LANZERO DRINKS USA — PRIVACY POLICY

Effective Date: September 1, 2026
Last Updated: September 1, 2026

 

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1. Introduction and Scope

Lanzero LLC, a Delaware limited liability company doing business as Lanzero Drinks USA (“Lanzero,” “we,” “us,” or “our”), respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit www.drinklanzero.com (the “Site”), purchase our products, subscribe to our communications, or otherwise interact with us.

By using the Site, you acknowledge that you have read and understood this Privacy Policy.

State-specific and region-specific disclosures appear in the Appendices:

• Appendix A — Notice for California Residents (CCPA/CPRA)

• Appendix B — Notice for Residents of Other U.S. States

• Appendix C — Notice for Visitors from Outside the United States

Where an Appendix conflicts with the main body of this Policy, the Appendix controls for residents of that jurisdiction.

Contact: contact@drinklanzero.com (mark privacy requests “Attn: Privacy”)
Mailing address: Lanzero LLC d/b/a Lanzero Drinks USA, 1178 Broadway, 3rd Floor, #3630, New York, NY 10001

 

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2. Personal Information We Collect

We collect the following categories of personal information. Not every category applies to every individual.

2.1 Information you provide directly

• Identifiers and contact data — first and last name, email address, postal/billing address, shipping address, telephone number, and account credentials if you create an account.

• Order and transaction data — products purchased or considered, order history, order value, delivery preferences, gift messages, and returns or refund history.

• Payment data — payment card and billing details. Payments are processed by our payment processors. We do not store full payment card numbers on our systems; our processors handle and store that data under their own security obligations.

• Communications data — the content of emails, contact-form submissions, customer service inquiries, survey responses, reviews, and social media messages you send us.

• Marketing preferences — your subscription status and preferences for our email communications. We do not currently send marketing text messages.

• Age confirmation — where we ask you to confirm you meet a minimum age to access the Site or purchase products, we record that confirmation.

2.2 Information collected automatically

• Device and technical data — IP address, browser type and version, operating system, device identifiers, screen resolution, language settings, and time zone.

• Usage data — pages viewed, products viewed, time spent on pages, clicks, scroll behavior, referring URLs, search terms that brought you to the Site, exit pages, and date/time stamps.

• Approximate location — general geographic location inferred from your IP address. We do not collect precise GPS location.

• Cookie and identifier data — cookies, pixels, tags, web beacons, log files, and similar technologies as described in Section 6.

2.3 Information from third parties

• E-commerce and fulfillment platforms, including our online store provider, which supply order and account data.

• Analytics and advertising partners, which supply audience, campaign performance, and measurement data.

• Social media platforms, where you interact with our accounts or content.

• Retailers, distributors, and event partners, where you provide information to them in connection with Lanzero.

2.4 Sensitive personal information

We do not intentionally collect sensitive personal information as defined under California or other U.S. state privacy laws — such as government identifiers, precise geolocation, racial or ethnic origin, religious beliefs, health data, sexual orientation, or the contents of your communications where we are not a party.

To the limited extent we process account log-in credentials, we use them solely to authenticate you and to secure your account. We do not use or disclose any sensitive personal information for purposes that would trigger a right to limit its use under applicable law.

 

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3. How We Use Personal Information

We use personal information for the following business purposes:

• To fulfill orders — process transactions, verify payment, arrange shipping and delivery, issue invoices and confirmations, and handle returns, exchanges, and refunds.

• To operate accounts — create, maintain, and authenticate your account.

• To communicate with you — respond to inquiries, send transactional messages about your orders, and provide service notices.

• To send marketing — where permitted by law or where you have consented, send newsletters, product news, promotions, and event invitations. You may opt out at any time.

• To personalize your experience — remember preferences and tailor content and product recommendations.

• For advertising and measurement — deliver, target, and measure advertising for Lanzero on third-party platforms, and build audiences of individuals who may be interested in our products.

• For analytics and improvement — understand how the Site is used, develop new products, and improve the Site and our offerings.

• For security and fraud prevention — screen orders for fraud, detect and prevent malicious or illegal activity, debug errors, and protect the Site and our users.

• For legal and compliance purposes — comply with applicable law, respond to lawful requests from public authorities, enforce our terms, and establish, exercise, or defend legal claims.

