Privacy Policy

Tipsy TOGO Privacy Policy

Welcome to Tipsy TOGO. Tipsy TOGO, Inc. (“Tipsy TOGO,” “we,” “us” and/or “our”)
provides an online beverage, hookah, and food delivery service that brings individual
users and vendors together. This Privacy Policy describes how your personal
information is collected, used, and shared when you visit our website at (the “Site”), any sub-domains of the Site, Tipsy TOGO’s mobile
applications (each, an “App”), and various online tools and services (collectively, the

Our Commitment To You
At Tipsy TOGO, we value and respect your privacy. Privacy considerations are at the
core of the way we design and build services and products for you so that you can fully
trust Tipsy TOGO and take advantage of everything the Services offer. We do not
compromise when it comes to your privacy, we seek to be transparent with you in the
way we process and manage your personal information, and we work hard to protect
your information and keep it secure. This Privacy Policy sets forth how we go about
accomplishing our privacy initiatives, and provides you with the information you need to
be comfortable that your data is being handled with care.
We encourage you to read this Privacy Policy carefully. If you have any questions,
please don’t hesitate to contact Tipsy TOGO directly using the contact information
provided below.

What personal information do we collect from our users?
Automatically Collected Information
When you visit the Site or Services, we automatically collect certain information about
your device, including information about your web browser, mobile device, IP address,

unique device identifiers, software and hardware attributes (including the type of
operating system you use), approximate geographic location, time zone, and some of
the cookies that are installed on your device (collectively, “Device Information”).
Additionally, as you browse the Services, we collect information about how you use the
Services, such as the date and time you logged in, the individual web pages or products
that you view, what websites or search terms referred you to the Services, and
information about how you interact with the Services and other users (including, for
example, breweries you review or users you connect and interact with as a brewery)
(collectively, “Usage Information”).
Information You Provide
Additionally, when you visit the Services, we may either require or collect “Personal
Information.” Personal Information is information that could personally identify you, for
example, your name, address, phone number, e-mail address, birth date, and requested
payment information. Personal Information
does not include any data where the identity has been removed (anonymous data). For
purposes of this policy, your Device Information and Usage Information is included
within the discussion of “Personal Information” (unless we clearly state otherwise
In the following instances, we collect and require you to actively submit Personal
When you visit the Services, regardless of whether you are a registered user or not, you
need to provide your birth date in order to access the Services.
When you set up your account with Tipsy TOGO (whether you are an individual or an
individual acting on behalf of a company), you need to provide your name, email
address, birth date, and gender. Accounts may also be set up using a user’s Facebook,
Google, or Apple per Tipsy TOGO’s choosing.
When you set up and use your account with Tipsy TOGO, you also provide us with
specific profile data, such as your username and password, verify age, and your
interests and preferences.
When you contact us with a question or concern, you may be required to provide certain
personal information like your name, email, mailing address, and/or phone number.
If Tipsy TOGO decides to add recurring payments; when you sign up for and purchase a
paid subscription or recurring delivery, you will be required to provide your name, email

address, and phone number as well as your billing address and payment information
(based on the third party payment method you choose, i.e. PayPal, iTunes, Google
Play) (collectively, “Payment Information”).
When you sign up to receive marketing communications, such as our newsletter or
updates about the Services, you must provide us with your email address.
When you respond to a survey or enter a promotion provided through the Services, you
may be required to provide your name, email address, mailing address, and/or phone
When you enter information into the Tipsy TOGO app such as: searches, pictures,
descriptions, comments, videos, operational information, history, and personal

Information We Receive or Collect from Other Third Parties or Public Sources
We may receive or collect information about you from third parties and store it on our
servers with other information we may have already received or collected from you,
such as publicly available information you provided on third-party platforms. Tipsy
TOGO is not responsible for and will assume no liability, if a business partner or other
entity whom you have authorized collects, uses, or shares any information about you in
violation of its own privacy policy or any applicable laws, rules, or regulations.

