Version 2026-04-21 — Effective and last updated April 21, 2026. Prior snapshot: 2026-04-19.

Summary of this update: Published the Policy on the website (/privacy), removed duplicate title lines from the web copy (the page header shows the title and dates), added conspicuous links from sign-up and the mobile app, and clarified in-app chat visibility and background-check readiness in Sections 5 and 13 (see prior version for comparison).

1. Introduction

Sampull, LLC ("Sampull," "we," "us," or "our") operates a three-sided marketplace platform (the "Platform") that connects (i) individuals who perform in-store beverage sampling activities ("Samplers"), (ii) beverage brand owners that hire Samplers to promote their products ("Brands"), and (iii) retail locations where sampling activities take place ("Retailers"). The Platform is accessible via our website at https://sampull.com and our mobile applications (collectively, the "Services").

This Privacy Policy ("Policy") describes how we collect, use, disclose, and protect personal information when you access or use the Services. By using the Services, you acknowledge that you have read and understood this Policy.

2. Scope and Eligibility

Sampler eligibility. Because the Platform involves promotional sampling of alcoholic beverages, you must be at least twenty-one (21) years of age to register as a Sampler. We may impose higher minimum ages where required by state or local law and may further restrict participation in jurisdictions with stricter alcohol-handling rules.

Brand and Retailer eligibility. Authorized representatives of Brands and Retailers must be at least eighteen (18) years of age and authorized to bind their organization to this Policy and our Terms of Service.

Geographic scope. The Services are offered throughout the United States, including all fifty (50) states, the District of Columbia, the Commonwealth of Puerto Rico, and the United States Virgin Islands. The Services are not directed to users outside the United States and its territories, and we do not knowingly collect personal information from individuals located in the European Economic Area, the United Kingdom, or other non-U.S. jurisdictions.

3. Information We Collect

3.1 Information You Provide as a Sampler

When you register and use the Platform as a Sampler, we collect:

Identity and contact information: full legal name, email address, phone number, mailing address, and date of birth.

Profile information: profile photo, biographical information, sampling experience, product categories you are qualified to sample, certifications, and availability.

Tax and payment information: taxpayer identification number (Social Security Number or ITIN), Form W-9 information, and bank account or debit card details required to receive payment for completed sampling jobs. Tax and payment information is collected and tokenized by Stripe and Stripe Connect; Sampull does not store full bank account numbers or tax identification numbers on our own servers.

Background check and age-verification information: information you submit to support identity verification, age verification, and consumer report checks performed by Checkr, Inc. or a similar consumer reporting agency. The collection and use of this information is governed by a separate disclosure and authorization that you must sign before any check is conducted, as required by the federal Fair Credit Reporting Act ("FCRA") and applicable state law.

Sampling history and performance data: a record of sampling jobs you have applied for, accepted, completed, or canceled; check-in and check-out times; photos and notes you upload; survey responses, observations, and feedback you submit about products and consumer reactions; and ratings or reviews assigned to you by Brands and Retailers.

Communications: messages you send through the Platform, support inquiries, and feedback.

3.2 Information You Provide as a Brand

Company and product information: company name, brand names, product details and attributes (including SKUs, packaging, ingredients, and on/off-premise classifications), distributor relationships, retail chain presence, states in which products are sold, and brand tenure.

Personnel contacts: names, business email addresses, business phone numbers, and roles of brand managers, marketing personnel, and other authorized users.

Billing information: billing contact, billing address, and payment-method details (collected and processed by Stripe).

Job specifications: sampling job parameters, target locations, schedules, talking points, compensation rates, and reporting requirements.

3.3 Information You Provide as a Retailer

Company and location information: company name, store locations and addresses, license information where applicable, and operating details.

Personnel contacts: names, business email addresses, business phone numbers, and roles of store managers and other authorized users.

Inventory information: the brands and products carried at each store location.

3.4 Information Collected Automatically

When you access the Services, we (and our service providers) automatically collect:

Device and technical information: device identifiers, operating system, browser type, IP address, mobile network information, app version, and crash and diagnostic data.

Usage information: pages or screens viewed, features used, search queries, click-through patterns, and timestamps.

Precise geolocation information: precise GPS-level location data from your mobile device, only with your prior opt-in consent through your device permission settings. Location data is used to surface nearby sampling opportunities, verify check-ins at sampling events, and provide map-based navigation. You may revoke location permission at any time through your device settings; doing so may limit certain Platform features.

Cookies and similar technologies: we and our analytics providers use cookies, SDKs, and similar technologies as described in Section 9.

