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Privacy Policy

Privacy policy



This Privacy Policy was last updated on September, 18th 2023.


Raymond Thomas Holding, Inc. (“we”, “us” or “Martingale Cognac”) has created this privacy policy statement (the “Privacy Policy”) in order to demonstrate our firm commitment to your privacy. The following describes how we collect, use, and disclose your personal information when you visit, use our services or purchase our products on  (the “Site”), or otherwise communicate with us (collectively, the “Services”).  For the purposes of this Privacy Policy, “you” and “your” mean you as the user of the Site, whether you are a customer, website visitor, or another individual whose information we have collected pursuant to this Privacy Policy. 

Please read this Privacy Policy carefully. By using or accessing the Site and any of the Services, you signify your assent to our Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access any of the Services.

  1. Personal and Non-Personal Information We Collect:

Information You Provide:  When using the Site, in order to utilize some of our Services, you may choose to upload, or we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Information”). Personally identifiable information may include, but is not limited to:

  • First name & last name
  • Email address
  • Username
  • “Usage Data,” which is data collected automatically, generated by either the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit). 

We collect Personal Information from you when you choose to participate in our offers and programs or when you otherwise provide information directly to us, including when you register with us, review products, participate in our interactive features or otherwise interact with us on the Site. 

If you are under 21 years of age, please do not use the Site. If you are under 21, you are not permitted to use our Site and should not provide any Personal Information to us. If you are under 21 years of age and believe we have collected your personal information or are the parent or guardian of a person under 21 years of age with an account or information collected by us, please inform us at

Non-Personal Information:  In addition, we may also collect non-personally identifiable information, such as IP addresses (which identify your device), pages viewed, computer type, screen resolution, operating system version, Internet browser type and version, information collected through cookies, pixel tags, web beacons, and other technologies, and other data (“Non-Personal Information”).  Because Non-Personal Information does not personally identify you, we may collect, use and disclose Non-Personal Information for any purpose. Non-Personal Information will be retained only for so long as to fulfill a legitimate business need.

Aggregate Information:  We may aggregate Personal Information so that the aggregated information does not personally identify you or anyone else, such as by using Personal Information to calculate the percentage of our customers who live in a particular area (“Aggregate Information”). In some instances, we may combine Non-Personal Information with Personal Information. If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined and may aggregate any information collected in a manner that does not identify any individual.

  1. Use of Information:

Personal Information to Provide Services:  We use Personal Information to process and fulfill any orders that you have placed, contact you about our products and Services, personalize your experience with us including by presenting products or offers tailored to you, and allow you to use, communicate and interact with us on our Site. This may include sharing information with third parties that provide us with services such as data analysis, web analytics such as Google Analytics (“Google Analytics”), payment processing, order fulfillment, site hosting such as Hostinger (“Hostinger”) information technology services, customer service, e-mail delivery services such as Mailchimp (“Mailchimp”), credit card processing, and other similar services. These third parties may have access to Personal Information necessary to perform their functions but may not use it for other purposes. Additionally, in order to deliver our products, we share your Personal Information with RESERVEBAR HOLDINGS CORP. (“ReserveBar”), an online marketplace and platform that handles the delivery and shipping of premium and luxury spirits, wine, and champagne from licensed liquor stores. ReserveBar may collect additional personal information such as shipping address, and payment information enabling full completion of the transaction. Please refer to ReserveBar’s privacy policy for more details on the collection of your personal information:

Site and Marketing:  We may use Aggregate Information to improve and enhance your experience on the Site and for our market research activities. For example, we may share Aggregate Information with third parties service providers in order to improve our marketing and advertising activities on our Site.

As Necessary:  We may disclose Personal Information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.  Additionally, if we, or substantially all of our assets, were acquired by a third party, or if we go out of business or enter bankruptcy, user information will be considered an asset of ours and may be transferred or acquired by a third party.  You acknowledge that such transfers may occur, and that any acquirer of user information may use your information per this Privacy Policy.

Mailing List:  In order to maintain our mailing list, we may combine information you give us online along with information that is publicly available and/or provided by our third-party service providers or another company. If you received our marketing materials and don’t know why, we may have received your information from another company. If you do not want to receive mailings or other marketing materials from us or if you do not want us to share your Personal Information with other companies, please contact us at

  1. Data Retention Period:

Data collected for the purposes outlined in section 1 will be retained by Martingale Cognac for one (1) year from the date we collected your data, or for the time period necessary for the performance of a contract, with legal and conventional guarantees provided for, or in accordance with obligatory legal terms regarding the retention of data. Data collected for the purposes outlined in section 2 will be retained until the client revokes consent to process his/her/their personal data and in any event, with particular reference to data collected for the purposes outlined in section 2. When said consent is revoked or if the time limit for the retention of data collected for the purposes outlined in section 2 expires earlier, the data will be automatically erased or made permanently anonymous.

