WALT Wines Privacy Policy

WALT Wines Privacy Policy

Effective Date: 5.25.2026

This Privacy Policy applies to information we collect about you when you visit our websites www.waltwines.com , www.hallwines.com, www.bacawines.com, www.michelfochwines.com, www.hallplatinumwines.com , www.harebrainedwines.com , and related websites and webpages (the “Sites”), visit our tasting rooms, use our mobile applications, attend our events, or use any other on- or off-line services we offer (collectively with the Sites, the “Services”).

This Privacy Policy does not apply to information collected in an employment context. This Privacy Policy also does not apply to third party websites or platforms, even if our Services link to them or vice versa. We recommend reviewing the privacy policies for third party websites and platforms to understand how your personal data is used and stored by those third parties.

Please note that we are providing the following disclosures in this Privacy Policy in the interest of transparency. Such disclosures are not intended to waive any applicable exemptions under state and federal law.

Table of Contents

1. Sources of Personal Data	We collect personal data in connection with your use of our Services.
2. Use of Personal Data	We use personal data for different purposes in connection with your use of our Services.
3. Disclosure of Personal Data	We may disclose personal data to certain third parties, including our service providers and advertising partners.
4. Cookies	We collect information about your use of our Services through cookies and other tracking technologies.
5. Children’s Privacy	Our Services are not directed to or intended for use by anyone under the age of 21.
6. Data Security	We use reasonable measures to protect personal data.
7. Data Retention	We retain personal data for as long as necessary to fulfill purposes set out in this Privacy Policy.
8. International Transfers	Our Services are operated in, and personal data may be transferred to, the United States.
9. Your Privacy Rights and Choices	We explain how you may exercise rights and choices related to personal data.
10. Supplemental State Notices	We provide additional disclosures and rights to residents of California; Connecticut, Nebraska, and Texas; and Nevada.
11. Updates to this Privacy Policy	Updates to this Privacy Policy become effective on the date they are posted.
12. Contact Us	You may contact us for comments or questions in various ways.

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1. Personal Data Collection

As used in this policy, “personal data” means any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device. Personal data includes “personal information” as that term is defined under certain privacy laws.

Personal data does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been de-identified or anonymized; or aggregate information. “Publicly available information” includes information that is made available from federal, state, or local government records; information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the individual; and information that is made available by a person to whom the individual has disclosed the information if the individual has not restricted the information to a specific audience.

We may create aggregated, de-identified, or anonymous information from data by removing certain data components that make the data identifiable, or through aggregation, obfuscation, or other means. Subject to applicable law, our use and disclosure of aggregated, de-identified, or anonymized information is not personal data and is not subject to this Privacy Policy.

a. Personal Data Collected Directly From You.

We collect personal data directly from when you use our Sites, visit our tasting rooms, attend our events, sign up for an account or membership, contact us, or otherwise interact with us or use our Services.

For example, we collect contact information such as your name; phone number; date of birth; email address; and password when you create an account, sign up for our email or SMS list, participate in promotions, or visit us. We collect your contact information as well as your shipping address; billing address; credit, debit, or other payment card information; and information about products and services purchased or considered when you make a purchase, book a tour or tasting, or otherwise use our Services. We may also collect veteran or military status to offer complementary tastings.

We may collect audio, visual, or other electronic information including user-generated content, such as photos you submit and any reviews you leave about our Services and products; and video data via security cameras that we deploy at some of our properties (we provide notice about our use of security cameras to the extent required by applicable law).

We also collect personal data if you send us emails or other communications such as requests for customer support, including your company information if you provide it on our contact form.

b. Personal Data Collected Automatically

Our Sites may use cookies and other tracking technologies such as web beacons, embedded scripts, and tags (collectively, “Cookies”), which collect information from you automatically as you use our Services, including:

· Browser and device data such as IP address; geolocation information; device identifier, device type; operating system and Internet browser type; screen resolution; operating system name and version; device manufacturer and model; plug-ins; add-ons; and the language version of our Services.

· Usage data such as time spent on our Services; pages visited; searches conducted; links clicked; patterns of use; and the pages that led or referred you to our Services; and diagnostic data. We may also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps, and other online features and services.

Please review Section 4 (“Cookies”) for more information about our use of these technologies.

c. Personal Data Collected from Other Sources

We also collect personal data from the following third parties:

· Our corporate affiliates, including our current and future parent companies, subsidiaries, and other companies under common control and ownership.

· Other users of our Services, including those participating in our memberships or other rewards programs, or those who send you our products.

