ATIAN Privacy Policy

Effective: December 12, 2022

Gin Runners, LLC (“Gin Runners”) respects your right to the privacy of personal information you provide on our platform, including through our website or otherwise (“Platform”). This policy describes how Gin Runners collects, uses, shares and secures the personal information you provide through your use of our Platform. This policy applies to any user of or visitor to our Platform, but this policy does not apply to information collected by a third party (including our affiliates and service providers) that may link to or be accessible from or on the Platform. We reserve the right to change this policy from time to time, so please check back periodically. Changes to this policy are effective when they are posted on this page. You acknowledge that your continued use of our Platform and services after we publish our changes to this policy means that the collection, use and sharing of your personal information is subject to the updated policy.

If you have questions about our privacy policy or feel that our company is not abiding by this privacy policy, please contact Gin Runners by email at

If you are a California resident, please review the “Additional Information for California Residents” section below for information about your rights under California privacy laws. If you are a Nevada resident, please review the “Additional Information for Nevada Residents” section below for information about your rights under Nevada privacy laws.

1. Sources of Personal Information:

Personal information collected by Gin Runners may (i) include your name, street and email addresses, billing information, click-through activity and any other information you may provide or that may be automatically collected, and (ii) vary depending upon the circumstances and services you use. Your personal information is typically collected as follows:

You Provide It to Us
We may collect personal information directly from individuals, such as when an individual purchases products through our Platform, fills out forms on our Platform, signs up to receive our email offers, or provides a review about products or services. If you contact us by email, mail, phone or otherwise regarding our Platform and services, we collect and maintain a record of your contact details, communications and our response. Further, if you choose to engage in reviews, forums, blogs, or similar features offered by us as part of the products, we may maintain records about the content you post, such as comments, reviews or questions, as well as date and time and other metadata associated with your user content. User content may also be viewable by other visitors and users of our services, and we are not responsible for the personally identifiable information you choose to submit in these reviews or forums.

Automated Information Collection.
When you visit the Platform, our servers automatically record information that your browser sends whenever you visit a website. The information sent automatically by your browser may include information such as the manufacturer and model of your mobile device; your domain name (e.g., whether you are logged on from or, etc.); your Internet Service Provider (ISP); your device’s Internet Protocol (“IP”) address (or other device identifier), browser type, and operating system; referring/exit pages; clickstream data; pages of the Platform that you visit, the time spent on those pages, information you search for on the Platform, access times and dates; and other statistics. We may also use web beacons in HTML emails to understand if individuals read the emails we send to them. (For more information on information collected on the Platform, see the “Cookies and Tracking Information” section below.) We also may collect location information, including through the mobile application and/or derived based upon the IP address of the device you use to access the Platform. In addition, we may derive certain insights about you based on this and other personal information we have collected about you.

In order to provide the best customer experience possible, we also use automated information collection technologies for reporting and analysis purposes. We examine metrics such as how you are shopping on our Platform, the performance of our marketing efforts, and your response to those marketing efforts.

Third-party Collection.
We and our service providers use anonymous identifiers such as cookies, web beacons and other technologies to collect and store certain types of information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, hardware/software information, cookie and session ID) whenever you interact with our Platform.

We allow third-party service providers (e.g., Google for Google Analytics) to place tags on our digital properties for analytics, advertising and other services once approved through our tagging process, as well as to use cookies, web beacons and other tracking mechanisms to collect information regarding visits to our Platform. The tags may collect information from your interactions on our Platform. The information generated (including through the cookies) about your use of the Platform (including your IP address) will be transmitted to and stored by these vendors on servers. These vendors will use this information for the purpose of evaluating your use of the Platform (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) compiling reports on Platform activity, and providing other services relating to Platform activity and internet usage for Gin Runners. These vendors may also transfer this information to third parties where required to do so by law, or where such third parties process the information for the vendors for purposes of providing those services. The information these vendors collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. This information may be used to provide you with interest-based (behavioral) advertising or other targeted content. Marketing and advertising cookies may also be used to enable you to share pages and content that you find interesting on our Platform through third party social networking (seeSocial Media Widgets” section below) and other websites. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, if you do block the use of cookies, you will not be able to use the full functionality of the Platform. By using the Platform, you consent to the processing of data about you by service providers (e.g., Google) in the manner and for the purposes set out above. Our privacy policy does not cover these third-party companies. Please contact these third-party companies (e.g., Google) directly for more information about their privacy policy and your choices regarding the tags and the information collected by the tags. For more information on refusing browser cookies or on opting out of receiving targeted advertising from service providers, see “Rights and Choices” and “Cookies and Tracking Information” sections below.

