This Privacy Policy explains how Disco Beverage Inc. (“Hole in 1”, “we”, “us”) collects, uses, discloses and protects personal information when you visit sipaholeinone.com (the “Site”), contact us, sign up for our emails, enter a promotion, or ask us about stocking our product.
Hole in 1 is an alcoholic beverage brand. The Site is intended only for adults of legal drinking age. Please read our Terms of Use alongside this policy.
1. Scope of this policy
This policy covers the Site and the direct interactions listed above. It does not cover:
- Third-party retailers and ordering platforms. When you click an ordering link you leave our Site and enter a licensed retailer’s own environment. Their privacy policy governs what happens there, including payment and delivery data. We never receive your full payment card number.
- Social media platforms. Interactions on Instagram, TikTok, Facebook, YouTube and similar services are governed by those platforms’ policies, though we may receive aggregated insights about our audience.
- Our distributors and trade partners in their own dealings with you.
2. Personal information we collect
We collect only what we need. Depending on how you use the Site, that may include:
| Category | Examples | Why |
|---|---|---|
| Identifiers & contact data | Name, email address, phone number, mailing address, city, state, ZIP code | To answer your message, send emails you asked for, run promotions, and manage trade accounts |
| Age-verification signal | The fact that you confirmed you are of legal drinking age, and the date of that confirmation, stored locally in your browser | To comply with alcohol advertising rules and avoid asking you on every page |
| Commercial & professional data | Company or club name, job title, property type, licenses held, markets covered, approximate annual rounds | To evaluate and service course accounts, distributor and retail inquiries |
| Message content | Anything you type into a form or email us | To respond and to keep a record of the request |
| Device & usage data | IP address, approximate location derived from it, browser and device type, operating system, referring page, pages viewed, time on page, clicks, and similar analytics | To operate and secure the Site, understand what content works, and fix problems |
| Cookie & identifier data | Cookie IDs, local storage values, pixel and SDK identifiers | See Cookie Policy |
| Marketing preferences | Whether you opted in, which emails you opened, whether you unsubscribed | To respect your choices and improve what we send |
What we do not collect
- We do not ask for or store your date of birth at the age gate, only a yes-or-no confirmation.
- We do not process payments on this Site, so we do not collect card numbers, CVVs or bank details.
- We do not knowingly collect sensitive personal information such as government ID numbers, precise geolocation, health data, biometrics, or information about race, religion, union membership, sexual orientation or immigration status. Please do not send it to us.
- We do not knowingly collect personal information from anyone under 21. See section 13.
3. Where the information comes from
- Directly from you: forms, emails, phone calls, event sign-ups, trade conversations.
- Automatically from your device: cookies, pixels, server logs and analytics tools when you browse.
- From service providers: our website platform, email platform and analytics providers, acting on our behalf.
- From business partners: distributors, courses, event organizers and co-marketing partners who pass along an inquiry you made to them, and advertising platforms that report aggregated campaign results.
- From public and commercial sources: for trade contacts only, business directories and licensing records used to verify a company’s details.
4. How we use personal information
- To run the Site: serve pages, remember your age confirmation, keep things working and secure.
- To respond to you: answer questions, follow up on where-to-buy requests, chase a retailer or distributor on your behalf.
- To manage trade relationships: evaluate course, distributor and retail inquiries, open and service accounts, send trade packets and pricing.
- To send marketing you asked for: new markets, course programs, events and product news. You can unsubscribe at any time.
- To run promotions and events: administer entries, verify eligibility and age, and award prizes, subject to the rules of each promotion.
- To measure and improve: analytics on what people read, which markets generate demand, and how campaigns perform.
- To advertise responsibly: reach adults of legal drinking age and, where permitted and consented to, show relevant ads. See section 7.
- To comply with the law: alcohol marketing codes, age-verification obligations, tax and licensing requirements, and lawful requests from regulators or law enforcement.
- To protect people: detect and prevent fraud, abuse, spam and security incidents, and enforce our Terms.