  1. Email and Telephone Communications: 

We do use “browse abandon” and “cart abandon” tracking functions (if we have your email address and you visit our store, we may send you an email about the products you viewed or left in your cart).  If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested.  We may also contact you from time to time via telephone regarding customer service inquiries pertaining to your orders. 

  1. Cookies:

“Cookies” are pieces of information that may be placed on your computer by a Site for the purpose of facilitating and enhancing your communication and interaction with that Site. We may use cookies to customize your visit to the Site and for other purposes to make your visit more convenient or to enable us to enhance our service. For example, cookies allow us to select which ads or offers are most likely to appeal to you, based on your interests, preferences, location, or demographic information.  Cookies also allow us to keep track of items you add to your shopping cart.  Many Sites use cookies for these purposes.

We use essential cookies that allow our Site to function correctly, functional cookies to help you record your choices, performance cookies for analytics, ad analytics and ad tracking to serve you interest-based ads. 

You may stop or restrict the placement of cookies on your computer or flush them from your browser by adjusting your web browser preferences, in which case you may still use our Site, but it may interfere with some of its functionality. We do not use cookies to retrieve personal information from your computer for purposes that are unrelated to the Site or your interaction with the Site.

  1. Clickstream:

As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. Clickstream data can tell us the type of computer and browsing software you use and the address of the website from which you linked to the Site. We may collect and use clickstream data as a form of Aggregate Information to anonymously determine how much time visitors spend on each page of our Site, how visitors navigate throughout the Site and how we may tailor our web pages to better meet the needs of visitors. This information will be used to improve our Site and our Services. Any collection or use of clickstream data will be anonymous and aggregated and will not intentionally contain any Personal Information.

  1. Site Analytics:

    We may work with third-party service providers who use the technologies described in this section to conduct Site analytics to help us track and understand how visitors use our Site. 
  1. Security:

The security of your Personal Information is very important to us. We attempt to provide for the secure transmission of your information from your computer to our servers by utilizing encryption software. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and Martingale Cognac, or information stored on the Site or our servers, will be free from unauthorized access by third parties such as hackers and your use of the Site demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your Personal Information.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with section 18 below. 

  1. Other Websites:

Our Site may contain links to other websites not maintained by Martingale Cognac. Other websites may also reference or link to our Site. The inclusion of a link on the Site, including the link to ReserveBar, does not imply endorsement of the linked site by us. We are not responsible for the privacy practices of websites operated by third parties that are linked to or integrated with our Site, or for the privacy practices of third-party Internet advertising companies. We encourage you to be aware when you leave our Site, or surf the Internet, and to read the privacy statements of each and every website that you visit.

  1. “Do Not Track”:

    Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform Sites and services that they do not want certain information about their webpage visits collected over time and across sites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

  2. Privacy of Minors:

We do not intentionally collect or maintain information from persons under the age of 21. If we determine upon collection that a user is under this age, we will not use or maintain his/her/their Personal Information. If we become aware that we have unknowingly collected personally identifiable information from a person under the age of 21, we will make reasonable efforts to delete such information from our records. We also recommend that parents monitor their children’s Internet activities and learn and employ software or other tools that can help their children enjoy their online experience without compromising their personal safety or allowing them to use the Internet in a manner inconsistent with their parent/guardian’s preferences.

  1. State Privacy Rights:

California: California law permits users who are California residents to request and obtain from us once a year, free of charge, information regarding (i) the categories of personal information collected, (ii) the categories of sources for the personal information collected, (iii) the business purpose for collecting that information, (iv) the categories of third parties with whom Martingale Cognac shares that information, (v) the specific pieces of personal information Martingale Cognac collects about the consumer, and (vi) whether Martingale Cognac sold or disclosed the personal information for a business purpose, Martingale Cognac will also provide two separate lists disclosing:  a) sales, identifying the personal information categories that each category of recipient purchased; and, b) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

If you are under 21 years of age, please do not use the Site. If you are under 21, you are not permitted to use our Site and should not provide any Personal Information to us. If you are under 21 years of age and believe we have collected your personal information or are the parent or guardian of a person under 21 years of age with an account or information collected by us, please inform us at

