PRIVACY POLICY

Last Updated: January 1, 2023

Welcome to the Delicato Family Wines Site (the “Site”). This Privacy Policy (the “Policy”) is intended to inform you of the ways in which Delicato Family Wines collects information for the Delicato Family Wines portfolio of brands, the ways in which the information is used, and the ways in which the personal information you choose to provide us will be protected.

If you are a Delicato Family Wines employee, employment applicant, supplier, distributor, or trade contact, additional policies may apply.

This Policy is subject to our Terms of Use. We may update this Policy from time to time.

California state law confers certain rights relating to personal information to its residents. If you are a California resident, please also see our California Consumer Privacy Rights in this Policy accessible at the link above.

Your Consent

Please review this Policy periodically. You should read this entire Policy before submitting information, including personal information, to us in any form. Whenever you submit personal information to us, whether online or offline, you consent to the collection, use, and disclosure of that information in accordance with this Policy.

All personal information may be used for the purposes stated in this Policy. We may make full use of all information that is de-identified, aggregated, or otherwise not in a personally identifiable form. We may also make full use of all user-generated content you submit to us, in accordance with our Terms of Use.

Intended Audience:

We are in compliance with the requirements of the Children’s Online Privacy Protection Act (“COPPA”) and other applicable privacy laws. The Site is maintained strictly for individuals who are of legal age to consume alcoholic beverages under applicable law. As a result, we do not request or knowingly collect personal information from individuals under legal drinking age. If you are not of legal drinking age, you should not access the Site.

INFORMATION COLLECTION AND USE

We collect personal information using three methods: 1) from you when you choose to voluntarily provide it; 2) using automated technology, including when you visit our websites or interact with our electronic advertisements or communications; and 3) using third party sources and service providers, including but not limited to entities providing data analysis and analytics, social media and social networking websites and other entities. To see a complete list of what we collect and how we use this data, please see our Annex 1 below.

Personal Information

We collect information volunteered by you, including but not limited to Contact information, location, birthdate, gender, household income ranges, consumption habits, product usage, opinions of our products and other personal information (collectively, “Personal Information”). Any Personal Information you provide will be used as indicated in this Policy.

We collect information about you through your browser, computer hardware and software. This information can include your IP address, device ID, domain names, browsers you used to access our Site and services, webpages viewed, time spent on webpages, links clicked, transactions entered into and site-navigation patterns. This information is used by Delicato Family Wines for the improvement of our business.

USE OF PERSONAL INFORMATION

We may use the information we collect from you to:

In addition, we may use your information for compliance with our company policies and procedures, for accounting and financial purposes, and as otherwise described above. If you do not provide this information we may not be able to fulfill the applicable purpose of collection, such as to respond to your queries or provide our Site to you.

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

The Personal Information you provide is held by Delicato Family Wines or an agent of Delicato Family Wines, and may be used by our affiliates, partners, agents, or licensees. The information will not be sold, shared, exchanged, or otherwise distributed to unaffiliated third parties, except to the extent required by law, or as outlined below:

Our Affiliates and Business Partners – We may share your information with our affiliates and business partners in the US and worldwide for the purposes described above and for other general business administration purposes. By visiting our websites or otherwise providing us with your information, you consent to this transfer of your information throughout our network of entities. To unsubscribe from such disclosures, please see the “Contact Preferences and Opting Out” section below.

Agents/Service Providers – The business and operation of Delicato Family Wines may be supported by other companies and individuals who perform services on our behalf (e.g., processing credit card payments, sending email marketing communications, processing job applications, data analysis, hosting or operating our Site and other business support services). Personal Information may be provided to these entities who have agreed to keep the information confidential and use it only to provide the applicable service(s) such as vendors that help us communicate with you, vendors that host our website and data, security and fraud detection vendors.

Legal Matters – We may disclose Personal Information to outside parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our (or others’) rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; in connection with disciplinary actions/investigations; or if by good faith belief that such action is necessary to protect and defend the rights, property, or safety of Delicato Family Wines, its affiliates, or users of the websites, or the public. Personal Information may also be used to enforce the Terms of Use of the applicable website, or to respond to claims that any content violates the rights of third parties.

Business Transfers – Where permitted by law, we may transfer your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any position of our business, brands, affiliates, subsidiaries or other assets.

