties to whom the business has sold or shared your personal
   information to delete your personal information unless this proves impossible
   or involves disproportionate effort.

Please note that we may not delete your personal information if it is reasonably
necessary to:

 * Complete the transaction for which the personal information was collected,
   fulfill the terms of a written warranty or product recall conducted in
   accordance with federal law, provide a good or service requested by you, or
   reasonably anticipated within the context of our ongoing business
   relationship with you, or otherwise perform a contract between you and us;
 * Help to ensure security and integrity to the extent the use of the consumer’s
   personal information is reasonably necessary and proportionate for those
   purposes;
 * Debug to identify and repair errors that impair existing intended
   functionality;
 * Exercise free speech, ensure the right of another consumer to exercise his or
   her right of free speech, or exercise another right provided for by law;
 * Comply with the California Electronic Communications Privacy Act;
 * Engage in public or peer-reviewed scientific, historical, or statistical
   research in the public interest that adheres to all other applicable ethics
   and privacy laws, when our deletion of the information is likely to render
   impossible or seriously impair the achievement of such research, provided we
   have obtained your informed consent;
 * Enable solely internal uses that are reasonably aligned with your
   expectations based on your relationship with us;
 * Comply with an existing legal obligation; or
 * Otherwise use your personal information, internally, in a lawful manner that
   is compatible with the context in which you provided the information.

Right to Correction If we maintain inaccurate personal information about you,
you have the right to request us to correct that inaccurate personal
information. Upon receipt of a verifiable request from you, we will use
commercially reasonable efforts to correct the inaccurate personal information.
Right to Appeal If you are a Colorado, Connecticut, or Virginia resident, you
may appeal our decision to your request regarding your personal information. We
respond to all appeal requests as soon as we reasonably can, and no later than
legally required.

 




11. ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

California law requires us to disclose the following additional information with
respect to our privacy practices.  If you are a California resident, this
section applies to you in addition to the rest of the Privacy Policy.


SHINE THE LIGHT

Under California’s “Shine The Light” law (California Civil Code Section
1798.83), California residents may annually request, free of charge, information
about the Personal Information (if any) disclosed to third parties for direct
marketing purposes in the preceding calendar year. However, no information is
shared with third parties for their own marketing purposes except where
expressly authorized by you.


CATEGORIES OF PERSONAL INFORMATION DISCLOSED FOR BUSINESS OR COMMERCIAL PURPOSES
OVER THE LAST 12 MONTHS

You can find a list of categories of Personal Information that we collect in the
“Personal Information we collect about you” section above.  For details
regarding the sources from which we obtain Personal Information, please see the
“How we collect your Personal Information” section above. We collect and use
personal information for the business or commercial purposes described in the
“How we use your Personal Information” section above. Below is a non-exhaustive
list of examples of such “business purposes” or “commercial purposes” as defined
under California law.

 1. Consumer Transactions, such as processing a purchase or fulfilling an order,
    as well as creating, maintaining, customizing, and securing your account
    with us.
 2. Customer Service and Relationship Management, such as addressing a customer
    complaint, applying &MORE Rewards points to a transaction.
 3. Customer Experience, such as improving website offerings and interface,
    identifying and repairing errors in our Sites’ functionality, testing,
    research, analysis, and product development, including to develop and
    improve our Sites, products, and Services.
 4. Marketing and Advertising, such as providing promotions that are interesting
    to you based on your purchasing and viewing history, ad customization that
    does not involve or contribute to profiling, and managing promotions and
    contests.
 5. Merchandising, such as determining and improving product assortment based on
    your purchasing history.
 6. Analytics, such as information about Site performance relative to your
    computer or device, hosting our Sites, and managing databases.
 7. Security and Compliance, such maintaining the safety, security, and
    integrity of our Sites, products and Services, databases and other
    technology assets and our business, including preventing fraud, detecting
    security breaches, and prosecuting violators, and responding to law
    enforcement requests and meeting requirements of applicable law, court
    order, or governmental regulations.


CATEGORIES OF PERSONAL INFORMATION SOLD OR SHARED OVER THE LAST 12 MONTHS

We do not “sell” your Personal Information in exchange for money. However,
certain state law views the “sale” of Personal Information more broadly, to
include any transfer to another business or third party for valuable
consideration. Under this broad definition, we have shared during the 12-month
period prior to the effective date of this Privacy Policy the Identifiers (as
defined above) with entities that compile Personal Information about prospective
or current Total Wine customers for purposes of updating, verifying or
deduplicating Personal Information, prospecting new potential customers, and
improving the types of services and products we offer to you.  For more
information about how your information is disclosed and the entities to whom it
is disclosed, see the “How we disclose your Personal Information” section
above.  The categories of information disclosed about you include identifiers,
commercial information, internet, or other similar network activity as defined
in the "Personal Information we collect about you" section above.  In addition,
the collection of Internet or electronic network activity information (as
defined above) through cookies on our Sites for a variety of purposes, including
personalized advertising and facilitating your activity on social media, may
constitute a “sale” under state privacy laws and occurred during the 12-month
period prior to the effective date of this Privacy Policy. Please refer to
our Cookie Policy to better understand your privacy options.




