Date last modified: May 21, 2022

Your use of our services is subject at all times to these Terms and Conditions of Use (the "Terms of Use"), as well as our Privacy and Security Policy (the “Privacy Policy”), which together constitute an agreement (the “Agreement”) between you and Zero Link Markets, Inc dba CompleteDTC (ZLM) for the use of our CompleteDTC web-based business management application and related services “CDTC”. The terms “CDTC”, “We”, “Us” or “Our” (and related words) mean ZLM. The terms “you” and “your” (and related words) mean any person or business entity who accesses CDTC or seeks to use CDTC through your website.

1. Description of CDTC.

ZLM provides CDTC as a service over the Internet. We may update, improve, or extend CDTC from time to time, with or without notice.

2. Accepting the Terms of Use.

You accept these Terms of Use and agree to be bound by this Agreement by checking the box labeled “I accept the CDTC Terms of Use” on your login page.

3. CDTC Accounts, Fees, and Payments.

3.1 Establishing a CDTC Account. When we accept you as a CDTC customer, we will provide you with a primary login.

3.2 Additional Authorized Users. You may create additional usernames and passwords for the additional users you authorize to access your CDTC Account through your Administration interface in CDTC. Every user of every username you create is subject to and must accept these Terms of Use.

3.3 Basic Account Cost. Your cost for using CDTC shall is stated on the CDTC website at https://completedtc.com/, which covers all Authorized Users as well as public access to the public-facing components of CDTC. Any pricing or fee changes will be notified to you 30 days in advance of said change.

3.4 Other Charges. We will also charge you, but only with your prior written agreement, for additional services (such as data migrations services, or third-party fees incurred by us on your behalf

3.5 Payment Terms. Payment will be paid via ACH Debit from your bank account. We bill monthly in arrears. Some fees may be deducted directly for each transaction as it occurs prior to the credit card settlement. There will be a $50 charge for any ACH Debits that are not cleared. Access to your account may be restricted by us without warning if your payment is not made.

4. Access to CDTC.

4.1 Access to CDTC Application through Designated URL. We will make CDTC accessible from a login page, in the form of https://yourdomain.cdtc.dev/ (the “Application URL”). You agree not to access or attempt to access CDTC by any means other than through the Application URL.

4.2 Interruptions of Service. CDTC may be unavailable when we may make periodic upgrades or perform scheduled maintenance. We will use reasonable efforts to alert Authorized Users to scheduled upgrade or maintenance interruptions, but we make no warranties or guarantees of continuous or uninterrupted service.

4.3 Control of Access. You agree to keep confidential and not disclose to any third parties any usernames or passwords associated with CDTC. You shall promptly notify us if you learn of a security breach related to your account, or if a username or password associated with your account is compromised in any way.

4.4 No Interference. You will not attempt to gain access to any portion of our systems or networks in any way that is not necessary for you to use CDTC. Thus, by way of example but without limitation:

(a) You may not access, attempt to access, or use the account or data of any CDTC account (or any portion of that account or data) if you are not an Authorized User with respect to that account.

(b) You may not access or use CDTC from any unauthorized software or network, or attempt to modify or reroute CDTC or combine it with any other software, product, service, or system.

(c) You may not provide any of C’TC's competitors with access of any kind to CDTC.

(d) You may not copy, modify, distribute, or publicly display any portion of CDTC or its underlying software.

(e) You may not license, rent, lease, sell, transfer, assign, distribute, display, host, outsource, or otherwise commercially exploit or make available CDTC, including on a time-share, service-bureau, or similar basis, to any third party other than an Authorized User.

(f) You may not create Internet links to CDTC which include log-in information (including but not limited to usernames, passwords, and secure cookies, or "mirror" or ”frame" any part of CDTC without our consent.

(g) You may not make any efforts to reverse engineer or reverse compile CDTC or underlying software or otherwise attempt to derive any source code, algorithms, program structure, or other trade-secret information therefrom, or allow any third party to do so, except to the extent such a restriction is expressly prohibited under applicable local law.

(h) You may not use any robot, spider, scraper, deep link or similar automated data gathering algorithm, tools, methodology or system to access, copy, monitor, CDTC or the CDTC website without our express written consent.

(i) You may not use any engine, software, tool, mechanism, algorithm, agent or device, including but not limited to robots, spiders, intelligent agents, to search or access the CDTC.net website except for a generally available third-party web browser application such as Internet Explorer, Firefox and Safari.

(j) You may not post or transmit to CDTC any files containing viruses, worms, or other contaminating or destructive elements or otherwise seek to interfere with the operation of CDTC.