We work with external payment processors to process your payment for products or services purchased from us, and those payment processors may collect additional information from you in order to complete your purchase. Please review their privacy policies for more details on how they collect and use your personal information.

In addition to the foregoing, our affiliates may provide information to us. Some areas in our Platform may be offered to you in association with affiliated or non-affiliated third parties. Such co-branded areas may require you to disclose personal information to the third party and will identify the third party; however, the third party’s privacy policy will apply to how they treat your personal information. We recommend you review the privacy policy of these third parties.

Generally, this policy does not apply to websites, apps, products, or services that we do not own or control, including any links to websites (including but not limited to the Passion Spirits and Take-A-Lot websites), apps, products, and/or services on our Platform. We have no control over these websites and they are subject to their own terms of use and privacy policies, which we encourage you to review for more information about their collection and use of your data. We are not responsible for the information practices of such third-party websites.

Social Media Widgets.
We may also use third party social media widgets such as buttons or similar mechanisms from Facebook, Twitter, Instagram, YouTube, and others. Such third party features may collect information about you, such as your IP address and the page(s) you visit on the Platform. Your interactions with those features are governed by the privacy policies of the third party social media networks that provide them.

Mobile Location Information
If you use a mobile device, your device may share location information (when you enable location services) with our websites, mobile application, services or our service providers. To manage how you share your device’s location settings, go to the “Rights and Choices” section of this privacy policy.

2. Use of Personal Information:

We may use the personal information we (and our service providers) collect for the following purposes:

  • Providing our products and services and related support, which includes authenticating users, providing and communicating with you about our Platform, responding to your requests, fulfilling your orders and processing your payments, providing technical support and other customer service and support. Further, we may use the information we collect (including location information) to determine which products may or may not be available to sell and ship to a particular state or other jurisdiction.
  • Analyzing and improving our services, which includes compiling statistics and reports to better understand how users access and use our Platform and products and services to improve our services and user experiences.
  • Communicating with you, which includes providing you with the information or services that you have requested, responding to your inquiries, and administering surveys and questionnaires, such as for market research or user satisfaction purposes.
  • Advertising, marketing and promotional purposes, which includes contacting you about our products or services, or the products and services of our affiliates or partners, or sending you newsletters, offers or other information we think may interest you, administering promotions and contests, reaching you with more relevant ads, and measuring and improving our advertising and marketing campaigns. Gin Runners may use third-party advertising companies to display ads tailored to your individual interests based on how you browse and shop online, as well as to provide advertising-related services such as ad delivery, reporting, attribution, analytics, and market research. Gin Runners also allows or may in the future allow third-party companies to collect certain information when you visit our Platform in connection with such advertising-related services. This information is or may be used to provide advertisements about goods and services likely to be of greater interest to you.
  • Processing transactions, including through our service providers.
  • In support of our general business operations, which includes audits and assessments regarding our business operations, security controls, financial controls, and compliance with legal obligation.
  • In connection with a merger, acquisition, reorganization or similar transaction and otherwise relating to the administration of our general business, accounting, record keeping and legal functions.
  • Securing and protecting our assets and rights, as well as the rights and safety of any person or third party, which includes against fraud, illegal activities, and unauthorized activities, access and other misconduct and where we believe necessary to investigate, prevent or take action regarding suspected violations of our Terms and Conditions and other agreements or policies.
  • We may also use your personal information to perform other business activities as needed, or as described elsewhere in this policy or where we have your consent.