Cookies and Similar Technologies
We use Cookies and similar technologies to enable our systems to recognize your
browser/device and to provide certain features. We also collect some Device
Information and Usage Information using such technologies.

  1. “Cookies” are data files that are placed on your device or computer and often include
    an anonymous unique identifier. A cookie may enable the website owner to track how a
    visitor navigates through its website and the areas in which they show interest. This is
    similar to a traffic report: it tracks trends and behaviors but does not identify individuals.
    Information gathered may include date and time of visits, pages viewed, time spent at
    the site, and the website visited just before and just after a visit to our Services. Cookies
    can be set to expire: (1) on a specified date;

(2) after a specific period of time; (3) when a transaction has been completed; or (4)
when a user turns off his/her Internet browser. A cookie that is erased from memory
when a visitor’s Internet browser closes is called a “session” cookie. Cookies that expire
based on a time set by the Web server are called “persistent” cookies.

Our Services may use both “session cookies” and “permanent cookies.” Most people do
not know that cookies are being placed on their computers when they visit our Service
or most websites because browsers are typically set to accept cookies. For more
information about cookies, and how to disable cookies, visit

  1. “Log files” track actions occurring on the Services, and collect data including your IP
    address, browser type, Internet service provider, referring/exit pages, and date/time
  2. “Web beacons,” “tags,” and “pixels” are electronic files used to record information
    about how you browse the Services.

We may also collect or receive various Usage Information and Device Information from
third-party analytics providers, such as Google, Facebook, Amazon Web Services,
Stripe, Paypal, App Store, Siteground, and Instagram as well as from other advertising
and payment networks.
You have a variety of tools available to control the data collected by cookies, web
beacons, and similar technologies. For example, you can use controls in your Internet
browser to limit how the websites you visit are able to use cookies and to withdraw your
consent by clearing or blocking certain non-strictly necessary cookies. Note that if you
disable cookies, there may be parts of our Services that may not function properly.

How do we use the information we collect?
We use your Device Information and Usage Information to monitor the usage of our
Service, assess its performance, ensure technological compatibility with your computer

or mobile device, and understand the relative importance of the information provided on
our Services. We may also use this data to conduct statistical analyses on visitors’
usage patterns and other aggregated data. We do this to improve and optimize our
Services for you. We also use your Device Information and Usage Information to help
us screen for potential risk and fraud (in particular, your IP address).
We use the Personal Information you provide us in order to perform basic business
functions. This may include communicating with you, processing any requests by you,
identifying and fixing any problems with the Services, and otherwise making the
Services available to you. Our use of this Personal Information is most commonly based
on our legitimate business purposes or other lawful bases set forth below. When we
make a decision to use your information for our legitimate interests, we make sure to
consider and balance any potential impact on you (both positive and negative) to ensure
that our rights or interests do not override your fundamental rights and interests.
We also use your Personal Information in order to perform the contractual relationship
with our subscribers (or prospective subscribers), and where we have your specific
consent, typically for marketing purposes only. See the “Communications” section below
for more information.
As referenced above, we may use your Personal Information for legitimate business
purposes or other lawful bases, including to:
Operate, evaluate and improve our business, our Services, and other products and
services we offer
Aggregate certain information that does not include your Personal Information and
disclose it for analysis, demographic profiling and/or targeted advertising
Provide you with technical service and support, including updates
Tailor the content we display in our communications with you and/or improve your user
Administer surveys and other market research
Provide you with information regarding Tipsy TOGO’s benefits and services
Store, archive, retrieve, and make copies of your user-generated content
Process payments

Comply with legal requirements, judicial process, and our company policies (including
verifying users’ identity in connection with access or correction requests)
Protect against, identity, investigate, and respond to fraud, illegal activity (such as
incidents of hacking or misuse of our Services), and claims and other liabilities,
including by enforcing the terms and conditions that govern the services we provide