3.5 Information from Third Parties

Background check and verification providers (such as Checkr, Inc.) provide identity verification, age verification, and consumer report results.

Payment and tax compliance providers (such as Stripe and Stripe Connect) provide transaction status, tax-form generation status, and limited account information.

Calendar providers (Google Calendar and Microsoft Outlook) provide limited calendar information when you authorize calendar integration so we may write sampling event details into your calendar.

Mapping providers (Google Maps and Google Places API) provide location and place data used to display retail locations and sampling events.

4. How We Use Information

We use the information described above for the following purposes:

Operating, maintaining, and providing the Services, including matching Samplers with Brand-sponsored sampling opportunities at participating Retailers.

Verifying identity and age, conducting background checks, and confirming eligibility to perform alcohol-related sampling.

Processing payments from Brands, calculating Sampull commissions, and remitting payment to Samplers, including the generation and delivery of IRS Forms 1099 and other tax reporting.

Communicating with you about your account, sampling jobs, scheduling, payments, support, and material changes to our policies (these are transactional communications you cannot opt out of while you maintain an account).

Sending marketing and promotional communications by email, SMS, and push notification, where you have opted in.

Generating analytics, performance metrics, and aggregated insights about sampling activity, Sampler performance, product reception, and Retailer foot-traffic.

Detecting, investigating, and preventing fraud, abuse, security incidents, and violations of our Terms of Service.

Complying with legal obligations, including tax reporting, alcohol-control regulations, responding to lawful requests from public authorities, and enforcing our agreements.

Improving and developing the Platform, including testing new features and conducting research.

5. How We Share Information

We do not sell your personal information for monetary consideration, and we do not share your personal information for cross-context behavioral advertising as those terms are defined under the California Consumer Privacy Act, the Colorado Privacy Act, and similar state laws.

We share information as follows:

5.1 Sharing with Brands

When a Sampler applies for or is hired for a Brand-sponsored sampling job, the Brand may receive:

The Sampler’s profile information, including name, profile photo, age (or age range), sampling experience and history, product categories sampled, total samplings completed, and ratings.

Detailed individual results and submissions from sampling jobs the Brand has hired the Sampler for, including check-in and check-out times, photos, notes, survey responses, and consumer feedback. In-app chat messages about a sampling event are visible to participants in that event’s conversation (for example, Brand, Retailer, and assigned Sampler) as implemented in the Services.

Aggregated and de-identified analytics about Samplers within the Brand’s campaigns and broader Platform trends.

5.2 Sharing with Retailers

Retailers may receive:

Brand and product information about sampling activities scheduled or conducted at their store locations, including the number of samplings conducted at their stores compared to other stores.

Aggregated and limited information about Samplers conducting activities at their locations, including names and check-in confirmations needed for store operations and access control. Retailers do not receive Samplers’ contact information, dates of birth, tax information, or payment details through the Retailer-facing Services. In-app chat messages tied to a sampling event may be visible to Retailer participants in that event’s conversation when the Services expose that chat to them.

Aggregated and limited financial information regarding sampling activity at their locations (for example, total payouts associated with samplings at the location). Retailers do not receive individual Sampler compensation amounts.

5.3 Sharing with Other Samplers

Samplers do not have access to other Samplers’ personal information through the Platform.

5.4 Sharing with Service Providers (Subprocessors)

We share personal information with service providers that perform services on our behalf under written contracts that limit their use of the information to providing services to us. Our current categories of service providers include:

Cloud hosting and infrastructure: Amazon Web Services, Google Cloud Platform, and/or Microsoft Azure; Vercel (application hosting); Supabase (managed database and authentication).

Payment and tax compliance: Stripe, Inc. and Stripe Connect (payment processing, payout disbursement, and IRS Form 1099 generation).

Identity verification and background checks: Checkr, Inc.

Communications: SendGrid (transactional and marketing email) and Twilio (SMS messaging).

Push notifications: mobile push notification service providers integrated with our applications.

Analytics: Google Analytics.

Mapping and location services: Google Maps Platform and Google Places API.

Calendar integrations: Google Calendar API and Microsoft Outlook Calendar API (only when you authorize the integration).

Domain and DNS services: GoDaddy.

5.5 Legal and Safety Disclosures

We may disclose personal information when we believe in good faith that disclosure is necessary to:

Comply with applicable law, regulation, court order, subpoena, or other legal process, including alcohol-control reporting requirements.

Enforce our Terms of Service or other agreements, or investigate potential violations.

Protect the rights, property, safety, or security of Sampull, our users, or the public, including investigating fraud or harm at sampling events.

Respond to a lawful request from law enforcement, regulators, or alcohol-control authorities.