3. Disclosure of Personal Information:

We disclose personal information in order to provide and improve our products and services, reach users with more relevant information and offers, and as otherwise set out in this policy. We may share or disclose the information (including personal information) that we collect as follows:

  • With our corporate affiliates and subsidiaries.
  • With third parties that perform services to support our core business functions and internal operations, which may include:
    • database administrators
    • cloud computing services
    • payment processors
    • advertising and marketing services
    • age verification services
    • customer satisfaction and support services
    • order fulfillment and warehouse services
    • application services providers
    • data enhancement services
    • analytics service providers
    • shipping service providers
  • With third parties that we have partnered with to jointly create and offer a product, service or joint promotion.
  • To support our audit, compliance, and corporate governance functions.
  • In connection with a change of ownership or control of all or part of our business (such as a merger, acquisition, reorganization, or bankruptcy).
  • If we have a good-faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to detect or protect against fraud or security issues.
  • If required or permitted by applicable law or regulation, including laws and regulations of the United States and other countries, or in the good faith belief that such action is necessary to: (a) comply with a legal obligation or in response to a request from law enforcement or other public authorities wherever Gin Runners may do business; (b) protect and defend the rights or property of Gin Runners; (c) act in urgent circumstances to protect the personal safety of users, customers, and contractors/employees of Gin Runners or others; or (d) enforce our Terms and Conditions or otherwise protect against any legal liability.
  • With your consent or at your direction.

4. Cookies and Tracking Information:

As noted in the “Sources of Personal Information” section above, each time a visitor comes to the Platform certain types of information are collected.

After signing up to receive Gin Runners communication by email, users will start receiving these communications on a regular basis. We collect subscribers’ email addresses in order to distribute those communications. Users can choose to unsubscribe from Gin Runners offers at any time by following the “Unsubscribe” instructions found in each email.

The Gin website has the ability to assign “cookies” to your web browser. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser. There are different kinds of cookies with different functions. Cookies serve various purposes, including (a) enabling your use of our Platform (e.g., logging into your account), and (b) record-keeping purposes and allowing a website to “remember” who a visitor is and therefore not require her/him to type in personal information over and over again. We and our service providers use cookies or similar technologies to analyze trends, administer the site, track users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. (See “Sources of Personal Information” for information on our Platform’s use of cookies.) Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. As noted above, certain features on our Platform may not be available or function properly if you block or disable cookies.

Do Not Track.
Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, we do not respond to browser “do not track” signals.

Other Web Site Analytics Services.
As noted in the “Sources of Personal Information” section above, analytics services, such as Google Analytics, provide services that (i) analyze information regarding visits to our websites and mobile application(s) and (ii) facilitate personalized advertisements. They use cookies, web beacons, recorded interactions and other tracking mechanisms to collect this information.

  • To learn more about Google’s privacy practices, click here. To access and use the Google Analytics Opt-out Browser Add-on, click here.
  • To learn more about Microsoft’s privacy practices, click here.

For guidance on other web site analytics service providers utilized by Gin Runners, and how to access their privacy practices, please email Gin Runners at

Web Beacons
Web beacons are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use web beacons (also referred to as pixel tags, web bugs or clear GIFs), in connection with our services to, among other things, help us manage ads and content, and compile statistics about usage of our services. We may also use web beacons in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

5. Security:

We have implemented safeguards to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

6. Rights and Choices:

In this section we describe the choices individuals have regarding our collection, use and handling of their personal information. If you are a California resident, see the “Additional Information for California Residents” section below for information about your rights under California privacy laws. If you are a Nevada resident, see the “Additional Information for Nevada Residents” section below for information about your rights under Nevada privacy laws.

Access, Update and Deletion. You may cancel your account with Gin Runners and/or request the removal of your personal information from our member records by sending e-mail to You may also access and update certain of your personal information by accessing and adjusting your account settings or e-mailing us at Your access to or correction of your personal information is subject to applicable legal restrictions and the availability of such information. Further, we may take reasonable steps to verify your identity before granting such access or making corrections. Please note that we may maintain copies of information that you have updated, modified or deleted, in our business records and in the normal course of our business operations, as permitted or required by applicable law. Further, deleting information from your account with Gin Runners will not remove such information from any back-end system or from records retained by third-party service providers. Finally, we reserve the right to maintain information on registered users who have violated our Platform’s Terms and Conditions or who have had their access to our services blocked in order to detect repeat offenders.