• For corporate transactions — evaluate or complete a merger, acquisition, financing, reorganization, or sale of assets.

We will not use your personal information for a materially different, unrelated, or incompatible purpose without providing you notice.

 

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4. How We Disclose Personal Information

We disclose personal information to the following categories of recipients:

• Service providers and processors — including e-commerce platform providers, payment processors, shipping and fulfillment partners, email marketing platforms, customer service tools, hosting providers, and analytics providers. These parties are contractually restricted from using your personal information for any purpose other than performing services for us.

• Advertising and analytics partners — including social media platforms, search and display advertising networks, and measurement partners. Some of these disclosures constitute a “sale” or “sharing” under U.S. state privacy laws. See Section 5.

• Retail, distribution, and event partners — where relevant to a purchase, promotion, or event you participate in.

• Professional advisors — attorneys, accountants, auditors, and insurers, subject to confidentiality obligations.

• Corporate transaction counterparties — in connection with a merger, acquisition, financing, bankruptcy, reorganization, or sale of all or part of our business.

• Government authorities and other parties where required — to comply with applicable law, a subpoena, search warrant, court order, or other lawful request; to protect our rights, property, or safety, or that of our users or the public.

We do not disclose personal information to third parties for their own independent direct marketing purposes without your consent, other than as described in Section 5.

 

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5. Sale, Sharing, and Targeted Advertising

5.1 What we do

We use cookies, pixels, and similar technologies from advertising and analytics companies on the Site. Through these technologies, those companies may receive information about your device and your activity on the Site, including identifiers, browsing activity, and products viewed or purchased.

Under the California Consumer Privacy Act, as amended, and comparable laws in other states, these disclosures may constitute a “sale” of personal information or “sharing” for cross-context behavioral advertising, and constitute “targeted advertising” under other state laws — even though we receive no money in exchange.

We therefore state clearly: we sell and share personal information for advertising purposes, as those terms are defined by applicable state privacy law.

The categories of personal information sold or shared are identifiers, internet or network activity, commercial information, coarse geolocation derived from IP address, and inferences. The categories of recipients are advertising networks, social media platforms, and analytics providers.

We do not sell or share the personal information of consumers we actually know are under 16 years of age.

5.2 How to opt out

You may opt out of the sale and sharing of your personal information and of targeted advertising by any of the following methods:

• Using the “Your Privacy Choices” link available in the footer of every page of the Site.

• Enabling an opt-out preference signal, such as the Global Privacy Control (GPC), in your browser or extension. We honor GPC signals. Because a GPC signal is tied to the specific browser and device you use, you should enable it on each browser and device you use.

• Emailing contact@drinklanzero.com with “Attn: Privacy — Opt Out” in the subject line.

• Adjusting your cookie preferences through the cookie banner or preference center on the Site.

You may also use industry opt-out tools, though these are operated by third parties and we do not control them:

• Digital Advertising Alliance: http://optout.aboutads.info/

• Network Advertising Initiative: http://optout.networkadvertising.org/

• Facebook/Meta ad settings: https://www.facebook.com/settings/?tab=ads

• Google ad settings: https://adssettings.google.com/

• Google Analytics opt-out: https://tools.google.com/dlpage/gaoptout

You do not need to create an account with us to exercise your opt-out rights, and we will not require you to do so.

6. Cookies and Similar Technologies

The Site currently runs our e-commerce platform (Shopify), Google Analytics, and the Meta advertising pixel. We use the following technologies:

• Cookies — small data files placed on your device, often containing a unique identifier. Strictly necessary cookies enable core Site functionality such as your shopping cart and cannot be disabled. Analytics, functional, and advertising cookies require your consent where the law requires it.

• Log files — records of actions on the Site, including IP address, browser type, internet service provider, referring and exit pages, and date/time stamps.

• Web beacons, tags, and pixels — electronic files used to record how you browse the Site and whether you open our emails.

You can control cookies through the preference center on the Site and through your browser settings. Disabling certain cookies may affect Site functionality. For general information about cookies, see http://www.allaboutcookies.org.

 

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7. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law.

Our retention criteria are as follows:

• Order and transaction records — retained for seven (7) years following the transaction, to satisfy tax, accounting, warranty, and audit obligations.

