This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual. It also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control and people we don’t manage.

Categories of Personal Data We Collect

The following details the categories of Personal Data that we collect and have collected over the past 12 months:

Profile or Contact Data

Category of Personal Data
Profile or Contact Data

Examples of Personal Data We Collect

• First and last name
• Email
• Phone number
• Mailing address

Categories of Third Parties With Whom We Share this Personal Data

• Service providers
• Advertising Partners
• Analytics partners
• Business partners

Payment Data

Category of Personal Data
Payment Data

Examples of Personal Data We Collect

• Payment card type
• Payment card number
• Billing address, phone number, and email
• Information necessary to process refunds

Categories of Third Parties With Whom We Share this Personal Data

• Service providers (specifically our payment processing partners)

Commercial Data

Category of Personal Data
Commercial Data

Examples of Personal Data We Collect

• Purchase history
• Consumer profiles, including wine-related preferences and interests

Categories of Third Parties With Whom We Share this Personal Data

• Service providers
• Analytics partners
• Business partners

Device/IP Data

Category of Personal Data
Device/IP Data

Examples of Personal Data We Collect

• IP address
• Device ID
• Type of device/operating system/browser used to access the Services

Categories of Third Parties With Whom We Share this Personal Data

• Service providers
• Advertising partners
• Analytics partners

Web Analytics

Category of Personal Data
Web Analytics

Examples of Personal Data We Collect

• Web page interactions
• Referring webpage/source through which you accessed the Services
• Non-identifiable request IDs
• Statistics associated with the interaction between device or browser and the Services

Categories of Third Parties With Whom We Share this Personal Data

• Service providers
• Advertising partners
• Analytics partners

Social Network Data

Category of Personal Data
Social Network Data

Examples of Personal Data We Collect

• Email
• User name

Categories of Third Parties With Whom We Share this Personal Data

• Service providers

Consumer Demographic Data

Category of Personal Data
Consumer Demographic Data

Examples of Personal Data We Collect

• Age, month and year of birth
• Zip code
• Gender
• Additional data you may optionally provide through survey response

Categories of Third Parties With Whom We Share this Personal Data

• Service providers

Geolocation Data

Category of Personal Data
Geolocation Data

Examples of Personal Data We Collect

• IP-address-based location information
• GPS data

Categories of Third Parties With Whom We Share this Personal Data

• Service providers
• Analytics partners

Inferences Drawn From Other Personal Data Collected

Category of Personal Data
Inferences Drawn From Other Personal Data Collected

Examples of Personal Data We Collect

• Profiles reflecting user attributes
• Profiles reflecting user behavior

Categories of Third Parties With Whom We Share this Personal Data

• Service Providers

Other Identifying Information that You Voluntarily Choose to Provide

Category of Personal Data
Other Identifying Information that You Voluntarily Choose to Provide

Examples of Personal Data We Collect

• Identifying information in emails or letters you send us
• Voluntarily-provided information to help us respond to security or safety incidents

Categories of Third Parties With Whom We Share this Personal Data

• Service Providers

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

When you provide such information directly to us

• When you create an account or use our interactive tools and Services.
• When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
• When you send us an email or otherwise contact us.
• When you provide us information at in-person or remote events.

When you use the Services and such information is collected automatically.

• Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).
• If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
• If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

Third Parties

Vendors

• We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.
• We may use vendors to obtain information to create or augment existing user profiles.

Our Commercial or Business Purposes for Collecting Personal Data

Our Commercial or Business Purposes for Collecting Personal Data

Providing, Customizing and Improving the Services

• Creating and managing your account.
• Processing orders or other transactions; billing.
• Providing you with the products, services or information you request.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Services.
• Improving the Services, including testing, research, internal analytics and product development.
• Personalizing the Services, website content and communications based on your preferences.
• Doing fraud protection, security and debugging.
• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

Marketing the Services

• Marketing and selling the Services.
• Showing you advertisements, including interest-based or online behavioral advertising.

Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Coravin or the Services.
• Sending emails and other communications according to your preferences or that display content that we think will interest you.

Meeting Legal Requirements and Enforcing Legal Terms

• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property or safety of you, Coravin or another party.
• Enforcing any agreements with you.
• Responding to claims that any posting or other content violates third-party rights.
• Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

We disclose your Personal Data to the categories of service providers and other parties listed in this section. For more information on how these disclosures are treated under state law, please refer to the state-specific sections below.

Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:

• Hosting, technology and communication providers.
• Security and fraud prevention consultants.
• Support and customer service vendors.
• Product fulfillment and delivery providers.
• Payment processors, who collect your voluntarily-provided payment information necessary to process your payment.

