PRIVACY POLICY
Last updated: February 2, 2026
As the owner of the Cîroc Vodka Athletic Club (“CVAC”) brand, First Round Collective LLC (the “Company”, “we”, “our” or “us”) is committed to protecting your privacy through our compliance with this Privacy Policy. This policy explains how we collect, process, retain and disclose personal data about you when you visit our websites, join our club, visit our social media or engage with other platforms or means that link to this policy (our “Services”).
This Privacy Policy applies only to information we collect:
Through the Services
In communications, including email, text, chat, and other electronic messages, between you and the Services.
When you interact with our advertising and applications (including mobile apps) on third-party websites and services, if those applications or advertising include links to this policy.
It does not apply to information collected by:
Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries) that does not link to this policy; or
Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Services.
Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates.
1. Children’s and Minors’ Data
Our website and Services are not intended for individuals under the age of 21. We do not knowingly collect information from anyone under 21. If we become aware that we have collected or received personal data from an individual under 21 years old, we will delete that information.
2. What information do we collect and why?
“Personal data” is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, or payment information (for example, account information such as name, postal address, and email address, any other identifier we may use to contact you online or offline).
The types and categories of personal data we collect or process include:
Identifiers: Name, date of birth (required for age verification), email address, telephone number, physical billing/shipping addresses, and other contact information you provide us.
Commercial Information: Records of products purchased, consumption preferences, and shopping history.
Demographic Information: Age, gender, if you consented to such information collection.
Location information: general geographic location such as country, state or province, or city.
Device Information: IP address, browser type and settings, device identifiers, operating system and version, preferred language, hardware identifiers, “cookie” data and other device information.
Miscellaneous: Content and information you elect to provide as part of your profile or in any reviews you make through the Services or emails, chats, or other communications sent to us.
If you are a California resident, to access our supplemental California privacy statement, refer here.
We also collect:
Statistics or aggregated information: Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Services feature.
Technical information: Technical information includes information about your internet connection and usage details about your interactions with the Services, such as clickstream information to, through, and from our Services (including date and time), products that you view or search for; page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page.
If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.
3. How We Collect Your Personal and Other Data
You provide information to us: We collect information about you when you interact with our Services, such as when you complete the age verification process, become a member, create or update your account, subscribe, participate in surveys, sweepstakes, contests, or promotions.
Automatically through our Services: As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies, web beacons, and other tracking technologies including details of your interactions with our Services, such as traffic data, location data, logs, and other communication data, and which resources and Services features that you access and use. We may use these automatic collection technologies to collect information about your online activities over time and across third-party sites or other online services (behavioral tracking). The technologies we use for this automatic data collection may include:
Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services.
Web Beacons. Some parts of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those parts or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).
To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling, under applicable laws, depending on where you live, you may opt out from use of these automated technologies for such uses by contacting us at ciroc@firstroundcollective.com. Please note that some Services features may be unavailable as a result.
When you interact with the Services, there are third parties that may use automatic collection technologies to collect information about your or your device. These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
These third parties may include:
Analytics companies.
Your device manufacturer.
Your internet or mobile service provider.
Customer relationship management companies.
Website building and hosting companies.
Email platform providers.
From business partners and service providers: We may receive personal data about you from other sources and combine that with information we collect directly from you. For example, we may obtain information about you from service providers that we engage to perform services on our behalf, such as email platform providers, content delivery services, promotions services, and analytics, security and anti-fraud services. We also may receive personal data from business partners that we engage to share consumer information with us, including your personal preferences and demographic information such as age and gender so that we can better provide you with a personalized experience.
4. How We Use Your Information
We use information that we collect about you or that you provide to us, including your personal data to:
Provide you with the Services and any contents, features, information, products, or services that we make available through the Services.
Fulfill and manage your membership.
Fulfill any other purpose for which you provide it.
Provide you with notices about your membership and account.
Verify that all users are over the age of 21 years old in compliance with U.S. law.
Sending updates on “Club Drops”, events, and exclusive offers.
Improve our Services, including by analyzing your information and creating aggregated data derived from your information) to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them.
To personalize website experiences and to deliver content and product and service offerings relevant to customer interests, including targeted offers through our website, third-party sites, and via email or text messages (with consent, where required by law).
Promote our Services, business, and offerings by publishing advertising on our own Services and by placing ads on third parties’ services. We may use your information to model, segment, target, offer, market, and advertise our Services.
Tailoring our Services and advertisements to your interests.
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
Detecting and preventing fraudulent transactions or security breaches.
Notify you when Services updates are available and about changes to any products or services we offer or provide through them.
In any other way we may describe when you provide the information.
For any other purpose with your consent.