Any Personal Information received may be used in the marketing, promotion, and advertising of Delicato Family Wines portfolio of brands. Such information may be used for purposes such as processing your orders; communicating with you about special offers and other marketing communications and advertisements; inviting you to participate in online and offline events (including, but not limited to, consumer experiences such as tastings, wine clubs, pool and cabine reservations, dining and restaurant reservations); to improve the quality of our products and services; and to send promotional communications and offers.

Therefore, providing your information may result in Delicato Family Wines contacting you by mail or other communications (electronic or otherwise) regarding our portfolio of products, services, promotions, surveys, or events.

HOW WE USE “COOKIES AND OTHER TECHNOLOGY”

As you access or use our websites, Delicato Family Wines may collect information passively, by using technologies such as cookies, web beacons, pixels, and navigational and location data collection (clickstream, log files, server logs) for the purposes described in this Policy. Such automated technologies further help us to keep track of your interactions with our website in order to personalize your web experience, including through offers, advertisements, language and location preferences. Most browsers are initially set to allow cookies, but also offer the option to restrict cookies or warn you of their use. By disabling cookies, you won’t be able to enjoy the convenience provided by our customization.

To find more information about cookies please visit www.allaboutcookies.org.

THIRD PARTY ADVERTISING AND ANALYTICS DISCLAIMERS:

We and/or third parties including advertising companies, social networking sites, and service providers on our behalf, use cookies, web beacons and other similar technology, to collect information for the purposes described in this Policy including advertising, analytics, online behavioral marketing, monitoring performance and improvement of our online services (traffic, errors, page load time, popular pages, etc.).

You may opt out of behavioral remarketing as follows:

Google Analytics and Facebook Pixel: We use Google Analytics and Facebook Pixel to understand how our website, services, and products perform, how you use them, and to serve you with ads on third-party websites and social networking sites like Facebook. To learn more about how Google processes your data, please visit https://www.google.com/policies/privacy/. To opt out of Google Analytics please visit https://tools.google.com/dlpage/gaoptout. To learn more about how Facebook uses your data, please visit https://www.facebook.com/policy.php.

Advertising and Remarketing Services: We use remarketing services to inform, optimize, and serve ads on third-party websites such as Facebook to you based on your use of our Site and social media. To understand more about Facebook advertising and manage your preferences, please visit https://www.facebook.com/about/ads. Login to Facebook and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app) for more information. For more information about targeted advertising and to opt out of collection of information and ad targeting from third-party websites, including Facebook and Google, please visit http://www.aboutads.info/choices. If you choose to opt out, you will continue to receive advertisements but they will not be tailored to your interests.

Digital Advertising Alliance

You can also opt out from companies like Google, Instagram, Pinterest, Facebook and other participating companies through the Digital Advertising Alliance in the USA: http://www.aboutads.info/choices. You can also opt out of participating companies from the Digital Advertising Alliance of Canada in Canada: http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe: https://www.youronlinechoices.eu/, or opt out using your mobile device settings.

RETENTION OF PERSONAL INFORMATION

We will retain your personal information (collected through offline and online methods) for as long as it is necessary for the purposes described in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. For more information regarding retention of personal information see Annex 1.

Alternatively, to the extent that applicable law requires your prior opt-in consent to receive marketing and promotional emails, we will ask for your consent and you can choose not to opt-in.

Contact Preferences and Unsubscribing From

Delicato Family Wines wants to communicate with you in a manner you find helpful. If you no longer wish to receive email marketing communications from us, you may unsubscribe from receiving marketing-related emails by using the unsubscribe method provided in our communications (e.g., by clicking on the “unsubscribe” link in the email to unsubscribe). Such communications may include information about products or services, promotions, or upcoming events or experiences. Please note that unsubscribing from our promotional material will not prevent Delicato Family Wines from contacting you for other reasons, such as order confirmations, responses to customer service inquiries, or information about an event for which you have registered.

Alternatively, to the extent that applicable law requires your prior opt-in consent to receive marketing and promotional emails, we will ask for your consent and you can choose not to subscribe.

Security

Delicato Family Wines takes commercially-reasonable technical, administrative, and physical security measures to protect your Personal Information from unauthorized or inappropriate use.