5. Who we share personal information with
We do not sell personal information for money. We share it only as described here:
- Service providers (processors) who work on our instructions and are contractually limited to that purpose: website hosting and platform, email and SMS delivery, form and CRM tools, analytics, cloud storage, customer support and fulfilment coordination.
- Licensed distributors, retailers and courses: when you ask us to find or stock the product, we pass on what is needed to act on that request.
- Advertising and analytics partners: where you have consented to non-essential cookies, identifiers and usage data may be shared with these partners. Under some US state laws this counts as “sharing” for cross-context behavioural advertising or a “sale” even though no money changes hands. You can opt out via Your Privacy Choices.
- Professional advisers: lawyers, accountants, auditors and insurers, under duties of confidence.
- Regulators and authorities: where we are legally required, or to establish, exercise or defend legal claims.
- In a corporate transaction: if all or part of the business is sold, merged or reorganised, information may transfer to the successor, which will remain bound by a policy at least as protective.
- With your direction: anything else you explicitly ask us to do.
6. Cookies and similar technologies
We use cookies, local storage, pixels and similar technologies. Strictly necessary technologies (including the local-storage entry that remembers your age confirmation) are always on because the Site cannot work properly without them. Analytics and advertising technologies are used only where permitted, and where consent is required we ask for it first.
Full detail, including how to change your choices, is in our Cookie Policy.
Global Privacy Control
We honour the Global Privacy Control (GPC) signal. If your browser or extension sends GPC, we treat it as a valid request to opt out of sale and of sharing for cross-context behavioural advertising for that browser.
Do Not Track
There is still no common industry standard for responding to browser “Do Not Track” headers, so we do not respond to them. We do respond to GPC as described above.
7. Advertising and age-gating of ads
As an alcohol brand we are bound by legal requirements and industry codes on where and to whom we advertise. We instruct our advertising partners to direct our advertising only to audiences reasonably expected to be of legal drinking age, and we apply the age and placement controls those platforms provide.
Where we run interest-based advertising, it depends on cookies and identifiers set with your consent. To stop it, withdraw consent through Your Privacy Choices or use the industry tools at optout.aboutads.info and optout.networkadvertising.org.
8. How long we keep it
We keep personal information only as long as we need it for the purposes above, then delete or anonymise it. As a guide:
| Type | Typical retention |
|---|---|
| Age-confirmation signal in your browser | 30 days, then you are asked again |
| Contact-form and email correspondence | Up to 24 months after the matter closes |
| Marketing list membership | Until you unsubscribe, plus a suppression record kept indefinitely so we do not email you again |
| Trade and course account records | Duration of the relationship, plus 7 years for tax, licensing and audit |
| Promotion entries | As stated in that promotion’s rules; winner records as required by law |
| Analytics and log data | Generally up to 26 months, often less |
We may keep information longer where we must for legal, tax, regulatory or dispute-resolution reasons.
9. How we protect it
We use administrative, technical and physical safeguards appropriate to the risk: encryption in transit (HTTPS), access controls and least-privilege permissions, vetted vendors under written contracts, and staff training.
No method of transmission or storage is perfectly secure, and we cannot guarantee absolute security. Please do not send sensitive information through a web form. If we become aware of a breach affecting your personal information we will notify you and any regulator as required by law.
10. Your choices and rights
Regardless of where you live, you can always:
- Unsubscribe: use the link in any marketing email, or email privacy@sipaholeinone.com. Service and transactional messages may still reach you.
- Change cookie choices: via Your Privacy Choices or your browser settings.
- Ask us anything about your data: write to us and we will help, whether or not a statute requires it.
- Clear your age confirmation: clearing your browser’s site data for sipaholeinone.com removes it.
11. US state privacy rights
If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah or Virginia, you may have some or all of the following rights, depending on your state’s law:
- Know / access: what we collect, the categories of sources, the purposes, the categories of recipients, and a copy of the specific pieces we hold about you.
- Correct: inaccurate personal information.
