Privacy policy

Effective Date: June 2026

This Privacy Policy describes how Flaviar, Inc. and its affiliates (“Flaviar”) collect, use, disclose, and protect your personal information in connection with the following, which we refer to as our “Services”:

  • “Flaviar Checkout,” which is our checkout functionality that integrates with the e-commerce websites of third-party brand suppliers or publishers (“Brand Websites”);

  • Flaviar’s own websites, currently available at flaviar.com, caskers.com, mashandgrape.com, business.flaviar.com, group.flaviar.com (the “Sites”);

  • Any other products, services, features, applications or events provided by Flaviar.

This policy uses the terms “we,” “us,” and “our” to refer only to Flaviar and its affiliates. This Privacy Policy does not apply to any part of the Brand Websites with which Flaviar Checkout is integrated. Purchases made through Flaviar Checkout are fulfilled by licensed independent third-party retailers (“Retailers”). Although we exchange certain personal information with the brand suppliers, publishers and Retailers, they may handle all personal information pursuant to their own practices and policies, not this Privacy Policy. Likewise, Flaviar handles all personal information pursuant to this Privacy Policy, not the privacy policies of the brand suppliers, publishers or Retailers.

TABLE OF CONTENTS

  1. Information We Collect

  2. Use of Information

  3. Disclosure of Information

  4. Your Rights and Choices

  5. Details for Californians

  6. International Data Transfer

  7. Data Retention

  8. Protection of Information

  9. Updates and Changes to This Policy

  10. Contacting Us

1. INFORMATION WE COLLECT

a. Information You Provide to Us:

When you use or interact with us through our Services, such as our Site or at in-person events, you may provide the following types of information to us or our service providers:

  • Identifiers, such as name, physical address, and contact details;

  • Payment information, such as credit card number, for your purchase;

  • Commercial information, such as:

    • a record of the content on our Site that you experience;

    • details about your purchases and other business interactions with your responses to surveys, and your participation in our events; and

    • information about your interests and preferences;

  • Audio or visual information, such as recordings of calls with us or events;

  • Rough geolocation (which may either be inferred from your IP address or provided directly by you, such as when you complete a transaction);

  • Internet or other electronic network activity information, as described in the Cookies and Other Technology section below;

  • Interactions you initiate or otherwise have with us, including with our customer service team and through your use of our AI customer service tools on the Sites; and

  • Inferences based on any of the above.

b. Information We Obtain Through Use of the Flaviar Checkout

More specifically, when you interact with or make a purchase through Flaviar Checkout, you may provide us or our service providers with more limited information, including:

  • Identifiers, such as name, physical address, and contact details;

  • Payment information, such as credit card number, for your purchase;

  • Commercial information, such as details and a record of your purchases;

  • Internet or other electronic network activity information, as described in the Cookies and Other Technology section below; and

  • Inferences based on any of the above.

c. Cookies and Other Technology

Through our online properties and certain emails, we and third parties may collect information from your computer or other device by automated means such as cookies, web beacons, local storage, JavaScript, mobile-device functionality and other computer code. This information may include unique browser identifiers, IP address, browser and operating system information, device identifiers (such as advertising identifiers), other device information, Internet connection information, as well as details about your interactions with the relevant website, email or other online property (for example, the URL of the third-party website from which you came, the pages on our Sites that you visit, and the links you click on in a website). In some cases (such as cookies), the tools described here involve storing unique identifiers or other information on your device for later use. We and our partners may use this information for the purposes described in this Privacy Policy, including, in certain cases, to provide more relevant advertising to you and to better understand how our users use the Services.

d. Information From Third Parties

We may also receive personal information from third parties, including our service providers, affiliates, operators of websites with which Flaviar Checkout integrates, and partners such as analytics and advertising partners, payment processors, as well as other users of the Services (such as through our Refer-a-Friend program, or when a user ships to you), and publicly available sources, such as social media websites. We may also receive information about you from a third party, such as Facebook or Google, when you use your account with them to sign up for or interact with our Services.

We may combine the information we collect about you from these various sources and treat it in accordance with this Privacy Policy.

