Privacy Policy

Effective Date: March 11, 2025

Retail Services & Systems, Inc. and its affiliated companies doing business under the Total Wine & More and related brands (collectively, “Total Wine,” “we,” “our,” or “us”) know that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This Privacy Policy lets you know what information we collect, how we may share that information, and your choices regarding the sharing of your information. Please note that our privacy practices are subject to the applicable laws of the places in which we operate. You will see additional region-specific terms that only apply to customers in those geographic regions, or as required by applicable laws.

You are subject to our Terms & Conditions, which govern your access to and use of the Total Wine & More Sites and Stores (defined below). The Terms & Conditions contain numerous additional details about our business and your use of our Sites, including termination of use, disclaimer of warranties, limitations of liability, choice of law, and dispute resolution through binding arbitration, among others. Click Terms & Conditions for more information.

Privacy Policy table of contents

Our privacy commitment
What our Privacy Policy covers
Acceptance of and changes to this Privacy Policy
Personal Information we collect and use
How we collect Personal Information
Notice of cookies & clickstream technology, including opting out
How we use your Personal Information
Security of your Personal Information
How we disclose or share your Personal Information
Your rights related to Personal Information held by us
Additional state-specific disclosures and notices
Our response to requests
Non-discrimination policy for exercising your privacy rights
Notice of financial incentive
Retention
Automated License Plate Recognition Usage and Privacy Policy
Updating your Personal Information
E-mail & account registration
Children’s and minor’s privacy
Chatbot Technology
How to contact us

1. Our privacy commitment

We value 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 our Privacy Policy covers and who is subject to it

This Privacy Policy covers our customer-facing operations and applies to Personal Information collected from and about existing and prospective customers of businesses that operate retail alcohol stores under the Total Wine & More and related brand names in certain states, whether collected at the retail location (a “Store”), or from the Total Wine & More website, webpages, mobile site, and/or app (the “Sites”), or through the &MORE Rewards Program, Concierge Program, or Customer Care, whether via phone, email, or chat. This Privacy Policy also applies to Members of the &MORE Rewards program. See the terms and conditions of the Rewards program page for more information. Terms of the &MORE Rewards program vary by state, so click on the state that applies to you.

We may provide different or additional privacy notices concerning certain activities, programs, and offerings. We may also provide additional “just-in-time” notices that may supplement or clarify our privacy practices or provide you with additional choices regarding your Personal Information. California residents who are job applicants for work in any of our businesses operating in the United States are subject to a different privacy policy regarding the information collected during the application process and any employment. See the Job applicant terms & conditions page for more information.

Our Sites may include links to websites and/or applications 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 of and changes to this privacy statement

As Total Wine continues to improve the services, products and the 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 Total Wine Sites or services or shopping in any of our Stores, you signify your acceptance of this Privacy Statement. If you do not agree with any term, condition or statement herein, your sole option is to discontinue use of Total Wine Stores or Sites. Your continued use of any portion of the Total Wine 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 e-mail to privacy@totalwine.com.

4. Personal Information we collect about you

Total Wine collects your Personal Information (including individuals associated with you, all of whom are referred to as “you” in this Privacy Policy) 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 Statement (or since July 1, 2023, for Connecticut residents), the following categories of Personal Information about you:

Identifiers, such as name, alias, delivery address, delivery signature, postal address, phone number, email address, date of birth, age or age range, IP address, device identifiers, unique personal identifier, Loyalty ID, online identifier, and other similar unique identifiers, certain of which are described in the “Cookie Policy” below
Characteristics of protected classifications under California or other state or federal law, such as age (over 40); gender identity or gender expression; marital status; military or veteran status; or disability information.
Commercial information, such as transaction history, purchase history or tendencies, last 4 digits of credit cards, &MORE Rewards or awards purchases, points, and benefit utilization, returns data, product delivery data, product or service ratings, product or service reviews, and email or mail subscriber status.
Internet or other similar network activity, such as search history and information about consumer’s interaction with an Internet website (including the Sites), application, or advertisement, as well as push-notification status, text-message status, email interactions, survey responses, and similar interactions with marketing efforts.
Geolocation Information, such as presence at a retail location, billing information, product delivery information, or “Preferred Store” election on the Sites.
Audio, video and/or still images collected from CCTV cameras and similar technology (only if you visit one of our Stores that use this technology), session replay recordings of visits to the Sites, or Customer Service phone call recording and Chatbot technology (described below) when authorized by you.
Job applicant information, such as education, employment, or other professional information. See the Job applicant terms & conditions page for more information.
Inferences drawn from Personal Information for purposes of creating a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, and attitudes.
Sensitive Personal Information. We may collect minimal sensitive personal information, as defined in the applicable state privacy laws, but only with your consent. Such sensitive personal information consists of account passwords used to access the Sites, which are encrypted and inaccessible to Total Wine in the ordinary course of business. We do not use sensitive personal information to infer characteristics about you.

