Privacy Policy

Privacy Policy

Last modified on July 25, 2025

This Privacy Policy explains how (COLDWATER CLUB LLC).  (“Coldwater Club”, “we”, “our”, “us”) collects, uses, shares, and protects personal information, and the privacy rights and choices we offer, in connection with our websites, online services, and products and services (collectively, “our Services”). By using this website, you are consenting to the practices described in this Privacy Policy. 

Personal Information We Collect

Information you provide to us. Personal information you may provide to us includes:

  • Identifying contact details, such as your first and last name, email and mailing addresses, and phone number.

  • Account data, such as the username and password that you may use to establish an online account with us.

  • Communications that we exchange with you, including when you contact us with questions, feedback, testimonials, reviews or otherwise.

  • Order and purchase history, including your interactions with our checkout page.

  • Payment details, such as your payment card number, bank account number and shipping address.

  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

Third party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

  • Data providers, such as information services, data co-ops, and data licensors.

  • Public sources, such as social media platforms.

  • Marketing partners, such as companies that have entered into joint marketing relationships with us.

  • Updated delivery and address information from our carriers or other third parties, which we use to correct our records and deliver your next purchase or communication more easily.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with our websites, online services and our communications, such as:

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type, IP address, unique identifiers , language settings, mobile device carrier, radio/network information, and general location information.

  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our websites, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.

Cookies and similar technologies. Our Services may use the following technologies:

  • Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.

  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser, in connection with specific applications.

  • When you visit our website, log in, register or open an email, cookies, ad beacons, and similar technologies may be used by our online data partners or vendors to associate these activities with information they or others have about you, including your email address. We (or service providers on our behalf) may then send communications and marketing to these email addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.

Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How We Use Personal Information

We use personal information to operate, provide, develop, and improve the products and services that we offer. These purposes include:
Product delivery. We use your personal information to take and handle orders, deliver products and services, process payments, and communicate with you about orders, products and services, and promotional offers.
Improve, monitor, personalize, and protect our services and products. We may also use personal information to improve and keep our Services safe for our users, which includes:

  • Understanding your needs and interests, and personalizing your experience with the services and products and our communications;

  • Engaging in surveys and recording our video and audio chats with consumers;

  • Investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.

Research and development. We may use personal information for research and development purposes, including to analyze and improve our services, product offerings, and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our products and services and promote our business.
Marketing and advertising. We, our service providers, and our third party advertising partners may collect and use personal information for the following marketing and advertising purposes:

  • Direct marketing. We may send you Coldwater Club-related direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt-out of marketing section.

  • Interest-based advertising. We may engage third party advertising companies and social media companies to display ads on our websites and other online services. These companies may use cookies and similar technologies to collect information about your interactions (including the data described in the “Automatic data collection” section) over time across our Services and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to them or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the “Your Choices” section below.

Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes, including:

  • Protect our, your or others’ rights, privacy, safety, or property;

  • Audit our internal processes for compliance with legal and contractual requirements and internal policies;

  • Enforce the terms and conditions that govern our Services;

  • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and

  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

How We Share Personal Information

Information about our customers is an important part of our business, and we are not in the business of selling our customers' personal information to others. We share customers' personal information only as described below.

Affiliates. Within Coldwater Club for purposes consistent with this Privacy Policy
Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business.

Payment processors. When you make a purchase at Coldwater Club, your payment information is collected and processed directly by our payment processors. We do not record or maintain payment card or bank account details. These payment processors may use your payment data in accordance with their privacy policies.

Third Parties. Third parties, such as advertising companies and data providers, for interest-based advertising and other marketing purposes, including those third parties’ own purposes. To learn how to opt-out, please see the “Privacy Rights and Choices” section below.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Coldwater Club.

Testimonials. For Coldwater Club’s website or marketing materials consistent with this Privacy Policy. 

Privacy Rights and Choices

Access, correct or delete. If you have a Coldwater Club account, you can review and update certain account information by logging into your account. Registered users may also contact us to request deletion of their account and certain personal information. We may request information from you to help us confirm your identity and process your request. Applicable law may require or permit us to limit or decline access and deletion requests, such as where we need to retain your information for security, compliance, fraud prevention, and safety purposes, to comply with law, to establish or defend legal claims, to protect the identities and rights of other users, to protect trade secrets, or because access or deletion is not practicable. If we delete your account, you will not be able to access it. If we delete your information, it will generally be deleted from our active databases, and the information may remain for a period of time in our backup files and in unstructured files until these records are deleted in the ordinary course of business.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com

Other Sites and Services. Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions
Security. We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of personal information.

Minors. Our Services are not intended for use by anyone under the age of 21.