2. USE OF INFORMATION

We and our service providers use the information described above for the following purposes:

  • A. Manage and improve the Services generally;

  • B. Process your registration and verify your information;

  • C. Customize content, preferences, and advertising on our Services, across the Internet and elsewhere;

  • D. Facilitate purchases through the Services, including, where applicable, to identify Retailers that can fulfill your order;

  • E. Send you confirmations, updates, security alerts, and support and administrative messages;

  • F. Conduct sales and marketing;

  • G. Conduct business operations such as auditing, security, fraud prevention, invoicing and accounting, analytics, and research and development;

  • H. Protect against, identify, investigate, and respond to misuse of the Services or other unlawful behavior;

  • I. Address legal requirements;

  • J. Establish, exercise, or defend our legal rights; and

  • K. Create aggregated or de-identified information.

In some cases (B and some situations described by D, E, G, and H in the list above), our processing of personal information is necessary for us to comply with a contract with you (such as our Terms of Service) or to take steps in anticipation of entering into a contract with you. In other cases (some situations described under I in the list above), we process personal information because we are required to do so by laws in jurisdictions such as the United Kingdom and countries in the European Economic Area. In certain cases, we process personal information based on your consent, such as certain situations covered by A, C, F, and G in the list above, though those situations do not always require consent. When we process personal information on the basis of consent, it may be express consent or implied consent, depending on the situation and on which laws apply. In the remaining situations in A and C–K in the list above, we process personal information because we believe it is necessary for purposes of our legitimate interests (primarily growing and protecting our business) or the legitimate interests of others. And in some countries outside the UK and European Economic Area, we process personal information on additional or other grounds.

3. DISCLOSURE OF INFORMATION

We may disclose your information as follows:

  • To brand suppliers or publishers whose Brand Websites integrate with Flaviar Checkout: We disclose information about you and your purchases to these brand suppliers or publishers.

  • To local Retailers: We may disclose information about you and the orders you place through the Flaviar Checkout to local Retailers who deliver your purchase, where applicable.

  • To vendors and service providers: We disclose information to companies that provide services to us, such as providers that handle deliveries, analyze data or provide customer service, data storage, marketing, analytics, security, or fraud prevention. We may engage a third party to host or operate any aspect of the Services, including any mechanism through which we send or receive communications, such as our email systems and our Sites.

  • To advertising partners: We disclose information to companies that help us provide advertising on our Sites and across the Internet that we believe will be more interesting to you.

  • To affiliates: We may disclose information to current or future parents, subsidiaries, affiliates, and other companies under common control or ownership with Flaviar.

  • In connection with legal matters: We may disclose information when we believe disclosure is appropriate due to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or government agency; or as otherwise required by law.

  • For the protection of Flaviar and others: We may disclose information when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our employees, our customers, or others; and to enforce our contracts.

  • In connection with corporate transactions: We may disclose your information as part of, or to take steps in anticipation of, a sale of all or a portion of our business, a divestiture, merger, consolidation, asset sale, bankruptcy, or other significant corporate event.

  • In other situations: We may also disclose your information in other situations where legally permitted.

We may use and disclose appropriately aggregated or de-identified information for any purpose.

4. YOUR RIGHTS AND CHOICES

a. Marketing Communications

You can unsubscribe from Flaviar marketing emails by clicking the unsubscribe link in a marketing email or contacting us at privacy@flaviar.com.

b. Cookies and Other Similar Technologies

You can make certain choices regarding the use of cookies and similar technologies on one of our Sites by clicking “Cookie Settings” in the footer of that Site. If you replace, change, upgrade or reset your browser or device, or delete your cookies, or if you use a browser that automatically clears your cookies, you may need to update your choices again.

You also may be able to set your browser to refuse certain types of cookies, or to alert you when certain types of cookies are being used. Some browsers offer similar settings for HTML5 local storage and other technologies too. However, if you block or otherwise reject all cookies, local storage, JavaScript or other technologies, certain parts of our Sites and Flaviar Checkout may not function as expected.