5. Permitted Use and Restrictions on Use.

5.1 Permitted Use. You and all your Authorized Users may use CDTC only for the purpose of sales, customer management, internal recordkeeping, marketing, reporting, and management activities related to your own business, in accordance with all the terms and conditions of this Agreement. You agree that each of your Authorized Users similarly will abide by all restrictions on use set forth in this Section 5 and all other terms and conditions of this Agreement. You may begin using CDTC as soon as we have approved your initial use, and you and your Authorized Users may continue using it as long as CDTC may be made available to Authorized Users, subject to the restrictions on use set and all additional terms and conditions of this Agreement.

5.2 No Wrongful Use. You agree to use CDTC only for authorized, legal and ethical purposes, consistent with all applicable laws, regulations, and the rights of others, and only for the permitted use described above. You may not use CDTC in any manner that harms, or is likely to harm, ZLM or any of our subscribers, suppliers, affiliates, resellers, or other business partners. Without limiting the foregoing, you are specifically prohibited from using CDTC:

(a) To damage, disable, overburden or impair our service (or the networks connected to our service) or to interfere with anyone's authorized use of CDTC.

(b) To engage in or further any fraudulent, deceptive, or otherwise unlawful practices, including but not limited to tax evasion, money laundering or the conduct of any business for which you have not obtained all necessary licenses, permits and other approvals.

(c) To engage in any activities that violate or infringe upon the rights of any third party (including but not limited to intellectual property rights, publicity rights and privacy rights).

(d) To promote or support violent or threatening actions; illegal or harmful activities, substances, goods or services; or discrimination based on race, gender, religion, nationality, disability, sexual orientation, or age.

(e) To transmit any bulk unsolicited commercial communications.

(f) To engage in communications with any obscene, offensive, defamatory, slanderous, libelous or hateful material or themes.

(g) In circumstances where system unavailability, errors, or other anomalies could result in property damage, bodily injury or death.

6. Disclaimer of Warranties; Limitation of Liabilities.

6.1 Disclaimer of Warranties. CDTC IS PROVIDED ON AN "AS IS" "AS” AVAILABLE" BASIS. TO THE FULLEST EXTENT PERMISSIBLE PURSUANT TO APPLICABLE LAW, ZLM EXPRESSLY DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. ZLM EXPRESSLY DISCLAIMS ANY WARRANTY THAT CDTC WILL BE FREE FROM ERRORS, DELAYS OR INTERRUPTIONS, THAT ALL ERRORS WILL BE CORRECTED, OR THAT CDTC WILL MEET YOUR REQUIREMENTS. WE MAY UPDATE, IMPROVE, OR OTHERWISE MODIFY CDTC (OR ANY OF ITS INDIVIDUAL FEATURES OR FUNCTIONALITIES) AT ANY TIME AS WE SEE FIT IN OUR SOLE DISCRETION. ZLM IS NOT RESPONSIBLE FOR DELAYS CAUSED BY ACCIDENT, WAR, ACT OF GOD, EMBARGO, COMPUTER SYSTEM FAILURE, OR ANY OTHER CIRCUMSTANCE BEYOND ITS CONTROL WHATSOEVER.

6.2 Disclaimer of Warranties or Representation Regarding Legal or Accounting Compliance and Similar Matters. ZLM AND ITS SUPPLIERS ARE NOT ENGAGED IN RENDERING LEGAL, ACCOUNTING OR OTHER PROFESSIONAL SERVICES. IF LEGAL OR ACCOUNTING ADVICE OR OTHER EXPERT ASSISTANCE IS REQUIRED, YOU SHOULD SEEK THE SERVICES OF A COMPETENT PROFESSIONAL. WE EXPRESSLY DISCLAIM ANY REPRESENTATIONS OR WARRANTIES THAT YOUR USE OF CDTC WILL SATISFY ANY STATUTORY OR REGULATORY OBLIGATIONS OR WILL OTHERWISE ENSURE COMPLIANCE WITH ANY APPLICABLE LOCAL, STATE, FEDERAL, NATIONAL OR INTERNATIONAL LAWS OR REGULATIONS (COLECTIVELY APPLICABLE LAWS"). YOU ARE SOLELY RESPONSIBLE FOR ENSURING THAT YOUR USE OF CDTC IS IN ACCORDANCE WITH APPLICABLE LAWS. IT IS YOUR RESPONSIBILITY TO BE AND REMAIN INFORMED REGARDING ALL APPLICABLE LAWS AND ACCOUNTING AND OTHER PRACTICES THAT AFFECT YOUR BUSINESS.

