Last Revised: Mar 3, 2021

1. Policy. The Swillio, Inc. (“Swill, “we,” or “us”) Privacy Policy covers Swill’s treatment of personal or personally identifiable information (“Personal Information”), that may be collected about users and visitors (“Users” or “you,” or “your”) when you are on the Swill website and when you use Swill’s website (“Website”) or mobile application (“Mobile App”), collectively referred to as the “Service”. This policy does not apply to the practices of companies that Swill does not own or control, or to individuals that are not under Swill’s supervisory control.

2. Age Restrictions. Use of the Service by anyone under the age of 21 is expressly prohibited. Persons under 21 are not allowed to register with, or in any way, use the Service. We do not knowingly collect Personal Information from or about anyone under the age of 21. If we discover that we have collected Personal Information from a person under 21, we will delete that information immediately. Please refer to our End User License Agreement and Terms of Service (License) for additional information about age verification and eligibility.

Collection of Your Personal Information

Swill may collect Personal Information when you use the Service on the Swill website, the mobile application, or when you visit cookie-enabled web pages. Swill may also log your IP address when you use the Swill website or mobile application.

3. User Account Information. Swill allows users to set up personal accounts to shop in our online store or to participate in our online communities. Under no condition will Swill share your user account information with another individual, business or government entity, unless Swill is required by court order, subpoena or other legal process. Personal Information, includes but is not limited to, and where applicable, your:

• Email and Login Credentials
• Name and Date of Birth
• Home or Delivery Phone Number, Address, and Zip Code
• Billing Address and Phone Number
• Sex
• Alcohol Preferences
• Driver’s license information
• Methods of Payment; Bank account number/Credit or debit card number.
• Personal characteristics, including photographic image, handwriting or other unique biometric data.

4. Device-Specific Information. When you register or use the App, we also collect device type within the mobile application and store this information in log files. We use this information to provide you with the most up to date application and features, or to advertise or promote products and services to you that are applicable to your device type, as described in this Privacy Policy.

5. Tracking Information. Tracking information is collected and stored in log files as you navigate through the Website or use the Service, including, but not limited to purchase history, delivery location history, and click tracking.

6. Geolocation Data. If you use the Services through your mobile device, we will collect your geo-location information so that we can determine to which retailer we should send your order for fulfillment. We will not share this information with third parties and will only use this information for the sole purpose of fulfilling your order. You may at any time no longer allow the App to use your location by turning this off at the device level.

7. Job Application Information. If you apply for a job on our Website, Swill will collect Personal Information such as your name, email address, phone number and additional information you provide, including but not limited to your resume. We use the information collected within this area of the Website to determine your qualifications for the position to which you have applied, and, if applicable, to contact you to for an interview.

8. Referral Information. If you invite others to use the Swill through the invite feature, Swill will collect and retain name and email address of the person receiving the invite in order to track results of User invitations.

9. Cookies. To help us serve your needs better, we use “cookies” to store and track user information. A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. A website can use cookies to recognize repeat users or track web usage behavior. Cookies take up minimal room on your computer and cannot damage your computer’s files. Cookies work by assigning a number to the user that has no meaning outside of the assigning website. Non-Personal Information and data may be automatically collected by virtue of the standard operation of Swill’s computer servers or through the use of cookies. If you do not want information to be collected through the use of cookies, your browser allows you to deny or accept the use of cookies. There may, however, be some features of the Service which require the use of cookies in order to customize the delivery of information to you.

Swill does not control the use of third-party cookies (or any resulting information collected). The use of third-party cookies is not covered by our Privacy Policy. We do not have access or control over these cookies.

Use of Your Personal Information

Swill uses Personal Information collected pursuant to this Privacy Policy to:

10. Provide the Service. Swill uses both Personal Information, and any other information we collect from you to provide you with the Service, to support and enhance your use of the Service, to monitor our most commonly used features, to display your purchase history, to display current promotions, to allow you to rate purchases, and to determine which features we need more of our focus or improvement.

11. Expand to New Markets. If the Service is not available in your geographic location, you will be presented the option to provide us with your email address and zip code so that we may notify you when the Service becomes available in your geographic area.

12. Fulfillment Optimization. We use Personal Information, and any other information we collect from you, to determine to which retailer(s) are selected to fulfil your order. where we should offer or focus services, features and/or resources.

13. Promotional Material. We may also track your past purchases to provide you with a personalized profile of your shopping history. In addition, Swill may notify you about new services or special promotional programs, or send you offers or information.

14. Application Optimization. We use Device-Specific Information to provide the correct application version depending on your device type, as well for troubleshooting technical issues.

15. Diagnose Technical Problems. Swill uses your Internet Protocol (IP) address to help diagnose problems with our servers, and to administer the Website and mobile application. Your IP address is used to gather broad demographic data. Your IP address contains no personal information about you.

16. Service-Related Announcements. We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. As these are service-related announcements, and not promotional material, you may not opt-out of these notices.

17. Customer Service. We will send you a welcoming email to the address you provide at registration to verify your username and password. We will also communicate with you in response to any inquiries, service requests, and any requests or inquiries regarding your account.

18. Identification of Age-Restricted Accounts. We use Personal Information to confirm that all Users of the Service are at least 21 years of age. Any age-related issues that may arise will results in a flag and/or suspension of your account in our system. Repeated violations of the age restrictions contained in this Privacy Policy will result in disclosure to applicable authorities.

Use of Non-Personal Information

Swill uses non-Personal Information collected pursuant to this Privacy Policy for the purposes stated herein. As used herein, non-Personal Information means information that may correspond to a particular person, account, or profile, but that is not sufficient to identify, contact, or locate the person to whom such information pertains. We may also use or share this information with third parties for research, marketing, and other business purposes.

