Privacy Policy

Table of Contents

1. Our Privacy Commitment
2. What This Privacy Policy Covers
3. Acceptance and Changes to This Policy
4. Personal Information We Collect
5. How We Collect Your Personal Information
6. Notice of Cookies & Tracking Technology
7. How We Use Your Personal Information
8. Security of Your Personal Information
9. How We Disclose Your Personal Information
10. Your Privacy Rights
11. State-Specific Privacy Rights
12. Our Response to Privacy Requests
13. Non-Discrimination Policy
14. Data Retention
15. Children's Privacy
16. Email & Marketing Communications
17. How to Contact Us

1. Our Privacy Commitment

Capital Spirits values the relationship we have with our customers and prospective customers. We are committed to protecting the confidentiality, accuracy, and integrity of your Personal Information, meaning any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include aggregated and de-identified information, or public information lawfully available from governmental records. We understand the importance of keeping your Personal Information secure.

2. What This Privacy Policy Covers

This Privacy Policy applies to Personal Information collected from and about existing and prospective customers of Capital Spirits, whether collected at our retail locations in Connecticut (our "Stores"), from our website at capspirits.com (the "Site"), or through our concierge services, whether via phone, email, or in-person.

Our Site may include links to websites operated and maintained by third parties. Please note that we have no control over the privacy practices of websites or applications we do not own. We encourage you to review the privacy practices of those third parties.

3. Acceptance and Changes to This Policy

As Capital Spirits continues to improve the services, products, and features we provide, this policy is subject to change. We reserve the right to amend this policy at any time by posting the amended policy on our Site and updating the Effective Date at the top of this page.

By using the Capital Spirits Site or services or shopping in any of our Stores, you signify your acceptance of this Privacy Policy. If you do not agree with any term, condition, or statement herein, your sole option is to discontinue use of Capital Spirits Stores or Site. Your continued use of any portion of the Capital Spirits Site following notification or posting of such changes constitutes your acceptance of those changes.

If you have questions or concerns about our specific policies, please send an email to concierge@capspirits.com.

4. Personal Information We Collect About You

Capital Spirits collects your Personal Information in its normal course of business and over the course of your relationship with us. We do so to save you time and money, deliver the products and services you request, enhance your shopping experience, and support our business operations and objectives. We may have collected during the 12-month period prior to the effective date of this policy, the following categories of Personal Information about you:

5. How We Collect Your Personal Information

We collect Personal Information about you from various sources. For example, we collect and obtain information:

• Directly from you, such as when you visit our Store or Site, navigate and use our website, manually enter Personal Information into our Site's forms to place a purchase and/or delivery order, create an account, or when you communicate with our concierge team.
• Indirectly from you by observing your actions on our Site using cookies and similar technologies (see Cookie Policy below).
• From service providers that process information for us, such as payment processors, delivery partners, web or data hosting, billing, security, marketing, or data management.
• From publicly available sources, such as online database searches or the National Change of Address (NCOA) service to ensure we have correct contact information.

6. Notice of Cookies & Tracking Technology

As you navigate the Site, we may collect information about you using common information-gathering tools, such as cookies, pixels, and web beacons and similar technologies (collectively "Website Navigational Information"). Website Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol ("IP") address, and the actions you take on the Site (such as the web pages viewed and the links clicked).

Cookies

Like many companies, we use cookies to collect and store information about visitors to our Site. Cookies create a faster and easier experience for the user, while also allowing us to learn about your interactions and improve our Site and services.

Types of Cookies We Use:

• Session cookies: These are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID, allowing you to browse our website without logging into each page.
• Persistent cookies: A persistent cookie is stored as a file on your computer and remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
• First-party cookies: These cookies retain your preferences for our Site. They are stored and sent between Capital Spirits' servers and your computer. They are used for personalization and essential Site functions.

Cookie Categories:

• Strictly necessary cookies: These cookies are necessary to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies, services you have asked for, such as logging into your account and using a shopping cart, cannot be provided. These cookies do not store any personally identifiable information.
• Functional cookies: These cookies allow our Site to remember choices you make and provide enhanced, more personal or customized features. For instance, the Site needs to remember your login details. The information these cookies collect is anonymized.
• Performance & analytics cookies: These cookies collect information about how many visitors come to our Site, how visitors use our Site, and how we can optimize our site. These cookies do not collect information that identifies a visitor, as all information these cookies collect is aggregated and anonymized.

Opting Out of Cookies

Through your browser settings, you can disable cookies or request to be prompted before accepting cookies from the Site. Please consult your web browser's "Help" documentation for more information. Certain parts of the Site may function differently, and you may be unable to use some portions of our Site if you choose to disable cookies entirely.