6.3 Disclaimer of Warranty of Continuous Operation. You acknowledge that CDTC may be inaccessible, unavailable or inoperable from time to time for any reason whatsoever, including but not limited to: (i) equipment malfunctions; (ii) periodic maintenance procedures or repairs that ZLM may undertake from time to time; or (iii) causes beyond the control of ZLM or that are not reasonably foreseeable by ZLM, including without limitation, interruption or failure of telecommunication or digital transmission links, hostile network attacks, the unavailability, operation or inaccessibility of websites or interfaces, network congestion, or other failures. You further acknowledge and agree that (i) We have no control over the availability of CDTC on a continuous or uninterrupted basis; (ii) We are not responsible for the functionality of any third-party website, interface, or link; (iii) The terms of this Agreement are subject to the limitations of our hardware, software and bandwidth; and (iv) Our failure to make CDTC available because of technical difficulties or for any reason out of our control does not amount to a failure to meet the obligations or result in a breach by ZLM of this Agreement, and you expressly waive all right to dispute such failure.

6.4 No Responsibility for User Communications. We have no obligation to monitor or police communications or data transmitted through CDTC and we will not be responsible for the content of any such communications or transmissions. You are responsible for the content of any communications and data that you transmit, upload or post through CDTC.

6.5 Limitation on Disclaimer of Warranties. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF CERTAIN WARRANTIES IN CERTAIN CIRCUMSTANCES. ACCORDINGLY, SOME OF THE LIMITATIONS SET FORTH ABOVE MAY NOT APPLY TO YOU

6.6 Limitation of Liability. UNDER NO CIRCUMSTANCES SHALL ZLM BE LIABLE TO YOU FOR ANY PUNITIVE, INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, OR EXEMPLARY DAMAGES OR LOSSES, COSTS OR EXPENSES INCLUDING BUT NOT LIMITED TO LOSS OF PROFITS OR INTERRUPTION OF BUSINESS (EVEN IF ZLM HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES), ARISING FROM ANY ASPECT OF THE RELATIONSHIP PROVIDED HEREIN. IN NO EVENT SHALL THE TOTAL OBLIGATIONS OR LIABILITY OF ZLM HEREUNDER EXCEED $500. REGARDLESS OF ANY LAW TO THE CONTRARY, NO ACTION, SUIT OR PROCEEDING SHALL BE BROUGHT AGAINST ZLM MORE THAN ONE YEAR AFTER THE DATE UPON WHICH THE CLAIM AROSE.

7. Additional Authorized User Responsibilities.

7.1 Internet Connectivity. In order to use CDTC you will need Internet connectivity and a web browser. The CDTC webstore currently is configured for use on specific versions of the Internet Explorer, Firefox, Safari, and Chrome browsers on current versions of both Windows and OS X operating systems. Other CDTC functionality currently is configured for use on specific versions of the Firefox, Safari, and Chrome web browsers. For the current list of acceptable browsers please see the 'requirements' information at http://www.CDTC.net/faqs. You will be solely responsible for acquiring and maintaining all telecommunications and Internet services and other hardware and software required to access and use CDTC, including, without limitation, any and all costs, fees, expenses and taxes of any kind relating to the foregoing.

7.2 Accuracy of Registration Data, Cooperation, Assistance. You understand that our ability to provide CDTC depends in part on the information and cooperation that we receive from you. Accordingly, you agree promptly to update Registration Data as necessary to keep it accurate, current and complete at all times. In addition, you agree to provide us with such information and cooperation as we may reasonably require in performing our duties under this Agreement.

7.3 Username and Password Control; Notification. Our ability to provide CDTC to you depends on the integrity and your proper use of your account. Accordingly, you agree that: (i) you will not allow access to or use of CDTC (or any portion thereof) by anyone other than Authorized Users or for any purpose prohibited under this Agreement; (ii) you will ensure that all Authorized Users comply with the terms and conditions of this Agreement; and (iii) you will be responsible for any violation of this Agreement by any Authorized User, and for any unauthorized use of the usernames, passwords, or other security credentials associated with your account. You further agree to notify us promptly if you become aware of any loss or theft or unauthorized use of any of your passwords, usernames, and/or account number, or of any other suspected or alleged violation of this Agreement, and you will cooperate with us in any investigation or enforcement efforts. In addition, you agree to maintain current and accurate information regarding the identity of each Authorized User (and their corresponding username and password), and you agree to make that information available to us upon request for purposes of enabling us to provide CDTC and to enforce the terms of this Agreement. Without limiting any of our other rights and remedies, we may suspend or terminate any Authorized User's access to CDTC upon notice to you in the event we determine that the Authorized User has violated the terms of this Agreement. We will communicate with you by email to the email address you provide. It is your responsibility to update or modify that email address as may be needed so that communications may be sent to you.

