Privacy Policy

PRIVACY POLICY

Effective Date: July 1, 2026

This Privacy Policy explains how Unico Inc. d/b/a Tinto Amorío (“Tinto,” “Unico,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information when you visit drinktinto.com, communicate with us, place or facilitate an order, join a subscription, interact with our marketing, or otherwise use our website and related services (collectively, the “Services”).

Unico Inc. is based in California, United States.

This Privacy Policy applies to information processed by Unico. Certain European transactions are sold and processed by Tipple Operations Limited, as described below, and Tipple may separately process your personal information under its own privacy practices.

1. Information We Collect

The information we collect depends on how you interact with us.

Contact and Identification Information

We may collect:

• your name;
• email address;
• telephone number;
• billing address;
• shipping address;
• postal code;
• account information; and
• other contact information you provide.

Order and Commercial Information

We may collect information relating to:

• products purchased or viewed;
• shopping-cart activity;
• order history;
• subscriptions;
• gift orders;
• promotions and discounts;
• delivery information;
• customer-service requests; and
• other commercial interactions with Tinto.

Payment Information

Payments are generally processed by third-party payment providers such as Shopify Payments, PayPal, or other payment services made available at checkout.

We may receive limited payment-related information, such as transaction status, payment method type, billing details, or transaction identifiers, but we generally do not receive or store full payment-card numbers.

Account and Subscription Information

If you create an account or join a subscription, we may collect:

• account identifiers;
• login information;
• subscription preferences;
• delivery frequency;
• payment status; and
• account activity.

Device and Website Usage Information

When you use the Site, we and our service providers may automatically collect information including:

• IP address;
• browser type;
• operating system;
• device type or identifiers;
• pages viewed;
• links clicked;
• referring website;
• timestamps;
• session information;
• shopping behavior; and
• approximate location derived from IP address.

Marketing and Advertising Information

We may collect or receive information concerning:

• marketing-email activity;
• SMS interactions;
• advertising impressions or clicks;
• campaign attribution;
• referral source;
• website interactions;
• audience or advertising identifiers; and
• information used to measure or improve advertising effectiveness.

Communications

If you contact us, we may retain the information contained in your email, message, form submission, survey response, customer-service inquiry, or other communication.

2. How We Collect Information

We may collect information:

• directly from you;
• automatically when you interact with the Site;
• through Shopify and other ecommerce providers;
• from payment processors;
• from delivery, fulfillment, logistics, and compliance providers;
• from Tipple in connection with European orders;
• from advertising and analytics providers;
• from email and SMS providers;
• from social-media platforms;
• from affiliates or referral partners; and
• from other service providers and business partners.

3. How We Use Personal Information

We may use personal information to:

• provide and operate the Site;
• process or facilitate orders;
• verify and manage customer accounts;
• arrange fulfillment and delivery;
• facilitate age and alcohol-compliance requirements;
• manage subscriptions;
• process returns, exchanges, reshipments, or customer-service requests;
• communicate with customers;
• send transactional communications;
• send marketing communications where permitted;
• administer promotional programs;
• personalize the shopping experience;
• analyze Site usage;
• measure advertising and marketing performance;
• conduct attribution and analytics;
• prevent fraud and abuse;
• maintain security;
• enforce our agreements;
• maintain business, tax, and accounting records;
• comply with legal and regulatory requirements; and
• protect our rights and the rights of others.

4. Shopify and Ecommerce Providers

Our Site is hosted on Shopify.

Shopify and related ecommerce providers may process personal information in connection with:

• Site hosting;
• shopping-cart functionality;
• checkout;
• account services;
• payment processing;
• analytics;
• security; and
• other ecommerce functions.

Those providers may process information under their own privacy policies and contractual obligations.

5. European Orders and Tipple Operations Limited

For purchases delivered to supported European Union markets, Tipple Operations Limited (“Tipple”) acts as the importer and Merchant of Record for the final sale.

Information necessary to complete an EU purchase may be provided to Tipple, including:

• your name;
• contact information;
• billing and shipping details;
• products ordered;
• transaction information; and
• information necessary for payment, refunds, tax, alcohol compliance, import, or fulfillment.

Tipple processes information associated with its responsibilities as Merchant of Record and seller.

Unico may separately process information relating to the Tinto Amorío brand, Site, customer service, marketing, analytics, and other activities described in this Privacy Policy.

Depending on the particular processing activity, Unico and Tipple may each act as separate controllers of personal information for their respective purposes.

Tipple's own privacy terms may also apply to its processing of an EU transaction.

6. Service Providers

We use companies and individuals to perform services on our behalf.

