The Wine Cellar Group Privacy Policy

The Wine Cellar Group Privacy Policy Overview

At The Wine Cellar Group, we appreciate the trust you place in us when you choose to visit our stores or websites and we take that responsibility seriously. The Wine Cellar Group Privacy Policy (the “Policy”) describes how we collect and use personal information about you when you visit our website, email us, call us on the phone, or visit our U.S. stores.
By “personal information”, we mean information that directly identifies you, such as your name, address, or email address. In this Policy, “we” and “our” mean The Wine Cellar Group, and “you” means any person who visits our website or visits our U.S. stores.

We may collect, receive, and use personal information through our website and third-party websites and services to facilitate consumer purchases, personalize experiences, and market wine products and related offerings.

Types of Information collected.

Notice At Collection and Use of Personal Information Although many areas of the Company Sites do not require registration and may be accessed by you without you having to disclose any personal information. We may sell or share personal information with Direct Wines, Inc., a third-party marketing partner for their own marketing purposes. You have the right to opt out at any time.Personal Information Category	How Collected	Primary Uses
Identifiers & Personal Information (name, date of birth, billing/shipping address, email, phone number, account credentials, IP address, payment card information)	Directly from consumers when placing orders, creating accounts, enrolling in rewards programs, contacting customer service, entering promotions, subscribing to marketing communications, and through website interactions.	Order fulfillment, payment processing, account administration, customer service, responding to inquiries, fraud prevention, legal compliance, marketing communications, and personalized recommendations.
Purchase Information / Commercial Information (products purchased, order history, payment method, transaction records, purchasing tendencies)	Collected during purchases online, by phone, and in stores; obtained through account activity and transaction records.	Fulfilling orders, servicing accounts, analyzing purchasing behavior, personalizing product recommendations, marketing, customer analytics, and business operations.
Profile & Account Information (account details, passwords, wish lists, saved carts, product reviews, gift card information, preferences)	Provided by consumers through account registration, profile management, reviews, loyalty programs, and website use.	Account maintenance, enhanced customer experience, personalization, product recommendations, customer support, marketing, and analytics.
Preference Information & Inferences (wine preferences, delivery preferences, shopping interests, consumer profiles)	Derived from purchases, website activity, account information, surveys, interactions with sales representatives, and stated preferences.	Personalization, targeted marketing, customer segmentation, recommending products, improving customer experiences, and analytics.
Internet / Network Activity Information (website usage, browsing activity, search history, clickstream data, pages viewed, time spent, interaction history)	Automatically collected through cookies, web beacons, tags, website logs, device identifiers, and similar technologies.	Website functionality, personalization, analytics, website improvement, advertising effectiveness, targeted advertising, fraud prevention, and recognizing user devices.
Device Information (IP address, browser type, operating system, device identifiers, ISP information)	Automatically collected when accessing the website, emails, advertisements, or applications.	Security, fraud detection, website optimization, analytics, device recognition, targeted advertising, and troubleshooting.
Location Information (general geolocation from device settings)	Collected through devices when enabled by user settings and website permissions.	Personalization, localized services, analytics, marketing, and improving customer experiences.
Sensory Information (recorded customer service calls, audio recordings)	Recorded during customer calls and customer service interactions.	Quality assurance, training, customer service, dispute resolution, fraud prevention, and legal compliance.
Video Recordings & Photographic Information	Captured through in-store surveillance and security systems.	Security, fraud prevention, loss prevention, incident investigations, operational management, and legal compliance.
Social Media Information	Obtained when consumers engage with social media plugins, login features, promotions, or share information through third-party platforms such as Facebook, Instagram, Pinterest, and X/Twitter.	Marketing, customer engagement, personalization, analytics, and improving products and services.
Third-Party Data & Demographic Information	Received from affiliated companies, service providers, analytics providers, advertising networks, data cooperatives, demographic providers, and other business partners.	Marketing, analytics, customer profiling, personalization, advertising, fraud prevention, and business operations.

How We Collect Information

We collect information on our website, during calls with you, and in our stores. We also obtain information from you and from third parties. We collect and retain only the personal information reasonably necessary for the purposes described in this Policy."