8. Ownership Rights.

8.1 Your User Data. When you use CDTC, you will be providing us with information, accounts, data, and other information and materials pertaining to your business (referred to here as your "User Data"). We acknowledge that your User Data belongs to you, and we will provide you with a mechanism to download your User Data in machine-readable form at any time you request in writing. When you submit any User Data to CDTC, you represent that you have all necessary rights in and to that User Data and you hereby grant us a license to use your User Data, solely for the purpose of making CDTC available to you, your Authorized Users, and (where relevant and appropriate) to visitors to your website.

8.2 CDTC Ownership and Intellectual Property Rights.

(a) CDTC, the software and other resources used to provide CDTC (and all copies of such software or other resources), and all associated intellectual property rights including, without limit, the registered trademark “CompleteDTC”, belong exclusively to ZLM and its licensors (the "ZLM Property"). Nothing in this Agreement gives you any rights with respect to the ZLM Property except for the access and usage rights expressly granted above.

(b) Except as permitted by this Agreement, neither the ZLM Property nor any materials, assistance, instructions, or information that we provide in relation to any ZLM Property (whether provided verbally, in writing , electronically or otherwise), may be copied, reproduced, modified, distributed, republished, displayed, posted, or transmitted in any form or by any means, in whole or in part, nor may you make any efforts to derive any source code, algorithms, program structure, or other trade-secret information therefrom, or allow any third party to do so, except to the extent such a restriction is expressly prohibited under applicable law.

(c) Nothing in this Agreement limits any rights that we may have under any trade secret, trademark, copyright, patent or other laws. Without limiting the foregoing, we will have the right to specific performance with respect to your obligations under this Section 7.

9. License to Use Feedback-related Content.

We may provide you with a mechanism to provide feedback, suggestions, and ideas about our products and services ("Feedback"). You agree that we may, in our sole discretion, use the Feedback you provide us in any way, including in future modifications of CDTC and in any multimedia works and/or advertising and promotional materials relating thereto. When you submit any Feedback to CDTC you may not post or transmit any message that is defamatory or libelous, or which discloses private or confidential information of any third party. You may not post or transmit any message or information that is obscene, pornographic, harassing, hateful, threatening, abusive, racially or ethnically offensive, or that encourages conduct that would be a criminal offense or other confidential or proprietary information of third parties that you do not have authorization to post or transmit. You hereby grant us a perpetual worldwide fully transferable non-revocable royalty-free license to use, reproduce, modify, create derivate works from, distribute, display and commercialize any materials, information and ideas you provide to us in the Feedback. Except as required by applicable law, we agree not to disclose your identity as the source of the Feedback other than to our employees, consultants, and advisors who are bound by confidentiality obligations, unless we have your permission to disclose it.

10. Privacy and Security.

Please review the CDTC Privacy and Security Policy, which can be found at http://www.CDTC.net/privacy-security/privacy-policy/ and which is incorporated into this Agreement by this reference. We will respect the privacy and confidentiality of your User Data, as described in our Privacy and Security Policy. We also understand the importance of protecting the security of your User Data and agree to the practices set forth in the Privacy and Security Policy regarding data security.

Our Privacy and Security Policy may be amended from time to time and posted in its amended form to our website. You will be deemed to agree to and accept the terms and conditions of this policy as last amended and you acknowledge that it is your responsibility to stay informed of changes to, our Privacy Policy and Security Policy.

11. Indemnification.

You will defend, indemnify and hold harmless ZLM, its officers, directors and employees, from and against any liabilities, losses, damages and expenses, including court costs and reasonable attorneys' fees, arising out of or in connection with (a) any breach by you of this Agreement or (b) any third-party claim that (i) a third party has suffered injury, damage or loss resulting from your or an Authorized User's use of CDTC; or (ii) you or any Authorized User have used CDTC (or have allowed any other person to use CDTC) in a manner that violates any term or condition of this Agreement. We will provide you with prompt written notice of any such claim, and we will cooperate with you and provide you with all reasonably available information and assistance, at your expense, in the defense and settlement of such claim.

