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 and business websites when we create or update winery, event, or experience information.

• 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.
• 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. As of the Effective Date, Oxto does not use personal information to target advertising to you based on activity across unaffiliated businesses and does not knowingly sell or share personal information as those terms are defined by the California Consumer Privacy Act.

We use analytics and performance services to understand and improve Oxto. Privacy laws can define "sale," "sharing," and "targeted advertising" differently. If our practices change or applicable law treats a use as a sale, sharing, or targeted advertising, we will provide required notices and opt-out methods.

• 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.

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.

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. We may need to verify your identity and authority before completing a request. 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 sale, targeted advertising, or certain profiling.
• 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.

Submit a request to legal@oxtoapp.com. 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; 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 has not knowingly sold or shared personal information, as defined by the CCPA, in the preceding 12 months. Oxto does not knowingly sell or share personal information of people under 16.

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. Because Oxto does not currently sell or share personal information, Oxto does not currently provide a "Do Not Sell or Share" link. We will recognize legally required browser-based preference signals if our practices become subject to an opt-out requirement.

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. 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