12. OUR RESPONSE TO REQUESTS

We will acknowledge receipt of your request within 10 days of receipt of your
request. We provide a substantive response to your request as soon as possible,
generally within 45 days from when we receive your request, although we may be
allowed to take longer to process your request under certain circumstances. If
we expect your Request is going to take us longer than normal to fulfill, we
will notify you.

We usually act on Requests and provide information free of charge, but we
reserve our right to charge a reasonable fee to cover our administrative costs
of providing the information in certain situations.

In some cases, the law may allow us to refuse to act on certain requests. When
this occurs, we will explain why.




13. NON-DISCRIMINATION POLICY FOR EXERCISING YOUR PRIVACY RIGHTS

We will not discriminate against you for exercising any of your privacy rights.
In particular, we will not:

 * Deny you goods or services
 * Charge you different prices for goods or services, whether through denying
   benefits or imposing penalties
 * Provide you with a different level or quality of goods or services
 * Threaten you with any of the above

However, under certain state privacy law, we may offer certain incentives that
result in different prices, offers, benefits, or services to customers who
choose to join our &MORE Rewards Program that may not be available to customers
who are not &MORE Rewards Program members or who choose to terminate their &MORE
Rewards Program membership. For more information about our &MORE Rewards
Program, the different product offerings and services available under that
program, how to opt-in to the program, and the value of &MORE Rewards Program
member data, see the &MORE Rewards Program Terms & Conditions.




14. NOTICE OF FINANCIAL INCENTIVE

We make various offers and financial incentives to our customers. The terms of
any such offer or financial incentive will be presented to you at the time you
receive our offer. The nature and value of any such offer or financial incentive
may differ depending on what information we collect and use about you and
whether you choose to enroll in our &MORE Rewards Program. For details about the
benefits of enrolment in our &MORE Rewards Program, please see the &MORE Reward
Program Terms & Conditions

Whether you choose to enroll in our &MORE Rewards Program and whether you choose
to allow us to collect and use other types of Personal Information about you
affects how we communicate with you and the types and frequency of offers that
you may receive. For example, if we collect no information from you, we will be
unable to make any offers to you other than through general advertising or when
you visit our stores. Conversely, when you enroll in our &MORE Rewards Program
or otherwise allow us to continue to collect and use Personal Information about
you, we are able to provide you different, more tailored or customized, and
generally more valuable offers and financial incentives than the ones we may
choose to make through our general advertising, which only reaches a small
percentage of our customers.

The value of your Personal Information that allows us to make these offers and
financial incentives is the value of the offer itself. We calculate the value of
our offers and financial incentives by using the expense related to the offer.

Whether or not you are a member of our &MORE Rewards Program, you may withdraw
from receiving any of our offers or financial incentives by contacting us at
privacy@totalwine.com or 1-855-330-6673 or by unsubscribing to our email
marketing by clicking "Unsubscribe" link in any e-mail from us.




15. RETENTION

We retain your personal information for the period necessary to fulfill the
purposes outlined in this Privacy Policy, unless a longer retention period is
required or permitted by law. Please note that in many situations we must retain
all, or a portion, of your personal information to comply with our legal
obligations; resolve disputes; enforce our agreements; protect against
fraudulent, deceptive, or illegal activity; or for another one of our business
purposes.  We dispose of the information we collect in accordance with our
retention policies and procedures.




16. UPDATING YOUR PERSONAL INFORMATION

Total Wine wants your personal information to be accurate and complete. We
provide several different methods for you to update your personal information.
To update your name, address, phone number and/or e-mail information:

Online: Login to My Account on TotalWine.com to update your personal account
information (if you've created an account on TotalWine.com) Phone:
1-855-330-6673 Email: privacy@totalwine.com Mail:

Total Wine & More, Store Support Center
6600 Rockledge Drive, Suite 150
Bethesda, MD 20817
Attn: Customer Care/Privacy

If you send an e-mail or letter request, please be sure to include your current
information and the requested changes.




17. E-MAIL & ACCOUNT REGISTRATION

During registration on the Sites, we collect an e-mail address to communicate
with you about your transaction. We use this e-mail address to contact you if
there are any issues and to notify you about the status of your order. If you do
not want this retained for future promotional e-mail inclusion, we provide you
the ability to opt-out.

