This privacy policy (the "Privacy Policy") sets forth the data protection and privacy practices and procedures of Direct Wines, Inc., a Delaware corporation, its affiliates, and its and their respective parents and subsidiaries (individually and collectively, "Company," "we," "our" or "us"), and applies to the URL,, and all other websites, social media pages and accounts owned by the Company (individually, and collectively, the "Websites"), and all mobile applications owned by the Company (together with the Websites, collectively, the "Company Sites").


Through the use of the Company Sites, the Company markets wines and related products directly to consumers, and offers consumers the opportunity to create a personal account with the Company (the "Account") or to log in to the Company Sites as a guest (the "Guest Log-In"), and to take advantage of the various products and/or services, including, without limitation, the opportunity to purchase wine and related products from licensed retailers in their state and to register as members of the various wine clubs that the Company services (the "Wine Clubs") (collectively, the "Wine Services"). The sale and delivery of orders purchased by consumers will be executed and fulfilled by third party retailers holding valid licenses issued by state alcohol beverage agencies allowing for the legal sale of wine.


Although many areas of the Company Sites do not require registration and may be accessed by you without having to disclose any personal information, when using the Wine Services and or other aspects of the Company Sites, we or our service providers may collect, use and share personally identifiable information, such as your name, age, billing address, shipping address, age, email address, telephone number, password, and credit card information (collectively, "PII"). Please remember that it is your responsibility to protect the confidentiality of your login and password data. The Company Sites are directed to adults aged twenty-one (21) or older.

We collect PII from you when you voluntarily provide it directly to us when you engage in activities on the Company Sites. We use the PII we collect for various purposes, including to: (i) create your Account; (ii) permit a Guest Log-In to the Company Sites; (iii) create a shopping cart and/or process your orders placed in connection with the Wine Services; (iv) register a Wine Club membership; (v) contact you, for example, if there is an issue with any orders placed through our Wine Services or your Wine Club membership; (vi) send you email communications, and/or newsletters you have requested; (vii) respond to questions or other requests; (viii) inform you of new products, services, promotions, and offers and those of our Brand Partners (as defined below) through email, postal mail, telephone or other means; (ix) contact you with respect to your use of the Company Sites or changes to the Privacy Policy or other Company policies; (x) improve the Company Sites and the content, features and services provided by the Company Sites, as well as customer service; (xi) update and maintain the accuracy of our information; (xii) use for our internal business purposes; (xiii) send you other notices in order to comply with applicable laws and regulations; and (xiv) for other purposes disclosed at the time you provide your PII. Depending on the activity, some of the PII we ask you to provide us is required and some is voluntary. If you do not provide the required information for a particular activity, you may not be permitted to engage in that activity.

The PII you provide to us to create your Account will be available for viewing by visiting the Company Sites and entering your personal log-in information that you create when registering your Account. By creating an Account, you may also utilize the "My Wine Cellar" feature of your Account, which tracks your order history, status of pending orders, favorites, preferences, credits, and Wine Club memberships. If you choose not to create an Account but to instead place orders by using a Guest Log-In, you may contact the Company to review or update the PII you have provided by using the telephone numbers and/or addresses listed below under the heading entitled "Contact Information." If you ever use a public computer to access the Company Sites, we strongly encourage you to log out at the conclusion of your session. We may permit you to log into your Account via social networks, but please note that by doing so, your use of a social network will be governed by such social network's privacy policy and terms and conditions.


When you visit the Company Sites, we may also collect certain non-personally identifiable information from you ("NPII"), including, without limitation, website usage information about how our visitors use and navigate the Company Sites, including the number and frequency of visitors to each web page, the duration of their stays, the visitor's browser and operating system, the domain name of each visitor's Internet service provider, and certain other information (e.g., IP address and clickstream data). When you request pages from the Company Sites, our servers log your IP address. We may use IP addresses for a number of purposes, such as system administration, to report aggregate information to our business partners or to audit use of the Company Sites. We may share NPII with others without express notice to you or consent from you, and we may exploit, use and disclose your NPII without limitation of any kind.

We may also collect certain information automatically, including through the use of cookies, web beacons and other technologies. We use "cookies" (i.e., small pieces of information placed on your computer hard drive) on certain parts of the Company Sites. Cookies allow websites to remember user activity and visits to a site. We use cookies on the Company Sites to determine the number of unique visitors we host on the Company Sites over any given period of time and to keep track of items placed in the "shopping cart" during a visit to the Company Sites. We do not use cookies to collect PII. You can program your computer to warn you each time a cookie is being sent, or disable cookies on your computer by indicating this in the preferences or options menus in your browser. However, by blocking all cookies you may not have access to certain features on the Company Sites. We may use third party advertising companies to serve ads or conduct email campaigns on our behalf. These companies may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness.