5.6 Business Transfers

If Sampull is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, personal information may be transferred to the successor or acquiring entity, subject to the commitments in this Policy or as updated upon notice to you.

5.7 With Your Direction or Consent

We may share personal information for any other purpose disclosed to you and with your consent.

6. Communications

6.1 Transactional Communications

We send transactional communications related to your account, sampling jobs, payments, security, and material changes to our policies. These communications are part of the Services and you cannot opt out of them while you maintain an account, but you may close your account at any time.

6.2 Marketing Communications

You may opt in to receive marketing emails, SMS messages, and push notifications during account registration. You can update your preferences at any time within the Platform settings or by:

Email: clicking the "unsubscribe" link in any marketing email.

SMS: replying STOP to any marketing SMS message. Reply HELP for help. Message and data rates may apply. Message frequency varies. Carriers are not liable for delayed or undelivered messages.

Push notifications: disabling notifications in your device settings.

6.3 Telephone Consumer Protection Act ("TCPA") Consent

By providing your mobile phone number and opting in to SMS communications, you consent to receive autodialed and pre-recorded messages from Sampull at that number for transactional and (if separately opted-in) marketing purposes. Consent to marketing messages is not a condition of using the Services.

7. Location Information

We collect precise geolocation information from your mobile device only after you grant location permission through your operating system. We use precise location to:

Display nearby sampling opportunities and Retailer locations.

Verify Sampler check-in and check-out at scheduled sampling events.

Provide turn-by-turn or map-based navigation through Google Maps Platform.

You can revoke location permission at any time through your device settings. If you revoke permission, certain Platform features (including event check-in) may not function.

8. Calendar Integration

If you authorize Sampull to integrate with your Google Calendar or Microsoft Outlook calendar, we will request the minimum permissions necessary to write sampling event details into your calendar. We do not read, store, or use other calendar entries for any purpose. You may revoke calendar access at any time through your Google or Microsoft account settings.

9. Cookies and Tracking Technologies

We and our service providers use cookies, mobile SDKs, web beacons, and similar tracking technologies to operate, secure, and analyze the Services. We use:

Strictly necessary cookies required for authentication, session management, and security.

Functional cookies that remember your preferences and settings.

Analytics cookies (including Google Analytics) that help us understand how the Services are used so we can improve them.

We do not use third-party cookies for cross-context behavioral advertising. Most browsers and mobile operating systems allow you to control cookies and tracking through their settings. Where required by law, we honor recognized opt-out preference signals such as the Global Privacy Control ("GPC").

10. Data Retention

We retain personal information for as long as your account is active and as necessary to:

Provide the Services and fulfill the purposes described in this Policy.

Comply with legal, tax, accounting, and regulatory obligations (including IRS recordkeeping and state alcohol-control recordkeeping requirements, which generally require retention for several years after the end of the applicable tax or reporting year).

Resolve disputes and enforce our agreements.

When you delete your account, we will delete or de-identify your personal information within sixty (60) days, except for information we are required or permitted by law to retain (for example, tax records retained for the period required by the IRS, payment records retained by Stripe, and limited records necessary to defend legal claims). Aggregated and de-identified data, which cannot reasonably be used to identify you, may be retained indefinitely.

11. Data Security

We implement administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, or destruction. These safeguards include encryption of sensitive data in transit and at rest, role-based access controls, tokenization of payment and tax information through Stripe and Stripe Connect, and routine security review of our service providers. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

In the event of a security incident affecting your personal information, we will notify you and applicable regulators as required by the data breach notification laws of the jurisdiction in which you reside, including (without limitation) state, territorial, and Commonwealth laws such as the Colorado Consumer Protection Act, the California Customer Records Act, the Massachusetts Data Security Regulations (201 CMR 17.00), the Puerto Rico Citizen Information on Databank Security Act (Act 111-2005), and analogous laws in every U.S. state, the District of Columbia, and U.S. territories.

12. Children’s Privacy

The Services are not directed to children. Samplers must be at least 21 years of age. Brand and Retailer representatives must be at least 18 years of age. We do not knowingly collect personal information from individuals under 18. If we learn that we have collected personal information from a person under 18, we will promptly delete it. If you believe we have collected information from a minor, please contact us at info@sampull.com.

13. Background Checks and Consumer Reports

The Platform is designed so that Samplers may be asked to complete identity verification, age verification, and (where we integrate a consumer reporting agency such as Checkr, Inc.) a background check consistent with applicable law. As of the Last Updated date above, the production mobile and web applications may not yet expose every verification step described in this Policy; where a flow is not yet live, we will not run a consumer report or share data with a consumer reporting agency except as described in any in-product disclosure you accept at that time.