• Account information — retained for the life of your account and for three (3) years after account closure.

• Marketing contact data — retained until you unsubscribe. Thereafter we retain the minimum data necessary to honor your opt-out, on a suppression list, for as long as we conduct email marketing.

• Website analytics and advertising data — retained for twenty-six (26) months, consistent with the retention settings configured on the relevant platform.

• Customer service correspondence — retained for three (3) years from the date of last contact.

Where information is no longer needed, we delete it or irreversibly deidentify it.

 

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8. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These include encryption in transit, access controls, and reliance on reputable third-party platforms for payment processing and hosting.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of any account credentials.

 

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9. Children’s Privacy

The Site is intended for a general adult audience (+21). We do not knowingly collect personal information from children under 16, and we do not knowingly sell or share the personal information of anyone under 16.

If you believe a child has provided us with personal information, please email contact@drinklanzero.com with “Attn: Privacy” in the subject line and we will take steps to delete it.

 

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10. International Data Transfers

Lanzero is based in the United States. We sell and ship our products only within the United States, and the Site is directed to a United States audience. Our service providers operate in the United States and in other countries.

If you access the Site from outside the United States, your personal information will be transferred to, stored in, and processed in the United States, whose data protection laws may differ from those of your country. See Appendix C.

 

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11. Third-Party Sites

The Site may contain links to third-party websites, plug-ins, and applications. We do not control those third parties and are not responsible for their privacy practices. We encourage you to review the privacy policy of every site you visit.

 

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12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for operational, legal, or regulatory reasons. We will post the updated Policy on the Site and revise the “Last Updated” date above. Where changes are material, we will provide additional notice, such as by email or a prominent Site notice.

 

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13. Contact Us

Questions, requests, or complaints regarding this Policy or our privacy practices:

Email: contact@drinklanzero.com, with “Attn: Privacy” in the subject line
Mail: Lanzero LLC d/b/a Lanzero Drinks USA, 1178 Broadway, 3rd Floor, #3630, New York, NY 10001

APPENDIX A — NOTICE FOR CALIFORNIA RESIDENTS

Effective Date: September 1, 2026

This Notice supplements the Privacy Policy above and applies solely to visitors, users, and others who reside in the State of California (“you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (together, the “CCPA”). Terms defined in the CCPA have the same meaning when used here.

A.1 Categories of Personal Information Collected

The Site launched recently and Lanzero has not yet processed consumer orders. The table below therefore describes the categories of personal information we collect through the Site today, together with those we will collect once sales begin. Categories not yet collected are identified as such, and this Notice will be updated as our practices develop.

Personal information does not include publicly available information from government records, deidentified or aggregated consumer information, or information excluded from the CCPA’s scope — including health information covered by HIPAA or the CMIA, clinical trial data, and information covered by the FCRA, GLBA, FIPA, or the Driver’s Privacy Protection Act of 1994.

A.2 Sources, Purposes, and Recipients

Sources of collection are described in Section 2 of the Privacy Policy. Business and commercial purposes for collection are described in Section 3. Categories of third parties to whom we disclose personal information are described in Section 4.

We disclose Categories A, D, F, G, and K for the business purposes described above, and we sell or share Categories A, D, F, G, and K as described in Section 5. Category B will be disclosed to payment and fulfillment providers once orders begin. We have not sold or shared Category B.

A.3 Retention

We retain each category of personal information according to the criteria set out in Section 7 of the Privacy Policy.

A.4 Your California Rights

Subject to verification and to statutory exceptions, you have the right to:

• Know and access — request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, our business or commercial purposes, and the categories of third parties to whom we disclose it.

• Delete — request that we delete personal information we collected from you and retained.

• Correct — request that we correct inaccurate personal information we maintain about you.

• Opt out of sale and sharing — direct us not to sell or share your personal information for cross-context behavioral advertising, as described in Section 5.2.

• Limit use of sensitive personal information — we do not use or disclose sensitive personal information for purposes that trigger this right, so no separate limitation mechanism is required.

• Data portability — receive the personal information you provided to us in a readily usable format that allows transmission to another entity without hindrance.

• Non-discrimination — not receive discriminatory treatment for exercising any of these rights.

