Privacy Policy
Effective/Last Updated Date: September 18, 2025
Last Reviewed: September 17, 2025
Van Winkle Goods LLC, d/b/a Pappy & Company, together with its affiliates, agents, and licensees (collectively “we,” “us,” or “our”), offers you access to its interactive online websites, applications, and services. This Privacy Policy (“Policy”) explains what information may be collected when you access our websitehttps://pappyco.com (“Website”), or any other website which we control on which we may place this Policy, purchase our products or services, or sign up for an account with us through our Pappy Points program (together with our Website, our “Services”). Additionally, this Policy addresses how we and others use this information, under what circumstances we may disclose the information to third parties, and the instances in which we may allow third parties to collect information directly, including in the past twelve (12) months.
Depending on your activities when using or accessing our Services, you may from time to time be required to agree to additional terms and conditions. This Privacy Policy applies regardless of whether you use our Services via a computer, mobile device, or other platform (collectively, your “Equipment”).
This Policy applies to information we collect:
· On our Website, including through your purchase of our products.
· In email and other electronic messages between you and Pappy & Company via our Services.
· Via your interaction with our advertisements on third party websites and services, if those advertisements include links to this Policy.
This Policy does not apply to information collected by:
· Us through any website, content application, or service we may offer which does not link to this Policy.
· Any third party, including through any application or content (including advertising) that may link to or be accessible from or through our Website or Services.
Our Website is hosted in the United States and directed at individuals in Canada, the United States, the European Union, and the United Kingdom. If you are located outside of the countries to which we direct our Services, you should not access or use our Services and should not share your Personal Information with us.
If you do not agree with this Policy, please do not use our Services. We reserve the right to update this Policy at any time. The Last Updated date above provides you with notice that this Policy has been updated.
Modifications to this Policy
We keep this Policy on our Website. You should review this Policy frequently, as it may change from time to time and without notice. Any changes will be effective immediately upon the posting of the revised Policy and will apply to all information collected after the posting of the revised Policy. If you continue to use our Services after this Policy is updated, you agree to this Policy as it is posted. If you do not agree with any changes to this Policy, please stop using our Services.
We may collect, use, store, or disclose various information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual (“Personal Information”). Personal Information does not include information that is publicly available or de-identified.
We may collect the following information:
· Sensitive Personal Information– such as your driver’s license number, passport number, or other similar identifier and credit card information including your card number and CVC/CVV code.
3. How We Collect Your Information
We collect information from you in the following ways:
We may use automatic data collection technologies when you visit our Website, view our advertisements, or use our Services. For example, we may use cookies (browser cookies and flash cookies), and web beacons (also called clear gifs or pixel tags), to distinguish you from other users of the Services to help us deliver a better and more personalized service when you use our Services. Such technologies also allow us to improve our Services by enabling us to:
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services. For more information, seeInterest-Based Advertising.
The technologies we use for automatic data collection may include:
We use your information to provide you with products, offer you services, communicate with you, deliver advertising and marketing, or to conduct other business operations, such as using information to improve and personalize your experiences. Examples of how we may use the information we collect include:
Legal Basis of Processing
We process your Personal Information under the following legal bases:
· You have given your consent for processing. Please note that where we use consent as the legal basis for processing your information that you have the right to withdraw that consent at any time by reaching out to us using the information contained in theContact Us section below.
· In furtherance of the performance of a contract of which you are a party;
· As necessary for compliance with a legal obligation to which we are subject; and
· In our own legitimate interest such as when we perform marketing, security, and fraud prevention.
We may share information that does not identify you without restriction. We may disclose Personal Information as follows:
We may also disclose Personal Information to others:
· In the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, where one of the transferred assets is the Personal Information we hold.
To Whom We Disclose Personal Information
We may disclose your Personal Information to the following:
Service providers. We share Personal Information with vendors who help us with certain services, including customer support, email and text message deployment, research and analytics, marketing and advertising services, data processing, management, analytics, fraud prevention, transaction and payment processing, survey administration, and order fulfillment.
Business Partners, Advertisers, and other Third Parties. With appropriate consent where required, we may share Personal Information with or make it available to our sponsors, partners, advertising networks, advertising servers, analytics companies, or other third parties in connection with our and their marketing, promotional and other offers, as well as product information.
