Privacy policy.

Effective Date: This privacy policy (this “Privacy Policy”) is effective and was last updated as of November 23, 2024.

This Privacy Policy applies when accessing, using, or otherwise interacting with https://www.whiterabbitwine.com and any related social media channel, website, application, feature, or other online service that is owned or controlled by White Rabbit Investments LLC, a California limited liability company, and its affiliates (“White Rabbit”, “us”, “our,” or “we”) that posts or includes a link to this Privacy Policy (collectively, the “Services”), but expressly excluding any White Rabbit services that state that they are offered under a different privacy policy.  This Privacy Policy informs you of our policies regarding the collection, use, and disclosure of personal information we receive from users of our Services and your choices.  

Please read this Privacy Policy carefully.  By accessing or using the Services, you consent to our Privacy Policy and our collection, use, and sharing of your information as described in this policy and our Terms of Service.

Table of Contents

1.      Information We Collect and How We Collect It

2.      How We Use Your Information

3.      How We Share Your Information

4.      Third Party Advertising and Analytics

5.      How We Respond to “Do Not Track” Signals

6.      Third Party Content and Links

7.      Your Choices About the Information We Collect

8.      Security of Your Information

9.      Services Intended for Adults of Legal Drinking Age

10.   Changes to This Privacy Policy

11.   Consent to International Transfer of Your Information

12.   Contact Us

13.   Notice to Nevada Residents

14.   Notice to California Residents

 

1.      Information We Collect and How We Collect It

We may collect information from you both directly and automatically when you use or visit the Services. Some of this information may be considered “personal information” under various applicable laws.  We consider information that is linked to a specific, identifiable individual (such as your name and email address) to be personal information, and we treat additional information, including IP addresses and cookie identifiers, as “personal information” where required by applicable law.  Note that we may de-identify personal information so that it is non-personal, such as by aggregating it or converting it to a code, sometimes using a function commonly known as a “hash.”  We will treat de-identified information as non-personal to the fullest extent allowed by applicable law.  If we combine non-personal information with personal information, then we will treat the combined information as personal information under this Privacy Policy.

White Rabbit collects information in the following ways:

a.      Information You Provide to Us. In the course of using the Services, you may provide us with certain information. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the services and features you use. The personal information we collect may include the following:

  • names

  • phone numbers

  • email addresses

  • usernames

  • passwords

  • contact preferences

  • billing addresses

  • transaction information

  • debit/credit card numbers (through our third-party payment processor)

We do not intentionally collect from you any “sensitive personal information” as that term and correlative terms are defined in various data privacy laws (generally data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic data and biometric data for the purpose of uniquely identifying an individual) for the purposes of the Services; however, if you volunteer such information to us, such as on any community or forum we make available, it may be available to others publicly viewing such community or forum, and we will process such sensitive personal data the same way we process all unstructured user-provided data in any of our communities and forums.

We may from time to time make available on our Services, or link to, features that allow you to generate your own content or share content online (e.g., on a forum, blog or product testimonial pages) which may be available in public sections of our Services. Please do not embed personal information (including any sensitive personal information) in the content you generate or share online in public forums, because any such information will be shared with and can be collected and used by others.

Our Services may allow you to provide information about your friends and family through our referral services, and our referral services may allow you to forward or share certain content with a friend or family, such as an email recommending our products to them. If you submit any information of a third party to the Services or share any content with a third party through the Services then you represent and warrant that you have consent from that third party to do so.

b.      Information We Collect Automatically From Your Use of the Services.  When you use our Services, we and our third-party service providers may automatically collect certain information (“Usage Information”).  One of the ways we collect Usage Information is when you use our Services, our servers automatically generate logs to help us determine how you use various features to improve our services.  Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as personal information.  This Usage Information may include your IP address and unique device identifiers (“Device IDs”) for your computer, mobile phone, or other device used to access the Services.  A Device ID is a number that is automatically assigned to your device, and our servers identify your device by its Device ID.  We may also collect and track other data and information relating to your device, including the hardware model, the Internet service provider you are using, browser, and operating system you are using.  We may track your use of the Services, including the features you access and how you interact with the Services.