Advertising Partners. These parties help us market our services and provide you with offers that may be of interest to you. They include:

• Ad networks and affiliate management platforms.
• Data brokers.
• Marketing providers.

Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include:

• Companies that track how users found or were referred to the Services.
• Companies that track how users interact with the Services.

Business Partners. These parties partner with us in offering various services.

Parties You Authorize, Access or Authenticate

• Third parties you access through the services.
• Social media services.
• Other users.

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services or satisfy a business need. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

At Coravin, we take security vulnerabilities seriously and appreciate your help notifying us of vulnerabilities in a responsible manner. If you encounter a security vulnerability, please submit it to security[at]coravin.com.

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at csr@coravin.com.

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at csr@coravin.com.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

• The categories of Personal Data that we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting or selling your Personal Data.
• The categories of third parties with whom we have shared your Personal Data.
• The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (which may include verification that you are able to login to your account and/or providing us with account or order history information), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

• Email us at: csr@coravin.com

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Personal Data Sales Opt-Out and Opt-In

In this section, we use the term ‘sell’ as it is defined in the CCPA. We sell your Personal Data, subject to your right to opt-out of these sales.

We sell your Personal Data to the following categories of third parties:

• Advertising partners.
• Analytics partners.

Over the past 12 months, we have sold the following categories of your Personal Data to categories of third parties listed above:

• Device/IP Data
• Web Analytics

You have the right to opt-out of the sale of your Personal Data. You can opt-out using the following methods:

• Clicking the Do Not Sell My Information link
• Email us at csr@coravin.com

Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.

To our knowledge, we do not sell the Personal Data of minors under 16 years of age.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Our Financial Incentive Program

From time to time, we may offer financial incentives, including discounts to you as compensation, for the collection of your Personal Data, the sale of your Personal Data, or the deletion of your Personal Data. These financial incentives include offering price discounts, shipping cost advantages, and access to special promotions, offers, and events in exchange for joining Club Coravin (where available) or subscribing to our newsletter, which requires providing us with your Contact Data. You may revoke your consent to participate in our financial incentive program at any time by emailing us at csr@coravin.com or by unsubscribing from our newsletter.

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at csr@coravin.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at csr@coravin.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

EU and UK Residents

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Coravin will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at csr@coravin.com.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services and send you the goods you order from our site. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
• Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
• Examples of these legitimate interests include (as described in more detail above):
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Sharing Personal Data

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.

EU Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at csr@coravin.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about Coravin's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here:https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Coravin and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Coravin in the U.S. and will be hosted on U.S. servers, and you authorize Coravin to transfer, store and process your information to and in the U.S., and possibly other countries.

Coravin complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF as set forth by the U.S. Department of Commerce. Coravin has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/

Coravin is committed to the EU-U.S. Data Privacy Framework Principles of (1) notice, (2) consent, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access and (7) recourse, enforcement and liability with respect to all Personal Data received from within the EU in reliance on the EU-U.S. Data Privacy Framework Principles. The Data Privacy Framework Principles require that we remain potentially liable if any third party processing Personal Data on our behalf fails to comply with these EU-U.S. Data Privacy Framework Principles (except to the extent we are not responsible for the event giving rise to any alleged damage). Coravin's compliance with the EU-U.S. Data Privacy Framework Principles is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the EU-U.S. Data Privacy Framework Principles, EU individuals have the right to obtain our confirmation of whether we maintain Personal Data relating to you in the U.S. Upon request, we will provide you with access to the Personal Data that we hold about you. You may also correct, amend, or delete the Personal Data we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the U.S., should direct their query to csr@coravin.com. If requested to remove data, we will respond within a reasonable timeframe.

We will provide you with the choice to opt-out, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than the purpose for which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your Personal Data, please submit a written request to csr@coravin.com.

In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Coravin's accountability for Personal Data that it receives in the U.S. under the EU-U.S. Data Privacy Framework Principles and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, Coravin remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process Personal Data on its behalf do so in a manner inconsistent with the Data Privacy Framework Principles, unless Coravin proves that it is not responsible for the event giving rise to the damage.

Coravin commits to resolve complaints about your privacy and our collection or use of your Personal Data transferred to the U.S. Please contact us at csr@coravin.com with any questions, concerns or complaints.

If your complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms as set forth in Annex 1 of the U.S. Department of Commerce’s Data Privacy Framework.

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Coravin website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• csr@coravin.com
• 34 Crosby Drive, Suite 101, Bedford, MA 01730