IP Addresses

When you visit our Site, Capital Spirits collects your Internet Protocol ("IP") address to track and aggregate non-Personal Information. For example, we use IP addresses to monitor the regions from which users navigate the Site. In addition, we use your IP address to get an approximate location so we can find a store closest to you. We do this for your convenience and legal compliance reasons.

7. How We Use Your Personal Information

We collect and use your Personal Information for various purposes, including:

• Consumer Transactions: Processing a purchase or fulfilling an order, as well as creating, maintaining, customizing, and securing your account with us.
• Customer Service and Relationship Management: Addressing a customer complaint, question, or service request.
• Customer Experience: Improving website, email, and offerings and interface, identifying and repairing errors in our Site's functionality, testing, research, analysis, and product development.
• Marketing and Advertising: Providing promotions and content that may interest you, managing promotions and events.
• Merchandising: Determining and improving product assortment based on your purchasing and browsing history.
• Analytics: Information about Site performance, hosting our Site, and managing databases.
• Security and Compliance: Maintaining the safety, security, and integrity of our Site, products and services, databases and other technology assets and our business, including preventing fraud, detecting security breaches, and prosecuting violators, and responding to law enforcement requests and meeting requirements of applicable law, court order, or governmental regulations.

8. Security of Your Personal Information

Whether you are shopping on our Site or in our Stores, we use reasonable security measures to protect the confidentiality of Personal Information under our control and appropriately limit access to it. The Capital Spirits Site uses Transport Layer Security (TLS) or equivalent encryption technologies to protect your Personal Information during data transport, including your name, address, and credit card number. However, no security controls are failproof, and Capital Spirits cannot completely ensure or warrant the security of your Personal Information. We therefore urge you to always use caution when transmitting information over the Internet.

When you create an account on capspirits.com you are required to establish a password. You are solely responsible for maintaining the secrecy of your password and account information. We strongly recommend that you do not share this information with others. You can purchase on our Site without creating an account; however, you will need to reenter your Personal Information each time you use our Site to make a purchase.

9. How We Disclose Your Personal Information

We do not disclose any Personal Information about you to others except as stated in this Privacy Policy, as otherwise permitted by law, or authorized by you. We only allow our service providers to handle your Personal Information if we are satisfied with the appropriate measures taken to protect your Personal Information. We also impose contractual obligations on service providers to ensure they can only use your Personal Information to provide services to us and to you.

We may disclose your Personal Information to the following categories of other parties for a business purpose:

• Our employees and authorized agents;
• Service providers for our business, such as payment processors, delivery partners, web or data hosting, billing, accounting, security, marketing, or data management;
• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you;
• Government regulators or law enforcement, where required;
• Our legal advisors and other parties when required by law or pursuant to legal process;
• To any entity involved in the purchase or sale of our business.

Sale of Business Assets

As we continue to develop our business, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. Also, if either Capital Spirits itself or substantially all Capital Spirits assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third-party purchaser in these circumstances.

Other Legally Required Disclosures

Capital Spirits reserves a right to disclose without your prior permission any Personal Information about you or your use of this Site if Capital Spirits has a good faith belief that such action is necessary to: (a) protect and defend the rights, property, or safety of Capital Spirits, employees, other users of this Site, or the public; (b) enforce the terms and conditions that apply to use of this Site; (c) respond to a legally valid request from a competent governmental authority; or (d) respond to claims that any content violates the rights of third parties. We may also disclose Personal Information as necessary to satisfy any applicable law, regulation, legal process, or governmental request.

No Sale of Personal Information

Capital Spirits does not sell your Personal Information to third parties. We do not share your Personal Information with third parties for their direct marketing purposes.

10. Your Privacy Rights

You have the following rights regarding your Personal Information:

• Right to Know: You have the right to request that we disclose what Personal Information we collect, use, disclose, and sell about you.
• Right to Access: You have the right to request access to the specific pieces of Personal Information we have collected about you.
• Right to Delete: You have the right to request that we delete Personal Information we have collected from you, subject to certain exceptions.
• Right to Correct: You have the right to request that we correct inaccurate Personal Information we maintain about you.
• Right to Opt-Out of Sale or Sharing: You have the right to opt-out of the sale or sharing of your Personal Information. However, Capital Spirits does not sell or share your Personal Information.
• Right to Limit Use of Sensitive Personal Information: You have the right to limit our use and disclosure of your Sensitive Personal Information. We only use Sensitive Personal Information for authorized purposes.