If a user wishes to subscribe to our e-mails, we ask for contact information
such as name, preferred store, and e-mail address. We may use your personal
information for purposes other than sending you promotional materials. For
example, we may use your information to send you administrative communications
about any account you may have with us or about future changes to this Privacy
Policy. If at any time you should wish to unsubscribe, please click on the
"unsubscribe" link in any e-mail from us or send an e-mail to 
privacy@totalwine.com.

When you register as a member of the Sites or sign-up to receive our e-mail
offers, we collect information that helps us identify you. The more information
you provide, the better we can customize our services and your experience to
suit your needs and preferences.




18. CHILDREN'S AND MINOR'S PRIVACY

Total Wine Stores and Sites are intended for adults 21 years of age and older.
We do not knowingly collect personal information from minors under the age of
21. If you have reason to believe that a person under the age of 21 has provided
Personal Information to us, please contact us as provided in the “How to contact
us” section below with sufficient detail to enable us to delete that information
from our databases.

For more information about Parental Control options, see our Terms & Conditions.




19. NEVADA PRIVACY NOTICE

Nevada law (SB 220) requires website operators to provide a way for Nevada
consumers to opt out of the sale of certain information that the website
operator may collect about them. Total Wine does not sell your personal
information to third parties as defined in Nevada law and will not do so in the
future without providing you with notice and an opportunity to opt-out of such
sale as required by law. See above for more information about how you can
protect your information, and what we do to protect your information.




20. HOW TO CONTACT US

Phone: 1-855-330-6673 Email: privacy@totalwine.com Mail:

Total Wine & More, Store Support Center
6600 Rockledge Drive, Suite 150
Bethesda, MD 20817
Attn: Customer Care/Privacy

Contact Customer Care
+ 1 (855) 328-9463
Mon.-Sun.: 9 a.m. - 12 a.m. ET

Copyright © 2023 Total Wine & More

Spirit sales where allowed by law

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PRIVACY NOTICE

Cookies are small text files stored on your computer or device when you visit a
website or app. This site uses cookies to provide you with a great user
experience. See our Cookie Policy for more information.

STRICTLY NECESSARY COOKIES

Always Active

These cookies are essential in order to enable you to move around the Site and
use its features, such as accessing secure areas of the Site. Without these
cookies, services you have asked for, such as logging into your account and
using a shopping cart, cannot be provided. You can set your browser to block or
alert you about these cookies, but then some parts of the site will not work.
These cookies do not store any personally identifiable information.

FUNCTIONAL COOKIES

Always Active

These cookies allow our Site to remember choices you make (such as your user
name, language or the region you are in) and provide enhanced, more personal or
customized features. For instance, the Site needs to remember your log in
details, so that you do not have to repeatedly sign in to your account when
using a particular device to access our Site. The information these cookies
collect is usually anonymized. They may be set by us or by third party providers
whose services we have added to our pages. They do not gather any information
about you that could be used for advertising or remember where you have been on
the Internet. See our Cookie Policy for more information.

PERFORMANCE & ANALYTICS COOKIES

Always Active

These cookies collect information about how visitors use a Site, for instance
which pages visitors go to most often, and if they get error messages from web
pages. They also allow us to record and count the number of visitors to the
Site, all of which enables us to see how visitors use the Site in order to
improve the way that our Site works. These cookies do not collect information
that identifies a person, as all information these cookies collect is aggregated
and anonymous. See our Cookie Policy for more information.

MARKETING & ADVERTISING COOKIES

Always Active

Total Wine does not "sell" your personal information as the word "sell" is
commonly understood; in other words, we are do not give your personal
information to third parties in exchange for money. However, our Sites do use
cookies that may be used by third parties to build a profile of your interests
and show you relevant advertisements on other sites. These cookies may also be
used to enable you to share pages and content that you find interesting on our
Site through third party social networking and other websites. The cookies do
not store directly personal information, but are based on uniquely identifying
your browser and Internet device. If you do not allow these cookies, you will
experience less targeted advertising and may not be able to share pages or
content you find interesting through third party social networking sites. See
our Cookie Policy for more information.

You may opt out (or “turn off”) these cookies by clicking on the button to the
right. The button is turned off when it is gray; the button is turned on when it
is blue. You can also opt-out, by disabling cookies on your internet browser.

Please Note: We embed videos or insert links to videos from YouTube on our
website(s). As a result, when you visit a page with content embedded from or
linked to YouTube, you may be presented with cookies from YouTube. If you opt
out of advertising and marketing cookies here, YouTube may still utilize cookies
for those embedded videos and links. You can control YouTube cookies by visiting
https://policies.google.com/technologies/cookies

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