As further explained below, you can control whether and how we collect Personal Information through cookies and other tracking devices. See “Opt Out of Cookies” in Section 6 of these Terms.

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 Sites, navigate and use our website or mobile app, manually enter Personal Information into our Sites’ forms to place a purchase and/or delivery order or join and use the &MORE Rewards program, or when you post on-line to a social media account.
Indirectly from you by observing your actions on our Sites or in our Stores using technology provided by third-party vendors who collect such information for Total Wine’s internal usage. For example, we utilize a software tool called “session replay” to assist us in understanding and troubleshooting an individual user’s journey through our website or app. This technology captures bits of code associated with a user’s clicks, keyboard entries, scrolls, and mouse movements. We share session replay data with our Customer Care team to reconstruct your journey and identify bugs, errors, or user experience (UX) and design flaws whenever you report errors or difficulty navigating our Sites or to improve your use of our Sites. The vendors who provide us with session replay and similar technologies are strictly prohibited from using any Personal Information for their own purposes––they merely process the data for the exclusive use of Total Wine. Affiliated Companies and Service Providers that process information for us, such as third-party social networking providers, tech or customer support, operations, web or data hosting, billing, credit card processing, accounting, security, marketing, or data management, validation, enhancement, or hygiene. For example, we get updated addresses from the National Change of Address (“NCOA”) service to ensure we have the correct contact information for our customers.
Consumer data resellers and renters, such as entities that compile Personal Information about prospective or current Total Wine customers for purposes of updating, verifying or deduplicating Personal Information, or prospecting new potential customers.
From publicly available sources. For example, online database searches.

6. Notice of cookies & clickstream technology, including opting out

As you navigate the Sites, we may also 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 Sites (such as the web pages viewed and the links clicked).

Cookies

Like many companies, we use various technologies, including cookies and pixels, to collect and store information about visitors to our Sites. These technologies perform similar functions to help us operate our Sites and serve you better. The use of cookies on our Sites creates a faster and easier experience for the user, while also allowing us to learn about your interactions, conduct analytics activities, improve our Sites and services, and facilitate interest-based advertising. When you visit our Sites for the first time, you will be given choices to manage (reject or allow) certain non-essential cookies. (We do not give you a choice to disable essential cookies because they are necessary to enable our Sites to work properly and securely.) Once you make your initial cookie choices, our server will remember your preferences and assume that you would like the same cookies to be used on future visits using the same device, unless you change your cookie preferences. If you visit our Sites using a different device, our server will not recognize that device and you will be prompted to make another cookie selection.

There are different kinds of cookies with different functions:

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 a website without logging into each page. They do not collect any information from your computer.
Persistent cookies: A persistent cookie is one stored as a file on your computer, and it 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: This type of cookie retains your preferences for a particular website for the entity that owns that website. They are stored and sent between Total Wine’s servers and your computer’s operating system. They are used for personalization as set by you. These cookies may be either Session or Persistent cookies.
Third-party cookies: This type of cookie retains your interaction with a particular website for an entity that does not own that website. They are stored and sent between the Third-party’s server and your computer’s or device’s operating system. These cookies are usually Persistent cookies.

We use third-party cookies on our Sites and third-party-provided web beacons and pixels (please see the section on Web Beacons below). These cookies, beacons, and pixels are used by us and our marketing partners to better understand your preferences, provide targeted advertising, and tailor and improve your experience on the site based on our impressions of your interests.

For example, our Sites use Google Analytics and Adobe Analytics, which are web analytic tools provided by Google, Inc. and Adobe Inc., respectively. These services use cookies to help our Sites analyze how users use the Sites. The information generated by the cookies about your use of the Sites (including your IP address) will be transmitted to and stored by these vendors on servers in the United States. These vendors will use this information for the purpose of evaluating your use of the Sites, compiling reports on Site activity, and providing other services relating to Site activity and internet usage for Total Wine. These vendors may also transfer this information to third parties where required to do so by law, or where such third parties process the information for the vendors to provide those services. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, if you do block the use of cookies, you will not be able to use the full functionality of the Sites. By using the Sites, you consent to the processing of data about you by Google and Adobe in the manner and for the purposes set out above.