We do not respond to browser-based do-not-track signals.

c. Rights Regarding Your Information

Depending on where you live, you may have certain rights with respect to your information. For example:

  • California, Colorado, Connecticut, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Rhode Island, Tennessee, Texas, and Virginia residents, in addition to residents of the EU and UK, may be able to request:

  • access to and/or a copy of certain personal information we hold about you;

  • correction of inaccurate information that we have about you;

  • deletion of certain personal information we have collected from you; and/or

  • provide information about financial incentives that we offer to you, if any.

  • EU and UK residents can object to the processing of personal information for direct marketing purposes.

  • Your local laws may also permit you to revoke your consent to the processing of your information for certain purposes.

  • California residents can also request information about the categories of personal information we collect, disclose or sell or share about you. California residents can request the categories of sources of such information; the business or commercial purpose for collecting or selling or sharing your personal information; and the categories of third parties to whom we disclose personal information. Such information is also set forth in this Privacy Policy. Minnesota residents can request a list of the specific third parties, other than natural persons, to which we have disclosed personal information. Residents of certain other countries may be able request one or more of the above under applicable law.

  • California, Colorado, Connecticut, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Rhode Island, Tennessee, Texas, and Virginia residents also have opt-out rights described below.

Please note: Your rights and our responses will vary based on your state or country of residency. You may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled.

If you would like information regarding your rights or would like to make a request (or if you are an authorized agent acting in accordance with applicable law), please email us at privacy@flaviar.com.

  • Where permitted by law, we reserve the right to take reasonable steps to verify your identity and requests, including by verifying your account information, residency or the email address you provide.

  • We have no obligation to accept requests from authorized agents representing individuals residing in locations where the law does not require us to do so. For security and legal reasons, we will not accept requests that require us to use websites other than our own. If you are an authorized agent submitting a request on behalf of another individual, we may require appropriate proof of your written authorization before processing the request.

  • Certain information may be exempt from requests under applicable law. For example, we are not required to delete information we must retain for legal compliance or to secure our Services. We may need certain information in order to provide the Services to you, so if you ask us to delete it, you may no longer be able to use the Services.

  • You will not be subject to unlawful discrimination or unlawful retaliation for exercising your rights.

  • Nebraska, New Jersey, Texas, Virginia, and Colorado residents may appeal the denial of a request by emailing us at privacy@flaviar.com.

d. Opt Out of “Sale” of Personal Information or “Sharing” or Processing of Personal Information for Targeted Advertising (California, Colorado, Connecticut, EU, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Rhode Island, Tennessee, Texas, UK, and Virginia Residents Only).

If you are a California, Colorado, Connecticut, EU, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Rhode Island, Tennessee, Texas, UK, or Virginia resident, you may opt out of certain processing of your personal information, including for certain forms of targeted advertising, under applicable law.

We and our advertising partners collect certain information from our visitors, such as device identifiers, cookies, advertising IDs, IP addresses and usage activity. We and our ad partners disclose this information to third parties or combine it with information from other businesses to deliver more relevant (targeted) ads to you. We may also disclose or use hashed contact information to certain advertising partners for this purpose. This activity is known as “sharing” or processing your personal information for targeted ads and may be considered “selling” your personal information under applicable law.

If you (or in the EU, UK, or certain states, your authorized agent) would like to opt out of our use or disclosure of your information for such purposes, you can do so by clicking the Your Privacy Choices link here or in the footer of our Sites. If you use a cookie blocker such as Ghostery, it may block visibility of this tool or link, including in your web footer. See the sections on “Cookies and Other Technology” and “Cookies and Other Similar Technologies” above for more information about how we use cookies and other choices you may have related to those cookies.

If you have enabled a legally recognized browser-based opt out preference signal (currently Global Privacy Control, or GPC) on your browser, we recognize such preference in accordance and to the extent required by applicable law for residents of certain states, such as California, Colorado, Connecticut, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, and Texas. We do so by treating that signal from those residents as an opt-out from “sales” of personal information and from certain “sharing” and processing of personal information for certain targeted advertising with respect to personal information that we receive from or connect to that browser, unless you later consent.