The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to:
Estimate our audience sizes and usage patterns.
Store information about your preferences, allowing us to customize the Services according to your individual needs and interests.
Speed up your searches.
Recognize you when you return to our Services.
We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile or contact us at ciroc@firstroundcollective.com. For more information, see Your Rights and Choices About Your Information..
We use location information we collect to ensure you reside in the United States and to provide you with relevant targeted advertising.
5. Who We Disclose Your Information To
We do not sell your personal information. However, we allow trusted partners to collect some of your data so they can provide you targeted advertising based on your interactions with us and others online. Under some U.S. state laws (like California), sharing information for targeted advertising may be considered a “sale” or “sharing.” We may disclose aggregated information about our users without restriction. We may also disclose personal data that we collect or you provide as described in this privacy policy:
To our subsidiaries and affiliates, such as Diageo and its subsidiaries.
To contractors, service providers, and other third parties we use to support our organization, such as: email platforms and website hosting companies such as SquareSpace.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or direct or indirect transfer of some or all of First Round Collective LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by First Round Collective LLC is among the assets transferred.
To third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see Your Rights and Choices About Your Information.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.
We may also disclose your personal data:
To comply with any court order, law, or legal process, including to respond to any government or regulatory request such as to comply with alcohol beverage control regulations.
To enforce or apply our terms of use and other agreements.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our customers, members, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
The categories of personal data we may disclose include:
Account and contact information.
Account history, including information about your subscription, account, membership, or transactions.
Demographic information.
Location information, including general geographic location.
Device information.
Content and information you elect to provide to us.
6. Your State Privacy Rights.
Depending on your state of residency, you may have certain rights related to your personal data, including:
Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information's nature and processing purpose.
Deletion. You may request that we delete personal data about you that we maintain, subject to certain exception under applicable law.
Opt Out of Using Personal Data for Targeted Advertising, Profiling, and Sales. You may request that we do not use your personal data for these purposes.
Important: The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request.
To exercise any of these rights, please email us at ciroc@firstroundcollective.com with the subject line “Privacy Rights Request.” To appeal a decision regarding a consumer rights request, please email us at ciroc@firstroundcollective.com and include sufficient information for us to identify your original request and the basis for your appeal. We will respond to your appeal in writing within the timeframe required by applicable law. If your appeal is denied, our response will include a written explanation of the reasons for the denial and, where required by law, information on how you may submit a complaint to the appropriate state regulator or attorney general.
Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data “sales” as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.
Nevada provides its residents with a limited right to opt out of certain personal data sales. Residents who wish to exercise their sale opt-out rights may submit a request to this designated address: ciroc@firstroundcollective.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.
If you are a California resident, additional information applies to you. To access our supplemental California privacy statement and learn more about California residents’ privacy rights, click here.
7. How We Protect Your Personal Data.
We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.
The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.
8. How We Retain Your Personal Data.
We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations (including U.S. tax and alcohol distribution laws), resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.
9. International Transfers.
This website and our Services are intended to apply solely to individuals who reside in the United States and to personal information collected in the United States. If you access our Services from outside the United States, please be aware that your information will be transferred to, processed and stored in the United States, where data protection laws may differ from those in your home country. By accessing this website or using our Services outside the United States, you acknowledge and consent to the transfer and processing of your information in the United States.
10. Changes to Our Privacy Policy.
We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the “last updated” date and posting the updated policy on the Services. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.
11. Contact Us.
To exercise your rights or ask questions or comment regarding this policy or our privacy practices, please contact: Cîroc Vodka Athletic Club Email: ciroc@firstroundcollective.com Address: First Round Collective LLC, 181 Chrystie Street, New York, New York 10002.
SUPPLEMENTAL CALIFORNIA PRIVACY NOTICE
Effective Date: February 2, 2026
Last Updated: February 2, 2026
This Supplemental California Privacy Notice (“Notice”) applies solely to California residents and supplements the Cîroc Vodka Athletic Club Privacy Policy (“General Privacy Policy”). It provides additional information required by the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). Capitalized terms not defined here have the meanings given in the CCPA/CPRA or the General Privacy Policy.
For details on the categories of personal information we collect, sources, purposes of use, and disclosures (including to service providers and affiliates), please refer to the General Privacy Policy.
Your Rights and Choices
If you are a California resident, the CCPA grants you the following rights regarding your personal information:
Right to Know and Data Portability Requests
You have the right to request that we disclose certain information to you about our collection and use of your personal information (the “right to know”), including the specific pieces of personal information we have collected about you (a “data portability request”). You may exercise your right to know twice in any 12-month period. Once we receive your request and confirm your identity (see How to Exercise Your Rights), we will disclose to you:
The categories of:
personal information we collected about you; and
sources from which we collected your personal information.