- Delete: personal information we hold, subject to legal exceptions.
- Portability: a copy in a portable, readily usable format.
- Opt out of sale or sharing for targeted or cross-context behavioural advertising.
- Limit use of sensitive personal information: we do not collect it, so there is nothing to limit.
- Opt out of profiling in furtherance of decisions with legal or similarly significant effects. We do not do this.
- Non-discrimination: we will not deny you goods or services, charge different prices or give you a lesser experience for exercising a right.
- Appeal: if we decline a request, you may appeal by replying to our decision. We will respond within the period your state allows.
How to submit a request
Email privacy@sipaholeinone.com with the subject line “Privacy Request”, or use the form on Your Privacy Choices. We will verify your identity before acting, usually by confirming the email address we already hold, and for access or deletion requests by asking you to confirm two data points we already have. We do not create new accounts or ask for ID documents to verify a request.
We respond within 45 days and may extend once where permitted, telling you why. Verified requests are free unless they are excessive or repetitive.
Authorised agents
You may use an authorised agent. We will ask the agent for written, signed permission from you, and may ask you to confirm directly that you authorised the request.
California: notice at collection and shine the light
The categories in section 2, the purposes in section 4, the recipients in section 5 and the retention periods in section 8 together form our notice at collection under the CCPA as amended by the CPRA. We do not sell personal information for monetary consideration and we do not knowingly sell or share the personal information of consumers under 16. California residents may also request information under Civil Code § 1798.83 by writing to the address in section 17.
12. UK and EEA residents
If you are in the United Kingdom or the European Economic Area, the following also applies.
Legal bases
| Purpose | Legal basis |
|---|---|
| Answering your enquiry; managing a trade account | Contract, or legitimate interests in running our business |
| Marketing emails | Consent, withdrawable at any time |
| Non-essential cookies and advertising | Consent |
| Site operation, security and fraud prevention | Legitimate interests |
| Age verification and alcohol marketing compliance | Legal obligation and legitimate interests |
| Tax, accounting and licensing records | Legal obligation |
Your rights
You have the rights of access, rectification, erasure, restriction, portability and objection (including to processing based on legitimate interests and to direct marketing), and the right to withdraw consent at any time without affecting processing already carried out.
You may lodge a complaint with your supervisory authority. In the UK that is the Information Commissioner’s Office, ico.org.uk. We would appreciate the chance to resolve it first.
We do not carry out automated decision-making that produces legal effects concerning you.
13. Age restriction: no one under 21
The Site is intended only for adults of legal drinking age, which is 21 in the United States. We do not market to, and do not knowingly collect personal information from, anyone under 21.
If you believe a person under 21 has given us personal information, email privacy@sipaholeinone.com and we will delete it promptly. Parents and guardians can also use filtering tools such as Net Nanny or Qustodio. Our pages carry the RTA label so they can be recognised and blocked by such software.
14. International transfers
We operate in the United States and our service providers may process information there and in other countries. Where we transfer personal information out of the UK or EEA we rely on an appropriate safeguard, normally the European Commission’s Standard Contractual Clauses together with the UK Addendum, plus additional measures where needed. You can request a copy of the relevant safeguard by writing to us.
15. Third-party links and platforms
The Site links to third parties, including licensed retailers and ordering platforms, social media and industry resources. We do not control them and are not responsible for their content or privacy practices. Read their policies before giving them information.
16. Changes to this policy
We will update this policy when our practices or the law change. The “last updated” date at the top always reflects the current version. If a change is material we will give prominent notice on the Site and, where required, ask for your consent. Continuing to use the Site after an update means you accept the revised policy.
17. How to contact us
Privacy questions, requests or complaints:
- Email: privacy@sipaholeinone.com
- General: hello@sipaholeinone.com
- Company: Disco Beverage Inc., Attn: Privacy
Data controller: Disco Beverage Inc.
Related: Terms of Use · Cookie Policy · Your Privacy Choices · Responsible Drinking