Privacy Policy

This Policy applies to personal information that Oxto controls. A winery, tasting room, tour operator, event organizer, or other reservation provider (a "Host") may separately control information it receives from you or enters into Oxto. A Host's use of that information is also governed by the Host's own privacy practices.

When Oxto processes guest, employee, team-member, notification-recipient, or wine-club roster information solely to provide business tools to a Host, Oxto may act as a service provider or processor for that Host. Contact the Host first for a request concerning information the Host supplied, and we will assist where appropriate.

We collect information:

• Directly from you when you create an account, build a profile, search, plan, post, contact us, make a reservation, register for an event, or purchase a service.
• Automatically from your browser, device, and use of the Services.
• From Apple, Google, Stripe, and other services you use to sign in, pay, connect a business account, or interact with Oxto.
• From Hosts and business users that create manual reservations, upload club rosters, manage teams, invite partners, or provide guest information.
• From other users through referrals, public collections, shared itineraries, reviews, and similar features.
• From public sources, such as business websites, wine and trade association member directories, and business listing platforms, when we create or update winery, event, or experience information or identify businesses that may be interested in Oxto's business services. In some cases we may create a likely business email address from a business's publicly listed domain and a person's publicly listed name.
• From Meta when you submit an Oxto lead form on Facebook or Instagram.
• From advertising and analytics partners, such as Meta and Google, which may tell us that you clicked or viewed an Oxto ad or provide aggregated reports about ad performance.

• Provide, operate, secure, troubleshoot, and improve the Services.
• Create and authenticate accounts, maintain profiles, and provide support.
• Process reservation requests, bookings, event registrations, payments, refunds, subscriptions, check-ins, messages, reminders, confirmations, and calendar information.
• Share reservation information with the applicable Host and allow authorized Host personnel to manage the booking.
• Create taste profiles, personalized rankings, search results, recommendations, explanations, and itineraries.
• Recognize winery club members by matching email or normalized phone information against a winery-supplied roster.
• Link a Host-created reservation to an existing Oxto account using email or phone and, where appropriate, add a missing contact phone or alternate contact email to that account.
• Provide public profiles, reviews, shared collections, events, listings, referrals, and social features.
• Send transactional communications and, with applicable permission, marketing or Host updates.
• Measure audience, conversion, feature use, engagement, performance, and marketing attribution.
• Advertise Oxto on other websites and platforms, including Facebook and Instagram, which may include showing ads to people who visited our website, reaching businesses that may be interested in Oxto's business services, finding similar audiences, and measuring whether our ads work. See Section 7.
• Detect, investigate, and prevent fraud, abuse, security incidents, unlawful conduct, and violations of our terms.
• Comply with law, enforce agreements, resolve disputes, protect rights and safety, and complete business transactions.
• Create aggregated or deidentified information that cannot reasonably be linked to you and use it for lawful purposes.

Oxto's taste intelligence uses both information you state and information learned from how you use the Services. Signals may include wine and atmosphere preferences, budgets, saved and visited wineries, repeated profile views, searches, click-throughs, itinerary choices, skips, reservation activity, and regions you browse. Oxto uses these signals to rank candidates, identify similarities, infer likely interests or price sensitivity, and explain why a winery may fit.

Some search, winery-content, and trip-planning features send limited inputs to artificial-intelligence providers, including OpenAI and Anthropic. Depending on the feature, those inputs may include a search phrase, trip request, taste preferences, budget, saved or visited winery names, viewed winery names and counts, browsed regions, behavioral summaries, and factual winery information. The providers return embeddings, classifications, summaries, draft content, or personalized explanations.

AI output can be inaccurate. We use it for recommendations and content support, not for decisions that produce legal or similarly significant effects. We do not intend to infer health, religion, politics, sexual orientation, or other highly sensitive traits from your taste activity. Please do not put highly sensitive or confidential information in free-text fields.

You may edit profile preferences, remove saves or visits, delete eligible content, or contact us to object to or ask questions about personalization. Some recommendations may be less personalized as a result.

Oxto does not sell personal information for money.

Oxto does use some personal information for advertising, as described in Section 6 under Advertising Partners. When we disclose website activity, form-submission information, or business contact information to Meta so Meta can show Oxto ads to you or to people like you on Facebook and Instagram, that may be "sharing" for cross-context behavioral advertising under the California Consumer Privacy Act, "targeted advertising" under other state privacy laws, and, under some state definitions, a "sale."