The business or commercial purpose for collecting your personal information and, if applicable, selling or sharing your personal information.
If applicable, the categories of persons, including third parties, to whom we disclosed your personal information, including separate disclosures identifying the categories of your personal information that we:
disclosed for a business purpose to each category of persons; and
sold or shared to each category of third parties.
When your right to know submission includes a data portability request, a copy of your personal information, subject to any permitted redactions.
Right to Delete and Right to Correct
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions and limitations (the “right to delete”). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it. We will also notify our service providers, contractors, and other recipients to take appropriate action.
You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the “right to correct”). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers, contractors, and other recipients to take appropriate action.
Right to Limit Sensitive Personal Information Use and Disclosure to Permitted SPI Purposes
You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA’s Permitted SPI Purposes (the “right to limit”). As we do not use or disclose sensitive personal information beyond the CCPA’s Permitted SPI Purposes (e.g., we do not use it to infer characteristics about you), we do not currently provide this consumer right.
Personal Information Sales or Sharing Opt-Out and Opt-In Rights
You have the right to request that businesses stop selling or sharing your personal information at any time (the “right to opt-out”), including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer’s parent or guardian for consumers under age 13 (the “right to opt-in”).
As we do not sell consumers’ personal data, we do not provide sales opt-out rights. However, we may share personal information for cross-context behavioral advertising, so we provide opt-out rights for sharing. Your opt-out will be specific to the web browser or device you use at the time you exercise your opt-out rights; if you use multiple web browsers or devices, you will need to opt-out from each browser and device. Opting out of the sale of your information for interest-based advertising purposes does not mean you will stop seeing ads, including interest-based ads, and your information that was collected prior to 90 days before your opt-out request may be further used for interest-based advertising purposes.
Right to Non-Discrimination
You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.
How to Exercise Your Rights
Exercising the Rights to Know, Delete, or Correct
To exercise the right to know (including data portability), delete, or correct described above, please submit a verifiable request to us by emailing us at ciroc@firstroundcollective.com with the subject line “Privacy Rights Request.”
Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to it. You or your authorized agent may only submit a request to know, including for data portability, twice in a 12-month period.
Verification Process and Authorized Agents
Only you, or someone legally authorized to act on your behalf, may make a request to know, delete, or correct related to your personal information. We may request specific information from you or your authorized representative to confirm your or their identity before we can process your right to know, delete, or correct your personal information.
We cannot respond to your request to know, delete, or correct if we cannot verify your identity or authority to make the request and confirm the personal information relating to you. We will only use personal information provided in the request to verify the requestor’s identity or authority to make the request.
For requests to opt-out, we ask for the information necessary to complete the request, which may include, for example, the consumer’s name, email address, or account username.
Responding to Your Requests to Know, Delete, or Correct
We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please contact ciroc@firstroundcollective.com.
We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to your verified email address. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, deleted, or made your personal information anonymous in compliance with our record retention policies and obligations.
Any disclosures we provide will cover information for the 12-month period preceding the request’s receipt date. We will consider requests to provide a longer disclosure period, unless providing the longer timeframe would be impossible or involves disproportionate effort.
For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
Response and Timing on Rights to Opt-Out
In response to your request to opt-out, we will process your request, as soon as feasibly possible, but no later than 15 business days from the date we receive the request. We will also notify our service providers, contractors, and certain other downstream recipients of your request to opt-out and instruct them to both:
Comply with your request.
Forward the request to their own downstream recipients, if applicable.
We may deny opt-out requests if we have a good-faith, reasonable, and documented belief that the request is fraudulent and will clearly explain our denial decision to the requestor.
Once you make a request to opt-out, we will wait at least 12 months before asking you to reauthorize personal information sharing. However, you may change your mind and opt back in at any time by contacting us at ciroc@firstroundcollective.com.
Privacy Policy Changes
We reserve the right to update this Supplemental California Privacy Statement at any time. If we make any material changes, we will update the effective date and post the updated statement on our Services. We encourage you to check our Services to review the current statement in effect.
Contact Information
If you have any questions or comments about this Supplemental California Privacy Notice, the ways in which we collect and use your information described here or in our general Privacy Policy, or your choices and rights regarding such use, please do not hesitate to contact us at:
Email: ciroc@firstroundcollective.com
Postal Address:
First Round Collective LLC
Attn: Privacy Department
181 Chrystie Street
New York, New York 10002
If you need to access this Supplemental California Privacy Statement in an alternative format due to a disability, please contact ciroc@firstroundcollective.com.