Along with the above noted uses, we categorize and use cookies for the following purposes:

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. You can set your browser to block or alert you about these cookies, but then some parts of the site will not work. These cookies do not store any personally identifiable information. For your security and the security of our Site, we do not allow these cookies to be deactivated.
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 anonymized details, so that you do not have to repeatedly sign into your account when using a particular device to access our Site. The information these cookies collect is anonymized. They may be set by us or by third party providers whose services we have added to our pages. They do not gather any information about you that could be used for advertising or to remember where you have been on the Internet.
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 based upon, for instance, which pages visitors use most often and if they encounter error messages from certain web pages. We use third parties to assist us in analyzing this data. These cookies do not collect information that identifies a visitor, as all information these cookies collect is aggregated and anonymized.
Marketing & advertising cookies: Our Sites use cookies and pixels that may be used by third parties to build a profile of your interests and enable us to show you relevant advertisements on other sites. These cookies and pixels may also enable you to share pages and content you find interesting on our Sites through third-party social networking and other websites. The cookies and pixels do not store Personal Information directly; instead, they use and/or capture unique identifying features of your browser and Internet device. If you do not allow these cookies and pixels, you will experience less targeted advertising and may be unable to share pages or content you find interesting through third-party social networking sites.
We embed videos or insert links to videos from YouTube and Vimeo on our Sites. Vimeo reports that it does not use third-party analytics or advertising cookies when its video player appears on a third-party website. When you visit a page with content embedded from or linked to YouTube, you may be presented with cookies from YouTube. If you opt out of advertising and marketing cookies on our website, YouTube may still utilize cookies for those embedded videos and links. You can control YouTube cookies by visiting https://policies.google.com/technologies/cookies.

For information on all these categories of cookies, and for more information generally on cookies please refer to aboutcookies.org or https://consumer.ftc.gov/articles/how-protect-your-privacy-online

Opting out of cookies

There are various ways for you to manage cookies and other technologies.

Browser settings

Through your browser settings, you can disable all the above-listed cookies (and other tracking tools) or request to be prompted before accepting cookies from the Sites and other websites you visit. These browser settings may also permit you to delete cookies you already have. Please consult your web browser’s ‘Help’ documentation or visit aboutcookies.org or https://consumer.ftc.gov/articles/how-protect-your-privacy-online for more information about how to turn cookies on and off for your browser. If you use different browsers and computers, you will need to adjust the appropriate cookie settings for each browser and computer. Certain parts of the Sites may function differently, and you may be unable to use some portions of our Sites if you choose to disable cookies entirely.

You may also opt out by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (“GPC”) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Cookie Banner

When you first accessed the Sites, a cookie banner at the bottom of the screen allowed you to access user-enabled privacy controls through a OneTrust preference center. Such controls allowed you to opt out of marketing, advertising cookies, and other non-essential cookies, as described above. The cookie banner can also be accessed by selecting “Your Privacy Choices” in the footer of the website.

Third-party extensions

Several browser extensions allow you to manage cookies and personalize your browsing experience. Since these extensions are made by third party providers, Total Wine does not control these features and cannot provide technical support for these products.

Targeted advertising cookies

You may opt-out of advertising cookies from companies that are members of the Network Advertising Initiative (“NAI”) or who subscribe to the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Please visit the Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page to opt out directly from providers who participate in those programs.

Web beacons and pixels

The Sites may also use web beacons and pixels (including web beacons and pixels supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of the Sites and interaction with e-mails from Total Wine. Web beacons and pixels are transparent electronic images that can recognize certain types of information on your computer, such as cookies, when you view a particular Site tied to the web beacon or pixel, and a description of a Site tied to the web beacon or pixel. We use web beacons and pixels to operate and improve the Sites, e-mail communications, and targeted advertising. We may use information from web beacons and pixels in combination with other data we have about our customers to provide you with information about Total Wine and our services. We will conduct this review anonymously.