We use (or may use from time to time) the following types of tracking technologies to automatically collect information when you interact with us online:  

Cookies and Local Storage are small text files stored locally on your device that help store user preferences. These technologies are able to store a unique identifier for a device to us to recognize the device whenever the device is used to access our Services. These technologies may be used for many purposes by us and our service providers, such as automatically collecting Usage Information, enabling features, and remembering your preferences. We may use cookies and other technologies to study usage patterns on the Services, to study the effectiveness of our user communications, to manage and measure the performance of our Services, and to personalize your experience of the Services, such as to recognize you when you return to the Services. The information we may store includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. You can find more information about cookies and how they work at www.allaboutcookies.org. 

Certain Browsers or Browser Add-Ons may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our Services may make use of this local storage.

Web beacons (also known as clear GIFs and pixel tags) are small pieces of code used to collect usage analytics.  They help us to determine, for instance, whether a page has been viewed or not and, if so, how many times. When you ask us to send you information on a promotion or a newsletter, we may use web beacons to establish how many of the emails are actually opened. We may use similar tools to collect such information from mobile devices. In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.

Embedded scripts are designed to collect data about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider, is active only when you are connected to a Site and is deactivated or deleted thereafter.

Data Collection from Mobile Devices. We use embedded scripts and similar tools to collect data from mobile devices such as the hardware model, operating system and version, identification numbers assigned to your mobile device, such as the ID for Advertising (IDFA) on Apple devices, and the Advertising ID on Android devices, mobile network information, location data and website usage behavior. In addition, we may use a variety of other technologies that collect similar device and device interaction information for security, fraud detection, and maintenance purposes.

Session replay technology may record your interactions with the Services, such as what pages you visit, how long you visit those pages, and any links you click or information you provide. We use this data for our internal business purposes, such as for website analytics, to improve the Services and other products and services, and to address functionality issues.

We may also use a variety of other technologies that collect similar data for security, fraud detection, site functionality and operational purposes.

c.      Social Media. We may permit you to interact with social media, such as Facebook, Instagram, LinkedIn, and Twitter. When you interact with third-party platforms through the Services, we may receive information about you.  We may also receive information about you if other users of social media give us access to their profiles and you are one of their connections or "friends."  The information we collect is subject to this Privacy Policy. The information collected and stored by the third party remains subject to the third party’s privacy practices, including, without limitation, whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third-party website or service. We or the third party may allow you to disable or remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected.

If you choose to post information to a third-party platform, that information may be public and the third party may have access to information about you and your use of the Services. You may also choose to participate in a way that connects that third-party service with the Services, such as posting to one of our pages on a social media site. Doing so may allow us to collect (or the third party to share) information about you, including personal information, and the third party may allow us to re-post content related to us on our own services.

In addition, these third parties may set their own cookies and collect information about your use of the Services, including your IP address or other device identifiers.  We encourage you to review the privacy policies of third parties that control platforms you post to or that connect to the Services and set your privacy preferences with them. 

2.      How We Use Your Information

We may use non-personal information for any purpose, including for advertising, research, and marketing purposes. We also use information that we collect, including personal information and Usage Information, as disclosed in this Privacy Policy and as follows: 

a.   to fulfill orders for our products or services or complete other transactions that may be engaged in on our Services;

b.   to facilitate account creation and authentication and otherwise manage user accounts;

c.    to share content with friends or family where you have permission to do so, for example, we may allow you to provide information about your friends and family through our referral services, and our referral services may allow you to forward or share certain content with a friend or family, such as an email inviting your friend or family member to try our products;

d.   to provide the Services to you and allow you to participate in the features the Services offer;

e.   to customize and optimize our content for you and your experience on our Services, including delivering marketing communications about our services and targeted advertising tailored to your interests, location and more;

f.     to evaluate and improve our Services, products, marketing, and your experience, identify usage trends, and determine the effectiveness of our marketing and promotional campaigns;