We may also use "pixel tags" (sometimes called "web beacons" or "clear gifs"), which are tiny graphic images, on the Company Sites. Pixel tags help us analyze users' online behavior and measure the effectiveness of the Company Sites and our advertising and marketing. We may also use other analytical tools to evaluate site performance through the use of aggregated data, which contain no PII. We work with service providers that help us track, collect, and analyze this information.

Cookies, pixel tags, and/or other analytical tools that we may use on the Company Sites may collect information about your visit, including the pages you view, the features you use, the links you click, and other actions you take in connection with the Company Sites. This information may include your computer's Internet protocol (IP) address, your browser type, your operating system, date and time information, and other technical information about your computer. We may also track certain information about the identity of the Company Sites you visited immediately before coming to the Company Sites. We do not otherwise track any information about your use of other Company Sites. Cookies, pixel tags, and/or other analytical tools in our emails may also be used to track your interactions with those messages, such as when you receive, open, or click a link in an email message from us. We may also work with businesses that use tracking technologies to deliver advertisements on our behalf across the Internet. These companies may collect information about your visits to the Company Sites and your interaction with our advertising and other communications, but no PII is shared with them.

We may combine the NPII collected through cookies, pixel tags and other analytical tools with other information we may have collected from you. This information may be used to improve the Company Sites, to personalize your online experience, to help us deliver information to you, to determine the effectiveness of advertising, and for other internal business purposes.

Ads appearing on the Company Sites may be delivered to users by us or one of our advertising partners. Our advertising partners may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement. In this way, ad servers may compile information about where you, or others who are using your computer, saw their advertisements and determine which ads are clicked on. This information allows an ad network to deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by us and does not cover the use of cookies by any advertisers.


Except as disclosed in this Privacy Policy, the Company does not share your PII with unaffiliated third parties. We may disclose your PII to outside individuals and/or companies who help us: (i) bring you the products and services we offer; (ii) create, operate, and maintain the Company Site(s); and (iii) with specialized services such as payment processing, shipping, mail and e-mail distribution, mobile messaging, website(s) hosting, monitoring, analytics, promotions management, survey and mobile payment processing. We provide these third-party companies only with the information they need to perform their services. For mobile payment processing, the mobile payment service providers will provide your information to your mobile telephone service provider to bill you directly. We also work with third parties, such as ad networks, analytics companies and social networking platforms, and they may collect information about your online activities over time and across our sites and other online services. We require that these outside individuals and/or companies agree to keep all information shared with them confidential and to use the information only to perform their obligations to us. We may also contribute to or participate in cooperative databases, which give other companies access to your PII.

We work with certain strategic partners (the "Brand Partners") in connection with the creation and operation of various co-branded Wine Clubs, which are promoted by us and our Brand Partners. We disclose only the PII required to make these particular Wine Clubs work and to support your membership with them, which typically includes your name and/or email address, as well as information regarding the purchases you make through the particular Wine Club. We disclose this information to our Brand Partners under an agreement that requires that they maintain the confidentiality and security of your PII in the same manner The Company does. If you do not wish to receive marketing, promotional, or other communications from our Brand Partners, you must contact them directly.

We may sell, transfer or otherwise disclose user information, including PII, in connection with a corporate merger, consolidation, the sale of all or substantially all assets or of a business group, or other corporate change of the Company.

We may disclose information about our users, including PII, when legally required to do so at the request of governmental authorities conducting an audit or investigation, or to verify or enforce compliance with the policies governing the Company Sites and applicable laws, rules, and regulations. We may use IP addresses to identify users in cooperation with Internet service providers or law enforcement agencies, and may also disclose user information whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests or safety of the Company Sites, our users or others.

The Company may share NPII with third parties. We may use and share aggregated and anonymous NPII to conduct market research and analysis for ourselves and/or for our business partners. Given the anonymous, non-personally identifiable nature of such information, there are no restrictions under this Privacy Policy on how we may use or disclose such information. For example, we may freely share such information with third parties who may use such data for their own marketing, advertising, research, or other business purposes. We may also freely share such information with our service providers in order for them to perform services to or for us. We authorize certain service providers to utilize NPII for their business purposes and in accordance with their privacy policies, such as to report on usage or industry trends to their customer base.