IP addresses

When you visit our Sites, Total Wine collects your Internet Protocol (“IP”) addresses to track and aggregate non-Personal Information. For example, Total Wine uses IP addresses to monitor the regions from which users navigate the Sites. IP addresses will be stored in such a way so that you cannot be identified from the IP address. In addition, Total Wine uses 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, such as processing a purchase or fulfilling an order, as well as creating, maintaining, customizing, and securing your account with us.
Customer Service and Relationship Management, such as addressing a customer complaint or applying &MORE Rewards points to a transaction.
Customer Experience, such as improving website, app, email, and push-notification offerings and interface, identifying and repairing errors in our Sites’ functionality, testing, research, analysis, and product development, including developing and improving our Sites, products, and Services. Marketing and Advertising, such as providing promotions and advertising content that are interesting to you based on your purchasing and viewing history, ad customization both on the Sites and on third-party sites (e.g., interest-based advertising discussed below), and managing promotions and contests.
Merchandising, such as determining and improving product assortment based on your purchasing and browsing history.
Analytics, such as information about Site performance relative to your computer or device, hosting our Sites, and managing databases.
Security and Compliance, such maintaining the safety, security, and integrity of our Sites, 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 Sites 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 Total Wine Sites use 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 Total Wine 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 TotalWine.com you are required to establish a password that must be at least 8 characters, contain one letter, one number, and one special character. Your password may not contain your first name or last name. 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 Sites without creating an account; however, you will need to reenter your Personal Information each time you use our Sites 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. This Privacy Policy does not apply to privacy practices of third parties that we do not own or control, including but not limited to any third-party websites, services, applications, or online resources to which the Sites may link, embed, reference, or otherwise provide access. We are not responsible for the privacy practices or the content of such third-party sites. Please contact these third parties directly for information regarding their privacy practices. However, 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, contractors, and third parties 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 or commercial purpose, as those terms are defined in state privacy laws:

Our affiliates, employees, and authorized agents;
Service providers for our businesses, as described further below;
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, as described further below;
Government regulators or law enforcement, where required;
Our legal advisors and other parties when required by law or pursuant to legal process
To the affiliated companies within our corporate family, including our Total Wine retail stores that operate under the Total Wine brand name; and
To any entity involved in the purchase or sale of our businesses, as described further below.

Website Security and Operations Service Providers

We use third-party service providers to enhance your consumer experience. This may include, for instance, providers who assist us with tech or customer support, operations, web or data hosting, billing, credit card processing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise help us to provide, develop, maintain and improve our services. These companies may use information about your visits to our Sites to help process delivery orders and/or provide personalized recommendations and advertisements about our goods and services on our Sites or third-party websites.

Because service providers we use may be located in the United States, your Personal Information may be processed and stored inside the United States; and the U.S. government, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Information under U.S. laws. These service providers are strictly prohibited from using your Personal Information for any purpose other than providing servings to Total Wine and you.

Other Service Providers

Some areas in our Sites may be offered to you in association with affiliated or non-affiliated third parties, such as co-promotional partners, dedicated producers of drinks, or co-sponsors of events you may want to attend. Such co-branded areas may require you to disclose Personal Information to a third party. The co-branded areas will identify the third party; however, the third party’s privacy policy will apply to how they treat your Personal Information. We recommend you review the privacy policy of these third parties. If you elect to register for events or products with these third parties you will be providing your Personal Information to both us and the third party.

Parts of the Sites use YouTube API Services to provide access to Total Wine’s YouTube channel. You acknowledge and agree to be bound by the YouTube Terms of Service (https://www.youtube.com/t/terms) and Google’s Privacy Policy (https://policies.google.com/privacy) when engaging YouTube content and services through the Sites. You may manage your YouTube API data by visiting Google’s "privacy and security" settings page. To provide relevant advertisements and content we and our advertising and content providers may collect Personal Information when you use our Sites (such as the IP address of your device, the identifier on your mobile device, or cookies stored on your device), and may share the information we collect with third parties. Please see our Cookie Policy for more information.

To provide advertisements and content that are more relevant to you, we and our advertising and content providers may collect Personal Information when you use our Sites (such as the IP address of your device, the identifier on your mobile device, or cookies stored on your device), and may share the information we collect with third parties. Please see our Cookie Policy for more information.

Social media, reviews, and user-generated content

Any personally identifiable information you submit on a social media website, such as Facebook, Instagram, TikTok or Twitter, bulletin board, blog, chat room, or any other public forum on our Sites can be read, collected, or used by other users of these forums, who could be used to send you unsolicited messages. We recommend not providing your name, e-mail address, or any other Personal Information in public forums on this Sites. Please note that if you choose to do so, it is at your own risk and you accept full responsibility for those posts and any consequences that may arise.

Interest-based or Behavioral Advertising

Interest-based advertising (also known as online behavioral advertising) occurs when advertisements are displayed to you based on information collected from your online interactions over time and across multiple websites that you visit or across multiple devices or online services that you may use. Interest-based advertising is used to predict your preferences and show you ads that are most likely to interest you.