These may include providers of:

• ecommerce technology;
• payment processing;
• fraud prevention;
• warehousing;
• fulfillment;
• alcohol compliance;
• delivery and shipping;
• email;
• SMS;
• customer support;
• analytics;
• advertising;
• website technology;
• hosting;
• security;
• accounting; and
• other business services.

We may provide those parties with information reasonably necessary to perform their functions.

7. Advertising, Analytics, and Marketing Partners

We may use advertising, analytics, attribution, and marketing technologies provided by third parties.

These technologies may collect or receive information such as:

• device identifiers;
• IP addresses;
• cookie identifiers;
• website activity;
• products viewed;
• purchases;
• advertising interactions;
• hashed or otherwise transformed contact information; and
• related marketing or attribution data.

This information may be used to:

• measure advertising effectiveness;
• understand how customers find the Site;
• attribute purchases to advertising campaigns;
• create or refine advertising audiences;
• personalize advertising;
• suppress existing customers from certain campaigns; and
• improve our marketing.

Certain third parties may collect information regarding your activities over time and across different websites or online services when their technologies are present.

We do not sell personal information to third parties for monetary compensation.

We may nevertheless disclose information to advertising, analytics, and marketing providers for the purposes described above.

8. Cookies and Similar Technologies

We and our service providers may use:

• cookies;
• pixels;
• tags;
• web beacons;
• local storage; and
• similar technologies.

These technologies may be used for:

• essential Site functionality;
• cart and checkout operation;
• security;
• account functionality;
• analytics;
• attribution;
• personalization; and
• advertising.

You may be able to block or delete cookies through your browser settings.

Disabling essential cookies may prevent portions of the Site from functioning correctly.

9. EU Cookie Consent

For visitors in the European Economic Area (“EEA”), we provide cookie-consent controls where required by applicable law.

Non-essential cookies and similar technologies used for purposes such as advertising or analytics will be activated only after consent where consent is legally required.

EEA visitors may use the cookie-preference controls made available on the Site to grant, refuse, or withdraw consent to non-essential technologies.

Withdrawing consent does not affect the lawfulness of processing performed before consent was withdrawn.

These EU cookie controls are provided in jurisdictions where such controls are required and should not be interpreted as representing that identical privacy-choice mechanisms are available in every jurisdiction.

10. Do Not Track

Some internet browsers transmit a “Do Not Track” (“DNT”) signal.

There is currently no universally accepted standard governing how websites should interpret all DNT signals.

Accordingly, our Site does not currently respond to general browser DNT signals, except where applicable law requires us to recognize a particular privacy mechanism.

Third-party advertising and analytics providers may have their own practices regarding DNT signals.

This section describes our current tracking practice for purposes of applicable California online-privacy disclosure requirements.

11. Email Marketing

If you subscribe to our marketing emails, we may use your email address and related engagement information to send Tinto Amorío news, offers, product information, and other promotional communications.

You may unsubscribe at any time using the unsubscribe link included in a marketing email.

Unsubscribing from marketing does not prevent us from sending transactional communications concerning an order, subscription, account, customer-service request, security issue, or other non-marketing matter.

12. SMS Marketing

If you expressly opt in to SMS marketing, we may use your telephone number and messaging activity to send recurring promotional or informational messages.

Consent to SMS marketing is not required to purchase our products.

Message and data rates may apply.

You may opt out by replying STOP.

We may use a third-party messaging provider to administer our SMS program.

13. How We Disclose Personal Information

We may disclose personal information to:

Service Providers

Companies that perform functions for us, including ecommerce, payment, fulfillment, shipping, communications, analytics, advertising, and technology services.

Tipple

For European purchases where Tipple acts as Merchant of Record.

Advertising and Marketing Partners

For measurement, attribution, advertising, audience creation, and related marketing functions.

Professional Advisers

Lawyers, accountants, insurers, auditors, consultants, or other advisers where reasonably necessary.

Corporate Transactions

Potential buyers, investors, lenders, advisers, or other parties involved in a merger, acquisition, financing, restructuring, sale of assets, or similar transaction.

Legal and Safety Purposes

Government authorities, law enforcement, courts, regulators, or other parties when we reasonably believe disclosure is required by law or necessary to protect legal rights, safety, security, or prevent fraud.

With Your Direction

Other parties when you request or authorize us to disclose information.

14. Aggregated and De-identified Information

We may create aggregated, statistical, or de-identified information that does not reasonably identify an individual.

We may use or disclose such information for analytics, business planning, marketing measurement, or other lawful purposes.