Collection Source	Data Categories Collected
Customer purchases and transactions	Identifiers, payment information, commercial information, preferences
Account registration and management	Identifiers, profile data, preferences
Customer service interactions and calls	Identifiers, account information, sensory data
In-store visits	Purchase information, video recordings, photographs
Website and mobile app activity	Internet activity, device information, location data
Cookies and tracking technologies	Internet activity, device information, advertising identifiers
Affiliates and family of brands	Identifiers, commercial information, account information
Third-party service providers and advertising partners	Demographic, behavioral, device, and marketing information
Social media platforms	Social, profile, and engagement information

How We Use Information

We use the information that we collect to conduct our business and to provide you with the best possible products, services, and experiences. We also may combine any or all of the information that we collect or obtain. Examples of how we use information include:

Business Purpose	Data Categories Typically Used
Order fulfillment and payment processing	Identifiers, payment, purchase information
Account administration	Identifiers, profile and account information
Customer service	Identifiers, account information, call recordings
Personalization	Purchase information, preferences, inferences, browsing activity
Marketing and advertising	Identifiers, purchase history, preferences, browsing activity, third-party data
Trusted third-party marketing partner promotions	Identifiers, purchase history, preferences, marketing profiles (subject to applicable opt-out rights)
Analytics and website improvement	Internet activity, device information, commercial information
Fraud prevention and security	Device information, identifiers, transaction information, video recordings
Business operations and research	Commercial information, account information, analytics data
Legal compliance and safety	Identifiers, transaction records, recordings, surveillance information

How We Share Information

. We may disclose customer identifiers, contact information, purchase history, preferences, demographic information, and related marketing segments to Direct Wines, Inc., a trusted third-party marketing partner for independent marketing, subject to applicable law and contractual restrictions. For example, we share personal information with:

Third parties and service providers that provide products or services to us, that help us market or advertise to you (including co-branded marketing and advertising), or that provide products or services to you.
We may share your email address with Direct Wines, Inc., a trusted third-parties so those companies can send their own promotions of similar products,
We may use third parties or service providers to perform any of the actions or activities allowed under this Policy;
Social media platforms and networks such as Facebook, Twitter, Pinterest, and Instagram that offer functionalities, plugins, widgets, or tools in connection with our website (e.g., to log into an account, or to share inspiration, finds, purchases, and other content with your friends and followers on social media). If you choose to use these functionalities, plugins, widgets, or tools, certain information may be shared with or collected by those social media companies—for more information about what information is shared or collected, and how it is used, see the applicable social media company’s privacy policy;
Additional third parties such as law enforcement, government entities, courts, or other third parties as required or allowed by applicable law, such as for the legal and safety purposes described under the “How We Use Information” Section above, or otherwise to help prevent harm or fraud to us, you, our customers, or other third parties. We also may share personal information with third parties upon your request or with your approval, though we may not be able to accommodate all requests.

Sale, Sharing, and Targeted Advertising

We may disclose certain personal information to advertising partners, analytics providers, social media platforms, and similar third parties for purposes of targeted advertising, measurement, analytics, and marketing. Under certain state privacy laws, including California law, these disclosures may be considered a "sale" or "sharing" of personal information.

Categories of personal information that may be disclosed for these purposes include:

Identifiers, such as name, email address, mailing address, purchase history, product preferences, demographic information, and related marketing segments to carefully selected third-party marketing partners so that those partners may market their own products and services directly to you and online identifiers and IP addresses;
Internet or electronic network activity information;
Customer and purchase information;
Device information; and
Information is derived from browsing activity and interactions with our websites.

We do not knowingly sell or share personal information of individuals under the age of 21.

Consumers who reside in states that provide opt-out rights may submit requests to opt out of the sale or sharing of personal information and targeted advertising by using the contact us methods described below.

With Whom Information is Shared

We may share your personal information with service providers, business partners, Direct Wines, Inc., a trusted third party, marketing partners, and affiliated companies, for business, marketing, and operational purposes.

Service Providers

We may share your information with vendors and service providers that help us operate our business and provide our products and services, including payment processors, shipping providers, website hosting providers, analytics providers, customer support providers, email and promotional and survey administrators. These parties may use your information as necessary to provide services to us and as otherwise permitted by applicable law.

Marketing and Advertising Partners

We may share your information with advertising, social media, Direct wines, Inc., a trusted third party and marketing partners to help us market our products and services and to enable them to market products, services, and offers that may be of interest to you. This information may include your name, email address, telephone number, purchase history, and other information you provide to us. We may also use your information to create audience segments, suppress advertising, and identify prospective customers with similar interests.

Business Transfers and Legal Disclosures

We may disclose or transfer your information in connection with a merger, acquisition, financing, sale of assets, or other corporate transactions. We may also disclose information when required by law, to respond to legal requests, enforce our policies, protect our rights or property, investigate fraud or security incidents, or protect the safety of individuals.

Non-Personal Information

We may use and share aggregated, anonymized, or non-personally identifiable information for research, analytics, advertising, marketing, and other business purposes. Because this information does not identify an individual, we may share it with service providers, business partners, and other third parties without restriction, subject to applicable law.