All orders placed on our websites require a credit card. Upon submitting an order, all credit card numbers are transmitted via secure and encrypted methods. If desired, credit card numbers can be kept on file for future purchases. For your security, these credit card numbers are stored in secure, encrypted databases.

However, as no security system is wholly failsafe or impenetrable, the transmission of information via the internet is not completely secure. We cannot guarantee the security of our database or the information you supply while being transmitted to us over the Internet. Although we strive to protect your personal information in accordance with this Policy, we will not be liable for disclosure of personal information obtained due to errors in transmission or security breaches. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately as detailed under the “Contact Information” section below.

Promotions

Personal Information will be requested when you enter a promotion or sweepstakes to be used for the purpose of administering the promotion or sweepstakes and potential future opportunities. The Personal Information will also be used and stored as set forth under the “Use of Personal Information” section unless otherwise indicated by you through the means provided under “Contact Preferences”. Any further uses of the Personal Information will be outlined in the Official Rules and Regulations for the specific promotion.

External Links

We may make available third party applications through our Site for your use. Links to other websites included in this Site operate with privacy policies beyond the control of Delicato Family Wines. Unless otherwise indicated, once you have left the Site, all use of information you provide is governed by the privacy policy of the other website’s operators. Delicato Family Wines is not responsible for any transactions that occur between you and a third-party website or social media account.

Governing Law

This Policy and our privacy practices will be subject exclusively to the laws of the State of California, United States of America. We make no representation that this Policy and its practices comply with the laws of any other jurisdiction.

Changes to This Policy

Any change made to the Policy will be considered effective immediately. By using the Site, you consent to the collection, use, and transfer of your information in accordance with the Policy. It is therefore recommended the Policy be referenced on a regular basis. If you do not agree to the Policy, please do not use the Site.

Contact Information

Please direct any questions regarding this policy to Customer Service at:

Trade Practices Compliance

Delicato Family Wines

12001 South Highway 99

Manteca, California 95336

Delicato Family Wines invites you to drink our wines responsibly.

©2023 Delicato Family Wines, Manteca, CA

 

CALIFORNIA CONSUMERS ONLY: Your California Privacy Rights

Updated on January 1, 2023

This Privacy Rights Act Notice (“Notice”) provides additional information to California residents whose Personal Information is collected by us pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). If you are not a California resident, this Notice does not apply to you. Please visit our Privacy Policy (“Policy”) for more information. Any capitalized terms undefined in this Notice have the same definition as the Policy.

The purpose of this notice is to inform our website users, customers, browsers, online community participants, those who purchase or inquire about our products and services, and other California residents from whom we may collect personal information (“California Consumers”), about our practices regarding the collection, use and disclosure of their personal information and certain rights under California law. This notice applies to both offline and online collection of personal information and applies to Delicato Family Wines and our affiliates and brands.

RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, DISCLOSED, OR SOLD AND SHARED

Information Collected

In the preceding 12 months, we have collected the categories of personal information about California consumers as described in Annex 1 to this Notice. To review these categories click here.

Business-to-Business (“B2B”) Information

If you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship, we collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating that business relationship. We use that information for internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship. We do not disclose that information outside our business relationship without your consent.

Information Sold or Shared

We have not sold or shared, as defined by the CPRA, any personal information to third parties for a business or commercial purpose in the preceding 12 months.

Information Disclosed for Business Purposes

We have disclosed the following categories of personal information to third parties in the preceding 12 months:

We do not knowingly sell the personal information of individuals under 16 years of age without affirmative authorization.

Because our products are strictly for individuals who are of legal age to consume alcoholic beverages under applicable law, we do not request, knowingly collect, or sell personal information of individuals under legal drinking age. If you are not of legal drinking age, you should not access our website or purchase our products.

For details regarding the categories of third parties with whom we have shared, sold, or disclosed personal information, please see Annex 1.

Requests to Know

You have the right to request that we disclose to you the following personal information we collect about you:

You also have a right to know if we have sold or disclosed your personal information for a business purpose over the past 12 months and, if so, the categories of personal information sold or disclosed and the categories of third parties to whom the personal information was sold or disclosed, along with the business or commercial purpose for which the personal information was sold or disclosed.

