Privacy Policy

1. Introduction

This Privacy Policy explains how White Glove Integrated Solutions LLC, a Florida limited liability company doing business as DrinkUp ("DrinkUp," "we," "us," or "our"), collects, uses, shares, and protects information about you when you use our mobile web platform, our website at drinkupapp.com, and related services (collectively, the "Platform").

This Privacy Policy is incorporated into our Terms of Service. By using the Platform, you agree to the practices described here. If you do not agree, do not use the Platform.

Quick summary (not a substitute for the full policy):

• We collect the information you give us to place an order (name, contact info, payment info, the order itself) plus standard device and usage data.
• We do not store or process your full payment card information. Stripe handles that.
• We share your order information with the Bar you order from, with payment and communications service providers, and as required by law.
• We do not sell your personal information. We do not run targeted advertising.
• You have rights to access, correct, and delete your information. Email hello@drinkupapp.com to exercise them.

2. Information We Collect

2.1 Information You Provide

When you create an account or place an order, you may provide us with:

• Account information — name, email address, mobile phone number, and a password.
• Profile information (optional) — date of birth (used for age verification of orders containing alcohol), saved preferences, and any other information you choose to add to your account.
• Order information — the items you order, the Bar you order from, the time of order, any special instructions, and any tips.
• Payment information — collected directly by our payment processor, Stripe. DrinkUp itself does not receive or store your full payment card number. We receive a tokenized reference and limited descriptive information (last four digits, card brand, billing zip) for displaying your saved payment methods and processing future orders.
• Communications with us — content of any emails, support requests, chat messages, or feedback you submit.

2.2 Information Collected Automatically

When you use the Platform, we automatically collect:

• Device information — device type, operating system, browser type and version, screen size, mobile carrier (where applicable), and a device identifier.
• Usage information — pages and screens you view, features you use, links you click, time spent on the Platform, referring URLs, and timestamps.
• IP address and approximate location — derived from your IP address, used for fraud prevention, regional compliance, and to show you Bars near you.
• Precise location (with your consent) — if you grant location permission to the browser or device, we may use precise geolocation to determine which Bars are nearby and to help you find your selected Bar. You can revoke location permission at any time through your device or browser settings.
• Cookies and similar technologies — see Section 5 below.

2.3 Information From Third Parties

We may receive information about you from:

• Bars — for example, if a Bar reports an issue with your order, an age-verification denial, an intoxication-related refusal, or other operational matter.
• Stripe — payment status, fraud signals, dispute information, and other data necessary to process and reconcile payments.
• Twilio — message delivery status, opt-out information, and carrier responses for SMS messages.
• SendGrid — email delivery status, bounces, and unsubscribe information.
• Analytics providers — aggregated usage analytics, attribution data, and (where applicable) crash and error diagnostics.
• Law enforcement and government authorities — when responding to lawful requests or investigations.

3. How We Use Information

We use the information we collect to:

• Operate the Platform — create and maintain your account, display Bar menus, accept orders, process payments, route orders to the Bar, send order confirmations and pickup notifications.
• Communicate with you — transactional messages about your orders and account; if you have opted in, marketing communications about DrinkUp and participating Bars (see Section 7).
• Provide customer support — respond to your questions, troubleshoot issues, investigate complaints.
• Prevent fraud and abuse — detect and prevent fraudulent transactions, age misrepresentation, chargeback abuse, account takeovers, and violations of our Terms of Service or Acceptable Use Policy.
• Comply with legal obligations — including obligations under the Florida Beverage Law, the Florida Information Protection Act, the Telephone Consumer Protection Act (TCPA), the CAN-SPAM Act, and tax laws.
• Improve the Platform — analyze usage patterns, identify bugs, develop new features, conduct A/B testing.
• Verify age — when you order alcohol, our records of age representations are part of our fraud-prevention and compliance file.
• Enforce our agreements — respond to disputes, resolve chargebacks, take action against accounts that violate our Terms.

4. How We Share Information

We share information with the following categories of recipients and only for the purposes described:

4.1 With Bars

When you place an order, we share the information necessary for the Bar to fulfill it: your name, the items ordered, any special instructions, your contact information for pickup coordination, and your tip. Bars are independent businesses and use your information under their own privacy practices for the purpose of fulfilling your order. DrinkUp requires Bars by contract to limit their use of customer information to order fulfillment and to protect it appropriately.

4.2 With Service Providers

We use service providers to operate the Platform. They process information on our behalf, under contracts that limit their use of the information to the services they provide to us. Our current service providers include:

• Stripe — payment processing and fraud prevention
• Twilio — SMS delivery
• SendGrid — transactional and marketing email delivery

4.3 With Law Enforcement and Legal Authorities

We may disclose information to law enforcement, regulators (including the Florida Division of Alcoholic Beverages and Tobacco), courts, or other government authorities when:

• Required by a valid subpoena, court order, or other legal process;
• Reasonably necessary to comply with applicable law or regulation;
• Reasonably necessary to protect the rights, safety, or property of DrinkUp, our users, the Bars, or others;
• Investigating suspected fraud, age misrepresentation, or other violations of our Terms.

4.4 In Connection with Business Transactions

If DrinkUp is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, information about you may be transferred as part of that transaction. We will provide notice (typically by email and an in-app banner) before your information becomes subject to a different privacy policy.

4.5 With Your Consent

We may share information for other purposes with your explicit consent.

4.6 What We Don't Do

We do not sell your personal information. We do not share your personal information with third parties for their own independent marketing purposes. We do not engage in targeted advertising or cross-context behavioral advertising.