Even if you opt out, you will still see advertising, but it may be less relevant to you, or it may be personalized for you based only on the data that the Flaviar has collected about you. Unless you sign in, you must opt out on each device and each browser where you want your choice to apply. Your preference may be lost if you clear, or your browser is set to clear, cookies. You will need to turn this on for each browser you use unless you sign into your Flaviar account.

5. DETAILS FOR CALIFORNIANS

This section applies only to California residents, and it deals only with information that is subject to the California Consumer Protection Act (CCPA). Data about individuals who live outside California may be handled differently.

During the 12 months leading up to the effective date of this Privacy Policy, we collected all of the types of personal information listed below (as further described in the “Information We Collect” section of this Privacy Policy) above.

Collection of personal information. The categories of personal information that we collected about California residents during the 12 months leading up to the effective date of this Privacy Policy include:

  • Identifiers (e.g., name, mailing address, email address, phone number)

  • Financial information (e.g., credit card numbers, payment information)

  • Details about user interaction with particular content in our Services

  • Audio or visual information (e.g., recordings of calls or meetings)

  • Commercial information (e.g., records of transactions)

  • Internet or other electronic network activity (e.g., device information, IP address, and information about your interaction with the website or app)

  • Geolocation data (inferred from IP address)

  • Inferences drawn from any of the information identified herein

Purposes of use. We may use the personal information about you described in the chart above for the following purposes:

  • Manage and improve the Services generally;

  • Process your registration and verify your information;

  • Customize content, preferences, and advertising on our Services, across the Internet and elsewhere;

  • Facilitate purchases through the Services, including to identify local Retailers that can fulfill your order(s) and when you use Flaviar Checkout on Brand Websites;

  • Send you confirmations, updates, security alerts, and support and administrative messages;

  • Conduct sales and marketing;

  • Conduct business operations such as auditing, security, fraud prevention, invoicing and accounting, analytics, and research and development;

  • Protect against, identify, investigate, and respond to misuse of our website or other unlawful behavior;

  • Address legal requirements;

  • Establish, exercise, or defend our legal rights; and/or

  • Create aggregated or de-identified information.

Information about sales/sharing of personal information. The CCPA defines the “sale” of personal information to include selling user data to random third parties for money, like a data broker does—something we do not do. But it also defines “sale” and “sharing” in a broader sense that includes some more common practices. For example, under the CCPA, these terms include the use of certain advertising services, like when we pay an ad tech company to place a cookie on the browser of a visitor to our website so that the user can see an ad for our Services on other websites. We’ve done that over the last year and plan to continue to do so. The ad tech company can see the website visitor’s IP address and other browser/device data as part of that process. The terms “sale” and “sharing” also cover the use of other advertising services, like if we were to pay a third-party website to serve ads for us to individuals that we specify by giving that website a list of those individuals’ email addresses or other identifiers (or hashes of those email addresses or identifiers).

We do not “sell” or “share” personal information (as those terms are defined under the CCPA) if we have actual knowledge that the consumer is less than 16 years of age.

Californians can opt out of the CCPA “sales” and “sharing” by following the instructions on our Your Privacy Choices page, or they can start their request by emailing us at privacy@flaviar.com and then completing the instructions we send in response (which will include returning to the Sites to deactivate certain cookies). Your browser may also offer a way to activate the Global Privacy Control signal (“GPC”). The Sites treat qualifying browsers for which the user has activated the GPC signal as having opted out of what CCPA calls a “sale” or “sharing” of any California personal information that is collected on that site from that browser using cookies and similar technology. You can override that treatment for a GPC-enabled browser by using the cookie controls available from the website’s footer to opt into particular categories of cookies from that browser. In that case, “sales” and “sharing” via cookies and similar technology in those categories may resume on that browser. Regardless of how you opt out of “sales” and “sharing,” most of the disclosures described in this Privacy Policy will continue, as they don’t qualify as “sales” or “sharing.”

Additional CCPA rights. The CCPA also entitles you to receive certain information from us about certain kinds of financial incentives that we may offer (when we offer them), and it prohibits various forms of discrimination against you for exercising your rights.

In certain circumstances, the CCPA allows consumers to request that businesses limit certain uses of certain “sensitive personal information” due to its sensitive nature. However, we do not engage in such uses of that information.