To make a request for any of the information set forth above (a “Request to Know”), please submit a verifiable consumer request pursuant to the instructions below. You may only make a Request to Know twice within a 12-month period. We will acknowledge your Request to Know within 10 days and will attempt to respond substantively within 45-90 days.

The Request to Know must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request.

You can make a Request to Know the personal information we have about you in the following ways:

Once we receive your Request to Know, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. If you are an account holder, making a request through your account is sufficient for verification purposes. If you do not have an account with us, you will be asked to provide us with two or three pieces of information that will help us to verify your identity.

Depending on the sensitivity of the personal information you are requesting to know, we may need to match two or three pieces of identifying information from your request with information from our records. If your Request to Know involves very sensitive information, we may also need a signed declaration stating that you are the consumer whose personal information is the subject of the request.

We take your privacy seriously. While we will do our best to verify your identity based upon the identifying information you provide to us in the request, we may request additional identifying information from you to complete the Verification Process.

RIGHT TO KNOW SENSITIVE PERSONAL INFORMATION COLLECTED

We collect and use your Sensitive Personal Information as described in Annex 1.

We do not collect or process sensitive personal information for the purpose of inferring characteristics.

RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION

You have the right to request the deletion of your personal information collected or maintained by us (“Request to Delete”), subject to certain exceptions permitted by law.

To make a Request to Delete, please submit a verifiable consumer request pursuant to the instructions below. We will acknowledge your Request to Delete within 10 days and will attempt to respond substantively within 45-90 days.

The Request to Delete must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request. Additionally, as permitted by law, if the information requested to be deleted is necessary for us to maintain, we will not be able to comply with your request. We will notify you if this is the case. You can make a Request to Delete in the following ways:

You can confirm your decision to have us delete your information in the following ways:

Once we receive your initial request to delete and your separate confirmation to delete, we will need to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. When making your request, you should be prepared to provide us with information that will help us to identify you.

Depending on the sensitivity of the personal information you are requesting to delete, we may need to match two or three pieces of identifying information from your request with information from our records. If your request to delete involves deleting very sensitive information, we may also need a signed declaration stating that you are the consumer whose personal information is the subject of the request.

While we will do our best to verify your identity based upon the identifying information you provide to us in the request, we may request additional identifying information from you to complete the Verification Process.

We will retain correspondence, documents and information related to any Request to Know, Request to Delete, or Request to Opt-Out for 24 months as required by law.

RIGHT TO OPT-OUT OF SALE OR SHARING OF PERSONAL INFORMATION

You have the right to opt-out of the sale or sharing, as defined by the CPRA, of your Personal Information. We do not and will not sell your personal information. As explained in Annex 1 of this Policy, we share your data with third parties such as social networking sites and advertising companies, in order to serve you with ads tailored to your preferences across various platforms.

Opt-out Preference Signals

Where applicable, we honor opt-out preference signals that you enable, including a Global Privacy Control. Opt-out preference signals are plug-ins available in certain browsers that signal to websites you visit of your preferences to opt out of the sale and sharing of certain personal information. If you have enabled an opt-out preference signal device from your browser, we will not sell or share your personal information without first seeking your explicit consent.

This Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third-parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third-parties to learn about their privacy practices.

Cookies

As explained in our “Cookies and other technology” section, you can opt out of cookies using your browser.

Please Note:

ADDITIONAL OPTIONS TO OPT-OUT OF SALE OR SHARING

In addition to the above options to opt out of the sale or sharing of your information under the CPRA as described above, you have controls and choices with respect to collection and use of your information by third parties. These are summarized for you below. We do not control or maintain opt-out mechanisms for third-party companies and are not responsible for their operation.

Advertising Opt-Out

You can opt out of sharing your information with third-party companies engaged in targeted advertising including social networking sites such as Google and Facebook using the following tools: For websites: http://optout.aboutads.info/?c=2&lang=EN. For mobile apps: http://www.aboutads.info/appchoices

Google Opt-Out

If you would like to opt out of Google Analytics and Ads, you can. If you are on the web, you can opt out of Google Analytics by installing Google’s Opt Out browser add on: https://tools.google.com/dlpage/gaoptout, and you can opt out of interest-based Google ads using https://adssettings.google.com/u/0/authenticated.

Facebook Ad Preferences

To understand more about Facebook advertising and manage your preferences, please visit https://www.facebook.com/about/ads. Login to Facebook and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app) for more information.