You may see our ads on other websites because we use third-party ad services. Through these ad services, we can tailor our messaging to individuals considering transaction history, demographic data, inferred interests, and browsing context. These ad services track information about your online activities over time and across third-party websites and apps by collecting information through automated means, including through the use of cookies, web beacons, and other similar technologies. These ad services may collect data about your visits to websites and apps that participate in these services, such as the pages or ads you view and the actions you take on the websites or apps. This data collection occurs both on the Sites and third-party websites and apps that participate in these ad services. These ad services use this information to show you ads that may be tailored to your individual interests. Some content, applications, and tracking technologies on our websites and mobile applications are serviced by third parties, including ad tech companies (for example, Meta or Google) or other online service providers that serve interest-based advertisements. These third parties may use cookies, web beacons, and other storage technologies to collect or receive information from our websites, apps, and elsewhere on the Internet and use that information to provide measurement services as well as for interest-based advertising.

We do not control these third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

In addition to exercising certain rights that you may have about controlling the use of your Personal Information in our Privacy Portal using the links “Do Not Sell or Share My Info” or "Your Privacy Choices" at the bottom or footer of the Totalwine.com website, you can also block the collection and use of information related to you by online platforms and ad tech companies that serve interest-based advertising by visiting the following websites of the self-regulatory programs of which those companies are members:

You may still see “contextual” ads even if you opt out of interest-based ads. These ads, however, are based on the context of what you are looking at on the websites and pages you visit. Even if you opt out of interest-based ads, you may still receive these non-personalized, contextual ads.

Sale of business assets

As we continue to develop our businesses, 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 Total Wine itself or substantially all Total Wine 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, including a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets.

Other legally required disclosures

Total Wine reserves a right to disclose without your prior permission any Personal Information about you or your use of this Sites if Total Wine has a good faith belief that such action is necessary to: (a) protect and defend the rights, property, or safety of Total Wine, employees, other users of this Sites, or the public; (b) enforce the terms and conditions that apply to use of this Sites; (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.

10. Your rights related to Personal Information held by us

Please note that your rights listed below may vary depending on your state of residence. If you are a resident of California, Colorado, Connecticut, or Virginia, the following rights apply to you unless a specific state is mentioned. You may exercise your rights through Total Wine’s Privacy Portal, which is also accessible through the “Do Not Sell or Share My Info” link at the bottom of our Site.

Right to Know Collected Personal Information	You have the right to know, and request disclosure of: The categories of Personal Information we have collected about you, including sensitive personal information (to the extent Total Wine begins collecting such sensitive information following your opt-in consent); The categories of sources from which the Personal Information is collected; Our business or commercial purpose for collecting, selling, or sharing Personal Information; The categories of third parties to whom we disclose Personal Information, if any; and The specific pieces of Personal Information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the Personal Information to you free of charge at a greater frequency than is required by the state laws where you reside. For example, Virginia residents may make two requests over 12 months, while Colorado residents may make one request over 12 months, while Connecticut residents are not similarly constrained.
Right to Know Disclosed, Sold, or Shared Personal Information	In connection with any Personal Information we may sell, share, or disclose to a third party for a business purpose, you have the right to know: The categories of Personal Information about you that we sold or shared and the categories of third parties to whom the Personal Information was sold or shared; and The categories of Personal Information that we disclosed about you for a business purpose and the categories of persons to whom the Personal Information was disclosed for a business purpose.
Right to Opt-Out of Sale or Sharing	You may have the right to opt-out of the sale of your Personal Information or sharing of your Personal Information. If you exercise your right to opt-out of the sale or sharing of your Personal Information, we will refrain from selling or sharing your Personal Information, unless you subsequently provide express authorization for the sale or sharing of your Personal Information.
Right to Limit Use of Sensitive Personal Information	Total Wine does not collect the following sensitive types of personal data about you (A) data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sex life, sexual orientation or citizenship or immigration status, (B) consumer health data, (C) the processing of genetic or biometric data for the purpose of uniquely identifying an individual, (D) personal data collected from a known child, (E) data concerning an individual’s status as a victim of crime, or (F) one’s precise geolocation data. For security purposes, when you log into your personal Loyalty account, Total Wine collects and validates your account password, which is encrypted and inaccessible to Total Wine in its ordinary course of business. If Total Wine ever begins collecting your sensitive information (other than account passwords) following your opt-in consent to such collection, you will have the right to opt-out to the use of sensitive personal information, which Total Wine will provide before or at the time of collection of such information.
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your Personal Information from our records; and Direct any service providers or contractors to delete your Personal Information from their records. Direct third parties to whom the business has sold or shared your Personal Information to delete your Personal Information unless this proves impossible or involves disproportionate effort. Please note that we may not delete your Personal Information if it is reasonably necessary to: Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Help to ensure security and integrity to the extent the use of the consumer’s Personal Information is reasonably necessary and proportionate for those purposes; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Right to Correction	If we maintain inaccurate Personal Information about you, you have the right to request us to correct that inaccurate Personal Information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate Personal Information.
Right to Appeal	In certain states, you may appeal our decision to your request regarding your Personal Information. We respond to all appeal requests as soon as we reasonably can, and no later than legally required.