12. Termination.

12.1 Termination by You. You agree to be bound by these terms and conditions until you close your account with ZLM or until we terminate your account. You may cancel your account at any time, by following the instructions found at Settings and then Manage Account after you sign in to CDTC. Once your CDTC account has been canceled, we will delete all of your User Data unless other arrangements have been made for storing the User Data for you, as described under "terminating your account".

12.2 Blocking access to your account. We may, at our sole discretion, block any or all Authorized User usernames and passwords associated with your account, including yours, if and as long as any invoice from us is delinquent; our failure to block your access in such an event does not in any way constitute a waiver of this right. Should we block your access, your data will be preserved for a minimum of 90 days but you will not be able to download it until you have brought your account current.

12.3 Termination by ZLM. We may terminate your account at any time without notice if: (a) you have breached any provision of this Agreement, except that breach resulting simply from nonpayment may result in blocking access to your account, as described above; or, (b) if we believe in our sole discretion that we are required by law to terminate your account; or, (c) we notify you that we no longer wish to allow you to use CDTC. We may terminate your account at any time in our own discretion on 30 days' written notice to you.

13. Modifications.

We may modify these Terms of Use from time to time. We will notify you of all changes to these Terms of Use through a notice posted to the CDTC.net website, as well as by requiring you and all other Authorized Users to accept the modified Terms of Use the first time you log in following a change. We will also post on these Terms of Use the date on which they were last modified. You will be deemed to have agreed to the Terms of Use as last modified and to be bound by them when you use CDTC after those modifications were posted.

14. Miscellaneous.

14.1 Governing Law, Jurisdiction and Venue. This Agreement will be construed in accordance with and governed by the laws of the State of California, without regard to its choice of law or conflicts of law provisions. The exclusive forum for any actions related to this Agreement will be in the state courts, and, to the extent that federal courts have exclusive jurisdiction, in the federal courts, in the City and County of San Francisco, California, except that, if ZLM is seeking injunctive relief with respect to preventing imminent harm ZLM may do so in any court with jurisdiction over the parties. The parties agree to such venue and jurisdiction.

14.2 Entire Agreement; Modification. This Agreement contains the entire understanding and agreement of the parties hereto and supersedes any agreements, either oral or written. ZLM shall have the right to change, modify or amend any or all of the terms and conditions contained in this Agreement, in whole or in part, at any time, on written notice to of such changes or modification, which notice may be provided by posting the modifications to the CDTC website and sending you an email alerting you that there has been a change.

14.3 Notice. All notices, demands and other communications provided for or permitted under this Agreement shall be made by email to ZLM at CustomerService@VinoShipper.com, and by email to you at the email address you designated when you created your CDTC account or at such other email address as you may designate by subsequent email notice to us.

14.4 Assignment. You may not assign any rights or obligations under this Agreement without the prior written consent of ZLM. Any assignment, transfer or attempted assignment or transfer in violation of this Section shall be void and of no force and effect. ZLM and any of its subsequent assignees or successors may assign this Agreement, in whole or in part, or any of its rights or delegate any of its duties under this Agreement, to any party.

14.5 Force Majeure. Neither party shall be liable by reason of any failure or delay in the performance of its obligations hereunder for any cause beyond the reasonable control of such party, including but not limited to electrical outages, failure of Internet service providers, default due to Internet disruption (including without limitation denial of service attacks), riots, insurrection, acts of terrorism, war (or similar), fires, flood, earthquakes, explosions, and other acts of God.

14.6 Survival; Severability. All covenants, representations, warranties and agreements made in these Terms of Use shall survive and remain in effect after the termination of this Agreement. In the event that any provision of this Agreement becomes or is declared by a court of competent jurisdiction to be illegal, unenforceable or void, this Agreement will continue in full force and effect without said provision; provided that no such severability will be effective if it materially changes the economic benefit of this Agreement to either party.

14.7 Effective Date. The effective date of these Terms of Use is May 23, 2022.

Last updated May 23, 2022

This privacy policy (the "Privacy Policy") sets forth the data protection and privacy practices and procedures of Zero Link Markets, Inc., a California corporation, its affiliates, and its and their respective parents and subsidiaries (individually and collectively, "Company," "we," "our" or "us"), and applies to the URL, https://www.CompleteDTC.com, and all other websites, social media pages and accounts owned by the Company (individually, and collectively, the "Websites"), and all mobile applications owned by the Company (together with the Websites, collectively, the "Company Sites").

