RNDC

RNDC Privacy Notice

Last Updated: November 2024

Welcome! We at Republic National Distributing Company (referred to in this Privacy Notice as the “Company,” “we”, “us,” “RNDC,” or “our”) have a proud history as one of the nation’s leading wholesale alcoholic beverage distributors. We serve as a brand-building and product expert liaison between suppliers and those who sell or serve alcoholic beverages. This Privacy Notice applies to our brands, websites, and apps where this Privacy Notice is posted (the “Sites”), and to your interactions with us by phone.

We greatly respect your privacy and value the relationship we have with you. That is why we have this Privacy Notice: it describes the types of personal information we may collect on our Sites and by phone, how we may use that information, with whom we may disclose it, the measures we take to protect the security of the information, and your rights concerning our collection, use, and disclosure of your information. In addition, we describe the choices you can make about how we use the information you provide to us. We also provide you direction on how you can reach us to update certain information you’ve given us, ask us not to send you future communications, or answer any questions you may have about our privacy practices.

Please note this Privacy Notice applies only to the Sites and to your interactions with us by phone, and does not apply to any other websites, services, products, or applications operated or provided by us or a third party.

This Privacy Notice is organized as follows:

How We May Change Or Update The Privacy Notice
Persons Under Legal Drinking Age Are Not Allowed To Use Our Sites
The Types of Information We Collect
How We Collect Information
How We May Use Your Information
When Do We Disclose Your Information
Security of Your Information
How We Use Cookies, Web Beacons, and other Automated Means of Collecting Information
Links to Other Sites
Your Choices
Data Transfers
Data Retention
Promotions
Information Posted by Visitors
How to Contact Us
Additional Information for California Consumers
Additional Notice of U.S. State-Specific Privacy Information and Rights

1. How We May Change Or Update The Privacy Notice

At times, we may need to update this Privacy Notice. The top of the Privacy Notice shows the date that modifications were last made, which should alert you to any changes since your last visit to the Sites. Any material changes to this Privacy Notice will be posted on the Sites and we encourage you to check back from time to time to ensure continuing familiarity with the most current version of this Privacy Notice. Your continued use of any of the Sites is your agreement to the revised Privacy Notice.

2. Persons Under Legal Drinking Age Are Not Allowed To Use Our Sites

These Sites are for individuals who are legally old enough to drink alcoholic beverages. If you are not legally old enough to drink alcoholic beverages, then you cannot use these Sites. Of course, this age may change depending on where you live and where you are accessing our Sites. This means you are responsible for making sure your use of our Sites complies with any applicable laws. We do not knowingly solicit, collect, sell, or share information from persons under such legal drinking age, and we do not knowingly market our products or services to persons under such legal drinking age. If you want more information about the risks of underage drinking, please visit https://www.responsibility.org/.

3. The Types of Information We Collect

We may collect the following categories of information from and about you:

Identifiers: such as your name, postal addresses, unique personal identifier, Internet Protocol (IP) address, account name, password, email addresses, social networking account information, telephone numbers, or other addresses at which you are able to receive communications;
Location information: such as information related to your state/province, city, or neighborhood, and, if you agree, more specific geolocation data that is provided through the devices you use to access the Sites;
Internet and other electronic network activity information: such as information about your browsing behavior and interactions with websites and advertisements, including data from cookies, pixel tags, and web beacons;
Inferences regarding preferences and other characteristics: such as our assessment of the types of products or services you may have an interest in;
Financial information: such as information collected from you as needed to process payments for products or services that you buy such as your payment card details or account number, expiration date, card verification number, and invoicing or billing address;
Professional or employment-related information: such as information you include when applying for jobs posted to our Sites;
Commercial information: such as information that enables us to determine interests, product preferences, including products or services purchased, obtained, or considered, and information collected through your interactions with social networks;
Audio information: such as the contents of calls when we notify you of the recording and obtain consent when required by law; and

Sensitive Personal Information: such as account login information allowing access to an account and your precise geolocation in each case as further described above in the relevant categories.