11. Additional state-specific disclosures and notices

California, Colorado, and other state laws requires us to disclose the following additional information with respect to our privacy practices. If you are a resident of one such state, this section applies to you in addition to the rest of the Privacy Policy.

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 except where expressly authorized by you.

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. If you wish to exercise this right, you can submit a request by visiting our Privacy Portal.

Categories of Personal Information disclosed for business or commercial purposes over the last 12 months (or since July 1, 2023, for Connecticut residents)

You can find a list of categories of Personal Information that we collect in the “Personal Information we collect about you” section above. For details regarding the sources from which we obtain Personal Information, please see the “How we collect your Personal Information” section above. We collect and use Personal Information for the business or commercial purposes described in the “How we use your Personal Information” section above. Below is a non-exhaustive list of examples of such uses and the “business purposes” or “commercial purposes”.

Consumer Transactions, such as processing a purchase or fulfilling an order, as well as creating, maintaining, customizing, and securing your account with us.
Customer Service and Relationship Management, such as addressing a customer complaint, applying &MORE Rewards points to a transaction.
Customer Experience, such as improving website offerings and interface, identifying and repairing errors in our Sites’ functionality, testing, research, analysis, and product development, including developing and improving our Sites, products, and Services.
Marketing and Advertising, such as providing ads or promotions that may interest you based on your purchasing and viewing history, ad customization that does not involve or contribute to profiling, and managing promotions and contests. Advertisers may use pixels or cookies in their ads that collect information from/about you to help them understand how you respond to their ads.
Publishers that operate the websites you visit (e.g. an online newspaper or an entertainment website). We share personal information with publishers to help us serve ads to you on their websites and to help us understand how those ads perform.
Social media platforms that help us serve ads to you on those platforms.
Advertising technology providers that use cookies, pixels, beacons and similar technologies to tailor the ads you see using information collected about you over time on our Sites, and across other participating websites and mobile services. These advertising technology providers include ad servers, advertising agencies, technology vendors that support media buying and selling, and research firms. For more information about your choices related to interest-based advertising, see Interest-Based or Behavioral Advertising, above.
Data technology vendors that help us manage and automate the use of the data we collect (including personal information). These companies include, for example, technology providers that help us automate our advertising services, and identity management companies.
Merchandising, such as determining and improving product assortment based on your purchasing history.
Measurement and analytics vendors that provide aggregated reporting on our website performance and the effectiveness of our advertising campaigns and services.
Security and Compliance, such as maintaining the safety, security, and integrity of our Sites, products and Services, databases and other technology assets and our business, including preventing fraud, detecting security breaches, prosecuting violators, and responding to law enforcement requests and meeting requirements of applicable law, a court order, or governmental regulations.

Categories of Personal Information sold or shared over the last 12 months (or since July 1, 2023, for Connecticut residents)

We may use or disclose your information in a manner that is considered a “sale” or “sharing” under California law (or the law of other states) to provide the most relevant product recommendations and deliver marketing messages and personalized offers through select companies (e.g., analytics, advertising, adtech, social networks, and technology companies). Those companies help us match your interests with brands who want to send promotions and offers that we believe save you money on products you buy frequently, and help you discover new products or services that you might like. When we work with these companies, your privacy, data integrity, and security remain a priority, and we require other businesses that we work with to do the same.

We have shared during the 12-month period prior to the effective date of this Privacy Policy (or since July 1, 2023, for Connecticut residents) the Identifiers, Commercial information, and Internet or other similar network activity (as defined above) with third-party advertising, marketing, and adtech companies that compile Personal Information about prospective or current Total Wine customers for purposes of operating our business, updating, verifying or deduplicating Personal Information, prospecting new potential customers, and marketing, personalization, advertising, and improving the types of services and products we offer to you. For more information about how your information is disclosed and the entities to whom it is disclosed, see the “How we disclose your Personal Information” section above. The categories of information disclosed about you include identifiers, commercial information, internet, or other similar network activity as defined in the "Personal Information we collect about you" section above. In addition, the collection of Internet or electronic network activity information (as defined above) through cookies or pixels on our Sites for a variety of purposes, including personalized advertising and facilitating your activity on social media, may constitute a “sale” under state privacy laws and occurred during the 12-month period prior to the effective date of this Privacy Policy. Please refer to our Cookie Policy to better understand your privacy options.

While this information is provided throughout the Privacy Policy, the chart below contains additional information pursuant to various state laws. Depending on how you interact with us, not all categories or examples of specific Personal Information may be collected about you.