Your Choices and Access Requests

We strive to offer you choices about how personal information is used and shared. Your choices include:

Social Media Platforms and Networks. We encourage you to review your privacy options and settings with the social media platforms and networks you use to understand what choices you have about sharing information from those platforms and networks with us.
Email Choices. You may opt out of marketing or advertising emails by utilizing the “unsubscribe” link or mechanism noted in marketing or advertising emails you receive from The Wine Cellar Group. You may also request to opt out of marketing or advertising emails by contacting us through one of the methods specified in the “Additional Information and Contacting Us” Section below, and sharing the email address at which you are receiving marketing or advertising emails.
Sale, Sharing, and Targeted Advertising Choices.

Residents of certain states may opt out of:

the sale of personal information;
the sharing of personal information for cross-context behavioral advertising; and
the processing of personal information for targeted advertising.
To exercise these rights, please contact us using by email mail@winecellargroup.com or call us at (847) 604-8745.

Telephone Choices (texts & calls). You may opt out of receiving marketing text messages by texting “STOP” in response to a text message that you receive. We will not call you to communicate any marketing offers.
Mobile Location Choices. You may choose not to provide your location to us in connection with your use of our mobile application by declining any prompt requesting location information, and by customizing your mobile device settings to prevent sharing of location information. You may prevent this by customizing your mobile device settings to prevent sharing of location information or by disabling Bluetooth on your device.
Access Requests. If you have registered for an online account, we allow you to access and update certain personal information that you have provided to us by logging into your online account and using the features and functionalities available there. You may also make a request for access to personal information by sending an email or writing to us at the address specified in the “Additional Information and Contacting Us” section below. We are not able to grant all access requests, and we may request additional information from you in order to verify your identity before accommodating an access request.

Security and Fraud

We take steps to help protect the confidentiality and security of personal information you share with us through our website. In general, information transmitted through the Internet may not be perfectly secure, and we are unable to guarantee the security of your personal information.
We encourage you to take steps to help protect the confidentiality and security of your account and personal information, including by doing the following:

Reviewing your The Wine Cellar Group account periodically and immediately reporting any unexpected activity or unrecognized information;
Installing the latest security updates and anti-virus software on your computer to help prevent malware and viruses;
Using complex passwords (a minimum of 7 alpha/numeric cAsE sEnsitive characters);
Not using the same password on more than one website;
Not sharing your password with others;
Password protecting your computer and mobile device; and
Sign out/log off of website sessions so that your session is closed, especially when using a public computer.

You may come in contact with websites, emails or texts that try to lure you into providing personal information with an offer such as The Wine Cellar Group gift card. The Wine Cellar Group does not sponsor or endorse these offers. If you become aware of any potentially fraudulent activity on a website or in an email or text, please forward the information to mail@winecellargroup.com or call us at (847) 604-8745 so that we can follow up.

Notices and Disclosures

Links to Other Websites and Services. Our website or mobile application may provide links to other Internet sites, content or videos (embedded or direct links) maintained by third parties. We are not responsible for the sites, content, or videos accessed via the links, and we have not reviewed the privacy practices of those third parties. We encourage you to review the privacy practices of those third parties.
Browsers Do Not Track Signals. While we strive to offer you choices when you use our website and mobile application, we do not promise that we will be able to receive or honor web browser Do Not Track signals.

· Consumer Privacy Rights for California and Other States
This section applies to California and Oregon residents and governs in the event of any conflict with another section of this Privacy Policy. California residents may request information regarding our disclosure of personal information to third parties for their direct marketing purposes under California Civil Code §1798.83. We are required to respond to such requests once per calendar year. To submit a request, please contact us using the information provided in the "Contact Information" section below.

In addition:
(a) Users may visit our websites anonymously.
(b) A link to this Privacy Policy is available on our website.
(c) Changes to this Privacy Policy will be posted on this page.
(d) Users may update their personal information by contacting us.
(e) We do not currently respond to browser-based "Do Not Track" signals.
(f) Third parties may collect behavioral tracking information on our websites, but we do not authorize them to collect personal information through our websites.
(g) We recognize and process Global Privacy Control (GPC) signals as requests to opt out of the sale, sharing, or targeted advertising of personal information where required by applicable law.

Rights and Choices for California Residents
The California Consumer Privacy Act ("CCPA") provides California residents with rights regarding their personal information. This section explains those rights and how to exercise them. Residents of other states may have different rights under applicable law.

Third-Party Selling & Sharing
We may disclose your name, email address, mailing address, purchase history, product preferences, demographic information, and related marketing segments to carefully selected third-party marketing partners so that those partners may market their own products and services directly to you. These disclosures may constitute a sale, sharing, or targeted advertising under applicable state privacy laws, and consumers may opt out at any time. References to "share" in this Privacy Policy mean sharing for those advertising purposes. During the previous 12 months, we sold and/or shared personal information as described below. We do not knowingly market alcoholic beverages to individuals under 21 years of age and do not knowingly sell or share personal information of individuals under 21 years of age.

