Handled · Legal

Privacy Policy

Last updated: July 1, 2026

Effective Date: July 1, 2026

Thank you for visiting the Privacy Policy (“Policy”) of Handled Spirits LLC (hereinafter referred to as either “Handled,” “we,” “our,” or “us”). Handled holds customer privacy in the highest regard, and we are committed to protecting your privacy. This Policy applies online and offline, to the websites, mobile applications and other interactive features and online services owned or operated by Handled that post a link to this Policy (collectively, the “Services”), and to other data collected offline from or about you by us.

Please take a moment to review this Policy. It provides you with information about the types of data that we collect on the Services, how to set your privacy preferences, and your rights under this Policy concerning your “Personal Information” (defined as information that can identify, relate to, describe, be associated with, or be reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household). This Policy does not govern the data practices of third parties that may interact with our Services.

We also encourage you to review Handled’s Terms of Service for other information concerning use of the Services. By using the Services, creating an account, or contacting Handled, you agree to this Policy and Terms of Service, and consent to the collection and use of your Personal Information as described in this Policy.

This Policy addresses the following topics:

  1. Information We Collect
  2. Sources of Personal Information
  3. Use of Your Information
  4. Disclosure of Your Information
  5. Cookies and Other Tracking Technologies
  6. Purchases and the Retailer of Record
  7. Third-Party Content and Services
  8. Children’s Online Privacy Protection
  9. Your Choices and Rights
  10. Data Security and Retention
  11. Updates to the Policy
  12. Contact Us

Information We Collect

Handled may collect information that you provide directly to us through the Services, as well as information collected automatically, including (1) Device Information; and (2) Personal Information (each as defined below).

Device Information

We may automatically collect Device Information regarding use of or access to the Services, such as:

  • The Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used);
  • The type of device you use to access the Services;
  • The operating system and/or browser type that you use to access the Services;
  • The date and time you access the Services;
  • The sections within the Services that you access;
  • The user language;
  • The screen resolution; and
  • The connection type that you use to access the Services.

This information (collectively, “Device Information”) does not, by itself, personally identify users. We use this Device Information to monitor the effectiveness of the Services, to help personalize your experience, and to consider potential improvements to the Services. Device Information may be collected through cookies or similar technologies. For more detailed information on cookies, please refer to the “Cookies and Other Tracking Technologies” section below.

Personal Information

The categories and specific types of Personal Information that Handled may collect about you include:

  • Direct identifiers and contact information, including your name, address, phone number, email address, business contact information, or other similar identifiers;
  • Demographic information, including age and general location;
  • Identifiers of our third-party partners, collaborators, and creators, and their employees, with whom we may interact; and
  • Information you submit when you contact us for support.

The following information may also be Personal Information depending on how it is used and linked with other information:

  • If you receive an email from us, we may use certain tools to capture data related to when you open our message or click on any links or banners it contains;
  • Website interactions, including how you interact with links you can click on, information that you type into online forms, or information about your device or browser;
  • Information about how you interact with our Services, including data such as access dates and times, pages viewed, system activity, type of browser, and third-party sites or services used before interacting with our Services; and
  • Browser type, operating system, IP address, domain name, click activity, referring website, and/or a date/time stamp for visitors.

Sources of Personal Information

We collect your Personal Information in the following ways, pursuant to applicable law:

  • Directly From You, when you use our Services, register for an account or create a profile, contact us, or sign up to receive emails, text messages, and/or postal mailings;
  • Through Our Use of Cookies and Other Automatic Data Collection Technologies, when you visit our Services, open or click on emails we send you, or interact with our advertisements. We or third parties we work with automatically collect certain information using technologies such as cookies, web beacons, clear GIFs, pixels, internet tags, web server logs, and other data collection tools. For more information, please see the “Cookies and Other Tracking Technologies” section below;
  • From Creators and Partners, including content creators who launch drops with us and other third parties we have partnered with to provide the Services; and
  • Other Sources, including data analytics providers or publicly available sources.

