WineView Privacy Policy

Effective date: October 1, 2026

WineView Inc., a Delaware corporation ("WineView," "we," "us," or "our"), provides software that helps businesses manage clubs, memberships, sales, payments, fulfillment, and related customer relationships. This Privacy Policy explains how we collect, use, and disclose personal information through wineview.com, our platform, Business Dashboard, Member Portal, and related services and communications (collectively, the "Services"). It also explains your choices and how to contact us.

"Personal information" means information that identifies or relates to an identifiable individual, including information treated as personal data under applicable law. The information involved depends on how you use the Services, the features enabled, and your relationship with WineView and the business whose club or storefront you use.

1 Our role and the role of Merchants

Businesses that use WineView to operate their clubs or sell products are referred to in this Policy as "Merchants." Their customers, members, and prospective members are referred to as "Members."

WineView determines how personal information is used for our own website, business relationships, account administration, billing for our Services, direct communications, and certain security and legal purposes. For that processing, WineView acts as the controller or business where those terms apply.

When a Merchant uses WineView to maintain Member records, manage subscriptions or orders, communicate with Members, or perform other activities on the Merchant's behalf, the Merchant determines the purposes of that processing. WineView processes that information as a service provider or processor to the extent provided by applicable law and our agreement with the Merchant. The Merchant's privacy notice also applies to its collection and use of information. This Policy does not give WineView additional rights to use Merchant-controlled information beyond those permitted by the applicable agreement and law.

If your request concerns a Merchant's membership, marketing, purchase records, or other Merchant-controlled information, contact that Merchant first. You may also contact us, and we will help identify the appropriate Merchant or assist with the request as required. A Merchant's authorized administrators and staff may access information associated with that Merchant's account according to their permissions.

2 Information we collect

Account and business information

We collect information supplied to create or administer accounts, request a demonstration, or establish a business relationship. This may include names, email addresses, telephone numbers, mailing addresses, business names and locations, staff roles, account identifiers, login credentials, and communication preferences. Merchant onboarding may also involve business, tax, billing, and payout information, depending on the services requested. A payment provider may collect information directly through its own onboarding process.

Membership and transaction information

We process information supplied by Members or Merchants about club enrollment, membership status and preferences, purchases, release selections, rewards, discounts, payments and refunds, order history, shipping addresses, pickup preferences, fulfillment status, and information used for age verification. Merchant records may include prospects, customer notes, imports from an earlier provider, and communications associated with a membership or order.

WineView uses Stripe for payment processing and supports tokenized payment methods. We receive payment-related information needed to support transactions, such as payment identifiers, tokens, transaction amounts and status, billing details, and limited payment-method information. We do not store full payment card numbers on our systems. Stripe's collection and use of information is also described in its privacy policy at https://stripe.com/privacy.

Communications and information you submit

We collect the information you provide in inquiries, emails, support requests, feedback, and other communications. Depending on the features used, this includes uploaded files, imported records, prompts, questions, and other content submitted to AI-assisted features, together with the responses or reports those features generate. An enabled help feature may also capture a screenshot of the page you are viewing and related page or account context to help answer your request.

If you use a feature that lets you publish content, such as a review, the information you choose to publish can be visible to its intended audience. Avoid including information you do not want that audience to see. Do not include passwords, complete payment card details, or unrelated sensitive information in support messages, uploaded files, or AI prompts.

Device and activity information

When you use the Services, we collect technical and activity information such as IP addresses, browser and device information, account or cookie identifiers, pages and features used, referral sources, interaction times, error reports, and security logs. An IP address may indicate an approximate location. Cookies and similar technologies are described in Section 6.

Information from other sources

We receive information from Merchants and their authorized users; systems connected to a Merchant's account; payment, point-of-sale, shipping, and fulfillment providers; and prior service providers involved in a Merchant-authorized migration. These sources can supply membership, transaction, reward, inventory, and fulfillment information relevant to the integration.