Personal Information Category	Business Purposes	Business Purposes
Identifiers and Characteristics	Consumer transactions Customer Service and Relationship Management Customer Experience Marketing and Advertising Merchandising Analytics Security and Compliance	Vendors who provide services on our behalf, including cloud service providers, payment processors, fraud prevention companies, internet service providers, etc. Professional services organizations, such as auditors and law firms Our joint marketing partners Our business partners Online advertising services and advertising networks, including adtech providers Data analytics providers Government entities
Commercial information	Consumer transactions Customer Service and Relationship Management Customer Experience Marketing and Advertising Merchandising Analytics Security and Compliance	Vendors who provide services on our behalf, including cloud service providers, payment processors, fraud prevention companies, internet service providers, etc. Professional services organizations, such as auditors and law firms Our joint marketing partners Our business partners Online advertising services and advertising networks, including adtech providers Data analytics providers Government entities
Internet and other similar network activity	Consumer transactions Customer Service and Relationship Management Customer Experience Marketing and Advertising Merchandising Analytics Security and Compliance	Vendors who provide services on our behalf, including cloud service providers, payment processors, fraud prevention companies, internet service providers, etc. Professional services organizations, such as auditors and law firms Our joint marketing partners Our business partners Online advertising services and advertising networks, including adtech providers Data analytics providers Government entities

Colorado Loyalty Program Disclosure

As explained in our &MORE Rewards Program, our loyalty program provides you with certain rewards and benefits.

As part of our &MORE Rewards Program and by having an account with us, we may collect the following categories of Personal Information:

Identifiers including name, email, phone number, zip code, birthday (optional)
Customer Account / Commercial Information including shopping history, preferred store
Internet/Network Activity including IP address, activity logs, browsing history
Inferences drawn from one or more of the above, including a consumer’s shopping history, which reflect a shopping preferences

We collect this data to understand better you and your journey with us as a shopper, offer personalized deals and targeted ads, and help us make better business decisions and continuously improve. We may disclose your Personal Information to our processors and third parties, such as analytics companies, third-party advertisers, and other merchants, to help handle parts of our &MORE Rewards Program because of their expertise, resources, or scale. They help us monitor activity on our services, serve ads on this and other services, and otherwise perform actions consistent with the uses described in this Privacy Policy. You can opt-out of this data sharing and targeted advertising by using our online form to submit an Opt-out of Sale or Share request.

To learn more about our &MORE Rewards Program, see the &MORE Rewards Program Terms & Conditions.

12. Our Response to Requests

We will acknowledge receipt of your request within 10 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.

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

However, under certain state privacy laws, we may offer certain incentives that result in different prices, offers, benefits, or services to customers who choose to join and use our &MORE Rewards Program that may not be available to customers who are not &MORE Rewards Program members or who choose to terminate their &MORE Rewards Program membership. For more information about our &MORE Rewards Program, the different product offerings and services available under that program, how to opt-in to the program, and the value of &MORE Rewards Program member data, see the &MORE Rewards Program Terms & Conditions.

14. Notice of financial incentive

We make various offers and financial incentives to our customers. The terms of any such offer or financial incentive will be presented to you at the time you receive our offer. The nature and value of any such offer or financial incentive may differ depending on what information we collect and use about you and whether you choose to enroll in our &MORE Rewards Program. For details about the benefits of enrolment in and/or use our &MORE Rewards Program, please see the &MORE Reward Program Terms & Conditions.

Whether you choose to enroll and/or use in our &MORE Rewards Program and whether you choose to allow us to collect and use other types of Personal Information about you affects how we communicate with you and the types and frequency of offers that you may receive. For example, if we collect no information from you, we will be unable to make any offers to you other than through general advertising or when you visit our stores. Conversely, when you enroll in and/or use our &MORE Rewards Program or otherwise allow us to continue to collect and use Personal Information about you, we are able to provide you different, more tailored or customized, and generally more valuable offers and financial incentives than the ones we may choose to make through our general advertising, which only reaches a small percentage of our customers.

The value of your Personal Information that enables us to make these offers and financial incentives, is the value of the offer itself. We calculate the value of our offers and financial incentives by using the expense related to the offer.

Whether or not you are a member of our &MORE Rewards Program, you may withdraw from receiving any of our offers or financial incentives by contacting us at privacy@totalwine.com or 1-855-330-6673 or by unsubscribing to our email marketing by clicking "Unsubscribe" link in any e-mail from us.

15. 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.