15. Data Retention

We retain personal information for as long as reasonably necessary for the purposes for which it was collected.

Retention periods may depend on:

• whether you maintain an account or subscription;
• our relationship with you;
• transaction and tax-record requirements;
• alcohol-compliance obligations;
• fraud-prevention needs;
• legal requirements;
• contractual requirements; and
• dispute-resolution needs.

When information is no longer reasonably required, we may delete, anonymize, or otherwise dispose of it, subject to applicable legal and technical limitations.

16. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, use, alteration, or disclosure.

These measures may include access controls, encrypted communications, vendor controls, authentication, and security technologies.

No method of electronic transmission or storage is completely secure.

Accordingly, we cannot guarantee absolute security.

17. Reviewing or Correcting Your Information

You may contact us at info@drinktinto.com to request that we review or correct personal information you previously provided directly to Unico.

We may need to verify your identity before making material changes.

Certain information associated with transactions may need to be retained even after a correction or account request for legal, tax, compliance, or recordkeeping purposes.

18. California Online Privacy Disclosures

Unico's Site collects the categories of information described in this Privacy Policy, including identifiers, contact information, commercial information, website activity, device information, and marketing information.

We disclose information to the categories of recipients described above, including service providers and advertising, analytics, fulfillment, and marketing partners.

Certain third parties may collect information about a visitor's online activities over time and across different websites when third-party advertising or analytics technologies are present on the Site.

As described in the Do Not Track section, the Site does not currently respond to general browser DNT signals because no uniform standard governs such signals.

We will update this Privacy Policy if our material information practices change.

Unico does not currently represent that it is a “business” subject to the California Consumer Privacy Act solely by virtue of operating this Site, and this Privacy Policy does not create consumer rights that do not otherwise apply under law.

For questions regarding our privacy practices, contact info@drinktinto.com.

19. EEA Privacy Rights

If you are located in the European Economic Area and Unico processes your personal information subject to the General Data Protection Regulation (“GDPR”), you may have the right, subject to applicable conditions and exceptions, to:

• obtain access to your personal information;
• request correction of inaccurate information;
• request deletion of personal information;
• request restriction of processing;
• object to certain processing;
• receive certain information in a portable format;
• withdraw consent where processing is based on consent; and
• lodge a complaint with an applicable data-protection supervisory authority.

You may exercise rights concerning information controlled by Unico by contacting:

info@drinktinto.com

Requests relating specifically to payment, sale, refund, tax, or transaction processing performed by Tipple may need to be addressed to Tipple.

We may need to verify your identity before fulfilling a request.

20. EEA Legal Bases for Processing

Where GDPR applies to Unico, we process personal information under one or more lawful bases depending on the circumstances.

Contract

We may process information where necessary to provide requested services, administer accounts or subscriptions, or facilitate a transaction.

Legitimate Interests

We may process information where necessary for legitimate business interests, such as:

• operating and securing our Site;
• providing customer service;
• preventing fraud;
• analyzing business performance;
• improving our Services; and
• conducting appropriate marketing,

provided those interests are not overridden by your rights and interests.

Consent

We rely on consent where applicable law requires it, including for certain non-essential cookies, advertising technologies, or marketing communications.

You may withdraw consent as described in this Policy.

Legal Obligations

We may process information where necessary to comply with legal, regulatory, tax, alcohol-compliance, accounting, or other obligations.

21. International Transfers

Unico is based in the United States.

Information processed by Unico may therefore be transferred to, stored in, or accessed from the United States and other countries where we or our service providers operate.

Those countries may have data-protection laws that differ from those in the EEA.

Where applicable law requires safeguards for an international transfer, we or our service providers may use legally recognized mechanisms such as contractual safeguards, adequacy decisions, or other lawful transfer mechanisms.

22. Children and Minors

Our Site markets alcoholic beverages and is not directed to children.

We do not knowingly solicit personal information from individuals who are below the legal age to purchase alcohol through the Site.

U.S. purchasers must be at least 21 years old.

If you believe a minor has provided personal information to us improperly, contact info@drinktinto.com.

23. Third-Party Sites

Our Site may link to third-party websites or services.

This Privacy Policy does not govern information collected independently by those third parties.

We encourage you to review their privacy policies before providing them with information.

24. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in:

• our business;
• our technology;
• our service providers;
• applicable law; or
• our information practices.

When we update the Policy, we will revise the effective date at the top.

Where applicable law requires additional notice or consent regarding a material change, we will provide it.

25. Contact Us

Questions or requests regarding this Privacy Policy may be sent to:

Unico Inc. d/b/a Tinto Amorío
California, United States
info@drinktinto.com