We may also receive information from analytics or marketing providers and publicly available business sources. If you choose to use a supported third-party sign-in or sharing feature, we receive the information that the provider makes available based on that feature and your choices.

Derived information and sensitive information

Reports and other features may derive information from existing records, such as member engagement, purchase preferences, estimated customer value, or indicators of potential membership cancellation. These are estimates and may be inaccurate.

Some information, including account credentials or certain financial information, may be considered sensitive personal information under applicable law. Provide sensitive information only through the relevant feature when it is necessary. Voluntarily submitting sensitive information does not remove any protections or consent requirements that apply to it.

3 How we use information

Subject to our role and the applicable Merchant agreement, we use personal information for the following purposes:

Providing the Services, including creating and managing accounts, authenticating users, applying staff permissions, and responding to requests

Supporting Merchant operations, including membership administration, recurring billing, one-time purchases, release selections, rewards, inventory coordination, shipping, pickup, and customer communications

Connecting systems and migrating Merchant records as requested by the Merchant

Delivering AI-assisted registration, record import, questions and answers, reporting, and other enabled features, as described in Section 4

Sending service communications about accounts, transactions, memberships, security, and changes to the Services

Understanding use of the Services, resolving technical problems, measuring performance, and developing and improving features and personalization

Managing our business relationships, handling billing, responding to prospective customers, and providing support

Sending WineView marketing communications and measuring or personalizing advertising, subject to your choices and applicable consent requirements

Detecting and addressing fraud, misuse, security incidents, and violations of applicable terms

Meeting legal obligations, maintaining necessary records, handling disputes, and establishing, exercising, or defending legal claims

Information processed solely on a Merchant's behalf is used according to the Merchant's instructions and our agreement with that Merchant. A Merchant's marketing activities and choices are governed by its own notice and applicable law.

We may create and use aggregated or de-identified information for analytics, research, reporting, and service improvement. Information remains subject to this Policy when it can reasonably be linked to an individual. Where we treat information as de-identified under applicable law, we maintain it in that form and do not attempt to reidentify it except as permitted by law.

4 AI assisted features

WineView offers AI-assisted functions, including Vino AI, natural-language reports, registration, and imports. These features can use information you submit and relevant information within the account or membership involved to answer questions, organize records, summarize activity, generate reports, or identify matters needing attention, such as payment issues, pending pickups, or possible membership cancellations.

The personal information involved can include prompts and uploaded content, screenshots or page context captured by an enabled help feature, relevant Member or transaction records, derived insights, generated responses, and usage or feedback associated with the feature. Processing depends on the feature, available account data, and user access permissions. Where third-party technology supports an AI feature, relevant information may be processed by the provider to deliver that feature, subject to the applicable arrangements.

Our evaluation and improvement of AI-assisted and personalization features is subject to the purposes, roles, and limitations described in this Policy and any applicable Merchant agreement. This Policy does not independently authorize unrestricted reuse of Merchant-controlled personal information to train AI models.

AI-generated information can contain mistakes. If an output contains inaccurate personal information about you, contact the relevant Merchant or WineView using the process in Section 8. Privacy rights concerning profiling or automated decisions apply where required by applicable law.

5 When information is disclosed

Merchants and their authorized users

Information associated with a Merchant's Members, orders, and operations is available to that Merchant and its authorized users as needed to operate the account and provide the requested services.

Service providers

We use providers that support hosting, storage, payments, communications, analytics, customer support, security, and other functions described in this Policy. They receive information relevant to the services they provide. Their permitted processing depends on the service and applicable contractual and legal requirements.

Connected services

Information flows between WineView and integrations enabled for the account. For example, Stripe supports payments; Toast supports point-of-sale activity and related member or inventory synchronization; and enabled shipping or compliance tools, such as Shippo, Vinoshipper, or ShipCompliant, support relevant order and fulfillment activities. Only integrations used for the account are relevant to that account's data flows.