When a background check or similar verification is conducted through a consumer reporting agency, you will receive a separate written disclosure and will be asked to provide written authorization, as required by the federal Fair Credit Reporting Act and applicable state laws (including Colorado, Connecticut, and Massachusetts state-specific notices). The information collected and reported in connection with the background check is governed by that separate disclosure and authorization, the consumer reporting agency’s privacy policy, and applicable law.

14. Your Privacy Rights

14.1 General Rights Available to All Users

You can exercise the following controls regardless of your state of residence:

Access and update most of your account information directly through the Platform.

Delete your account in its entirety through the Platform settings.

Update marketing communication preferences in the Platform settings.

Revoke device-level permissions (location, push notifications, calendar access) through your device or account settings.

14.2 California Residents (CCPA/CPRA)

If you are a California resident, you have the right to:

Know the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the categories of third parties with whom we share it.

Request deletion of personal information we have collected from you, subject to legal exceptions.

Correct inaccurate personal information.

Opt out of the "sale" or "sharing" of personal information for cross-context behavioral advertising. As stated above, we do not sell or share personal information as those terms are defined by the CCPA.

Limit the use and disclosure of sensitive personal information to the purposes permitted under the CCPA.

Be free from discrimination for exercising your privacy rights.

To exercise these rights, submit a request through our intake form at https://sampull.com/privacy-request or contact us at info@sampull.com. We will verify your request by matching information you provide against information we have on file. You may use an authorized agent to submit a request on your behalf, subject to verification.

14.3 Residents of States with Comprehensive Consumer Privacy Laws

If you reside in a U.S. state that has enacted a comprehensive consumer privacy law, you have rights that generally include the ability to access, correct, delete, and obtain a portable copy of your personal data, and to opt out of the sale of personal data, processing for targeted advertising, and certain profiling activities that produce legal or similarly significant effects. As stated in Section 5, Sampull does not sell personal information, does not share personal information for cross-context behavioral advertising, and does not engage in profiling that produces legal or similarly significant effects about you.

As of the Effective Date of this Policy, these rights apply to residents of the following states under their respective comprehensive privacy statutes:

California (California Consumer Privacy Act, as amended by the California Privacy Rights Act — see Section 14.2 above)

Colorado (Colorado Privacy Act)

Connecticut (Connecticut Data Privacy Act)

Delaware (Delaware Personal Data Privacy Act)

Indiana (Indiana Consumer Data Protection Act)

Iowa (Iowa Consumer Data Protection Act)

Kentucky (Kentucky Consumer Data Protection Act)

Maryland (Maryland Online Data Privacy Act)

Minnesota (Minnesota Consumer Data Privacy Act)

Montana (Montana Consumer Data Privacy Act)

Nebraska (Nebraska Data Privacy Act)

New Hampshire (New Hampshire Privacy Act)

New Jersey (New Jersey Data Privacy Act)

Oregon (Oregon Consumer Privacy Act)

Rhode Island (Rhode Island Data Transparency and Privacy Protection Act)

Tennessee (Tennessee Information Protection Act)

Texas (Texas Data Privacy and Security Act)

Utah (Utah Consumer Privacy Act)

Virginia (Virginia Consumer Data Protection Act)

Your specific rights, any applicable exceptions, and the procedure for exercising them are governed by the law of your state of residence. We will honor each applicable right to the extent required by the law of your state. Several states (including Colorado, Connecticut, Maryland, Minnesota, Montana, New Hampshire, New Jersey, Oregon, Rhode Island, Texas, and Virginia) also provide a right to appeal our denial of a privacy request; if we deny your request, we will explain our reasons and provide appeal instructions in our response. Minnesota additionally provides a right to question the result of profiling decisions, and Oregon provides a right to obtain a list of specific third parties to which we have disclosed your personal data. We will honor these rights as required by applicable law.

14.4 Florida Residents

If you are a Florida resident, the Florida Digital Bill of Rights ("FDBR") may provide you with rights of access, correction, deletion, portability, and opt-out of certain processing activities. The FDBR primarily applies to controllers that derive substantial revenue from specific categories of online activity. Whether or not Sampull meets the FDBR’s applicability thresholds, Sampull will honor the general rights described in Section 14.1 for all Florida residents and will comply with the FDBR to the extent it applies to us.