5. Cookies and Tracking Technologies

We use cookies and similar technologies (such as local storage and pixel tags) for the following purposes:

• Strictly necessary — to log you in, maintain your session, remember your cart, and process payments. These cannot be disabled without breaking the Platform.
• Functional — to remember your preferences (selected Bar, saved address, language).
• Analytics — to understand how users interact with the Platform so we can improve it.
• Security / fraud prevention — to detect suspicious activity.

We do not use third-party advertising cookies. You can disable non-essential cookies through your browser settings, but doing so may impair Platform functionality.

6. Data Retention

We retain personal information for as long as needed to provide the Platform and for the following purposes:

• Account information — for the life of your account, plus a reasonable period after deletion for backups and audit trails (typically up to one year after account closure).
• Order history — at least three (3) years for tax, accounting, dispute resolution, and chargeback defense purposes. Longer in jurisdictions that require it.
• Age representation records — at least four (4) years from the date of order, to align with applicable statutes of limitations.
• SMS/email consent records — at least five (5) years, exceeding the four-year TCPA statute of limitations, for defense against potential class-action claims.
• Customer support communications — at least two (2) years.
• Security and fraud logs — at least two (2) years.

We may retain information longer when required by law, when investigating ongoing fraud, or when needed for ongoing legal claims. When we no longer need information, we delete or de-identify it.

7. Communications and Your Marketing Choices

7.1 Transactional Messages

When you place an order, you will receive transactional SMS messages (order confirmation, status updates, pickup notification) and email messages (order receipt). These are necessary to deliver the service you requested. Standard message and data rates may apply for SMS. You may reply STOP to any SMS to opt out of transactional SMS, but you assume responsibility for tracking your order status through alternative means.

7.2 Marketing Messages

We will send you marketing communications only if you have separately opted in. Opt-in is never a condition of placing an order. If you opt in to marketing SMS, you can opt out by:

• Replying STOP to any marketing SMS
• Sending an email to hello@drinkupapp.com
• Adjusting your account preferences in the Platform

If you opt in to marketing email, you can opt out by clicking the unsubscribe link in any marketing email or by contacting us. Opt-out requests are processed within ten (10) business days, consistent with FCC rules.

7.3 Required SMS Opt-In Disclosure (TCPA)

At the point of marketing SMS opt-in, you will see a clear disclosure stating: (a) the identity of the sender (DrinkUp); (b) the categories of messages you will receive; (c) approximate message frequency; (d) that consent is not a condition of any purchase; (e) that message and data rates may apply; (f) how to opt out. We retain a record of your consent (including the disclosure language version you saw, the timestamp, and the affirmative action you took) as required by law.

8. Your Rights

Regardless of where you live, you have the following rights regarding the personal information we hold about you:

• Access — to request a copy of the personal information we hold about you.
• Correction — to ask us to correct information you believe is inaccurate.
• Deletion — to ask us to delete information about you, subject to exceptions for information we are required to retain (such as tax records, fraud records, and ongoing legal claims).
• Portability — to receive a copy of certain information in a portable, machine-readable format.
• Opt-out of marketing — to stop receiving marketing communications (transactional messages tied to your active orders may continue).
• Withdraw consent — where we process information based on your consent, to withdraw that consent at any time.
• Object to processing — to object to certain uses of your information.

To exercise these rights, email hello@drinkupapp.com or send written request to the address in Section 14. We will respond within 45 days, or as required by applicable law. We may need to verify your identity before fulfilling certain requests.

8.1 California Residents

If you are a California resident, the California Consumer Privacy Act (CCPA) gives you specific rights. The rights described in Section 8 above are substantively similar to CCPA rights. Submit requests through the same process. We do not sell or share personal information for cross-context behavioral advertising.

8.2 Other State Residents

Residents of states with comprehensive consumer privacy laws (Virginia, Colorado, Connecticut, Utah, Texas, and others) generally have rights similar to those described above. Submit requests through the same process.

9. Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access. These include:

• Encryption of personal information in transit (TLS) and at rest where appropriate;
• Access controls limiting employee and contractor access to a need-to-know basis;
• Use of Stripe for payment data, which is PCI-DSS certified;
• Routine security review of code, infrastructure, and third-party service providers;
• Logging and monitoring for suspicious activity.

No system is 100% secure. We cannot guarantee that information will not be subject to unauthorized access, and we expressly disclaim any such guarantee. If we ever experience a data breach involving Florida residents' personal information, we will notify affected individuals and the Florida Department of Legal Affairs as required by the Florida Information Protection Act (Fla. Stat. § 501.171).

10. Children's Privacy

The Platform is not directed to children, and we do not knowingly collect personal information from anyone under the age of 13. Under our Terms of Service, you must be at least 18 years of age to use the Platform at all, and at least 21 years of age to order any alcoholic beverage. If we become aware that we have collected information from a child under 13, we will delete it promptly. If you believe a child under 13 has provided information to us, contact hello@drinkupapp.com.

11. Third-Party Links and Services

The Platform may contain links to third-party websites or services (for example, Bar websites or social media pages). We are not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third party whose site you visit.

12. International Data Transfers

The Platform is operated in the United States and intended for users in the United States. If you access the Platform from outside the United States, you understand that your information will be transferred to, stored in, and processed in the United States, where data protection laws may differ from those in your country.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by updating the "Last Updated" date above and through an in-app banner and/or email to the address associated with your account. Continued use of the Platform after the effective date of changes constitutes acceptance.

14. Contact Us

For privacy-related questions, requests, or complaints:

Email: hello@drinkupapp.com
Mail: White Glove Integrated Solutions LLC d/b/a DrinkUp, 4718 Dunquin Place, Tampa, FL 33610

We aim to respond to all privacy requests within 45 days.

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