Marketing Communications. We may use some of the information we collect for marketing purposes, including to send you promotional communications about new features, products, events, or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions, such as clicking “Unsubscribe” (or similar opt-out language) in email communications. In addition to any of the foregoing methods of communication, you can also contact us via email at to opt out. Despite your indicated email preferences, we may send you service-related communications, such as notices of updates to our Terms and Conditions or privacy policy.

Geo-Location. With respect to Gin Runners’s website, depending on your browser type and configuration, your browser may inform you that the website would like to collect your specific location and request your permission to do so. If you do not allow it, or your browser does not permit it, only your general location information is collected and stored. Any location data obtained by Gin Runners’s third-party service providers would be subject to their privacy policies.

Targeted Advertising Cookies. You may opt out of receiving advertising cookies from companies who are members of the Network Advertising Initiative (NAI) or who subscribe to the Digital Advertising Alliance’s (DAA’s) Self-Regulatory Principles for Online Behavioral Advertising. To opt out visit DAA’s Choices page at here and perform a global opt-out. Many web browsers allow users to selectively block cookies, which can effectively reduce tracking.

Minor’s Privacy. Gin Runners’s Platform is intended for adults of legal drinking age (currently 21 years of age and older in the U.S. and 18 years and older in South Africa). You must be of legal drinking age in your country of residence to use our Platform. We do not knowingly collect personal information from individuals under the legal drinking age. If you have reason to believe that a person under the legal drinking age has provided personal information to us, please contact us with sufficient detail to enable us to delete that information from our databases.

See “Sources of Personal Information” and “Cookies and Tracking Information” sections above for guidance on blocking cookies.

7. Additional Information for California Residents:

This section applies only to California residents. For purposes of this section, “personal information” has the meaning given in the California Consumer Privacy Act, as amended (“CCPA”), but does not include information exempted from the scope of the CCPA. The CCPA provides California consumers with several individual rights with respect to Personal Information. Note that these rights apply to individual consumers, not to companies. This section describes those rights in detail and provides information on how to exercise those rights.

Exercising Your Rights.
To exercise any of the rights described in this section, please contact us via email at Please include (i) a complete description of your request, including the specific right(s) you wish to exercise and (ii) sufficient information about you so we can confirm that your request is a verifiable customer request, including at a minimum your name and email address. Once we have received your verifiable consumer request, we will respond consistent with applicable law. Please note that you may also designate an authorized agent to make a request on your behalf in the United States. In order for us to process a request from your authorized agent, we must (i) confirm that the agent is a natural person or business entity registered with the Secretary of State that you have authorized to act on your behalf, (ii) receive from you a copy of the written authorization that provides the authorized agent to act on your behalf, and (iii) verify your identity by asking you to provide us sufficient information in order to do so.

Access and Data Portability Rights.
You have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:

  • Categories of and specific pieces of personal information we have collected about you.
  • Categories of sources from which we collect personal information.
  • Purposes for collecting, using, or selling personal information.
  • Categories of third parties with which we share personal information.
  • Categories of personal information disclosed about you for a business purpose.
  • If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.

Deletion Rights.
You have the right to request that we delete personal information about you that we have collected, subject to certain exceptions set forth in CCPA. You may also access, edit, or delete certain parts of your personal information through your account settings. Please review the sections above titled “Rights and Choices” and “Cookies and Tracking Information” for more details. Note that, in accordance with CCPA, if you request deletion of your personal information, Gin Runners will direct third party service providers to delete any such personal information held by them.

You have the right not to receive discriminatory treatment for the exercise of your rights under the CCPA, subject to certain limitations. Please note that we reserve the right to offer you certain financial incentives as permitted by the CCPA that may result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time by contacting us.