· Our service providers, including those providing hosting, analytics, customer and technical support, address verification services, email and text services, and other services. For example, we may collect personal data if you use a live chat or chatbot our Sites, which is provided by our third-party service provider, Re:amaze, on our behalf.

· Social media and other content platforms, such as Meta and Google, if you interact with us on these platforms, visit our Sites while logged into these platforms, or link your social accounts to your HALL Wines account.

· Other third parties, including data providers, business and marketing partners, joint marketing campaign partners, ad network providers, analytics providers, and advertisers.

We may supplement or combine the personal data we receive from these third parties with personal data we otherwise collect about you through your use of our Services.

2. Use of Personal Data

We may use or disclose the personal data we collect for one or more of the following purposes:

· Furnish the products and Services you request, process your transactions, and send you related information, such as order and shipping confirmations and receipts

· Provide customer support

· Notify you of products, services, offers, promotions, events and features that may be of interest to you

· Provide discounts, promotions, rewards, and other incentive programs

· Develop and improve our products and Services

· Monitor and analyze trends, usage, and activities

· Advertise and market our products and Services, including through targeted advertising

· To grow our business, including through business partner and investor recruitment

· Selectively market third-party branded products and branded collaborations

· Manage your online account(s) and provide updates, security alerts, and administrative messages

· For internal business purposes, including general business administration

· Debug, identify, and repair errors that impair the functionality of the Sites

· Detect and prevent fraud and protect the security of the Sites and our operations

· Comply with our legal obligations, including responding to subpoenas, court orders, or legal process; and to establish or exercise our legal rights or defenses against legal claims

· Fulfill any other purpose for which the information was collected in a lawful manner that is consistent with the context in which you provided the information and/or as otherwise disclosed at the time your information is collected

· Any other purpose consistent with your consent and expressed preferences

3. Disclosure of personal data

We may disclose personal data that we collect to the following:

· Our corporate affiliates. We may disclose personal data to our corporate affiliates, including our current and future parent companies, affiliates, subsidiaries, and other companies under common control for the purposes provided in Section 2.

· Our service providers. We disclose personal data to our service providers who provide services on our behalf, such as: payment processors; shipping and delivery providers; analytics providers; advertising and marketing providers; web hosting and cloud storage providers; customer and technical support providers; software development and IT providers; email and text providers; and providers of other services. For example, if you use the chatbot or live chat on our Sites, the information provided may be recorded and stored by our third-party provider, Re:Amaze, on our behalf.

· Advertising partners and platforms. We may disclose your personal data to joint marketing campaign partners and third-party advertising platforms and analytics providers, including advertising, social media, and analytics companies who assist us in serving advertising regarding the Services to others who may be interested and who use Cookies to serve interest-based advertising and content on their respective third-party platforms that may be based on your preferences, location and/or interests.

· Authorities for compliance and harm prevention. Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities, and/or in response to a threat of harm involving an individual’s health and/or safety.

· Business transferees. If we or our affiliates are involved in a merger, acquisition, asset sale, or other corporate combination, your personal data may be transferred to the acquiring or surviving entity.

· Professional advisors. We may disclose personal data to our professional advisors, including lawyers, auditors, bankers, investors, shareholders, and insurers, where necessary in the course of the professional services they render to us.

· Other parties with your consent. We may disclose personal data to other parties with your consent in accordance with applicable law.

4. Cookies

We may collect information from you by using Cookies to improve and analyze our Services and provide targeted advertising.

Cookies on the Sites generally fall into the following categories:

Strictly Necessary. We may use Cookies that we consider to be strictly necessary to allow you to use and access our Services, including Cookies required to prevent fraudulent activity and improve security.
Functionality. We may use Cookies that are required to offer you enhanced functionality when accessing our Services, including identifying you when you sign in to our Services or keeping track of your specified preferences, including in terms of the presentation of content on our Services.

· Performance/Analytics. Our Sites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses Cookies to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity, and providing other services relating to website activity and internet usage for Hall Wines and its affiliates. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of Cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website.

· Targeting/Advertising. These Cookies are placed by third-party advertising platforms or networks to deliver ads and track ad performance, enabling advertising networks to deliver ads that may be relevant to you based upon your activities (sometimes called “targeted advertising”) on the Services.

You may modify your browser settings to decline or accept certain Cookies. However, if you decline certain Cookies, some of our Sites’ features may not function as designed.

5. Children’s Privacy

Our Services are not directed at children, and our Sites cannot be accessed by persons who do not verify that they are of legal drinking age. As a result, we will not knowingly collect information from minors in the U.S. with or without consent from their parents or guardians. Protecting the privacy of children is very important to us. If we obtain knowledge that a user is under the age of 21, we will take steps to remove that user's information from our databases.