4. How We Collect Information

We may collect personal information about you from a variety of sources, including, but not limited to:

· From you: We collect information that you submit to us. For example, when you create a profile on one of our Sites or register to receive information, products, or services available through one of the Sites, you may choose to give us certain location, demographic, or commercial information. You may also choose to apply for jobs posted on one of our Sites. We will collect any information you voluntarily provide, and we may also request optional information to support your use of our Sites. If you send an e-mail to us at any of the addresses provided on our Sites, we will collect your e-mail address and the full content of your e-mail, including attached files and other information you choose to provide to us. We also may collect information about you and our interactions with you over the phone. We will not disclose data you provide to us in order to opt in to receive text messages with third parties for their marketing purposes.

· From your device: When you visit one of our Sites, we may collect information about the devices you use to access the Site, including hardware model, operating system and version, Internet Protocol (“IP”) address, and other unique device identifiers, mobile network information, and information about the device’s interaction with our Sites. We may also collect precise information about the location of your device as described above. We also collect information about how you use our Sites, including your access times, browser types, and language. This type of data enables us to understand how often individuals use parts of the Sites so we can analyze and improve it. To collect this information, we may use cookies, web beacons, and other similar technologies, including Google Analytics. To learn more about how we automatically receive and record information when you interact with our Sites, please review the section below titled “How We Use Cookies, Web Beacons, and Other Automated Means of Collecting Information.” Click here to learn more about how Google collects and uses data when you use our Sites.

· Social media networks and other third parties: We may obtain information about you or your use of our Sites from third party sources, such as our vendors, like web hosting providers or analytics providers. You may give us permission to access your information from services offered by third parties, including social media networks, applications, tools, widgets, and plug-ins (including social sign on and similar third-party login services). The information we obtain from third party services depends on your account/privacy settings with those third parties and the third parties’ privacy policies, so be sure to check those policies and to adjust your settings to meet your preferences. Please keep in mind that any information provided to us by a third party may also be subject to that third party’s privacy policy.

5. How We May Use Your Information

We use substantially all categories of the information we collect as described in this Privacy Notice for the following purposes:

Operate, maintain, and improve the Sites and other programs, features, and functionality related to the Sites;
Provide you with interest-based ads, communications, and offers for products from us and the owners and suppliers of the beer, wine, and spirits brands featured on our Sites (our business partners);
Evaluate your eligibility for certain types of offers, products, or services that may be of interest to you, and analyze advertising effectiveness;
Answer your questions and respond to your requests;
Perform analytics and conduct customer research;
Communicate and provide additional information that may be of interest to you about us and our business partners, sometimes by combining your information with information we obtain from other sources;
Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, marketing messages, and requested information, including on behalf of our business partners;
Manage our everyday business needs, such as administration of the Sites, forum management, fulfillment, analytics, fraud prevention, and enforcement of our corporate reporting obligations, or to comply with the law;
Verify your requests made pursuant to this Privacy Notice;
Enhance other information we have about you to help us better understand you and determine your interests;
Train employees and improve customer support;
Increase the quality and efficiency of interactions with and among RNDC business units, customers, and suppliers;
Allow you to apply for a job; and
Facilitate and fulfill orders.

We also may use information collected as described in this Privacy Notice with your consent or as otherwise required or permitted by law.

The information we receive may be used in our marketing, promotion, and advertising of the Brand and, when directed by you and/or with your consent, by owners and operators of beer/wine/spirits brands featured on our Sites. As a result of providing us with your contact information, we may contact you by sending you mailings or other communications (electronic or otherwise) regarding the Brand and products, services, promotions, or upcoming events that we believe may be of interest to you. We may also ask you (or have a service provider ask on your behalf) to participate in surveys seeking information or opinions related to our category of products and services.