RIGHT TO CORRECT

You have the right to request that we rectify inaccurate information about you.

Requests to Correct

To make a Request to Correct, please submit a verifiable consumer request pursuant to the instructions below. We will acknowledge your Request to Correct within 10 business days and we will attempt to respond substantively within 45-90 days.

You can make a Request to Correct in the following ways:

Once we receive your request to correct, we will need to verify that you are the person that is the subject of the request through the Verification Process. The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. When making your request, you should be prepared to provide us with information that will help us to identify you.

Depending on the sensitivity of the personal information you are requesting to correct, we may need to match two or three pieces of identifying information from your request with information from our records. If your Request to Correct involves correcting very sensitive information, we may also need a signed declaration stating that you are the consumer whose personal information is the subject of the request.

While we will do our best to verify your identity based upon the identifying information you provide to us in the request, we may request additional identifying information from you to complete the Verification Process.

We will review all information provided by you to us, to determine whether the information is inaccurate. We reserve the right to delete the information instead of correcting if such deletion does not impact you or your consent to the deletion.

We will inform you of our decision to deny or grant your request.

We will retain correspondence, documents and information related to any Request to Correct for 24 months as required by law.

RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS

You have the right to not receive discriminatory treatment for exercising your privacy rights conferred by the California Consumer Privacy Act, including by exercising the rights specified herein.

RIGHT TO ACCESS INFORMATION ABOUT AUTOMATED DECISION MAKING AND THE RIGHT TO OPT-OUT OF AUTOMATED DECISION MAKING

You have a right to request information about automated decision making processes Delicato Family Wines uses, and you may request to opt out of automated decision making. If you have questions about automated decision making processes used by Delicato Family Wines, please email us at CCPA@delicato.com.

NOTICE OF FINANCIAL INCENTIVE

From time to time, Delicato Family Wines may provide financial incentives to consumers who elect to participate in these programs and, in connection with such programs, allow us to collect and retain certain personal information, such as Identifiers (e.g., your name, email address, or phone number), and Commercial Information (e.g., your purchase history).  These incentives may result in differences in the prices of our products offered to consumers (e.g., discounts and other promotions).  For example, the financial incentives we may provide include discounts based upon purchase activity and other periodic discounts for promotional purposes.

The material aspects of any financial incentive will be explained and described in its program terms or in the details of the incentive offer.

Participation in any financial incentive program is entirely optional and participants may withdraw from the program at any time. To opt-out of the program and forgo any ongoing incentives, please follow the instructions in the program’s terms and conditions, or contact us using the contact information below.

Each financial incentive or price or service difference related to the collection and use of personal information is based upon our reasonable, good-faith determination of the estimated value of such information to our business, taking into consideration the value of the offer itself and the anticipated revenue generation that may be realized by rewarding brand loyalty and repeat purchases.

RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information for as long as it is necessary for the purposes set out in Annex 1 and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

AUTHORIZED AGENT INFORMATION

You may designate an authorized agent to make a request on your behalf under the California Consumer Privacy Act.

In order to allow an authorized agent to make a request on your behalf, please email us at CCPA@delicato.com to provide your written request and consent to an authorized agent.

When your authorized agent makes a request related to your personal information, we will require the agent to provide the above written permission. We may also require that you verify your own identity directly with us at the time such a request is made.

California Do Not Track Notice

Because there are not yet common, industry accepted “do not track” standards and systems, our website does not respond to Do Not Track signals. In addition, we may allow third-parties to collect personal information from your activity on our website, as described in the “Information Collection and Use” section above.

California Shine The Light Disclosure Information

Although we do not disclose to any third-parties for their marketing purposes any personal information, California residents are entitled to receive the following disclosure information under California law:

Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. We will respond to such written requests within 30 days following receipt at the e-mail or mailing address specified below under “Contact Us”. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are required to respond to each customer only once per calendar year.

Changes to This Privacy Policy

This Policy may be revised from time to time for any reason. If this Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page. Be sure to check the Policy whenever you submit personal information to us.

CONTACT FOR MORE INFORMATION

For information and questions about the use of your personal information or this California Consumer Privacy Section or your rights under California law, you may contact us at CCPA@delicato.com.