g.   to post testimonials, including with your consent testimonials on our products or Services that may contain personal information;

h.   to provide information on special offers and promotions from us using the contact information you provide and to allow you to register for offers, promotions and events;

i.     to contact you to respond to your customer or prospective customer service questions, feedback, or requests or to provide you with technical support;

j.     to communicate with you about our services, content, features or products you use or request, including to provide you with information concerning changes or updates to the Services which may affect your use of the Services or, in our discretion, changes to our policies;

k.    to respond to subpoenas, court orders or legal process, or to establish or exercise our legal rights or defend against legal claims;

l.     for internal business purposes, including to prevent fraud or other illegal activity, to prevent imminent bodily harm, or to protect ourselves and you from people violating our Terms of Service, or otherwise to protect our or third-party rights or interests, which may include sharing information with other companies, lawyers, courts, or other government entities; and

m.  in any other way we describe when you provide the information, or otherwise with your prior consent.

3.      How We Share Your Information

We may aggregate, de-identify, and/or anonymize any information collected through the Services such that the related information is no longer linked to your personal information.  We may share non-personal information (including hashed or other de-identified data) with third parties for advertising and other purposes.  We do not share your personal information with third parties for those third parties’ own direct marketing purposes unless we provide you the opportunity to opt-in or opt-out prior to such sharing, as required by applicable law.  

In addition, we may share the information we have collected about you, including personal information and Usage Information, as disclosed at the time you provide us with information or your consent, and as described in this Privacy Policy, including:

a.      At Your Request.  We may share information when you direct us to do so, such as if we present you with an opportunity to receive marketing offers from a third party, or if you choose to engage with a social media service or third-party feature through which information about you is shared. We do not control the actions or policies of third parties, and you direct us to share your information at your own risk.  

b.      Service Providers.  We may contract with certain companies to perform services on our behalf, including order/service fulfillment, payment processors, advertising (e.g., ad networks), marketing assistance, e-mail delivery, hosting services, cloud computing services, site maintenance and repair, security, quality assurance, customer service, surveys, and data research and analysis, and provide your information to them only to fulfill such services.

c.      Affiliates and Business Partners. We may share information within our family of affiliated companies and with companies with whom we partner to offer goods or services (e.g., affiliate marketing programs, joint products or promotions).

d.      Sweepstakes, Contests and Promotions. We may offer sweepstakes, contests, or other promotions (any of which, a “Promotion”) that may require registration.  By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern the Promotion, which may contain specific requirements of you (including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing materials).  If you choose to enter a Promotion, personal information may be disclosed to third parties or the public in connection with the administration of such Promotion, including in connection with winner selection, prize fulfillment, as required by law, or as permitted by the Promotion’s terms or official rules (such as on a winner’s list).

e.      In Connection with Business Transactions. In the event White Rabbit undergoes a business transaction, such as a merger with or acquisition by another company, or sale of all or a portion of its assets, we may transfer your personal information and other information to the successor organization in connection with such transaction and disclose it in the course of any due diligence subject to confidentiality.  By providing your personal information, you agree that we may transfer such information to the other entity in such a transaction without your further consent.  If material changes to the Services’ privacy practices will occur as a result of the business transition, White Rabbit or its successor will attempt to notify you, including by posting a notice on the Services.  

f.       For Administrative and Legal Reasons.  We reserve the right to use or disclose any information as needed to satisfy any law, regulation, or legal request; to protect the integrity of the Services; to fulfill your requests; to cooperate in a law enforcement investigation, an investigation on a public safety matter, or an investigation into claims of intellectual property infringement; to protect and defend the legal rights and/or property of White Rabbit and any of our subsidiaries, affiliates, and shareholders, or the Services, any of their users, or any other party; or, in an emergency, to protect the health and safety of users or the general public.

g.      User Generated/Posted Content. If we implement features on our Services that allow you to generate your own content or share content online (e.g., on a blog or product testimonial pages) such content and any information therein may be available in public sections of our Services. Please do not embed personal information in the content you generate or share online in public forums, because any such information will be shared with and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage, dissemination or erasure of personal information embedded in user-generated content or shared content on the Services. By posting personal information online in public forums, you may receive unsolicited messages from other parties.