6. When Do We Disclose Your Information

We may disclose your information to the following categories of third parties for the purposes described below:

Law enforcement agencies, courts, regulators or other government entities, as allowed or required by law, such as to comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions, or in response to a subpoena, or similar legal process;
Our vendors and service providers who perform a variety of services and functions for us, such as data storage, website hosting, transmitting emails, and managing digital content. We may share your information with such vendors subject to confidentiality obligations consistent with this Privacy Notice and on the condition that the service providers use your information only on our behalf to perform the services requested and pursuant to our instructions;
Entities with which we may engage in a business transition such as a merger, acquisition by another company, bankruptcy, reorganization, or sale of all or a portion of our assets;
Third parties in order to combat fraud or criminal activity, to enforce any applicable Terms of Use or customer agreements, to respond to claims that any content violates the rights of third parties, and to protect our rights, users, and business partners, or as part of legal proceedings affecting us;
Our affiliates and subsidiaries, who may use the information for the purposes described in this Privacy Notice; and
Any other third parties consistent with this Privacy Notice, with your consent, or as otherwise allowed or required by applicable law.

We may work with advertising networks that deliver targeted advertisements and generate statistics and metrics related to the delivery of such advertisements using information collected through cookies, pixels, web server logs, web beacons, and other digital technologies. This information is used to provide customization, auditing, research and reporting for us, our Affiliates and other advertisers. This data collection takes place both on the Sites and on third-party websites that participate in the advertising networks. Click on the links in the following paragraph to learn more about ad serving companies and opt-out from each of those listed.

Many companies that collect information for behavioral advertising are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”). NAI and DAA offer the ability for you to opt-out of the behavioral advertising programs of their members by going to https://thenai.org/opt-out/ or https://www.aboutads.info/choices. Please note that if you use a different computer, change your web browser, or delete your cookies, you will need to renew all of your opt-out choices. Please note that this does not opt you out of being served advertising but only excludes you from interest-based advertising. If you use the Sites or Affiliate websites, you will continue to receive generic advertisements.

We may disclose your information to third parties for any purpose if the information has been aggregated or de-identified or otherwise does not identify you personally.

7. Security of Your Information

We use physical, electronic, and administrative safeguards designed to protect your information from unauthorized access. However, regardless of the effectiveness of our security measures, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet.

8. How We Use Cookies, Web Beacons, and other Automated Means of Collecting Information

When you visit the Sites, certain information regarding use of the Sites or the services is collected and/or aggregated by or on behalf of RNDC through the use of automated means, like cookies, web beacons, pixels, and other digital tools. “Cookies” are small files sent from a web server that are stored on a computer’s hard drive for the purpose of identifying the browser during interaction on websites or storing information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. The information collected automatically may include information about your visit to, and use of, the Sites, such as your IP address, type of browser and operating system used, date and time you access the Sites, pages you visit, video viewing history for videos you watch on the Sites, clicks, scrolling, and text entered in the course of using the Sites, search engine used to access the Sites, and if you linked to the Sites from another website, the address of that website.

We may also allow certain third-party analytics, advertising, and social media providers to include cookies, web beacons, pixels, and other digital tools within the pages of the Sites to collect information regarding how visitors use the Sites and the effectiveness of the Sites, and to help us improve and optimize the Sites and products and services we offer. Most web browsers enable users to exercise certain control over the use of cookies. If you choose to decline cookies, certain features of the Sites may not function properly or at all as a result. We and our third-party service providers may monitor visits to our Sites and sessions of users; this monitoring may log the details of your visits to our Sites and information generated in the course of using our Sites, such as clicks, page visits, text entered, how long you spent on a page, and other details of your visits to or actions on our Sites. We use these technologies to collect and retain usage data for the purposes described in this Privacy Notice, including for marketing and security purposes and to improve your experience with our Sites.

9. Links to Other Sites

We may provide links to other websites for your convenience and information. These websites operate independently from our Sites and are not under our control. These websites may have their own privacy notices in place, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of these websites, any products or services that may be offered through these websites, or any other use of these websites.

10. Your Choices

You are able to make certain choices about how we communicate with you and the information we collect from you and share with third parties. You may choose not to receive marketing email communications from us by clicking on the unsubscribe link in our marketing emails or contacting us as specified in the “How to Contact Us” section below. You may still receive service-oriented, administrative communications from us as you cannot opt-out of receiving such administrative communications.

We will endeavor to implement requested changes within a reasonable time or as provided by law. We reserve the right to retain any personal information reasonably necessary to document our business activities and for archival and record retention purposes.