We use Google Analytics to analyze use of our Services. For more information about how Google uses information from sites or apps that use its services, please seeGoogle’s Privacy Policy.
We may also disclose Personal Information to:
Law Enforcement, Regulators, Courts, and other Governmental Authorities. We share any of the categories of information we collect, pursuant to applicable law, to respond to subpoenas, court orders, legal process, and other law enforcement measures, to comply with other legal obligations, to respond to an emergency, or otherwise to protect our or the rights, property, safety, or security of other parties, visitors to or users of our Services, or the public.
Third-Party Business or Asset Transfer Partners. In the event we are involved in a merger, acquisition, transfer of control, bankruptcy, reorganization, or sale of assets, or diligence associated with such matters, we may share Personal Information. For example, if another entity acquires us or all or substantially all our assets, or assets relating to any of our businesses, your information may be disclosed to that entity as part of the due diligence process and may be transferred to that entity as one of the transferred assets.
7. International Transfers of Data
Our Services are based and hosted in the United States. If you use our Services, your Personal Information will be transferred to, processed in, and stored in the United States. We will handle your Personal Information consistent with this Privacy Policy and as required by the laws of the countries in which we offer our Services.
Our Services may integrate technology of third-party advertising networks (“Ad Networks”) that allows for the recognition of your Equipment and the collection of information about browsing, searching, and other activities of you or anyone else using your Equipment. This information is then used to send you advertisements for products and services that are more likely to be of interest to you. For more information on how this type of advertising works, visithttps://youradchoices.com/.
To enable interest-based advertising across your Equipment and software, we may also share data, such as technical identifiers derived from your registration information on our Services or Personal Information, with these Ad Networks. This allows them to link your Equipment, browser, etc. and to better identify you across different environments.
If you do not wish to participate in interest-based advertising via Ad Networks, you may opt-out by visiting and following the instructions set forth at either: (1) the Digital Advertising Alliance’s website (https://youradchoices.com/); or (2) the Network Advertising Initiative’s website (https://optout.networkadvertising.org/?c=1). A couple of important notes about these opt-out tools: (i) they includes all the advertising networks with which we may work, but also many with which we do not work; and (ii) they may rely on cookies to ensure that a given advertising network does not collect information about you (“Opt-out Cookies”) – an explanation of how Opt-out Cookies work can be found onwww.aboutads.info. Therefore, if you use different Equipment, change web browser, or delete the Opt-out Cookies, you will need to perform the opt-out task again.
We have created mechanisms to provide you with the following control over your information:
Data Subject Access Rights. Your rights may vary depending on in which state you are a resident. You may have the following rights related to your Personal Information:
● The right to know what Personal Information we process about you.
● The right to request certain Personal Information that we process about you be deleted.
● The right to request we correct Personal Information we have about you which you believe is incorrect.
● The right to have certain Personal Information we process about you returned to you in an accessible and useable format upon your request, if such request is technically feasible.
● The right to opt out of having your Personal Information processed in such a way that enables us to create a profile of inferences about you or for targeted advertising purposes.
● The right to limit the use of your Sensitive Personal Information.
● The right to not have your Personal Information processed by us using technology that produces an automatic decision which results in a legal or similarly significant effect.
● The right to opt out of the sale of your Personal Information.
● The right to restrict the processing of your Personal Information pursuant to applicable law.
● The right to not receive discriminatory treatment by us for exercising the privacy rights above, including if you are an employee, applicant, or independent contractor, the right against employment related retaliation for exercising your privacy rights.
● We will respond to and abide by or honor universal opt-out mechanisms that are consistent with applicable law.
California Residents. If you are a California resident, you may have additional personal rights and choices regarding your personal data. For example, California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. Additionally, if you are a California resident, we will respond to and abide by or honor opt-out requests you make to us via universal opt-out mechanisms as consistent with applicable law.
How to Submit a Data Subject Rights Request
To submit a Data Subject Rights Request, use the contact information provided in theContact Us section below.
How We Verify Consumer Requests
We may require that you verify your identity prior to processing verifiable rights requests. If your request requires verification, we will verify your identity by comparing the information we have about you against the information we receive when you submit your request. If we do not have enough information to verify your identity, we may request additional information from you, consistent with applicable law. We may deny a rights request if we are unable to verify your identity.