Use of Your Information

Handled may use information about you for any purpose that is not inconsistent with this Policy or a statement made by Handled at the point of collection, including but not limited to the following:

  • Providing our Services: We process your Personal Information to perform the services and fulfill our obligations under the applicable Terms of Service; where we have not entered into a contract with you, we base the processing of your Personal Information on our legitimate interest to operate and administer our Services;
  • Promoting the Security of Our Services: We process your Personal Information by tracking your use of our Services, creating aggregated non-Personal Information, verifying accounts and activity, investigating suspicious activity, and enforcing our Terms of Service, to the extent necessary to protect our legitimate interest in promoting the safety and security of the Services, systems, and applications, in protecting our rights and the rights of others, and in addressing potential or actual fraud, breach of policies or terms, and threats of harm;
  • Handling Contact and Support Requests: If you fill out a “Contact Us” web form or request support, or if you contact us by other means including via phone or email, we process your Personal Information to perform our contract with you and to the extent necessary for our legitimate interest in fulfilling your requests and communicating with you;
  • Developing and Improving our Services: We process your Personal Information to facilitate, manage, personalize, and improve your online experience, to analyze trends, and to track your usage of and interactions with our Services, to the extent necessary for our legitimate interest in developing and improving our Services and providing our users with more relevant content and offerings;
  • Identifying Opportunities: We process your Personal Information to assess new potential customer opportunities to the extent it is in our legitimate interest to ensure that we are meeting the demands of our customers;
  • Sending Marketing Communications: We process your Personal Information to send you marketing information, product recommendations, and other non-transactional communications (e.g., marketing newsletters or push notifications) about us and our affiliates and partners, including information about products, promotions, or events, as necessary for our legitimate interest in conducting direct marketing or, where necessary, to the extent you have provided your prior consent;
  • Sending Notifications: We process your Personal Information to send you required notices and other relevant, non-marketing communications, as necessary for our legitimate interest in providing you with required notices and important information related to our Services; and
  • Complying with Legal Obligations: We process your Personal Information when cooperating with public and government authorities, courts, or regulators to the extent necessary to comply with our legal obligations, protect our rights, protect against misuse or abuse of our Services, protect personal property or safety, pursue remedies available to us, limit our damages, comply with judicial proceedings, court orders, or legal process, respond to lawful requests, or for auditing purposes.
  • Other Uses with Your Consent: When you have provided your consent for processing, we may also rely on that consent as a basis for processing your Personal Information.

Use of Your Sensitive Personal Information

With regard to Sensitive Personal Information, we only use your Sensitive Personal Information to provide you with the requested Services.

Disclosure of Your Information

We are committed to maintaining your trust, and we want you to understand when and with whom we may disclose the information we collect. We will disclose your Personal Information only in the ways that are described in this Policy, with the following parties:

  • Service Providers: Handled’s agents, vendors, consultants, and other service providers (collectively, “Service Providers”) may receive, or be given access to, your Personal Information in connection with their work on our behalf. Service Providers’ access to data is strictly limited to the purpose of providing such services to Handled. These Service Providers are sub-processors under the GDPR and other laws. We maintain written contracts with these Service Providers and require that they provide at least the same level of privacy protection and security as required by applicable law. They are required to perform the services based on our instructions and are not permitted to use the Personal Information for any other purpose;
  • Affiliates: Handled may disclose your Personal Information to its affiliates;
  • Retailer of Record, Distributors, and Fulfillment Partners: Because product is sold through a licensed three-tier chain, we may share the information necessary to process and fulfill a drop with the licensed retailer of record, its distributor, and fulfillment providers. The retailer of record operates the checkout and is the merchant of record for the consumer purchase; information you submit at checkout is collected by, and governed by the privacy policy of, that retailer, not Handled;
  • Other Disclosures with Your Consent: Your activities on the Services may, by their nature, result in the disclosure of your Personal Information to third parties. By engaging in these activities, you consent to that disclosure. Such third-party data collection is subject to the privacy and business practices of that third party;
  • Legal Obligations and to Authorities: Under certain circumstances, Handled reserves the right to disclose your Personal Information to a third party if it is necessary to comply with the law, law enforcement, or other legal process, and, where permitted, in response to a government request. We may also disclose your Personal Information if Handled believes your actions are inconsistent with our Terms of Service, policies, or any other notice made about the use of the Services, or if Handled believes it is necessary to protect the rights, property, life, health, security, and safety of Handled, its customers, or any third party;
  • Disclosure to Subsequent Owner or Operator: We may disclose or transfer your Personal Information to a successor entity in connection with any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Handled’s assets, or transfer of all or a portion of Handled’s business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding; and
  • De-identified or Aggregate Information: We may aggregate and anonymize information you provide to us in such a way as to ensure it will no longer be identifiable to you. We may share aggregate information, such as demographic and usage statistics, with advertisers, sponsors, or other organizations, in accordance with applicable laws.