Some providers act on a Merchant's or WineView's instructions for particular activities and determine their own processing for others, such as fulfilling independent legal obligations. Review the relevant provider's privacy notice for its practices. Disconnecting an integration does not necessarily delete information the provider already received.

Advertising and business partners

Advertising, analytics, and social-media providers may receive information in connection with the technologies described in Section 6. We may also disclose information to partners when you request or participate in a joint offering, or with your consent where required.

Legal matters and business transactions

We may disclose information to comply with applicable law or valid legal process; investigate fraud or security incidents; protect rights, property, or safety; or establish, exercise, or defend legal claims. Information may also be disclosed to advisers and prospective or actual parties involved in a merger, acquisition, reorganization, sale of assets, or similar transaction, subject to applicable confidentiality and legal requirements.

At your direction

We disclose information when you direct or authorize us to do so, including through features that publish or share content, and in other circumstances with your consent where required.

6 Cookies analytics and advertising

We use cookies and similar technologies, which can include pixels and local storage, to operate the Services, remember preferences, understand activity, and support personalization and advertising. These technologies can collect personal information, including online identifiers, IP addresses, device information, and browsing or interaction activity. A cookie does not need to contain your name to relate to you or your device.

Our public website uses Google advertising tags. Third-party analytics, advertising, or social-media technologies may allow their providers to collect information about activity on our Services and across other websites or services over time. Their own privacy notices describe their processing. Information about Google’s use of data from participating sites is available at https://policies.google.com/technologies/partner-sites.

WineView does not sell personal information in exchange for money. Disclosures through advertising technologies may nevertheless qualify as a "sale," "sharing," or processing for targeted advertising under certain privacy laws. Your rights depend on the law that applies and the processing involved. You may contact angela@wineview.com to request an applicable opt-out or ask about the technologies involved.

Your browser or device may let you block or delete cookies and limit certain tracking. Blocking essential technologies may affect sign-in or other functions. Browser settings may not control every disclosure, and choices may need to be applied separately to each browser or device. If the Services present a cookie or privacy-choice control, use it to manage the options described there. Consent and opt-out requirements under applicable law continue to apply regardless of the controls available in your browser.

7 Communications and account choices

You can update information through the account or Member Portal features available to you, or ask WineView or the relevant Merchant for help.

To stop WineView promotional emails, use the unsubscribe link or contact us. We may still send non-promotional communications necessary for your account, transactions, security, or the Services. To change a Merchant's marketing preferences, follow that Merchant's instructions or contact it directly.

Where processing relies on consent, you may withdraw that consent by contacting us or using the relevant control. Withdrawal does not affect processing already carried out lawfully and does not prevent processing justified on another lawful basis. You do not have to delete your entire account to withdraw a particular consent.

Closing a WineView account or requesting deletion of personal information does not by itself cancel a Merchant membership, an order, a payment obligation, or a contract. Address those requests separately with the appropriate Merchant or WineView.

8 Privacy rights and requests

Depending on where you live, the applicable law, and WineView's role in the processing, you may have rights to:

Learn whether we process personal information about you and receive information about that processing

Access personal information and obtain a portable copy

Correct inaccurate personal information or request deletion

Object to or restrict particular processing, including direct marketing

Withdraw consent where processing is based on consent

Opt out of a sale, sharing for cross-context behavioral advertising, targeted advertising, or certain profiling or automated decision-making, where the applicable law provides that right

Limit specified uses or disclosures of sensitive personal information, where applicable

Appeal a decision about a privacy request or complain to the relevant regulator

These rights are subject to the conditions and exceptions in applicable law. We will not unlawfully discriminate against you for exercising them.

Submit requests to angela@wineview.com or write to the address in Section 13. Include enough information to identify the account or relationship involved and explain your request. Do not send passwords, full payment card details, or government identification documents in an initial email.

Where appropriate, we may ask for information to verify your identity or authority before providing, correcting, or deleting personal information. An authorized agent may submit a request where permitted by law; we may need to verify the agent's authority and, where permitted, your identity. Verification requirements do not apply to opt-out requests where the law prohibits them. You do not need to open a new account to submit a request.