Types of Information Collected and How It Is Used

Through the use of the Company Sites, the Company markets wines and related products directly to consumers, and offers consumers the opportunity to create a personal account with the Company (the "Account") or to log in to the Company Sites as a guest (the "Guest Log-In"), and to take advantage of the various products and/or services, including, without limitation, the opportunity to purchase wine products and related products from licensed entities in their state and to register as members of the various wine clubs that the Company services (the "Wine Clubs") (collectively, the "Wine Services"). The sale and delivery of orders purchased by consumers will be executed and fulfilled by us and third-party entities holding valid licenses issued by state alcohol beverage agencies allowing for the legal sale of wine products.

Personal Information (PI)

Although many areas of the Company Sites do not require registration and may be accessed by you without having to disclose any personal information, when using the Wine Services and or other aspects of the Company Sites, we or our service providers may collect, use and share personally identifiable information, such as your name, age, billing address, shipping address, age, email address, telephone number, password, and credit card information (collectively, "PI"). Please remember that it is your responsibility to protect the confidentiality of your login and password data. The Company Sites are directed to adults aged twenty-one (21) or older.

We collect PI from you when you voluntarily provide it directly to us when you engage in activities on the Company Sites. We use the PI we collect for various purposes, including to: (i) create your Account; (ii) permit a Guest Log-In to the Company Sites; (iii) create a shopping cart and/or process your orders placed in connection with the Wine Services; (iv) register a Wine Club membership; (v) contact you, for example, if there is an issue with any orders placed through our Wine Services or your Wine Club membership; (vi) send you email communications, and/or newsletters you have requested; (vii) respond to questions or other requests; (viii) inform you of new products, services, promotions, and offers and those of our Brand Partners (as defined below) through email, postal mail, telephone or other means; (ix) contact you with respect to your use of the Company Sites or changes to the Privacy Policy or other Company policies; (x) improve the Company Sites and the content, features and services provided by the Company Sites, as well as customer service; (xi) update and maintain the accuracy of our information; (xii) use for our internal business purposes; (xiii) send you other notices in order to comply with applicable laws and regulations; and (xiv) for other purposes disclosed at the time you provide your PI. Depending on the activity, some of the PI we ask you to provide us is required and some is voluntary. If you do not provide the required information for a particular activity, you may not be permitted to engage in that activity.

The PI you provide to us to create your Account will be available for viewing by visiting the Company Sites and entering your personal log-in information that you create when registering your Account. By creating an Account, you may use our services to track your order history, status of pending orders, preferences, credits, and Wine Club memberships. If you choose not to create an Account but to instead place orders by using a Guest Log-In, you may contact the Company to review or update the PI you have provided by using the telephone numbers and/or addresses listed below under the heading entitled "Contact Information." If you ever use a public computer to access the Company Sites, we strongly encourage you to log out at the conclusion of your session. We may permit you to log into your Account via social networks, but please note that by doing so, your use of a social network will be governed by such social network's privacy policy and terms and conditions.

Non-Personal Information (NPI)

When you visit the Company Sites, we may also collect certain non-personally identifiable information from you ("NPI"), including, without limitation, website usage information about how our visitors use and navigate the Company Sites, including the number and frequency of visitors to each web page, the duration of their stays, the visitor's browser and operating system, the domain name of each visitor's Internet service provider, and certain other information (e.g., IP address and clickstream data). When you request pages from the Company Sites, our servers log your IP address. We may use IP addresses for a number of purposes, such as system administration, to report aggregate information to our business partners or to audit use of the Company Sites. We may share NPI with others without express notice to you or consent from you, and we may exploit, use and disclose your NPI without limitation of any kind.

We may also collect certain information automatically, including through the use of cookies, web beacons and other technologies. We use "cookies" (i.e., small pieces of information placed on your computer hard drive) on certain parts of the Company Sites. Cookies allow websites to remember user activity and visits to a site. We use cookies on the Company Sites to determine the number of unique visitors we host on the Company Sites over any given period of time and to keep track of items placed in the "shopping cart" during a visit to the Company Sites. We do not use cookies to collect PI. You can program your computer to warn you each time a cookie is being sent or disable cookies on your computer by indicating this in the preferences or options menus in your browser. However, by blocking all cookies you may not have access to certain features on the Company Sites.

We may also use "pixel tags" (sometimes called "web beacons" or "clear gifs"), which are tiny graphic images, on the Company Sites. Pixel tags help us analyze users' online behavior and measure the effectiveness of the Company Sites and our advertising and marketing. We may also use other analytical tools to evaluate site performance through the use of aggregated data, which contain no PI. We work with service providers that help us track, collect, and analyze this information.