Category of Recipient

Categories of Personal Information

Sell and/ or Share

Providers of consumer goods

Identifiers; contact information; internet activity; device information, inferences/preferences, Personal Information as described in Cal. Civ. Code § 1798.80(e); and inferences drawn from the above Personal Information

Sell

Ad Networks and Social Media companies

Identifiers; contact information; internet activity; device information,

inferences/preferences, Personal Information as described in Cal. Civ. Code § 1798.80(e); and inferences drawn from the above Personal Information

Sell and Share

Data Brokers

Sell

Consumer Privacy Rights

Consumer Right	Description
Right to Know / Access	You may request information regarding the personal information we collect, use, disclose, sell, or share, including the categories of personal information collected, sources of collection, business purposes for processing, categories of recipients, and specific pieces of personal information maintained about you.
Right to Delete	You may request that we delete personal information we have collected from you, subject to certain legal and operational exceptions.
Right to Correct	You may request correction of inaccurate personal information that we maintain about you.
Right to Opt Out of Sale of Personal Information	You may direct us not to sell your personal information to third parties, as defined by applicable state privacy laws.
Right to Opt Out of Sharing for Advertising	You may direct us not to share your personal information for cross-context behavioral advertising or similar advertising purposes.
Right to Opt Out of Targeted Advertising	You may opt out of the processing of your personal information for targeted advertising purposes.
Right to Opt Out of Third-Party Marketing Disclosures	You may opt out of our disclosure of personal information to trusted third-party marketing partners for their own marketing of products and services.
Right to Limit Use of Sensitive Personal Information	Where applicable, you may request that we limit the use and disclosure of sensitive personal information to purposes authorized by law.
Right to Non-Discrimination	We will not discriminate against you for exercising your privacy rights. Unless permitted by law, we will not deny goods or services, charge different prices, or provide a different level of service because you exercised a privacy right.
Right to Use an Authorized Agent	Where permitted by law, you may designate an authorized agent to submit a privacy rights request on your behalf.
Right to Appeal	Residents of certain states may appeal our denial of a privacy rights request. Instructions for submitting an appeal will be provided if a request is denied.

How to Exercise Your Rights

Method	Contact Information
Email	mail@winecellargroup.com
Toll-Free Number	(847) 604-8745

Categories of Personal Information Subject to These Rights

Category

Identifiers and Contact Information

Commercial and Purchase Information

Account and Profile Information

Internet and Network Activity Information

Device and Geolocation Information

Audio, Video, and Photographic Information

Preferences and Inferences

Other Personal Information Described in this Privacy Policy

Additional Disclosure Regarding Marketing Partners

Activity	Consumer Right
Disclosure of personal information to trusted third-party marketing partners for their own marketing purposes	Right to Opt Out
Sale of personal information, where applicable under state law	Right to Opt Out
Sharing of personal information for cross-context behavioral advertising	Right to Opt Out
Use of personal information for targeted advertising	Right to Opt Out

·
DATA RETENTION
We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, enforce agreements, prevent fraud, improve our services, and protect our legal rights. When personal information is no longer required, we take reasonable measures to securely delete or anonymize it.Universal Opt-Out Signals

Where required by law, we recognize and process Global Privacy Control (GPC) and other legally recognized universal opt-out preference signals as requests to opt out of sale, sharing, and targeted advertising.

Children’s & Minor’s Privacy. The Wine Cellar Group’s Web site is intended for adults 21 years of age and older. We do not knowingly sell or share personal information of individuals under the age of 21. However, if the parent or guardian of an individual under 21 believes that the individual has provided us with personally identifiable information, the parent or guardian of that child should contact us at mail@winecellargroup.com so that we can take steps to delete the personal information that she or he provided.

If you have questions about this Policy or our privacy practices, please contact us at:
The Wine Cellar Group
544 Lakeview Parkway, Suite 100
Vernon Hills, IL 60061
(847) 604-8745
mail@winecellargroup.com

Updates to This Policy

We may make changes to this Policy, and may apply any changes to information previously collected, as permitted by law. When we make material changes to this Policy, we will notify you by posting the updated Policy on our website, and we will update the effective date at the end of this Policy.

Remedy for Breach

You agree to resolve a possible breach of this policy by means of binding arbitration.

Effective Date

This Policy is effective October 10, 2026.

The Wine Cellar Group Privacy Policy

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The Wine Cellar Group Privacy Policy

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