We respond within the period required by applicable law and explain any permitted extension or refusal. If applicable law gives you a right to appeal, reply to our decision or email angela@wineview.com with the subject "Privacy appeal" and explain why you believe the decision should be reconsidered. You may also contact your state attorney general or other competent privacy regulator. Individuals protected by European or UK data protection law may complain to the relevant supervisory authority.

When we hold the information solely on a Merchant's behalf, we will direct the request to the Merchant or assist it in responding as required by our agreement and applicable law.

9 Retention and deletion

Retention depends on the information and its purpose. In determining how long information is needed, we consider the account or business relationship, pending transactions and support matters, the sensitivity of the information, applicable legal recordkeeping obligations, limitation periods, disputes, fraud and security needs, and our contractual obligations.

Account and operational records may be needed while an account or Merchant relationship continues. Transaction and business records may need to remain after account closure to complete transactions, handle refunds or disputes, and meet legal requirements. Technical and diagnostic records are retained according to their operational and security purposes. We may retain a limited record of an opt-out or privacy request to honor that choice and document our response.

For information processed on a Merchant's behalf, retention and deletion also depend on the Merchant's instructions and the applicable agreement. When information is no longer needed for the relevant purposes, we delete or de-identify it, subject to applicable requirements. Backup copies may remain until removed through the applicable backup cycle. Deleting information from WineView does not automatically remove copies held independently by a Merchant or another provider.

10 Security

We use reasonable measures designed to protect personal information. No online service or storage system can guarantee absolute security. Protect your credentials, use available account security controls, and tell support@wineview.com if you believe your account or information has been accessed without authorization.

11 International processing and legal bases

WineView is based in the United States, and the Services involve processing information in the United States. Information may also be processed in other countries where relevant providers operate. Those countries may have different privacy laws from those where you live. Contact us for information about the locations and transfer arrangements relevant to your personal information. Accessing the Services does not by itself constitute consent to a transfer for which the law requires a separate legal mechanism or consent.

Where European or UK data protection law applies to processing for which WineView is a controller, our legal basis depends on the purpose. This may be performance of a contract with you or steps you request before entering one; our legitimate interests in administering business relationships, operating and securing the Services, responding to inquiries, and improving our offerings, subject to the required balancing of rights and interests; compliance with legal obligations; or consent where required. If we need particular information to perform a contract or comply with law and you do not provide it, we may be unable to provide the related service. For processing carried out on a Merchant's behalf, the Merchant determines the applicable legal basis.

Text messaging.

If you opt in to text messages from WineView, we use your mobile number to send messages about your wine club memberships and orders. Message frequency varies. Message and data rates may apply. Reply STOP to opt out or HELP for help.

We do not sell, rent, or share your mobile phone number, or your text-message opt-in data and consent, with third parties or affiliates for their marketing or promotional purposes. The information-sharing practices described elsewhere in this policy, including sharing with service providers, integrations, and business partners, do not apply to text-messaging opt-in data and consent.

12 Children and age restricted services

WineView accounts and business-user access are intended for people age 18 or older. Alcohol-related memberships and purchases are subject to the applicable legal drinking age, including age 21 in the United States. The Services are not directed to children. We do not knowingly collect personal information from children through the Services. If you believe a child has provided information to us, contact angela@wineview.com so we can investigate and take appropriate steps, including deletion where required.

13 Contact and policy changes

For privacy questions, requests, or complaints, contact:

WineView Inc. Email: angela@wineview.com Mail: 2200 Wilson Blvd, Suite 102 PMB 8, Arlington, VA 22201, United States For account or technical support: support@wineview.com

We may update this Policy as the Services and our practices change. The revised version will identify its effective date. We will provide additional notice of material changes, such as a notice within the Services or an email, as required by applicable law. Where a change requires consent or another legal step, posting a revised Policy alone does not satisfy that requirement.