Cookies, pixel tags, and/or other analytical tools that we may use on the Company Sites may collect information about your visit, including the pages you view, the features you use, the links you click, and other actions you take in connection with the Company Sites. This information may include your computer's Internet protocol (IP) address, your browser type, your operating system, date and time information, and other technical information about your computer. We may also track certain information about the identity of the Company Sites you visited immediately before coming to the Company Sites. We do not otherwise track any information about your use of other Company Sites. Cookies, pixel tags, and/or other analytical tools in our emails may also be used to track your interactions with those messages, such as when you receive, open, or click a link in an email message from us. We may also work with businesses that use tracking technologies to deliver advertisements on our behalf across the Internet. These companies may collect information about your visits to the Company Sites and your interaction with our advertising and other communications, but no PI is shared with them.

We may combine the NPI collected through cookies, pixel tags and other analytical tools with other information we may have collected from you. This information may be used to improve the Company Sites, to personalize your online experience, to help us deliver information to you, to determine the effectiveness of advertising, and for other internal business purposes.

With Whom Information May Be Shared

Except as disclosed in this Privacy Policy, the Company does not share your PI with unaffiliated third parties. We may disclose your PI to outside individuals and/or companies who help us: (i) bring you the products and services we offer; (ii) create, operate, and maintain the Company Site(s); (iii) with specialized services such as payment processing, shipping, mail and e-mail distribution, mobile messaging, website(s) hosting, monitoring, analytics, promotions management, survey and mobile payment processing; and (iv) state governments to the extent required to meet their regulatory and compliance requirements . We provide these third-party companies only with the information they need to perform their services. For mobile payment processing, the mobile payment service providers will provide your information to your mobile telephone service provider to bill you directly.

We work with certain strategic partners (the "Brand Partners") in connection with the creation and operation of various co-branded Wine Clubs, which are promoted by us and our Brand Partners. We disclose only the PI required to make these particular Wine Clubs work and to support your membership with them, which typically includes your name and/or email address, as well as information regarding the purchases you make through the particular Wine Club. We disclose this information to our Brand Partners under an agreement that requires that they maintain the confidentiality and security of your PI in the same manner The Company does. If you do not wish to receive marketing, promotional, or other communications from our Brand Partners, you must contact them directly.

We may sell, transfer or otherwise disclose user information, including PI, in connection with a corporate merger, consolidation, the sale of all or substantially all assets or of a business group, or other corporate change of the Company.

We may disclose information about our users, including PI, when legally required to do so at the request of governmental authorities conducting an audit or investigation, or to verify or enforce compliance with the policies governing the Company Sites and applicable laws, rules, and regulations. We may use IP addresses to identify users in cooperation with Internet service providers or law enforcement agencies, and may also disclose user information whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests or safety of the Company Sites, our users or others.

The Company may share NPI with third parties. We may use and share aggregated and anonymous NPI to conduct market research and analysis for ourselves and/or for our business partners. Given the anonymous, non-personally identifiable nature of such information, there are no restrictions under this Privacy Policy on how we may use or disclose such information. For example, we may freely share such information with third parties who may use such data for their own marketing, advertising, research, or other business purposes. We may also freely share such information with our service providers in order for them to perform services to or for us. We authorize certain service providers to utilize NPI for their business purposes and in accordance with their privacy policies, such as to report on usage or industry trends to their customer base.

Changing Your Preferences; Opt-Out

You may opt out of your subscriptions to receive marketing mailings or e-mail communications from the Company at any time by (a) following the instructions to "opt-out" of future marketing communications contained within the direct mailing, or e-mail, that you receive from the Company, or (b) by sending us an email or writing to us at the addresses listed below under the heading entitled "Contact Information." Please allow up to ten (10) business days for changes to take place. During that time, you may continue to receive such communications from us that were already in process.

You can opt out of accepting cookies or disable them from your browser. The "help" function on most browsers contains information on how you can set your browser to notify you before accepting cookies or can disable them entirely. If you opt out of cookies, you will not be able to take advantage of various features of the Company Site(s) that are available to other users. For example, we may use cookies to recognize you by name when you return to a Company Site so you don't have to login again and provide your password.

You may ask us to delete your PI from our system, however, because we archive and keep track of past transactions, you cannot delete information associated with past transactions or archived information on the Company Sites.

If you do not receive a response from us to any emails you send to us within ten (10) business days, please send us another email as your original email may not have been received.

Links to Other Sites and Content Accessible Through the Company Sites

Our Company Sites may include links to other websites whose privacy practices may differ from ours. We are not responsible for the privacy practices of websites operated by third parties that are linked to or integrated with the Company Sites or for the privacy practices of third parties. If you submit PI to any of those websites, your PI is governed by the privacy statements of those websites. We encourage you to carefully read the privacy statement of any website you visit.