A.5 How to Exercise Your Rights

Submit a verifiable consumer request by either:

• Emailing contact@drinklanzero.com with “Attn: Privacy” in the subject line; or

• Submitting a request through the “Your Privacy Choices” link in the Site footer.

Lanzero operates exclusively online and has a direct relationship with the consumers from whom it collects personal information. In accordance with Cal. Civ. Code § 1798.130(a)(1)(A), we therefore provide an email address for submitting requests in lieu of a toll-free telephone number.

Only you, or an agent legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a request on behalf of your minor child. An authorized agent must submit written proof of authorization, and we may require you to verify your own identity directly with us.

You may make a verifiable request for access or data portability no more than twice within a 12-month period. Your request must provide sufficient information for us to reasonably verify that you are the person about whom we collected personal information, and must describe your request with enough detail for us to evaluate and respond to it. We cannot respond or provide personal information if we cannot verify your identity or authority.

We will use personal information provided in a request solely to verify the requestor’s identity and authority and to process the request.

A.6 Responding to Requests

We confirm receipt of requests within ten (10) business days and respond to verifiable consumer requests within forty-five (45) days of receipt. If we require additional time, we will inform you in writing of the reason and the extension period, which may be up to an additional forty-five (45) days.

We deliver responses electronically or by mail, at your option. Disclosures cover the twelve (12) month period preceding receipt of the request, unless you request a longer period and providing it would not be impossible or involve disproportionate effort. Our response will explain the reasons we cannot comply with a request, where applicable.

We do not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine a fee is warranted, we will explain the basis and provide a cost estimate before completing the request.

A.7 Grounds for Denying a Deletion Request

We may deny a deletion request where retaining the information is necessary for us or our service providers to:

• Complete the transaction for which the personal information was collected, provide a good or service you requested, take actions reasonably anticipated within the context of our ongoing business relationship, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you;

• Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible;

• Debug products to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another consumer to exercise free speech, or exercise another right provided by law;

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to applicable ethics and privacy laws, where deletion would likely render the research impossible or seriously impair it, and where you previously provided informed consent;

• Enable solely internal uses reasonably aligned with consumer expectations based on your relationship with us;

• Comply with a legal obligation; or

• Make other internal and lawful uses of the information compatible with the context in which you provided it.

A.8 Minors

We do not sell or share the personal information of consumers we actually know are under 16 years of age without affirmative authorization — from the consumer directly if they are at least 13 but under 16, or from a parent or guardian if the consumer is under 13. Consumers who opt in may opt out of future sales or sharing at any time.

A.9 Non-Discrimination

We will not discriminate against you for exercising your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services; charge different prices or rates, including through discounts, benefits, or penalties; provide a different level or quality of goods or services; or suggest that you will receive any of the foregoing.

We may offer financial incentives permitted by the CCPA that result in different prices, rates, or quality levels. Any such incentive will reasonably relate to the value of your personal information and will be governed by written terms describing the program’s material aspects. Participation requires prior opt-in consent, which you may revoke at any time.

A.10 “Shine the Light”

California Civil Code § 1798.83 permits California residents to request, once per calendar year and free of charge, information about the categories of personal information (if any) we disclosed to third parties for their direct marketing purposes, and the names and addresses of those third parties. To make such a request, email contact@drinklanzero.com with “Attn: Shine the Light” in the subject line.

A.11 Removal of Content Posted by Minors

If you are under 18, reside in California, and have a registered account with the Site, you may request removal of content you publicly posted on the Site. Email contact@drinklanzero.com with “Attn: Privacy” in the subject line, including the email address associated with your account and a statement that you reside in California. We will ensure the content is not publicly displayed, though it may not be completely removed from all systems.

APPENDIX B — NOTICE FOR RESIDENTS OF OTHER U.S. STATES

This Appendix applies to residents of states with comprehensive consumer privacy laws in effect, including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Minnesota, Maryland, Tennessee, Indiana, Kentucky, and Rhode Island. Rights vary by state; we honor the rights available to you under your state’s law.

B.1 Your Rights

Subject to verification and to statutory exceptions, you may have the right to:

• Confirm whether we process your personal data and access that data.

• Correct inaccuracies in your personal data.

• Delete personal data you provided or that we obtained about you.

• Obtain a portable copy of your personal data in a readily usable format.