In the preceding 12 months, the categories of personal information we have shared or may have shared for these purposes are: identifiers (such as hashed email address, hashed phone number, hashed name, IP address, and cookie identifiers); professional information (such as business city and state, and role or company for lead forms); and internet or other electronic network activity (such as pages viewed on our website and form submissions). We disclosed them to Meta Platforms, Inc.

We do not sell or share sensitive personal information, and we do not knowingly sell or share personal information of anyone under 21. We do not use reservation notes, allergy or accessibility details, payment information, precise location, or taste-profile information for advertising.

How to opt out. You can opt out of the sale or sharing of your personal information and of targeted advertising at any time:

• Visit Your Privacy Choices (also linked in our website footer) and submit an opt-out request. We will remove the email address you give us from business contact lists we provide to Meta and keep it off future lists.
• Turn on Global Privacy Control in a browser or extension that supports it. This stops the Meta Pixel and Meta website events in that browser. See Section 7A.
• Email legal@oxtoapp.com with the subject line "Do Not Sell or Share."

You do not need an account to opt out, and we will not ask you to verify your identity to opt out, although we may ask for your email address so we can apply your choice to our contact lists. We act on opt-out requests within 15 business days. After you opt out, you may still see ads for Oxto that are not based on information we shared, such as ads shown to everyone in a region.

Oxto honors the Global Privacy Control ("GPC") signal as a request to opt out of the sale or sharing of personal information and of targeted advertising for that browser. When our website detects GPC, we do not load the Meta Pixel and do not send website events, including form-submission lead events, to Meta. We apply GPC without requiring you to take any other step, and we do not ask you to confirm it. Because GPC is tied to your browser, it does not by itself remove your email address from business contact lists; to do that, submit a request on Your Privacy Choices.

If your GPC signal conflicts with a choice you made in your account or elsewhere with Oxto, we follow the GPC signal for opt-out purposes.

Some browsers offer a "Do Not Track" setting. There is no common standard for Do Not Track, so Oxto does not respond to it separately. We recommend using GPC instead.

• Use the unsubscribe link in marketing email to stop that sender's marketing messages.
• Manage Oxto notification preferences in the application where available.
• Change push permissions in your device settings.
• Do not select the optional Host-updates choice when making a reservation if you do not want Host marketing.
• Visit Your Privacy Choices to opt out of targeted advertising and the sharing of your information with advertising partners.
• Adjust ad settings in your Facebook or Instagram account, including Meta's ad preferences, to control ads you see there.

Even if you opt out of marketing, Oxto and Hosts may still send necessary messages about accounts, security, reservations, events, transactions, subscriptions, and support.

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy. The period depends on the type of information, whether your account is active, the sensitivity of the information, our relationship with a Host, and legal, tax, accounting, payment, fraud-prevention, safety, dispute, and enforcement needs.

Reservation, payment, event, subscription, business, and communication records may be retained after account deletion when needed to complete a transaction, preserve a Host's operational record, comply with law, resolve a dispute, prevent fraud, or establish legal rights. Public content may remain if you or another user shared it, although we may remove or deidentify the account association. Deletion from active systems may not immediately remove encrypted backups, provider records, or copies held by a Host.

We may retain aggregated or deidentified information for analytics and service improvement. We will not attempt to reidentify information we maintain as deidentified except to test whether deidentification is effective or as permitted by law.

If you opt out or ask us to delete your information, we may keep a minimal record of your request, such as your email address, so we can honor your choice and avoid adding you back to our contact or advertising lists.

You may initiate account deletion from the mobile application's account settings where available or contact legal@oxtoapp.com. Account deletion removes the authentication account, profile, and many directly associated records. Some records may be retained or deidentified as described in the Data Retention section.

You may also contact us to request access, correction, deletion, or a portable copy of eligible personal information, including business contact information we obtained from public sources. We may need to verify your identity and authority before completing a request. When we delete your information, we also remove it from contact lists we provide to advertising partners and ask those partners to delete it where their tools allow. If information was supplied and controlled by a Host, we may refer the request to that Host.