Note that we may process your Personal Information for more than one lawful ground
depending on the specific purpose for which we are using your data. Please contact us
if you need details about the specific legal ground we are relying on to process your
personal data where more than one ground has been set out in the table below.
How do we share the information we collect?
We do not rent or sell your Personal Information without your permission. However, we
may share your Personal Information with others for the purposes described below:
We may share your Personal Information whenever you specifically consent to us doing
We may share or disclose your Personal Information where necessary to provide you
with the Services and/or associated services, including with trusted third-parties who
assist in operating the Services, providing any associated Tipsy TOGO services, and
otherwise conducting our business.
We may share your Personal Information with our third-party payment processors.
We may share your Personal Information, where necessary, with Tipsy TOGO’s parents,
subsidiaries, successors, assigns, licensees, affiliates, or business partners.
We may share your Personal Information to comply with applicable laws and
regulations, to respond to a subpoena, search warrant or other lawful request for
information we receive, or to otherwise protect our rights.
We may share your Personal Information when doing so is needed to help prevent
against fraud or the violation of any applicable law, statute, regulation, ordinance, or
We may disclose Personal Information you provide us in connection with the sale,
assignment, or other transfer of the business or a portion of the business of the Site,

including a corporate merger, consolidation, restructuring, sale of assets, or other
corporate change of our company.

Without limiting the foregoing, Tipsy TOGO currently shares your Personal Information
with the following third-parties:
Siteground – Server
Google – App, Map, and other services
GLDN – App, Map, and other services
Stripe – Payment processor
Apple – App, Map, and other services

Aggregated Data
We may aggregate and/or de-identify any Personal Information, Usage Information or
Device Information that you provide or we collect, such that the information no longer
identifies any specific individual. We may use, disclose and otherwise process such
information for our own legitimate business purposes – including historical and
statistical analysis, marketing, and business planning – without restriction. However, if
we combine or connect any aggregated data with your personal data so that it can
directly or indirectly identify you, we treat this combined data as Personal Information
which will be used in accordance with this privacy notice.

When you provide us consent to do so (either upon contacting us through our Services
or through our normal marketing communications), we will communicate with you
through general marketing communications via email and push notifications directly to
your mobile device. You must affirmatively opt-in to receive these communications
before you receive them.

Third-party Marketing
We will get your express opt-in consent before we share your Personal Information with
any company outside the Tipsy TOGO group of companies (or other third parties listed
herein) for marketing purposes.
Opting Out
Regardless of where you live, you may also opt-out of these marketing communications
at any time by following the instructions provided in any marketing communication you
receive. Please note that even if you opt-out of receiving marketing communications,
you may still receive-business related communications, such as transactional emails.

Do Not Track
Please note that we do not alter our Services’ data collection and use practices when
we see a Do Not Track signal from your browser.

Access to and Managing Your Information; Opt-Out
We believe it is important for you to be able to: (1) find out what Personal Information
you have provided to us through our Services; (2) update your information; or (3) “opt
out” of receiving future marketing communications. To inquire about your Personal
Information, update your Personal Information, or “opt out” of receiving future marketing
communications or any other collection or use practice based on your consent, please
send an email with your request and current contact information to info@MyTipsy
We generally respond to email requests within 24 hours of receiving a request, but it
may take up to 30 days depending on the volume of requests we receive.

Your Rights to the Personal Information You Provide
You have the right to access and control the Personal Information you provide us.
These rights include the right to:
Access your Personal Information;

Correct, update, or delete your Personal Information;
Withdraw or limit your consent (to Personal Information that was provided based on
Data portability of certain Personal Information;
Object to us processing your Personal Information for reasons such as direct marketing
purposes and for scientific or historical research or statistical purposes;
Not be subject to automated decision-making, which includes profiling, where such
decision-making could have a legal, or similarly significant, effect on you from being
made solely based on automated processes.