4.      Third Party Advertising and Analytics/Privacy Controls

We may work with network advertisers, ad agencies, analytics service providers, and other vendors to serve our advertisements on our Services and third-party websites, apps, and elsewhere online and to provide us with data regarding use of and traffic on the Services (including without limitation the pages viewed and the actions users take when visiting the Services) and the effectiveness of our advertisements. For example, if you click on an advertisement for White Rabbit, our service provider(s) may be able to tell us the advertisement you clicked on and where you were viewing the advertisement. The advertisements you see may be served by us or one or more third parties, who may use data about your activities on the Services, and other websites and services you visit across the various devices you use, to provide you targeted content and advertising. Our service providers may collect certain data about your visits to and activity on the Services and other websites and services and may use this data to target advertising to you.

These third parties may set and access their own tracking technologies on your device (including without limitation cookies and web beacons) and may otherwise collect or have access to information about you (such as Device IDs). Some of these parties may collect personal data over time when you visit the Services or other online websites and services. Cookies and web beacons, including without limitation those set by third-party network advertisers, may be used to (among other things): target advertisements, prevent you from seeing the same advertisements too many times, and conduct research regarding the usefulness of certain advertisements to you. We may share certain data such as device identifiers, Device IDs, hashed information, records of transactions you conduct on our Services and other types of de-identified or pseudonymized data with third-party advertising companies, analytics providers, and other vendors for advertising and analytics purposes. In addition, we and our third-party service providers may use this data to perform matching with third-party cookies to provide targeted online marketing. If you would like to opt-out of third-party advertising and analytics, there are a variety of tools available to you:

Cookie Opt-Out Tools. If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. If you block all cookies or delete all cookies our Services may not work properly.

NAI/DAA Opt-Out. Some of the companies we use for delivery of advertising may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”). The NAI provides information regarding targeted advertising and the opt-out procedures of NAI members, including opt-out mechanisms for web browsers, mobile and other connected devices, and a tool to opt out from participating NAI members using your hashed email address for interest-based advertising. You may also want to visit the DAA's website, which provides information regarding targeted advertising and offers an opt-out for DAA-participating companies. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

Google Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of the Services and report on activities and trends.  This service may also collect information about the use of other websites, apps, and online services.  You can learn about Google’s practices by going to https://policies.google.com/technologies/partner-sites, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

5.      How We Respond to “Do Not Track” Signals

Do Not Track (“DNT”) signals offered by some web browsers are settings that request that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and/or other web services you encounter while browsing to stop tracking your activity. There is no consensus among industry participants as to what “Do Not Track” means in this context.  Like many websites and online services, we may not alter our practices when our systems receive a “Do Not Track” signal from a visitor’s browser, except as specifically required by law. You can learn more about Do Not Track at www.allaboutdnt.com.

6.      Third Party Content and Links

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including, but not limited to, any third-party websites, services and applications (and the information or content contained therein) ("Third Party Services") that may be linked to or from the Services and/or that you elect to access through the Services. When you navigate away from our Services to another site, this Privacy Policy is no longer in effect. Those Third Party Services may use their own cookies or other tracking technologies, may independently collect information from you or about you, and match your data with data from other sources and use your data in ways other than described in this Privacy Policy. Your browsing and interaction on any Third Party Services is subject to such Third Party Services’ own rules and policies, which we encourage you to review prior to providing them with your information.