Authorized Agents
Some states permit their residents to designate an authorized agent to submit requests to exercise certain privacy rights. Even if you use an authorized agent to submit a request on your behalf, pursuant to applicable law, we may still require that you verify your identity depending on the nature of the request and sensitivity of the information at issue.
If you are an authorized agent submitting a request on behalf of an individual, please submit a request using the contact information provided in theContact Us section below. You must include a copy of the written, signed permission indicating that you are permitted to act on that person’s behalf.
Appealing a Denied Request to Exercise Data Subject Rights
In some circumstances, we may deny your request to exercise one or more of the rights described above. If you disagree with our decision to deny your request or any portion of your request, you may appeal our decision within sixty (60) days of receipt of notice that your request has been denied. If you submit an appeal to a denied request more than sixty (60) days after you have been notified of our decision to deny the request, we may deny your appeal. If you submit a timely appeal, we will respond within forty-five (45) days of our receipt of your appeal.
If you wish to appeal a decision, please clearly and plainly describe your basis of disagreement with our decision by responding through the same means by which we communicated our decision or by submitting your appeal using the information provided in theContact Us section below. We will review your appeal and either amend or uphold our decision In either case, we will provide a written explanation of the reason for the decision. This decision will be final.
We will retain and use your Personal information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required by law.
We do not direct our websites or services to individuals under the age of 21 years old, and we do not knowingly collect, sell, or share, (as those terms are defined by applicable law) the Personal Information of any individual under the age of 21. If you are under the age of 21, do not use or provide any information through the Services. If you believe we may have any information from or about an individual under the age of 21 please contact us atpolicies@pappyco.com.
Our Services may link to or contain links to third-party websites that we do not control or maintain, such as in connection with purchasing products we may recommend or reference via our Services and/or advertisements you may see while using our Services. We are not responsible for the privacy practices employed by any third-party website. We encourage you to read the privacy statements of all third-party websites before submitting any Personal Information through these websites.
The security of your Personal Information is very important to us. We use physical, electronic, and administrative safeguards designed to protect your Personal Information from loss, misuse, and unauthorized access, use, alteration, or disclosure. The safety and security of your Personal information also depends on you. You are responsible for keeping confidential the password you use to access certain parts of our Services.
14. Notice of Financial Incentive
From time to time, we may offer coupons or other price reductions for our products and services for enrolling in email updates, newsletter delivery, our Rewards Program (as described in ourTerms of Use), or similar services we provide (“Incentives”) in exchange for our use of your Personal Information. To provide these Incentives, we utilize the contact information and unique identifiers you have provided to us and may use the details from your commercial relationship with us (from your commercial information), as described inInformation We May Collect About You above.
To opt-out of financial incentives, please follow the applicable steps identified in theYour Rights and Choices section of this Policy. If you opt out, we will not reduce the value of any financial incentives you previously received from us. The value of data from the Rewards Program is calculated by determining the approximate additional spending per participant per year compared to individuals who have not participated in the Rewards Program. The value of the Rewards Program data is reasonably related to the costs associated with offering the Rewards Program Incentives. We do not assign monetary value to the other data that we collect and strive to only use that information to further our business in accordance with this Policy, and to the extent there is any value, it is reasonably related to the applicable incentives.
As noted above, we may update this Policy from time to time, and we will provide notice of any material changes to the Policy as required by law. All changes will be effective upon posting of the updated Privacy Policy on our Website. If you object to any change, you should stop using the Services.
16. Contact Us
If you have any comments or questions about our Privacy Policy, or to exercise your Data Subject Rights, you may contact us using theContact Us page on the Website or at:
Address: 843 East Market Street, Louisville, KY 40206
Phone: 1-888-834-9831
Email: policies@pappyco.com
If you wish to raise a complaint on how we handle your personal data, you can contact us using the information in theContact Us section above.
If you are not satisfied with our response you can complain to the data protection authority in the country in which you reside.
This Policy as posted on this Website is the sole statement of our privacy practices with respect to our Website and Services. No summary, modification, restatement, or other version of this Policy, or other privacy statement or policy, in any form, is valid unless we post a new or revised policy to this Website.
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