If you would like to exercise these rights (which you may do at any time) or inquire as to
any additional rights you may have under applicable law, please contact us through the
contact information provided below. We will respond to any request as promptly as

Personal Information Transfer and Storage
Please note that your Personal Information will be transferred outside of Europe,
including to the United States, where it is stored. When we transfer your information to
the U.S., we will protect it as described in this Privacy Policy. Through your use of the
Services, you consent to the processing and storage of your Personal Information in this
manner. We also are working to and have worked to incorporate appropriate safeguards
such as standard contractual clauses with any third party processors identified herein.
We further will make best efforts to protect information from EU residents in accordance
with applicable law.
When you provide information to us, you understand and agree that Tipsy TOGO will
retain your Personal Information as long as is necessary and relevant for our
operations, and in accordance with applicable laws.

How We Protect Your Information
We strive to maintain internal controls and procedures to ensure that the information
you share with us is handled in a safe, secure and responsible manner. We have

security measures to help protect against loss, unauthorized access and alteration of
the information in our control. We will only disclose such information to employees and
authorized service providers who require such information for the purposes described in
this Policy. Our databases are protected by physical, technical, and procedural
measures that restrict access to authorized persons in accordance with this Policy.
Although no data transmission over the Internet can be guaranteed 100% secure, and
we cannot ensure against any loss, misuse, unauthorized disclosure, alteration, or
destruction of data, we take reasonable precautions to prevent such unfortunate
occurrences. Nevertheless, we cannot and do not guarantee that information you post
on or transmit to the Services will not be viewed by unauthorized persons.

Third-Party Service Providers and Third-Party Links
Any third parties to whom we may disclose Personal Information (identified herein) have
their own privacy policies which describe how they use and disclose your Personal
Information. Those policies will govern use, handling and disclosure of your personal
information once we have shared it with those third parties as described in this Privacy
Policy. Tipsy TOGO has no responsibility or liability for the activities of these third
parties. If you want to learn more about their privacy practices, we encourage you to
visit the websites of those third parties.
When you click on links on our Services that take you to third-party websites, you will be
subject to the third parties’ privacy policies. While we support the protection of privacy
on the Internet, we cannot be responsible for the actions of any third-party websites. We
encourage you to read the posted privacy policies of any and every website you visit,
whether you are linking from our Services or browsing on your own.

California Privacy Rights
Under California’s “Shine the Light Law,” California residents have the right to receive
information that identifies any third-party companies or individuals that Tipsy TOGO has
shared your Personal Information with in the previous calendar year, as well as a
description of the categories of Personal Information disclosed to that third party. You
may obtain this information once a year and free of charge by contacting Tipsy TOGO at
the address below.

Personal Information About Children

Our Services is targeted for use by users over the age of 21. Accordingly, we do not
knowingly collect age identifying information, nor do we knowingly collect any personal
information from children under the age of 13 years. However, we hereby advise all
visitors to our site under the age of 13 not to disclose or provide any personally
identifiable information on our Services. If you are concerned that Personal Information
may have been inadvertently provided to or collected by Tipsy TOGO, please contact us
immediately so appropriate steps may be taken to remove such information from Tipsy
TOGO’s database.

Changes to this Policy
We may update this Privacy Policy from time to time in order to reflect, for example,
changes to our practices or for other operational, legal or regulatory reasons. We
suggest that you review the current Privacy Policy at the start of each visit to our
Services. Unless we clearly express otherwise, we will use Personal Information in
accordance with the Privacy Policy then in effect. YOU ARE HEREBY ADVISED THAT

Suspected Violations
If at any time you believe we have not adhered to the policies and principles set forth in
this Privacy Policy, please notify us using the contact information provided below. We
will make all commercially reasonable efforts to promptly respond to your concerns.

Contact Us
If you have any questions or comments concerning our Privacy Policy, please submit
your inquiry along with your current contact information to:;
Privacy Policy © 2021 Tipsy TOGO, LLC.