11. Data Transfers

Please note that we may transfer the personal information we collect about you to countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Notice and in accordance with applicable law.

12. Data Retention

We keep your information for the length of time needed to carry out the purposes outlined in this Privacy Notice and to adhere to our policies on keeping records (unless a longer period is needed by law). Our records policies reflect applicable laws. We will retain and use your information to the extent necessary to manage your relationship with us, personalize and improve your overall customer experience, comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, for archival purposes, and as we reasonably deem necessary for the other purposes described in this Privacy Notice.

13. Promotions

We may have promotions or sweepstakes on our Sites. When you enter a promotion or sweepstakes, we may ask for personal information about you. We will use this information for the purposes of administering the promotion or sweepstakes. We may also use and store this information for the purposes set forth under “How We May Use Your Information” above, to the extent permitted by law, unless you instruct us otherwise by contacting us. Any additional uses for this information will be set forth in the official rules of the promotion.

14. Information Posted by Visitors

RNDC may make available through the Sites services such as message boards to which you are able to post information, photos, images and other materials. Please note that any information, photos, images or materials you disclose through such services or otherwise on the Sites, becomes public information, and may be available to visitors of the Sites all over the world and to the general public. In addition, when you choose to make a posting on such services, certain personal information will be available for other users to view. We urge you to exercise discretion and caution when deciding to disclose personal information, or any other information, on the Sites. WE ARE NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH THE SITES.

Also, please recognize that the individual forums and chat rooms may have additional rules and conditions. Each participant’s opinion on a forum or chat room is his or her own and should not be considered as reflecting our opinion.

15. How to Contact Us

If you have any questions or comments about this Privacy Notice, or if you would like us to update certain information you have provided to us or your communication preferences, contact us by:

Mail:

Republic National Distribution Company

One National Drive SW,

Atlanta, GA 30336

Email:

servicedesk@rndc-usa.com

16. Additional Information for California Consumers

This section of our Privacy Notice applies to California residents only. For ease of reference, we refer to this section as our “California Privacy Notice.” The following provisions apply to our processing of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. For California consumers, the provisions of this California Privacy Notice prevail over any conflicting provisions in other sections of this Privacy Notice.

Personal Information Collected on California Consumers and Sources of Collection for the Last Twelve Months

We collect information from users of our Sites when they visit and use our Sites, as described in detail above in “The Types of Information We Collect” and when California consumers interact with us by phone. We collect this personal information directly from consumers, from other companies and organizations, and from publicly available sources. For more information, please see “How We Collect Information.”

Sensitive Personal Information. We do not use or disclose sensitive personal information for purposes that, under applicable law, require us to offer you a right to limit the use or disclosure of sensitive personal information.

Business Purposes for Collecting Personal Information for the Last Twelve Months

We use the personal information we collect for our operational purposes, including all purposes notified to you in the above section titled “How We May Use Your Information.” In addition to the purposes described above, we use personal information for the following business purposes:

Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with state privacy laws and other standards;
Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes;
Debugging to identify and repair errors in our systems;
Short-term, transient use including non-personalized advertising shown as part of a consumer’s current interaction with us;
Providing services on our behalf or on behalf of others, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
Conducting internal research to develop and demonstrate technology; and
Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide, or to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for us, or controlled by us.

Disclosures of Personal Information on California Consumers for Business Purposes for the Last Twelve Months

We have disclosed the categories of personal information identified in this California Privacy Notice to service providers for various business purposes as specified above in the section titled “Business Purposes for Collecting Personal Information for the Last Twelve Months.” For more information on the service providers with whom we share information, please see “When Do We Disclose Your Information” above.

No Sales or Sharing of Personal information for the Last Twelve Months

We have not sold or shared any personal information described in this California Privacy Notice to third parties within the previous twelve (12) months, as “sell” and “share” are defined in the California Consumer Privacy Act (the “CCPA”).