Security

While the Company strives to secure your PI, even reasonable security measures do not guarantee the security of any information you transmit via the internet, including to the Company. The Company cannot guarantee that information it seeks to protect will be protected under all circumstances, including those beyond its reasonable control. You acknowledge and agree that you transmit information to the Company via the Company Sites at your own risk. Additionally, please be advised that if you share with others emails or URLs you receive from the Company, such sharing may allow access to limited PI on the Company’s website, including your name, shipping address and product orders (in addition to the PI in the email itself). In doing so, you may be sharing your PI with others and you acknowledge that you will be sharing at your own risk.

Children

The Company Sites are directed to adults aged twenty-one (21) or older. We do not knowingly collect PI from children under thirteen (13) years of age. We will promptly delete any information later determined to be from a user younger than thirteen (13) years of age.

Consent to Transfer

The Company Sites are located in the United States. Your PI will be processed and shared in the United States, where data protection and privacy regulations may provide different levels of protection compared with non-United States jurisdictions. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the Company Sites or providing us with your information, you consent to this transfer.

Modifications

The Company may modify this Privacy Policy from time to time. If we make any substantial changes in the types of PI we collect or how we use it, we will inform you of such changes by posting a revised notice on our Company Sites and such changes will be effective when posted. Unless you inform us otherwise, we will use your PI consistent with the Privacy Policy currently in effect. It is your responsibility to review any such changes or updates and check the Company Sites from time to time to be sure you understand all terms and conditions, agreements and policies of the Company Site(s) and are in compliance with them. Your continued use of the Company Sites following the posting of any amendment, modification or change shall constitute your acceptance thereof.

California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request information with respect to the disclosure of your PI by us to third parties for such third parties' direct marketing purposes. We are only required to respond to a particular customer's request for such information once during a calendar year. To make such a request, please send us an email or write to us at the addresses listed below under the heading entitled "Contact Information."

In Addition, Please Note the Following:

(a)Users can visit the Company Sites anonymously;(b)We will add a link to this Privacy Policy on our home page, or at a minimum, on the first significant page after entering the Company Sites;(c)Our Privacy Policy link can easily be found on the page specified above;(d)Users will be notified of any privacy policy changes on our Privacy Policy page;(e)Users are able to change their PI by emailing us or by calling us;(f)Some Internet browsers include the ability to transmit "Do Not Track" signals that give you control over the collection and use of web browsing information. Because uniform standards for "Do Not Track" signals have not yet been adopted, we do not process or respond to such signals in users' web browsers at this time; and(g)We allow the collection of users' behavioral tracking (but not PI) by third parties. We do not authorize the collection of PI on the Company Sites by third parties.

Non-Confidential Information

We do not want you to send to us any confidential or proprietary information through email or otherwise. Any information, materials, suggestions, ideas or comments sent to us will be considered non-confidential, and by submitting the same to us, you are giving us the absolute right to use, modify, reproduce, transmit, display and distribute the information for any purpose whatsoever, with no payment or other compensation to you. However, we will not use your name unless we are required by law to identify the source of the materials, information, suggestions, ideas or comments, or unless we first obtain your permission.

Assignment

We may freely assign this Privacy Policy or any of our rights and/or obligations hereunder.

Disputes

Any disputes regarding this Privacy Policy are subject to our Terms & Conditions, including that this Privacy Policy will be governed by the laws of the State of California, applicable to agreements made and performed in California, and the Dispute Resolution Policy therein. THE DISPUTE RESOLUTION POLICY INCLUDES A REQUIREMENT THAT ANY DISPUTES BE SUBMITTED TO ARBITRATION (NOT TO A COURT OR A JURY) AND A WAIVER OF ANY RIGHT TO BRING A CLASS ACTION OR PRIVATE ATTORNEY GENERAL CLAIM. See Terms & Conditions SOME JURISDICTIONS DO NOT ALLOW THE LIMITATIONS OR EXCLUSION OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO SOME OF THE TERMS & CONDITIONS MAY NOT APPLY TO YOU.

Contact Information

If you have any questions or comments about our Privacy Policy, or would like to review or update the PI that you have provided to us, please contact us at:
Email
CustomerService@Vinoshipper.com
Phone
1-866-678-8466
Mail
Zero Link Markets, Inc.
Attn: Customer Service
228 Windsor River Rd. #111
Windsor CA 95492

Effective Date of Policy

This Privacy Policy is effective as of May 23, 2022