14.5 Other U.S. States and the District of Columbia

If you reside in a U.S. state or the District of Columbia that has not enacted a comprehensive consumer privacy law, you may still have rights under state-specific data security, data broker, biometric-information, and breach-notification statutes, as well as Attorney General consumer-protection authority. These states include (without limitation) Alabama, Alaska, Arizona, Arkansas, Georgia, Hawaii, Idaho, Illinois, Kansas, Louisiana, Maine, Massachusetts, Michigan, Mississippi, Missouri, Nevada, New Mexico, New York, North Carolina, North Dakota, Ohio, Oklahoma, Pennsylvania, South Carolina, South Dakota, Vermont, Washington, West Virginia, Wisconsin, Wyoming, and the District of Columbia.

Regardless of whether your state has enacted a comprehensive consumer privacy law, Sampull extends the general rights described in Section 14.1 to all U.S. residents as a matter of policy. Certain states have additional sector-specific protections, including (without limitation):

Illinois residents are protected by the Illinois Biometric Information Privacy Act ("BIPA") and the Personal Information Protection Act. Sampull does not knowingly collect biometric identifiers or biometric information as defined under BIPA.

Massachusetts residents are protected by 201 CMR 17.00 (Standards for the Protection of Personal Information of Residents of the Commonwealth) and the Massachusetts data breach notification law (M.G.L. c. 93H).

Nevada residents may opt out of the sale of certain personal information under Nevada Revised Statutes Chapter 603A. Sampull does not sell personal information as defined under Nevada law.

New York residents are protected by the New York SHIELD Act and applicable General Business Law provisions.

Washington residents’ consumer health data is protected by the Washington My Health My Data Act ("MHMDA"). Sampull does not knowingly collect consumer health data subject to the MHMDA.

14.6 Puerto Rico Residents

Residents of the Commonwealth of Puerto Rico are protected by the Puerto Rico Citizen Information on Databank Security Act (Act 111-2005), the Puerto Rico Privacy Policy Notification Act (Act 39-2012) and related regulations (including Regulation 8568 and Regulation 9158), and the Cybersecurity Act of the Commonwealth of Puerto Rico (Act 40-2024), as applicable. Sampull will comply with these laws as applicable and will notify affected Puerto Rico residents and the Puerto Rico Department of Consumer Affairs (DACO) of qualifying data security incidents as required. Puerto Rico residents may exercise the general rights described in Section 14.1 by contacting us as described in Section 14.8.

14.7 U.S. Virgin Islands Residents

Residents of the U.S. Virgin Islands are protected by applicable U.S. Virgin Islands consumer protection and data security laws, as well as any applicable federal law. U.S. Virgin Islands residents may exercise the general rights described in Section 14.1 by contacting us as described in Section 14.8.

14.8 How to Submit a Privacy Request

To submit a privacy request under any of the above laws, please use our online intake form at https://sampull.com/privacy-request, which is the fastest way for us to verify and process your request. You may also email us at info@sampull.com with the subject line "Privacy Rights Request" and include the email and phone number associated with your account. We will respond within the timeframes required by applicable law (generally 45 days, with one possible extension where permitted).

15. Account Deletion

You may delete your Sampull account at any time through the Platform settings. Account deletion will:

Remove your profile from search and matching.

Cancel pending sampling jobs (subject to our Terms of Service).

Initiate the deletion or de-identification of your personal information consistent with Section 10.

Information that we are required to retain by law (such as tax records, payment records, and dispute records) will be retained for the period required and then deleted.

16. Third-Party Services and Links

The Services may link to or integrate with third-party services (including Stripe, Checkr, Google Maps, Google Calendar, Microsoft Outlook, Google Analytics, SendGrid, Twilio, AWS, GCP, Azure, Vercel, Supabase, and GoDaddy). These third parties have their own privacy policies governing their collection and use of information. We are not responsible for the privacy practices of third parties.

17. Alcohol Sampling Activities

Because the Platform supports promotional sampling of alcoholic beverages, Samplers, Brands, and Retailers are responsible for complying with all applicable federal, state, and local laws and regulations governing the sale, service, sampling, and promotion of alcoholic beverages. We may share information with state alcohol control authorities or other regulators as required by law or to support a Brand’s or Retailer’s compliance with its license obligations.

18. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will notify you by email, through the Platform, or by other means as required by law, and we will update the "Last Updated" date above. Your continued use of the Services after the effective date of the updated Policy constitutes your acceptance of the changes.

19. Contact Us

If you have questions about this Policy or our privacy practices, please contact us:

Sampull, LLC

2443 S University Blvd

Suite 101 PMB 1052

Denver, CO 80210

United States

Email: info@sampull.com

Privacy Rights Requests: https://sampull.com/privacy-request

END OF PRIVACY POLICY