19. Targeted or Behavioral Advertising. Targeted advertising (also known as Behavioral Advertising) uses information collected on an individual’s web browsing behavior such as the pages they have visited, the searches made, type of device used, or orders placed. This information is then used to select which advertisement should be displayed to a particular individual via the Service. For example, if you have shown a preference for a type of beverage while using the Service, you may be served an advertisement via the Service relating to that type of beverage. We may share or sell aggregated demographic information about our user base, including information related to your use of the Service (e.g., how you interact with our App and website, our partners and advertisers), your device type, UUID, purchase history, delivery location history, and click tracking, with third party advertisers for the purpose of selecting an appropriate audience for their advertisements, but only after either removing from such information anything that personally identifies you or combining it with other information so that it no longer personally identifies you. This information does not identify individual users by name, email or other contact information. If you would like to opt out of targeted advertising that occurs when using the Services, please contact us at [email protected]. Please note that this will opt you out of targeted ads delivered via the Services. If you opt out, you will continue to receive online advertising via the Services; however, these ads may not be as relevant to you.

20. Facilitate General Improvements to the Service, Website, or Mobile App. We strive to provide you the best possible experience when using our Service, whether on the Website or mobile app. To that end, we use non-Personal Information to assess the functionality of our Service and identify areas requiring additional resources or focus.

Disclosure of Your Information

Swill shares collected Personal Information, or non-Personal Information, from or about you only as set forth herein:

21. Aggregated Data. Swill may share or sell aggregated demographic or other information about our user base that includes non-Personal Information and log data (including how users interact with our Mobile App and Website), with third parties for industry analysis, demographic profiling, and to deliver targeted advertising about other products and services. This information does not identify individual users by name, email or other contact information.

22. Third Party Service Providers. Swill uses a third-party provider to host the ‘support’ section of the Service. Information collected within this section of the Service is governed by this Privacy Policy. Our third-party service provider does not have access to this information. We may employ, at our discretion and without notice, third party companies and individuals to facilitate our Service, to provide the Service on our behalf, provide customer support, perform Website-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Website’s features) or to assist us in analyzing how our Website and Service are used. Any access by these third parties to access to your Personal Information is provided only to perform these tasks on our behalf and is not retained by these third-parties.

23. Payment/Credit Card Transactions All payments and credit card transactions are processed by secure third party payment processors, and not by Swill. We have no control over third party payment processors. Any information that you provide to a third party payment processor is governed by such payment processor’s separate privacy policy, instead of this Privacy Policy. Please consult the privacy policy of the applicable third party payment processor. Swill neither accepts nor processes any payments, and neither Swill nor any retailers that facilitate the Services ever see or receive your payment card information.

24. Legal Process. Swill cooperates with federal, state, city, and local governments, law enforcement agencies and officials, and, where by court order, private parties, to enforce and comply with any and all applicable laws related to or arising out of the Services. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Swill or a third party whose property or rights we are required to protect, as well as to protect the safety of the public or any person(s), or to prevent or stop activity we may consider to be illegal, unethical or that would otherwise expose Swill to legally action.

25. Acquisition of Swill. In the event that all or a substantial portion of the assets, business or stock of Swill are acquired by, merged with or transferred to another party, or in the event that Swill goes out of business or enters bankruptcy, your Personal Information would be one of the assets that is transferred to or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Swill or its assets may continue to use your Personal Information pursuant to, and as set forth in this Privacy Policy.

Updating Your Personal Information

26. If your wish to update your Personal Information or email preferences, or if you no longer wish to use our Service, you may correct, delete, or amend your personal information and preferences by making the change on our user information page, or by emailing us at [email protected]. We will respond to your request as soon as we can, and usually within 30 days. Please note that your friends and contacts may still choose to send email invitations to you. Any user who receives an email invitation to join the Service may choose not to receive such invitations in the future by following the instructions in the email invitations and, in addition, if you are a user, you may also choose not to receive such invitations by changing your preferences as indicated above. We will take commercially reasonable steps to implement your opt-out requests promptly, but you may still receive communications from us for up to 30 days as we process your request.

Retention of Personal Information

27. Swill will retain your Personal Information for the period of time necessary to fulfill the purposes outlined in this Privacy Policy, but in any event, for no less than the minimum period required by law, and for no longer the maximum period allowed by law.

Security

28. All information Swill collects is securely stored within our database, and we use standard, industry-wide, Payment Card Industry-compliant, commercially reasonable security practices such as 128-bit encryption, firewalls and SSL (Secure Socket Layers). However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply won’t be intercepted while being transmitted to us over the Internet, and any information you transmit to Swill you do at your own risk. We recommend that you use unique numbers, letters and special characters in your password and not disclose your password to anyone. If you do share your password or personal information with others, you are responsible for all actions taken in the name of your account. If your password has been compromised for any reason, you should immediately notify Swill and change your password.

Public Forums

29. Our Website and App may offer publicly accessible blogs or community forums. Any information you provide in these areas may be read, collected, and used for any purpose by others who access them, including but not limited to Swill. We are not responsible for the personally identifiable or other information you choose to submit in these areas. To request removal of your personal information from our blogs or community forums, contact us at [email protected]. Please be aware, we may not always be able to remove your Personal Information once it is posted in a public forum.

Amendments and Swill Contact

30. Amendments. Swill reserves the right to amend this policy at any time. Swill will contact registered users by e-mail, and shall also post a notice of changes on its website, when and if the terms of this Privacy Policy are amended.

31. Contact. Should you have any questions regarding this policy, You may contact Swill directly by e-mailing [email protected]. or by mail at

Contact

Address: Swillio, Inc., 99 Wall St, New York, NY 10005

Email: [email protected]