Any user may request the discontinuation (or opt-out) of our sharing of the information with third parties and/or that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your California Privacy Rights Request (see below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.) (“CCPA”).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Please submit any requests (“California Privacy Rights Request”) by:

  • emailing us at with a subject line of “Your California Privacy Rights”
  • sending us a letter to addressed to Raymond Thomas Holdings, Inc. 120 Kisco Avenue, Suite I Mt Kisco, NY 10549 USA or 
  • calling us at +1 (332) 264-1005 

For each California Privacy Rights Request, please clearly state the following:

  • sufficient detail of your request such that it allows us to properly understand, evaluate, and respond to it;
  • that the request is related to “Your California Privacy Rights;”
  • your name, street address, city, state, zip code, and email address; and
  • whether you prefer to receive a response to your request by mail or email.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete your Personal Information. To designate an authorized agent, email us at

We cannot respond to your California Privacy Rights Request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Martingale Cognac is not responsible for a California Privacy Rights Request that is incomplete, incorrectly labeled, or incorrectly sent. Making a California Privacy Rights Request does not require you to create an account with us. It may take us up to 45 days to process your California Privacy Rights Request. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. 

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you with a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Colorado, Connecticut, Virginia, and Utah: Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

  • Confirm whether we process their personal information.
  • Access and delete certain personal information.
  • Data portability.
  • Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

  • Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
  • Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights or to appeal a decision relating to your consumer rights request, please contact us at

  1. Opt-Out or Change Your Information: 

How to change your information on our Site:

To opt out of our email marketing campaigns:

To opt out of apps that we use, to receive a copy of your Personal Information, to request that we delete or erase your Personal Information, to restrict our use of your Personal Information or to obtain an exportable copy of your Personal Information:

To Opt-Out of our Mailing List:

  • Email and we will make a request for your data to be erased from our mailing list. It may take up to 90 days to remove your information from our mailing list.
  1. Visitors From Outside The United States—Cross-Border Transfer:

The Site is hosted in the United States. The European Commission has not determined that the United States ensures an adequate level of protection for Personal Information.  The data protection and other applicable laws of the United States or other countries may not be as comprehensive as those laws or regulations in your country or may otherwise differ from the data protection or consumer protection laws in your country. Your information may be available to government authorities under lawful orders and laws applicable in such jurisdictions.

By providing us with Personal Information, you consent to the storage or processing of your Personal Information in the United States and acknowledge that the Personal Information will be subject to the laws of the United States, including the ability of governments, courts or law enforcement or regulatory agencies of the United States to obtain disclosure of your Personal Information.  By using the Site and/or providing personal data to us, you also consent to the transfer, storage, and processing of your information as described in this Privacy Policy. We will protect the privacy and security of Personal Information according to this Privacy Policy, regardless of where it is processed or stored.

  1. Existence of Automated Decision-Making:

We may use automated decision-making processes to personalize the Site to enhance your shopping and consumer experience on our Site (for example, by recommending certain products to you) or, if you have opted into receiving promotional material from us, to send you personalized promotional emails. We do not believe any of these automated decision-making processes will produce legal effects concerning our users or similarly significantly affect our users.

  1. Communications with Martingale Cognac:

By providing your email address to Martingale Cognac, you expressly consent to receive emails from us. We may use email to communicate with you, to send information that you have requested or to send information about other products or services developed or provided by us that Martingale Cognac believes will be of interest to its audience. If you receive an unwanted email from us, you can simply reply and ask not to receive future emails. We also give you the option to remove your personal information from our list of active users completely. All unsubscribe or opt-out requests should be sent to us at and we will process your request within a reasonable time after receipt. We are not responsible for removing your personal information from the lists of any third party who has been provided with your information in accordance with this policy, such as a business partner.

For questions or concerns relating to privacy, we can be contacted at: 

  1. Changes to policy:

We reserve the right, at our discretion, to change, modify, add, or remove portions from this policy at any time by posting the updated policy here. Your continued use of the Site following the posting of any changes to this policy means you accept such changes.  If you are concerned about potential changes in our Privacy Policy, you should check for an updated version each time you use the Site.  You are also advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.


  1. Contacting us: 

If you have questions about this Privacy Policy, please contact us by writing to: 

Raymond Thomas Holdings, Inc. 
120 Kisco Avenue, Suite I
Mt Kisco, NY 10549 USA

or emailing
. If you have any questions or comments about Martingale Cognac or our products or have other customer service needs, please email for information on contacting our consumer service representatives.


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