We use administrative, technical, and organizational safeguards designed to protect personal information, including encrypted network connections, authentication, access controls, database row-level security, restricted server credentials, and service-provider security measures.

No system is completely secure. You are responsible for protecting your device and account access and for notifying us if you suspect unauthorized use.

Depending on your state and whether a law applies to Oxto, you may have rights to:

• Confirm whether we process your personal information and access it.
• Correct inaccurate personal information.
• Delete personal information, subject to exceptions.
• Obtain a portable copy of certain information.
• Opt out of the sale or sharing of personal information, targeted advertising, or certain profiling. See Section 7 for how.
• Limit certain uses of sensitive personal information.
• Receive information about categories of information, sources, purposes, and recipients.
• Not receive unlawful discrimination for exercising a privacy right.

To opt out, use Your Privacy Choices or Global Privacy Control. For any other request, email legal@oxtoapp.com. These rights may also apply to information about you in your role at a business, depending on your state. You may use an authorized agent where permitted by law. If we deny your request, you may appeal by replying to our decision and writing "Privacy Appeal" in the subject line. You may also have the right to contact your state attorney general.

For California residents, the categories of personal information we may have collected in the preceding 12 months include identifiers; customer-record information; characteristics protected under law; commercial information; internet or other electronic-network activity; precise or approximate geolocation; audio, visual, and similar information; professional or employment-related information for business users and business prospects; sensitive personal information; and inferences.

We collect these categories from the sources in Section 3, use them for the purposes in Sections 4 and 5, and disclose them to the recipient categories in Section 6. We retain them under the criteria in Section 9. Sensitive personal information may include account credentials, precise geolocation when enabled, message contents, payment information processed by Stripe, age or date-of-birth information, and health or accessibility details you voluntarily place in a reservation note.

Oxto does not use or disclose sensitive personal information to infer characteristics beyond purposes permitted by California law. Oxto does not sell personal information for money. In the preceding 12 months, Oxto has shared, as the CCPA defines that term, the following categories of personal information with Meta Platforms, Inc. for cross-context behavioral advertising: identifiers; professional or employment-related information; and internet or other electronic-network activity. Section 7 describes these disclosures. Oxto does not knowingly sell or share personal information of people under 16, and the Services are intended only for people 21 or older.

California residents may exercise the rights described in Section 12, including rights to know, access, delete, correct, limit qualifying uses of sensitive personal information, opt out of sale or sharing, and receive equal service. To opt out of sale or sharing, use the "Your Privacy Choices" link in our website footer, which goes to our Do Not Sell or Share My Personal Information page, or turn on Global Privacy Control as described in Section 7A. These rights apply to California residents acting in a business capacity, including winery owners and staff whose business contact information we use.

Oxto is based in the United States, and personal information may be processed in the United States and other countries where our providers operate. Those countries may have different data-protection laws. Where required, we use appropriate transfer safeguards.

If European Economic Area, United Kingdom, or Swiss data-protection law applies, our legal bases may include performing a contract with you, our legitimate interests in providing and securing the Services, compliance with legal obligations, and consent where required. You may have rights to access, correct, erase, restrict, port, or object to processing, and to withdraw consent without affecting earlier lawful processing.

Oxto's personalization produces winery recommendations and does not make solely automated decisions with legal or similarly significant effects. You may contact us to object to qualifying profiling or request information about the personal data used for personalization. You may also lodge a complaint with your local data-protection authority.

The Services are intended only for people age 21 or older. We do not knowingly collect personal information from anyone under 21. If you believe a person under 21 has provided personal information, contact legal@oxtoapp.com so we can investigate and take appropriate action.

The Services may link to or interact with Host sites, social networks, maps, payment services, app stores, and other third parties. Their privacy policies govern their independent collection and use, including Meta's use of information collected through the Meta Pixel and Facebook and Instagram lead forms. Oxto is not responsible for a third party's privacy practices.

We may update this Policy to reflect changes in the Services, technology, law, or our practices. We will post the updated Policy and change the Effective Date. If a change materially expands how we use information already collected, we will provide additional notice or obtain consent where required rather than relying only on a silent policy change.

For privacy questions, rights requests, or complaints, contact:

Starr Road Ventures LLC, doing business as Oxto
legal@oxtoapp.com
oxtoapp.com