Your California Privacy Rights

If you are a California resident, you have the following rights for purposes of the personal information covered by this California Privacy Notice:

Right to Know About Personal Information Collected, Disclosed, or Sold and Right to Access. You have the right to request that we disclose the following information to you, in each case in the twelve-month period preceding your request:

the categories of personal information we have collected about you;
the categories of sources from which the personal information is collected;
our business or commercial purpose for collecting, selling, or sharing personal information;
the categories of third parties to whom we disclose personal information;
the specific pieces of information we have collected about you.
if any, the categories of personal information about you that we have sold or shared, by category or categories of personal information for each third party to which we sold or shared the personal information;
the categories of personal information about you that we disclosed for a business purpose and the categories of persons to whom we disclosed the information for a business purpose; and

Right to Correct. You have the right to request that we correct inaccurate personal information that we have collected about you.
Right to Deletion of Personal Information. You have the right to request deletion of your personal information we collected from you. Please note if you have requested a service that requires the use of your personal information, we may not be able to provide that service if you choose to delete your person information.
Right to Non-Discrimination for Exercise of a California Privacy Rights. We may not discriminate against you because of your exercise of any of the foregoing rights, or any other rights under the CCPA, including by:

Denying you goods or services;
Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
Providing you a different level or quality of goods or services; or
Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to RNDC by your personal information.

How to Exercise Your California Rights; How We May Verify Your Request

You may request the rights listed above by:

emailing us at servicedesk@rndc-usa.com
calling us at 866-RND-CHLP
writing us at:

Republic National Distribution Company

One National Drive SW,

Atlanta, GA 30336

When you make a request, we may take steps to verify your identity before responding to your request. As part of this process, we may ask you to confirm your email address by sending you an email or questions about your account, if applicable, or the scope of your interaction with us. We reserve the right to take additional steps to verify your identity using other information we have about you. We may limit our response to your exercise of the above rights as permitted under applicable law.

You may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the agent with written permission, signed by you, to act on your behalf. As permitted by law, we may take steps to verify your agent’s authorization, require you to confirm you have authorized the agent to act on your behalf, or require you to verify your own identity in response to a request even if you choose to use an agent.

California Do-Not-Track Disclosure

Do-not-track is a privacy preference that users can set in their web browsers. When a user activates the do-not-track settings in browsers that offer this setting, the browser sends a message to websites requesting them not to track the user. At this time, our Sites are not set up to process web browser do-not-track settings. For more information about do-not-track matters, please visit www.allaboutdnt.org.

Information on Marketing Disclosures

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for their direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident, you may ask us to refrain from sharing your personal information with certain of our affiliates and other third parties for their marketing purposes. If you are a California resident and would like to make such a request, please submit your request in writing to us at support@erndc.com

17. Additional Notice of U.S. State-Specific Privacy Information and Rights

This part of our Privacy Notice applies to consumers who reside in states that have enacted comprehensive consumer data privacy laws.

1. Targeted Advertising. Like many companies, RNDC processes personal information for targeted advertising. You can opt out of targeted advertising by visiting the Digital Advertising Alliance website or the Network Advertising Initiative website. You can also opt out of targeted advertising by submitting an opt-out request to us as provided below.

2. Privacy Rights. Under applicable law, you may have the following rights, in each case under the conditions and to the extent set out in applicable law:

Right of Access: A right to confirm whether RNDC is processing personal information about you, and to request to access such personal information (including, if applicable, in a portable and readily usable format).
Right of Correction: A right to correct inaccuracies in certain personal information RNDC may hold about you.
Right of Deletion: A right to request that RNDC delete personal information concerning you. Please note that if you have requested a service that requires the use of your personal information, we may not be able to provide that service if you choose to delete your personal information.
Right to Opt Out: A right to opt out of the disclosure of personal information about you for monetary or other valuable consideration, the sharing of personal information about you for cross-context behavioral advertising, targeted advertising, and profiling.

If any of the above rights are available to you under applicable law, you can submit a request to exercise your rights by contacting us with any of the methods listed below.

emailing us at servicedesk@rndc-usa.com
calling us at 866-RND-CHLP
writing us at:

Republic National Distribution Company

One National Drive SW,

Atlanta, GA 30336

If your rights request is denied, applicable law may give you a right to lodge an appeal with us. The response to your rights request will inform you of any appeal rights you may have and tell you how you can exercise them.

servicedesk@rndc-usa.comEmail Us

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