Changes to This Privacy Policy. We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our websites and online services. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through our Services. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of our Services after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to Contact Us. You can reach us by email at hello@drinkcoldwaterclub.com.

State-Specific Privacy Disclosures

These additional disclosures are required by certain state privacy laws, and provide a Notice at Collection under the California Privacy Rights Act:

Categories of personal information collected. The personal information that we collect, or have collected from consumers in the twelve months prior to the effective date above, fall into the following categories established by the California Privacy Rights Act and other state privacy laws:

  • identifiers such as your name, alias, address, phone numbers, IP address, your account log-in information, or a government-issued identifier;

  • personal information, such as a credit card number or other payment information;

  • inference data, such as information about your purchase preferences; and

Categories of personal information disclosed for a business purpose. The personal information that we may have disclosed for a business purpose to the third parties identified in the "How we share personal information" section of our Privacy Notice in the twelve months prior to the effective date above falls into the following categories established by the California Privacy Rights Act and other state privacy laws:

  • identifiers such as your name, address, phone numbers, IP address, or government identifier, for example if we use a third-party carrier to deliver your order, or if we use a third-party service to verify your identity, certain types of ID you provide for identity verification, which may in some cases reflect your citizenship or immigration status;

  • personal information, such as a credit card number or other payment information, for example if we use a third-party payment processor;

  • internet or other electronic network activity information, such as if we use a service provider to help us gather crash reports for analyzing the health of our services, or information relating to our prevention and detection of fraud or other unauthorized activity, which may require disclosing certain information about potentially affected customers to law enforcement;

  • audio or visual information, for example if a service provider reviews recordings of customer service phone calls for quality assurance purposes;

  • inference data, for example if we use a service provider to help us optimize the accuracy of your shipping address to make sure your order reaches you; and

Advertising. As explained in the "Marketing and advertising" section of our Privacy Notice, we share limited information. Any personal information we may have shared for the purpose of cross-context behavioral advertising, as that term is defined by the California Privacy Rights Act, in the twelve months prior to the effective date above falls into the following categories:

  • identifiers such as a cookie, a device identifier, or a code derived from applying irreversible cryptography to other information like an email address; we do not share your name or other information that directly identifies you with ad companies.

  • inference data; while we do not share your specific shopping actions like purchases, product views, or searches with ad companies, we may share an advertising identifier and an estimate of the value of the ads they show you on our behalf

The categories of third parties with whom we may share personal information for the purpose of cross-context behavioral advertising are identified in the "How we share personal information" and "Marketing and advertising" sections of the Coldwater Club Privacy Notice. 

Children and Teens. As stated in the Coldwater Club Privacy Notice, children and teens are not permitted to purchase products.  

No sale of personal information. In the twelve months prior to the effective date of this Disclosure, Coldwater Club has not sold any personal information of consumers, as those terms are defined under the California Privacy Rights Act.

De-identified Data Disclosure. Coldwater Club may use de-identified data in some instances. Coldwater Club either maintains such data without attempting to re-identify it or treats such data as personal data subject to applicable law.

California Privacy Rights Act Sensitive Personal Information Disclosure. The categories of data that Coldwater Club collects and discloses for a business purpose include "sensitive personal information" as defined under the California Privacy Rights Act. Coldwater Club does not use or disclose sensitive personal information for any purpose not expressly permitted by the California Privacy Rights Act.

California Privacy Rights Act and Minnesota Consumer Data Privacy Act Retention Disclosure. To enable your continued use and purchase of products from Coldwater Club, we keep your personal information for as long as it is required in order to fulfill the relevant purposes described in the Coldwater Club Privacy Notice, as permitted or as may be required by law, or as otherwise communicated to you. For example, we retain your transaction history so that you can review past purchases (and repeat orders if desired) and what addresses you have shipped orders to, and to improve the relevance of products and content we recommend.

California Privacy Rights Act Non-discrimination Statement. Coldwater Club will not discriminate against any consumer for exercising their rights under the California Privacy Rights Act.

Colorado Privacy Act and Oregon Consumer Privacy Act Profiling Disclosure. Coldwater Club does not engage in profiling of consumers in furtherance of automated decisions that produce legal or similarly significant effects, as those terms are defined under the Colorado Privacy Act or the Oregon Consumer Privacy Act.

Oregon Consumer Privacy Act Controller Entity Disclosure. The controller entities that are subject to the Coldwater Club Privacy Notice and this Disclosure include Disruptive Beverage, Inc.

New Jersey Notice of Material Change Disclosure. If we make material changes to our Privacy Notice, we will provide affected customers with advance notice of the change, such as by email or via their account.