Cookies and Other Tracking Technologies

Handled may, from time to time, use the following methods to collect usage information on the Services:

Log Information

We may collect and review web log information to understand how you interact with the Services. The information gathered in this format may include your IP address, browser type, internet service provider, referring/exit pages, operating system, and date/time stamps.

Web Beacons

Some of our Services web pages may use web beacons in conjunction with cookies to compile aggregate statistics about Services usage. A web beacon is an electronic image (also referred to as an “action tag,” “single-pixel,” or “clear GIF”) that is commonly used to track the traffic patterns of users from one web page to another in order to analyze the effectiveness of websites. Some web beacons may be unusable if you elect to reject their associated cookies.

Cookies

Handled may use “cookies” to collect information about your visit to our Services and to manage information concerning your preferences. A “cookie” is a unique identifier that we transfer to your device to enable our systems to recognize your device and to provide you with features that enhance the user experience. Tools available as part of most commercial browsers allow you to block new cookies, instruct the browser to notify you when you receive a new cookie, and, in some instances, delete existing cookies. The following describes how we use different categories of cookies:

  • Essential cookies. Essential cookies are necessary for basic website functionality, such as session cookies needed to transmit the website, authentication cookies, and security cookies. The Services will not perform as intended without these cookies. Examples include determining when you are signed in and other troubleshooting and security purposes;
  • Analytics cookies. Analytics cookies allow us to understand more about how many visitors we have, how many times they visit us, and how many times a user viewed specific pages within our Services. This information is used by us to improve our Services.

Purchases and the Retailer of Record

Handled is a licensed wholesaler and does not sell products directly to consumers. When you place an order through a drop page, the transaction is completed by a licensed retailer of record, which operates the checkout and is the merchant of record. Your payment and order details are collected and processed by that retailer (and its payment processor), not by Handled, and are subject to the retailer’s own terms and privacy policy. Handled receives only the information necessary to source, produce, and supply the product through the licensed distribution chain. We encourage you to review the retailer’s privacy policy before completing a purchase.

Third-Party Content and Services

The Services include functionality that allows certain kinds of interactions with a website, platform, tool, application, or other service that is not owned or operated by Handled (“Third-Party Services”). For example, we may provide interfaces or links on the Services to facilitate your purchase of products. However, such linking does not mean, and should not be interpreted to mean, that Handled endorses or makes any representations concerning such third-party websites. Handled neither reviews, controls, nor is responsible for these third-party sites or any content therein. By using such links, you will leave the Services. Any Personal Information that you provide to such third parties will be governed by their privacy policies, and we have no control over or responsibility for their privacy practices. If you decide to access any of the third-party sites linked to the Services, you do so entirely at your own risk. Unless otherwise indicated, this Policy does not apply to Third-Party Services. We encourage you to review the applicable third-party privacy policies or notices to understand how they collect, use, or disclose your Personal Information.

If you choose to use any Third-Party Services to enhance your use of the Services, the providers of those Third-Party Services may send Personal Information about you to Handled. To the extent that we combine such third-party sourced information, we will treat it as Personal Information under this Policy.

Children’s Online Privacy Protection

The Services are not directed to individuals under the age of 21 and/or children under the age of 13, and Handled does not knowingly collect information from children under the age of 13 through the Services. If we learn that we have received Personal Information from a child under the age of 13 through our Services, we will exercise commercially reasonable efforts to delete the information in accordance with applicable law.

Your Choices and Rights

By using the Services, you acknowledge and certify that you are at least 21 years of age. Depending on where you live, you may have certain rights with respect to your Personal Information. Your rights will vary depending on where you are located. Specifically, you may have the following rights:

  • Correction (Rectification): You have the right to request that we correct or supplement any inaccurate or incomplete Personal Information we process about you;
  • Deletion (Right to be Forgotten): You have the right to request that we delete your Personal Information. If required by law, we will grant your request. However, when we delete Personal Information it will be removed from our active database, but it may remain in archives where it is not practical or possible to delete it, and we may keep your Personal Information as needed to comply with our legal obligations, resolve disputes, and/or enforce our agreements;
  • Access: You have the right to request access to the Personal Information we hold about you, along with other information such as the purposes of the processing, the recipients or categories of recipients, the sources of the Personal Information, the retention period, and transfers of Personal Information;
  • Data Portability: In certain circumstances, you have the right to request that we provide the Personal Information you provided to us in a structured, commonly used, and machine-readable format, and the right to transmit that Personal Information to another entity;
  • Consent Withdrawal: Where our processing is based on your consent, you have the right to withdraw such consent at any time; however, you may not be able to use the Services or feature for which you are withdrawing your consent. Withdrawing your consent will not affect the lawfulness of the processing we conducted prior to your withdrawal;
  • Opt-Out of the “Sale” or “Sharing” of Personal Information: Subject to certain exceptions, California residents have the right to opt out of the “sale” or “sharing” (cross-context behavioral advertising) of their Personal Information. Handled does not currently sell your Personal Information or share it for cross-context behavioral advertising. If this changes, we will update this Policy and provide a method to opt out. To ask about our practices, please email us at lfd@handledspirits.com;
  • Restriction of Processing: You have the right to request that we restrict the processing of your Personal Information in certain cases;
  • Objection to Processing: In certain circumstances, you have the right to object to our processing of your Personal Information;
  • Automated Processing: Under certain circumstances, you have the right to object to a significant decision based solely on automated processing (i.e., without human intervention) unless that decision is required or authorized by law. We do not engage in automated decision-making without human intervention;
  • Right of Non-Discrimination / Non-Retaliation: We do not discriminate or retaliate against individuals who exercise any of their rights described in this Policy. However, we may offer financial incentives for the collection, retention, and use of Personal Information as permitted by applicable law, the material terms of which will be described in the applicable program terms. Participation in any such program is optional and you may opt out prospectively;
  • Right to Opt Out of Use of Sensitive Personal Information: We do not currently use or disclose Sensitive Personal Information for purposes other than those which cannot be limited under applicable law;
  • Promotional Emails: You may stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications. Even if you opt out of receiving promotional communications, Handled may, subject to applicable law, continue to send you non-promotional communications, such as those about your transactions, servicing, or Handled’s ongoing business relations; and
  • Promotional Text Messages: If you receive a text message from us that contains promotional information, you can opt out of receiving future text messages by replying “STOP.”

Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request and your state or country of residency, and you may be located in a jurisdiction where we are not obligated to fulfill a request. To the extent permitted by applicable law, we may reject requests that are unreasonably repetitive, unduly burdensome, risk the privacy of others, or would be very impractical to honor. Depending on where you are located, you may have the right to lodge a complaint with the relevant supervisory authority.

If you are a Nevada resident, in addition to the rights set forth above, you have the right to request that we do not make any sale (as defined in N.R.S. 603A) of your covered information. To opt out of the sale of your Personal Information, please email us at lfd@handledspirits.com.

If you are a California resident, in addition to the rights set forth above, you have the right to request information regarding the manner in which we share certain categories of your Personal Information with third parties for the third parties’ direct marketing purposes. You may submit such a request by emailing us at lfd@handledspirits.com and receive the categories of information disclosed, the names and addresses of the third parties that received it, and, where the nature of a third party’s business cannot reasonably be determined from its name, examples of the products or services marketed. You may also have a person authorized to act on your behalf make a verifiable request related to your Personal Information; we will require verification that you provided the authorized agent permission to make the request on your behalf.

To submit a request to exercise any of the rights described above (if they apply to you), please email us at lfd@handledspirits.com. Handled may require use of your Personal Information to provide access to the Services; therefore, when you exercise your deletion right in particular, you may lose access to certain aspects of the Services that require your Personal Information.

Data Security and Retention

Handled takes reasonable measures to protect Personal Information collected through the Services from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure, so we cannot guarantee that your Personal Information will be absolutely safe from intrusion by others, such as hackers. In the event that we are required by law to inform you of a breach of your Personal Information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

How long we retain your Personal Information depends on the context in which, and the purposes for which, we collected it. We generally retain Personal Information for as long as necessary for achieving the purposes for which it was collected or processed, unless a different retention period is required by applicable law. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process the data and whether we can achieve those purposes through other means; and applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove Personal Information from our systems and records or take appropriate steps to properly anonymize it.

Presently, we do not sell any personally identifiable information, nor do we share it for cross-context behavioral advertising. We reserve the right to change these practices in the future, and in such event we will offer you the opportunity to opt out at that time. You will not be discriminated against for the exercise of any of these rights.

Updates to the Policy

To the extent allowed by applicable law, Handled reserves the right to change or modify this Policy at any time and will notify you of material changes by posting the changed or modified Policy on our Services. Any changes will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Services after the effective date of the revised Policy will constitute your consent to those changes to the fullest extent allowed by applicable law. We encourage you to review this page periodically for the latest information on our privacy practices.

Contact Us

To contact us with questions about this Policy, your Personal Information, or other inquiries, please email us at lfd@handledspirits.com.