Retention. We keep your information until after we determine its retention no longer is necessary for the purposes described in this notice. We may collect and use the same category of personal information for different purposes and in different contexts, so the length of time for which we retain a particular category of personal information may vary. For example, information may remain in copies made for backup or business continuity longer than in production systems.

Our specific retention practices may vary by jurisdiction. For example, the chart below lists the categories of personal information we collected about California residents in the last twelve months, along with examples of how long we typically would intend to retain those types of personal information in the particular situations described below. However, these are not necessarily the only retention periods applicable to California personal information, and information about residents of other states and countries may be handled differently.

Do Not Track (“DNT”). DNT is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our websites for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above. Some web browsers offer users a “Do Not Track” privacy preference setting in the web browser. We do not currently recognize or respond to browser-initiated Do Not Track signals.

California “Shine the Light” disclosure. California’s Shine the Light Law (CA Civil Code § 1798.83) allows California residents with which a business has an established business relationship primarily for personal, family, or household purposes (a “customer”) to request a list of the “third parties” to which the business has disclosed certain “personal information” during the preceding calendar year where the business knows or reasonably should know that those third parties used the personal information for the third parties’ own "direct marketing purposes” (each term as defined by the Shine the Light Law). With certain exceptions, direct marketing purposes generally means use of such personal information to solicit or induce a purchase, rental, lease, or exchange of products, goods, property, or services directly to individuals by means of the mail, telephone, or electronic mail for their personal, family, or household purposes. However, a business is not required to provide this information where the business adopts and discloses a policy of not disclosing “personal information” to “third parties” for their “direct marketing purposes” (1) unless the customer first affirmatively agrees or (2) if the customer has exercised an option that prevents that information from being disclosed for such purposes within the meaning of that law. Flaviar maintains such a policy and thus is not required to provide this information. Flaviar provides California residents the ability to exercise rights under the California Consumer Privacy Act (“CCPA”) to opt out of “sharing” of their personal information for cross-context behavioral advertising and “sales” of their personal information (as such terms are defined by the CCPA). Such opt out would apply to any disclosures to which you did not affirmatively agree that are covered by Shine the Light, if applicable. Please click the Your Privacy Choices link in the footer of the Site or Brand Website to exercise those CCPA rights.

6. INTERNATIONAL DATA TRANSFER

We are headquartered in the United States, and recipients of the data disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as the laws of your country where you live. For this reason, your personal information may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of any of the countries where we (or the recipients of disclosures mentioned in this Privacy Policy) operate, pursuant to the laws of such countries. However, this Privacy Policy applies to Flaviar’s operations worldwide. To the extent that personal information is transferred from the European Economic Area (“EEA”) and the UK to any non-EEA members of our group or third-party processors who handle the information solely on our behalf, we will take appropriate measures to require such companies to protect your information in accordance with this Privacy Policy. These measures include signing Standard Contractual Clauses in accordance with EEA and UK data protection laws to govern the transfers of such data where appropriate. For more information about these transfer mechanisms, please contact us as set out below.

7. DATA RETENTION

We keep your information until after we determine it is no longer necessary for the purposes described in this Privacy Policy and we are not legally required to retain it for longer.

If you are a California resident, you can see the section “Details for Californians” above for more detail related to your information.

8. PROTECTION OF INFORMATION

To help protect personal information, we have put in place certain physical, technical, and administrative safeguards. However, we cannot assure you that data that we collect under this Privacy Policy will never be used or disclosed in a manner that is inconsistent with this Privacy Policy.

9. UPDATES AND CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time, such as to reflect changes in our practices or for legal reasons. We will post those changes here or on a similarly accessible page.

10. CONTACTING US

If you have any questions or comments regarding our privacy policy and practices, or to submit a request or complaint, please email our privacy team at privacy@flaviar.com or use the contact details below:

Flaviar, Inc.

ATTN: Legal Department
244 Fifth Avenue, Suite F247

New York, NY 10001

EU:
ATTN: Legal Department
Likozarjeva ulica 1,

1000 Ljubljana, Slovenia