Statutory Categories of Personal Information Collected.
The chart below describes the categories of personal information we collect by reference to the statutory categories specified by the CCPA:


Examples of What We Collect



Email, full name, date of birth, full address, phone number, other similar identifiers

You and third party sources (e.g. our payment processors)

Personal Information Categories Under California Customer Records Statute

Financial information

You and third party sources (e.g., our payment processors)

Customer Record Information

Email, full name, full address, phone number, credit card number or other form of online payment for goods and services rendered

You and third party sources (e.g. our payment processors and our partners)

Characteristics of Protected Classifications


You and third party sources

Commercial Information

Records of products/services purchased by you on the Platform, other purchasing or consuming histories and tendencies

You and third party sources

Internet or Other Network Activity

Browsing history, search history, information on your interaction with a website, application, or advertisement

You, third party sources (e.g. our advertising service providers), and via automatic collection (see the section above titled ”Cookies and Tracking Information” for information on tracking technologies we use for automatic data collection)

Geolocation Data

IP address of device used to access Platform, billing information, product delivery information, or general location information

You and third party sources

Audio, Electronic, Visual or Similar Information

Recordings of guest interactions with Platform

You and third party sources

Professional or employment-related information

We may use third party demographic information services that provide information about your employment that you have entered on social media sites such as LinkedIn, Facebook or Twitter

You and third party sources

In addition to the foregoing, we will collect inferences drawn from any of these personal information categories to create a profile about a consumer reflecting their preferences and psychological trends (among other characteristics).

Use of Personal Information.
Under the CCPA, a “sale” means providing to a third party personal information for valuable consideration. We have shared identifiers with entities that compile personal information about prospective or current customers who reside in California for purposes of updating or verifying personal information, prospecting new potential customers, and improving the types of services and products we offer to you. In addition, the internet or other network activity information (as defined above) collected through cookies on our Platform, which are used for a variety of purposes, including personalized advertising and facilitating your activity on social media, may be shared with third parties providing services to us. However, at this time, we don’t believe any of our data practices in the last 12 months constitute a traditional “sale” under the CCPA.

In the last 12 months, we have used or disclosed certain personal information we collected to our corporate affiliates and subsidiaries and service providers for the following purposes:

  • Consumer transactions, such as processing a purchase, or fulfilling an order.
  • Customer service and relationship management, such as addressing a customer complaint.
  • Customer experience, such as improving website offerings and interface, or providing specialized promotions.
  • Marketing and advertising, such as providing promotions that are interesting to you based on your purchasing and viewing history and/or to assess website traffic and performance.
  • Analytics, such as information about Platform performance relative to your computer or device.
  • Security and compliance, such as protecting us and you from fraud on our Platform, and reporting information that may be required by applicable laws that regulate our business in California and elsewhere.

In addition to the above, in the last 12 months, we have used or disclosed certain personal information we collected for the following business purposes or commercial purposes (among others): to audit interactions with consumers; to provide, support, and develop our website, products, and services; to create, maintain, customize, and secure your account with us; to process your requests, purchases, transactions, and payments and prevent transactional fraud; to directly respond to your requests or inquiries, including to investigate and address your concerns and monitor and improve our responses, or to otherwise meet the reason for which you provided the information; to personalize your Platform experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Platform, third-party sites, and via email or text message (with your consent, where required by law); to help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business; and to fulfill other commercial purposes.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We may disclose your personal information to the following categories of other parties for a business purpose or commercial purpose, as those terms are defined in the CCPA:

  • Our affiliates, employees and authorized agents
  • Service providers for our businesses
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you
  • Government regulators or law enforcement, where required
  • Our legal advisors and other parties when required by law or pursuant to legal process
  • To any entity involved in the purchase or sale of our businesses

Shine the Light Law.
If you are a California resident and a customer, you have the right to request information from us once per calendar year regarding the customer information we share with third parties for the third parties’ direct marketing purposes. To request this information, please send an email to with “Request for California Shine the Light Privacy Information” in the subject line and in the body of your message. We will provide the requested information to you via an email response in a standardized format and the information will not be specific to you individually.

8. Additional Information for Nevada Residents:

Nevada law gives Nevada consumers the right to request that a company not sell their personal information for monetary consideration to certain other parties. This right applies even if their personal information is not currently being sold. If you are a Nevada consumer and wish to exercise this right, please contact us via email at