To exercise these rights, please contact us at concierge@capspirits.com or call us at the phone number listed in the Contact section below.

11. State-Specific Privacy Rights

Connecticut Residents (CTDPA)

If you are a Connecticut resident, you have specific rights under the Connecticut Data Privacy Act (CTDPA), effective July 1, 2023. You have the right to:

• Confirm whether we are processing your personal data;
• Access your personal data;
• Correct inaccuracies in your personal data;
• Delete your personal data;
• Obtain a copy of your personal data in a portable and readily usable format;
• Opt out of the processing of personal data for:
• Targeted advertising;
• Sale of personal data; or
• Profiling in furtherance of decisions that produce legal or similarly significant effects.

Capital Spirits does not engage in targeted advertising, sale of personal data, or profiling for legal/significant decisions.

California Residents (CCPA/CPRA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). In addition to the rights listed above, you have the right to:

• Request disclosure of categories and specific pieces of Personal Information collected, sold, or disclosed;
• Request deletion of Personal Information, subject to certain exceptions;
• Opt-out of the sale or sharing of Personal Information (Capital Spirits does not sell or share Personal Information);
• Correct inaccurate Personal Information;
• Limit use and disclosure of Sensitive Personal Information.

Shine the Light

Under California's "Shine The Light" law (California Civil Code Section 1798.83), California residents may annually request, free of charge, information about the Personal Information (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year. However, no information is shared with third parties for their own marketing purposes.

Colorado Residents (CPA)

If you are a Colorado resident, you have rights under the Colorado Privacy Act (CPA) similar to those described above for Connecticut residents.

Virginia Residents (VCDPA)

If you are a Virginia resident, you have rights under the Virginia Consumer Data Protection Act (VCDPA) similar to those described above for Connecticut residents.

Nevada Residents

If you are a Nevada consumer, you have the right to request that a company not sell your personal information for monetary consideration to certain other parties. This right applies even if your personal information is not currently being sold. Capital Spirits does not sell personal information.

12. Our Response to Privacy Requests

We will acknowledge receipt of your request within 10 business days of receipt of your request. We provide a substantive response to your request as soon as possible, generally within 45 days from when we receive your request, although we may take longer to process your request under certain circumstances. If we expect your request to take us longer than normal to fulfill, we will notify you.

We usually act on requests and provide information free of charge, but we reserve our right to charge a reasonable fee to cover our administrative costs of providing the information in certain situations, such as excessive or repetitive requests.

In some cases, the law may allow us to refuse to act on certain requests. When this occurs, we will explain why.

13. Non-Discrimination Policy for Exercising Your Privacy Rights

We will not discriminate against you for exercising any of your privacy rights in the following ways:

• Deny you goods or services;
• Charge you different prices for goods or services, whether through denying benefits or imposing penalties;
• Provide you with a different level or quality of goods or services;
• Threaten you with any of the above.

14. Data Retention

We retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Please note that in many situations we must retain all, or a portion, of your Personal Information to comply with our legal obligations; resolve disputes; enforce our agreements; protect against fraudulent, deceptive, or illegal activity; or for another one of our business purposes. We dispose of the information we collect in accordance with our retention policies and procedures.

Examples of retention periods:

• Order and tax records: Retained for at least 7 years to satisfy legal and accounting obligations.
• Account information: Retained while you maintain an active account and for a reasonable period thereafter to allow for reactivation.
• Marketing preferences: Retained while you maintain an active relationship with us or until you unsubscribe.
• Support tickets: Retained for a reasonable period to address follow-up questions and improve service quality.

15. Children's Privacy

Capital Spirits Stores and Site are intended for adults 21 years of age and older. We do not knowingly collect Personal Information from minors under the age of 21. If you have reason to believe that a person under the age of 21 has provided Personal Information to us, please contact us as provided in the "How to Contact Us" section below with sufficient detail to enable us to delete that information from our databases.

We do not knowingly collect, sell, or share the Personal Information of consumers under 16 years of age.

16. Email & Marketing Communications

If you create an account or subscribe to our email list, we collect an email address to communicate with you about your transactions and our promotions. We also use this email address to contact you if there are any issues and to notify you about the status of your order.

If at any time you wish to unsubscribe from marketing emails, please click on the "unsubscribe" link in any email from us or send an email to concierge@capspirits.com.

Please note that even if you unsubscribe from marketing communications, we may still send you transactional and administrative emails, such as order confirmations, account notifications, and important policy updates.

17. How to Contact Us

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or want to update your Personal Information, please contact us:

Please include your name, contact details, and the nature of your request so we can assist you promptly.