 

ANNEX 1

California Notice of Collection, Use, and Disclosure

Category Examples Collected From Purposes Disclosed to Sold or Shared Retention Period

Personal Identifiers

Commercial Information

Name, signature, address, telephone number, driver’s license, credit card number, email address, age, image and social media handle.

Products or services purchased, obtained, considered, reviewed or other purchasing or consuming histories or tendencies.

You, such as through registration, a transaction or inquiry (including via a telephone call) or through your submission of a form, registration, or communication to us.

We may also collect information from third-party sources, such as third-party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals, and through your online activities and interactions with us, including, without limitation, your use of our services, your online activity on our website and on our social media channels.

To respond to and fulfill your requests, follow up with you after you have communicated with us or submitted information to us, and to provide products or services that you have ordered;

To process your order transactions, contact you regarding your order, and deliver products or materials to you;

To improve our products, services, and Site;

Analyze and track usage of our services and products including our website and social media accounts;

Determine the popularity of our products;

Better understand how you use our Site and services;

To send promotional communications or offers (unless you have requested that we not send such communications);

To authenticate your account credentials and identify you, as necessary to log you in and/or ensure the security of your account;

For marketing, research, legal, and other business purposes; and

To comply with our policies, procedures and legal obligations, including complying with law enforcement or government authority requests, addressing litigation-related issues, investigating fraudulent activity, and exercising rights or obligations conferred by law.

Consultants, service providers, and contractors that we use to support our business and operations (e.g. hosting or operating our services, data collection, reporting, ad response measurement, Site metrics and analytics, data analysis, delivering marketing messages and advertisements, processing credit card payments, and providing fraud detection services) who have agreed to keep the information confidential and use it only to provide the applicable services;

Third-party payment processors, including in connection with transactions where we require credit or debit card account information such as credit or payment card account information (including card number, expiration date, and security code);

Third-party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics or behavior remarketing, as explained further below;

Third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; and

Third parties sponsoring contests, sweepstakes, discounts, and promotions that you voluntarily enter into or third parties who lawfully request such information.

N

We will retain your Personal Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.

Internet/Network Activity

IP address, your device information, domain name, browsers you used to access our Site and services, webpages viewed, time spent on webpages, links clicked, transactions entered into and site-navigation patterns.

Your online activities and interactions with us, including, without limitation, your use of our services, your online activity on our Site, and on our social media channels or through our third-party sources.

Third-party sources including third-party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals.

Our third-party providers are bound by confidentiality obligations and are restricted to only using the data to provide our business with applicable services.

Analyze and track usage of our services and products including our Site and social media accounts;

Determine the popularity of our products;

Better understand how you use our Site and services;

Improve our Site, services, and products;

To send promotional communications or offers (unless you have requested that we not send such communications); and

For other marketing, research, legal, and other business purposes.

Consultants, service providers, and contractors that we use to support our business and operations;

Third-party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics, targeted advertising or behavior remarketing, as explained further below; and

Third-parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests.

N

We will retain your Personal Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.

Sensitive Personal Information

Personal identification numbers, including, driver’s license, passport, or state ID card numbers; account or debit or credit card numbers; consumer’s geolocation;

You when you visit our Site (including your online activities on our Site), purchase a product (through our Site, in person, or on the phone), register for an account on our Site, join our wine club programs, enter a promotion or competition conducted by us, engage with us on social media, or otherwise interact with us through posting content on our Site, or communicating with us via phone or email.

We may also collect information from third-party sources, such as third-party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals.

To prevent, detect, and investigate any security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted sensitive personal information.

For purposes that do not infer characteristics about the consumer

To respond to and fulfill your requests, purchase orders, and wine club orders, follow up with you after you have communicated with us or submitted information to us, and to provide products or services that you have ordered;

To process your order transactions, contact you regarding your order, and deliver products to you;

To improve our products, services, Site, and social media;

To provide you with a customized user experience;

To send promotional communications or offers regarding our products and services (unless you have requested that we not send such communications);

To authenticate your account credentials and identify you, as necessary to log you in and/or ensure the security of your account;

For marketing, research, legal, and other business purposes; and

To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies

N

We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

Business-to-Business (“B2B”) Information

Name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating the business relationship.

You, if you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship.

For internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship.

We do not disclose B2B Information outside our business relationship without your consent.

N

We will retain your B2B Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.

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