You may opt out of your subscriptions to receive marketing mailings or e-mail communications from the Company at any time by (a) following the instructions to "opt-out" of future marketing communications contained within the direct mailing, or e-mail, that you receive from the Company, or (b) by sending us an email or writing to us at the addresses listed below under the heading entitled "Contact Information." Please allow up to ten (10) business days for changes to take place. During that time, you may continue to receive such communications from us that were already in process.

You can opt out of accepting cookies or disable them from your browser. The "help" function on most browsers contains information on how you can set your browser to notify you before accepting cookies or can disable them entirely. If you opt out of cookies, you will not be able to take advantage of various features of the Company Site(s) that are available to other users. For example, we may use cookies to recognize you by name when you return to a Company Site so you don't have to login again and provide your password.

You may ask us to delete your PII from our system, however, because we archive and keep track of past transactions, you cannot delete information associated with past transactions or archived information on the Company Sites.

If you do not receive a response from us to any emails you send to us within ten (10) business days, please send us another email as your original email may not have been received.


Our Company Sites may include links to other websites whose privacy practices may differ from ours. We are not responsible for the privacy practices of websites operated by third parties that are linked to or integrated with the Company Sites or for the privacy practices of third parties. If you submit PII to any of those websites, your PII is governed by the privacy statements of those websites. We encourage you to carefully read the privacy statement of any website you visit.


While the Company strives to secure your PII, even reasonable security measures do not guarantee the security of any information you transmit via the internet, including to the Company. The Company cannot guarantee that information it seeks to protect will be protected under all circumstances, including those beyond its reasonable control. You acknowledge and agree that you transmit information to the Company via the Company Sites at your own risk. Additionally, please be advised that if you share emails you receive from the Company with others, you may be unintentionally sharing your PII contained in these emails with such parties and acknowledge that you will be sharing at your own risk.


The Company Sites are directed to adults aged twenty-one (21) or older. We do not knowingly collect PII from children under thirteen (13) years of age. We will promptly delete any information later determined to be from a user younger than thirteen (13) years of age.


The Company Sites are located in the United States. Your PII will be processed and shared in the United States, where data protection and privacy regulations may provide different levels of protection compared with non-United States jurisdictions. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the Company Sites or providing us with your information, you consent to this transfer.


The Company may modify this Privacy Policy from time to time. If we make any substantial changes in the types of PII we collect or how we use it, we will inform you of such changes by posting a revised notice on our Company Sites and such changes will be effective when posted. Unless you inform us otherwise, we will use your PII consistent with the Privacy Policy currently in effect. It is your responsibility to review any such changes or updates and check the Company Sites from time to time to be sure you understand all terms and conditions, agreements and policies of the Company Site(s) and are in compliance with them. Your continued use of the Company Sites following the posting of any amendment, modification or change shall constitute your acceptance thereof.


If you are a California resident, California Civil Code Section 1798.83 permits you to request information with respect to the disclosure of your PII by us to third parties for such third parties' direct marketing purposes. We are only required to respond to a particular customer's request for such information once during a calendar year. To make such a request, please send us an email or write to us at the addresses listed below under the heading entitled "Contact Information."

In addition, please note the following:

(a) (b) (c) (d) (e) (f) (g)


We do not want you to send to us any confidential or proprietary information through email or otherwise. Any information, materials, suggestions, ideas or comments sent to us will be considered non-confidential, and by submitting the same to us, you are giving us the absolute right to use, modify, reproduce, transmit, display and distribute the information for any purpose whatsoever, with no payment or other compensation to you. However, we will not use your name unless we are required by law to identify the source of the materials, information, suggestions, ideas or comments, or unless we first obtain your permission.


We may freely assign this Privacy Policy or any of our rights and/or obligations hereunder.


Any disputes regarding this Privacy Policy are subject to our Terms & Conditions, including that this Privacy Policy will be governed by the laws of the State of New York, applicable to agreements made and performed in New York, and the Dispute Resolution Policy therein. THE DISPUTE RESOLUTION POLICY INCLUDES A REQUIREMENT THAT ANY DISPUTES BE SUBMTITED TO ARBITRATION (NOT TO A COURT OR A JURY) AND A WAIVER OF ANY RIGHT TO BRING A CLASS ACTION OR PRIVATE ATTORNEY GENERAL CLAIM. See Terms & Conditions SOME JURISDICTIONS DO NOT ALLOW THE LIMITATIONS OR EXCLUSION OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO SOME OF THE TERMS & CONDITIONS MAY NOT APPLY TO YOU.


If you have any questions or comments about our Privacy Policy, or would like to review or update the PII that you have provided to us, please contact us at:



This Privacy Policy is effective as of April 7th, 2016.