16. Automated License Plate Recognition Usage and Privacy Policy

Total Wine may use Automated License Plate Recognition (“ALPR”) Systems where not prohibited by law and in accordance with this Privacy Policy. An ALPR System is a searchable computerized database resulting from the operation of one or more mobile or fixed cameras combined with computer algorithms to read and convert images of license plates and the characters they contain into computer-readable data.

We may collect and use information an ALPR System generates for fraud prevention, security, and asset protection purposes (“Authorized Purpose”).

Select employees and independent contractors with an Authorized Purpose, including, those in our security, loss prevention, information technology, and legal departments (“Authorized Personnel”) will be authorized to use or access the ALPR Systems or collect Information from the ALPR Systems. Total Wine’s Vice President, Loss Prevention & Safety, will be the official custodian of the ALPR Systems and is responsible for implementing this Usage and Privacy Policy. Authorized Personnel will be trained on the appropriate access and use of ALPR Systems in compliance with applicable privacy and security laws. Total Wine will maintain and periodically check our ALPR System access records to ensure the security of collected information and compliance with applicable privacy and security laws.

In accordance with its Privacy Policy, Total Wine will not sell, share, or transfer Information collected by an ALPR System to any third party outside Total Wine, except in limited circumstances, including:

To our service providers so that they may perform services on our behalf; however, we may permit these service providers to use anonymized and aggregated information for the improvement of their services; and
For the purposes of (1) ensuring the safety and security of our customers, employees, and third parties, (2) protecting our rights and property and the rights and property of our customers, employees, and third parties, (3) complying with legal processes, or (4) satisfying other legal requirements.

To identify and correct data errors, Authorized Personnel will periodically compare license plate readings recorded and license plate images captured by the ALPR Systems.

In accordance with our Privacy Policy, Total Wine will retain information collected from ALPR Systems for as long as necessary for the Authorized Purposes and regularly destroy such information when we determine its retention is no longer necessary, unless we are informed that we must retain the information to comply with legal processes or to satisfy other legal requirements.

17. Updating your Personal Information

Total Wine wants your Personal Information to be accurate and complete. We provide several different methods for you to update your Personal Information. To update your name, address, phone number and/or e-mail information:

Online:	Login to My Account on TotalWine.com to update your personal account information (if you've created an account on TotalWine.com)
Phone:	1-855-330-6673
Email:	privacy@totalwine.com
Mail:	Total Wine & More, Store Support Center 6600 Rockledge Drive, Suite 150 Bethesda, MD 20817 Attn: Customer Care/Privacy

If you send an e-mail or letter request, please be sure to include your current information and the requested changes.

18. E-mail & account registration

During registration on the Sites, we collect an e-mail address to communicate with you about your transactions, &MORE Rewards, or our advertising and promotions. We also use this e-mail address to contact you if there are any issues and to notify you about the status of your order. If you do not want this email used for purposes other than confirmation of an online order or acknowledgement of an award of points, you must notify us in writing of your desire to unsubscribe. Please contact us at customercare@totalwine.com.

If a user wishes to subscribe to our e-mails, we ask for contact information such as name, preferred store, and e-mail address. We may use your Personal Information for purposes other than sending you promotional materials. For example, we may use your information to send you administrative communications about any account you may have with us or about future changes to this Privacy Policy. If at any time you should wish to unsubscribe, please click on the "unsubscribe" link in any e-mail from us or send an e-mail privacy@totalwine.com.

When you register as a member of the Sites or sign-up to receive our e-mail offers, we collect information that helps us identify you. The more information you provide, the better we can customize our services and your experience to suit your needs and preferences.

19. Children's and minor's privacy

Total Wine Stores and Sites 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. Further, do not knowingly collect, sell, or share the Personal Information of consumers under 16 years of age.

For more information about Parental Control options, see our Terms & Conditions.

20. Chatbot Technology

Our Sites may feature certain customer-facing chatbot functions that are provided, facilitated, monitored, and maintained by a third-party service provider subject to a non-disclosure obligation. The third-party service provider may not use any information from the chat functions for its own purposes. All customer data or messages collected or viewed by the third-party service provider are anonymized and utilized by the third-party service provider strictly for updating and maintaining the service. The chatbot is not a real person, but instead a computer relying on software code to answer questions you may have in navigating our Sites. You will be asked to consent to this use before proceeding. If you do not consent to use the Chabot feature, you must exercise your preference on the screen by simply typing “no” or “yes” when prompted. If you select “no”, you will be redirected to the phone number for our customer care department.

21. How to contact us

Phone:	1-855-330-6673
Email:	privacy@totalwine.com
Mail:	Total Wine & More, Store Support Center 6600 Rockledge Drive, Suite 150 Bethesda, MD 20817 Attn: Customer Care/Privacy