7.      Your Choices About the Information We Collect

a.      Marketing Emails.  You may unsubscribe from any marketing email we may send you through the opt-out mechanism included in each such email, or you can communicate your preferences to us by emailing us at info@whiterabbitwine.com.  We reserve the right to send you certain communications relating to your product orders, use of the Services, service announcements, notices of changes to this Privacy Policy or other terms, or similar administrative or transactional messages, and such messages will be unaffected by any choice to opt out of marketing communications.

b.      Deletion or Correction. Please submit any requests for deletion or correction of your personal information to us at: info@whiterabbitwine.com. Please provide full details about your request, including your contact information and anything you believe is relevant. Under certain circumstances, we may not fulfill your request, such as when doing so would interfere with our regulatory or legal obligations, when we cannot verify your identity, or when applicable law allows or requires us to retain that information.

c.      Account Information. We may from time to time offer means by which you can update your account information by accessing your account on our Services, or you may contact us at info@whiterabbitwine.com.  

d.      Mobile Devices. We may collect location-based information if you use our mobile applications.  You may opt-out of this collection by changing the settings on your mobile device, although that will affect functionality of the Services (e.g., location-based offers). We also may send you push notifications through our mobile application.  You may at any time opt out from receiving these types of communications by changing the settings on your mobile device, or by following the instructions in our push notifications. 

8.      Security of Your Information

We implement commercially reasonable security measures to protect the security of your information. However, no website or Internet transmission is completely secure, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal information safe.

9.      Services Intended for Adults of Legal Drinking Age

Because of the nature of our business, products and services, the Services are not intended for persons under the age of 21.  We do not knowingly collect or solicit personal information from persons younger than the age of 21. If we learn that we have collected personal information from a person in violation of applicable law, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

10.   Changes to this Privacy Policy

To the extent allowed by applicable law, we reserve the right to change this Privacy Policy at any time.  We will inform you by posting a notice on the Services.  We may also provide notice to you in other ways, such as through contact information you have provided.  Your continued use of the Services after the effective date of the revised Privacy Policy will constitute your consent to those changes to the fullest extent allowed by applicable law.  However, we will provide notice and obtain your consent (opt-in or opt-out) if required.  Note that you may no longer be able to use certain or any features of the Services if you do not consent to the revised Privacy Policy.      

11.   Consent to International Transfer of Your Information

We are a U.S.-based company so if you are located outside of the United States, please be aware that the information that we collect from you will be transferred to, and stored at, a destination outside of your country. By using our Services or providing us with any information, you fully understand and unambiguously consent to this transfer to, and processing, usage, sharing, and storage of your information in, the United States and other jurisdictions, which may have different and in some cases less protective privacy laws than those in your country.  As a result, your information may be subject to access requests from governments, courts, or law enforcement in the United States and other countries according to the laws in those jurisdictions. 

12.   Contact Us

If you have any questions, comments, or concerns regarding our Privacy Policy and/or practices, please send an email to: info@whiterabbitwine.com.

13.   Notice to Nevada Residents

Nevada S.B. 220 provides consumers with the ability to opt out of the sale of their personal information. We do not sell your personal information as defined in S.B. 220. However, you may still submit an opt-out request, and if our practices were to change in the future, we would honor your request.  If you are a Nevada resident and would like to opt out of the sale of your covered information, your request must be submitted to info@whiterabbitwine.com. Your request must include your full name, street address, city, state, zip code, and a valid email address so that we can contact you if needed regarding your request.  If you previously provided a phone number, including it will assist us in making sure we identify you as someone who wants to opt out.  You may be required to take reasonable steps as we determine from time to time to verify your identity and/or the authenticity of your request.

14.   Notice to California Residents

California’s “Shine the Light” law (Civil Code Section 1798.83, also known as S.B. 27) allows California residents to request from companies conducting business in California certain information relating to third parties to which the company has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes.  Alternatively, the law provides that a company may comply, as White Rabbit does, by disclosing in its privacy policy that it provides consumers choice (opt in or opt out) regarding sharing personal information with third parties for those third parties’ direct marking purposes, and information on how to exercise that choice. White Rabbit will not share your personal information with third parties for their direct marketing purposes without providing you with a choice (opt in or opt out) prior to sharing your personal information with such third parties.  If you do not opt-in or if you opt-out at the time we offer that choice, we will not share your information with that identified third party for its direct marketing purposes.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please write to us at info@whiterabbitwine.com, put the statement “California Privacy Rights” in the subject line and include in the email your name, street address, city, state, and zip code. We are not responsible for notices that are not addressed or sent properly, or do not have complete information.