• Opt out of the processing of your personal data for targeted advertising, the sale of personal data, and profiling in furtherance of decisions producing legal or similarly significant effects. We do not engage in such profiling.

• Opt out of the processing of sensitive data, or to withhold consent for it. We do not process sensitive data.

We honor universal opt-out mechanisms, including the Global Privacy Control, in states where recognition of such signals is required.

B.2 How to Exercise Your Rights

Submit a request by emailing contact@drinklanzero.com with “Attn: Privacy” in the subject line, or through the “Your Privacy Choices” link in the Site footer.

We respond within forty-five (45) days of receipt and may extend that period by an additional forty-five (45) days where reasonably necessary, with notice to you.

B.3 Appeals

If we decline to act on your request, you may appeal our decision within a reasonable period by emailing contact@drinklanzero.com with “Attn: Privacy Appeal” in the subject line. We will respond in writing within sixty (60) days, setting out the reasons for our decision.

If your appeal is denied, you may contact your state Attorney General to submit a complaint. Contact details are available on the website of your state Attorney General’s office.

B.4 Nevada

Nevada residents may submit a verified request directing us not to sell certain covered personal information. Email contact@drinklanzero.com with “Attn: Nevada Do Not Sell” in the subject line.

APPENDIX C — NOTICE FOR VISITORS FROM OUTSIDE THE UNITED STATES

Lanzero sells and ships its products exclusively within the United States. We do not offer goods or services to individuals in the European Economic Area, the United Kingdom, or Switzerland, we do not price or present the Site in the currencies or languages of those markets, and we do not direct our marketing to them.

The Site is nevertheless reachable from anywhere in the world. If you visit the Site from outside the United States, please note:

• Your personal information will be transferred to and processed in the United States.

• We do not knowingly target advertising to individuals located in the European Economic Area, the United Kingdom, or Switzerland.

• Regardless of where you are located, you may email contact@drinklanzero.com, marking your message “Attn: Privacy”, to request access to, correction of, or deletion of personal information we hold about you, or to ask us to stop sending you marketing. We will honor reasonable requests of this kind as a matter of practice.

If Lanzero begins offering products to customers in the European Economic Area or the United Kingdom, or begins directing marketing to those markets, this Policy will be updated with the additional disclosures the General Data Protection Regulation and the UK GDPR require, including legal bases for processing, transfer safeguards, and the appointment of a representative where applicable.

 

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IMPLEMENTATION CHECKLIST

The following items must be completed before this Policy is published. They are not legal drafting questions but factual and technical ones.

• Add a persistent “Your Privacy Choices” link in the footer of every page of the Site, linking to a functioning opt-out mechanism.

• Configure the site to detect and honor the Global Privacy Control signal.

• Deploy a cookie banner and preference center capable of blocking non-essential cookies, and confirm that the choices it offers actually take effect.

• Add a “Notice at Collection” at or before each point where personal information is collected, listing the categories collected, the purposes, whether they are sold or shared, and the retention period, with a link to this Policy.

• Set Google Analytics 4 data retention to 26 months (Admin → Data Settings → Data Retention). The default is 14 months, and this Policy now promises 26.

• Re-scan the live Site before launch and confirm no tracker is running that this Policy does not disclose. Shopify apps frequently install pixels of their own.

• Execute data processing agreements with each service provider, containing the CCPA service provider restrictions.

• Verify that Sections 2.4 and A.1 remain accurate — if any sensitive personal information is in fact collected, a “Limit the Use of My Sensitive Personal Information” mechanism becomes mandatory.

• Revisit this Policy if any of the following change: launching SMS marketing, shipping to the EU or UK, adding a loyalty or referral program, or adding a new tracking vendor.

• Confirm the assumed-name filings for “Lanzero Drinks USA” are on record, and that the LLC is authorized to do business in New York, before relying on the name in customer-facing contracts.

• Set the payment descriptor that appears on customer card statements to a name they will recognize, and make sure it matches the name used at checkout.

• Set up a filter or label on contact@drinklanzero.com that catches “Attn: Privacy” and routes it somewhere it will not be missed. Privacy requests now arrive in the same inbox as general mail, and the response deadlines are legally binding.

• Establish an internal process to log requests, meet response deadlines, and handle appeals.