6. Data Security

We will use reasonable and appropriate administrative, procedural, physical, and technical safeguards to protect your personal data. Although we take measures to safeguard personal data against unauthorized access, destruction, loss, alteration, disclosure, or misuse, due to the nature of the Internet, we cannot ensure or warrant the complete security of any information you transmit to us.

7. Data Retention

We will retain your personal data for as long as required for the purpose outlined in this Privacy Policy, including to provide the Services, complete the transactions for which your personal data was collected, to comply with any legal obligations or policies, resolve disputes, enforce legal agreements, and for internal analytics purposes. Our determination of precise retention periods will be based on (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable given our legal position, including with regard to applicable statutes of limitations, litigation, or regulatory investigations.

8. International Transfers

Your personal data may be transferred and maintained outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside of the United States and choose to provide information to us, please note that we transfer personal data to the United States and process it there. For such transfers, we take the necessary measures to ensure that your personal data receives an adequate level of protection.

9. Your Privacy Rights and Choices

You may have certain rights and choices regarding your personal data based on your location or place of residency.

a. Privacy Rights

Certain states provide residents with certain rights with respect to their personal data. Please review Section 10 (“Supplemental State Notices”) for more information on rights specific to your place of residence.

You can exercise the rights described in this Privacy Policy by:

Emailing us at info@waltwines.com
Calling us at (866) 667-4255
Note that if you are utilizing an opt-out preferences signal, such as the Global Privacy Control (“GPC”), to transmit your request to opt out, such signals will be identified and processed as an opt-out request.

All requests are subject to certain exceptions under applicable law. Consistent with applicable law, you may designate an authorized agent to submit a request on your behalf, and if so, we may require proof of your authorization of the agent and/or verification of the agent’s own identity. Please note that any request submitted to us is subject to an identification and residency verification process, to the extent permitted under applicable law. We will only use personal data provided in a request to verify your (or your authorized agent’s as applicable) identity or authority to make the request.

We will respond and process requests consistent with applicable law. For requests to know/access, delete, and correct, we will confirm receipt of your request within ten (10) business days. Except where otherwise noted, we will respond to your request within forty-five (45) calendar days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary, provided that the notice of extension is made within the first forty-five (45) days.

We do not charge a fee to process or respond to a request unless it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. You may be limited in how many requests you make within a twelve (12) month period.

b. Opting Out of Promotional Communications

We may use your personal data to send you email updates regarding our Services, other announcements, and inquiries. If you no longer wish to receive promotional email communications from us, you may opt out via the unsubscribe link included in such emails or by emailing us at info@waltwines.com. We will comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving promotional emails from us, we may still send you important administrative messages that are required to provide you with the Services (including your account) or for other reasons disclosed in this Privacy Policy.

Additionally, with your consent, we may send you SMS messages for promotional purposes, internal business purposes, internal user research, and to provide customer service, including troubleshooting. To cancel the SMS service at any time, text “STOP” to any text message you receive. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have unsubscribed. After this, you will no longer receive SMS messages from us. If you are experiencing issues with the messaging program you can text “HELP” for more assistance, or you can email us at info@waltwines.com.

10. Supplemental State Notices
Certain states provide individuals rights with respect to their personal data. Note that we are providing the following disclosures and rights regarding personal data in the interest of transparency and our commitment to privacy; such disclosures and rights are not intended to waive any applicable exemptions under federal and state laws.

a. California Privacy Notice

This notice supplements the information contained in the rest of our Privacy Policy and is intended to comply with the California Consumer Privacy Act of 2018 (“CCPA”).

i. Personal data we collect

In the last 12 months (from the date listed at the top of this Privacy Policy), we have collected the following categories of personal data for the following purposes to the third parties (excluding service providers and affiliates) listed in the chart below.

· Identifiers

· Commercial information

· Internet or other electronic network activity information

· Geolocation data

· Audio, electronic, visual, or similar information

· Categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e)) (e.g., signature and financial data)

· Professional or employment information

· Inferences

Because of the overlapping nature of certain categories of personal data identified above, some of the personal data we collect may be reasonably classified under multiple categories.

ii. How we use personal data

We may use or disclose the personal data we collect for one or more of the following purposes:

· Furnish the products and Services you request, process your transactions, and send you related information, such as order and shipping confirmations and receipts

· Provide customer support

· Notify you of products, services, offers, promotions, events and features that may be of interest to you

· Provide discounts, promotions, and other incentive programs