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California residents have specific rights that are described below and may vary from the rights of other residents.
TYPES OF INFORMATION COLLECTED AND HOW IT IS USED
Through the use of the Company Sites, the Company markets wines and related products directly to consumers, and offers consumers the opportunity to create a personal account with the Company (the "Account") or to log in to the Company Sites as a guest (the "Guest Log-In"), and to take advantage of the various products and/or services, including, without limitation, the opportunity to purchase wine and related products from licensed retailers in their state and to register as members of the various wine clubs that the Company services (the "Wine Clubs") (collectively, the "Wine Services"). The sale and delivery of orders purchased by consumers will be executed and fulfilled by third party retailers holding valid licenses issued by state alcohol beverage agencies allowing for the legal sale of wine.
Although many areas of the Company Sites do not require registration and may be accessed by you without you having to disclose any personal information, when using the Wine Services and or other aspects of the Company Sites, we or our service providers may collect and use the following categories of information, some or all of which may be considered personal information:
(a) (b) (c) (d) (e)
We collect personal information from you when you voluntarily provide it directly to us and directly from you or indirectly from your or from your browser or mobile device when you engage in activities on the Company Sites. We also receive personal information from partners, cooperative databases, and personal information supplementation services, and share personal information with such sources.
We use the personal information we collect for various commercial and business purposes, including to:
(a) (b) (c) (d) (e) (f) (g) (h) (i) (j) (k) (l) (m) (n) (o) (p) (q)
Depending on the activity, some of the personal information we collect is required and some is provided by you voluntarily. If you do not provide the required information for a particular activity, you may not be permitted to engage in that activity.
The personal information that you directly provide to us to create your Account will be available for viewing by visiting the Company Sites and entering your personal log-in information that you create when registering your Account. By creating an Account, you may also utilize the "My Wine Cellar" feature of your Account, which tracks your order history, status of pending orders, favorites, preferences, credits, and Wine Club memberships. If you choose not to create an Account but to instead place orders by using a Guest Log-In, you may contact the Company to review or update the personal information you have provided by using the telephone numbers and/or addresses listed below under the heading entitled "Contact Information."
The Company Sites are directed to adults aged twenty-one (21) or older.
When you visit the Company Sites, we may also collect certain non-personally identifiable information from you ("NPII"), including, without limitation, website usage information about how our visitors use and navigate the Company Sites, including the number and frequency of visitors to each web page, the duration of their stays, the visitor's browser and operating system, the domain name of each visitor's Internet service provider, and certain other information (e.g., clickstream data). We may aggregate IP addresses into NPII, to report aggregate information to our business partners or to audit use of the Company Sites. We may share NPII with others without express notice to you or consent from you, and we may exploit, use and disclose your NPII without limitation of any kind.
We and advertising companies that we use may also use "pixel tags" (sometimes called "web beacons" or "clear gifs"), which are tiny graphic images, on the Company Sites. Pixel tags help us analyze users' online behavior and measure the effectiveness of the Company Sites and our advertising and marketing. We may also use other analytical tools to evaluate site performance through the use of aggregated data, which contain no personal information. We work with service providers that help us track, collect and analyze this information.
We may also track certain information about the identity of the Company Sites you visited immediately before coming to the Company Sites. We do not otherwise track any information about your use of other Company Sites. Cookies, pixel tags, and/or other analytical tools in our emails may also be used to track your interactions with those messages, such as when you receive, open, or click a link in an email message from us.
We may combine the NPII collected through cookies, pixel tags, action tags and other analytical tools with other information we may have collected from you. This information may be used to improve the Company Sites, to personalize your online experience, to help us deliver information to you, to determine the effectiveness of advertising, and for other internal business purposes.
WITH WHOM INFORMATION MAY BE SHARED
We work with certain strategic partners (the "Brand Partners") in connection with the creation and operation of various co-branded Wine Clubs, which are promoted by us and our Brand Partners. We disclose only the personal information required to make these particular Wine Clubs work and to support your membership with them, which typically includes your name and/or email address, as well as information regarding the purchases you make through the particular Wine Club. We disclose this information to our Brand Partners under an agreement that requires that they maintain the confidentiality and security of your personal information in the same manner the Company does. If you do not wish to receive marketing, promotional, or other communications from our Brand Partners, you must contact them directly.
We may sell, transfer or otherwise disclose user information, including personal information, in connection with a corporate merger, consolidation, the sale of all or substantially all assets or of a business group, or other corporate change of the Company.
We may disclose information about our users, including personal information, when legally required to do so at the request of governmental authorities conducting an audit or investigation, or to verify or enforce compliance with the policies governing the Company Sites and applicable laws, rules, and regulations. We may use IP addresses to identify users in cooperation with Internet service providers or law enforcement agencies, and may also disclose user information whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests or safety of the Company Sites, our users or others.
CHANGING YOUR PREFERENCES; OPT-OUT
You may opt out of your subscriptions to receive marketing mailings or e-mail communications from the Company at any time by (a) following the instructions to "opt-out" of future marketing communications contained within the direct mailing, or e-mail, that you receive from the Company, or (b) by sending us an email or writing to us at the addresses listed below under the heading entitled "Contact Information." Please allow up to ten (10) business days for changes to take place. During that time, you may continue to receive such communications from us that were already in process.
If you do not receive a response from us to any emails you send to us within ten (10) business days, please send us another email as your original email may not have been received.
LINKS TO OTHER SITES AND CONTENT ACCESSIBLE THROUGH THE COMPANY SITES
Our Company Sites may include links to other websites whose privacy practices may differ from ours. We are not responsible for the privacy practices of websites operated by third parties that are linked to or integrated with the Company Sites or for the privacy practices of third parties. If you submit personal information to any of those websites, your personal information is governed by the privacy statements of those websites. We encourage you to carefully read the privacy statement of any website you visit.
While the Company strives to secure your personal information, even reasonable security measures do not guarantee the security of any information you transmit via the internet, including to the Company. The Company cannot guarantee that information it seeks to protect will be protected under all circumstances, including those beyond its reasonable control. You acknowledge and agree that you transmit information to the Company via the Company Sites at your own risk. Additionally, please be advised that if you share emails you receive from the Company with others, you may be unintentionally sharing your personal information contained in these emails with such parties and acknowledge that you will be sharing at your own risk.
The Company Sites are directed to adults aged twenty-one (21) or older. We do not knowingly collect personal information from children under thirteen (13) years of age. We will promptly delete any information later determined to be from a user younger than thirteen (13) years of age.
CONSENT TO TRANSFER
The Company Sites are located in the United States. Your personal information will be processed and shared in the United States. Your data will also be processed in the United Kingdom and accessed from the United States. Data protection and privacy regulations in the United States may provide different levels of protection compared with non-United States jurisdictions. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the Company Sites or providing us with your information, you consent to this transfer.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California Civil Code Section 1798.83 permits you to request information with respect to the disclosure of your personal information by us to third parties for such third parties' direct marketing purposes. We are only required to respond to a particular customer's request for such information once during a calendar year. To make such a request, please send us an email or write to us at the addresses listed below under the heading entitled "Contact Information."
In addition, please note the following:
(a) (b) (c) (d) (e) (f) (g)
Rights and Choices for California Residents
The California Consumer Privacy Act ("CCPA") provides California residents with specific rights regarding their personal information. This section describes California residents' CCPA rights and explains how to exercise those rights. If you are a resident of a state other than California, we may respond to requests in ways that differ from responses that are required only under California law.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your request, we will disclose to you:
(a) (b) (c) (d) (e) (f)
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, 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 providers to:
(a) (b) (c) (d) (e) (f) (g) (h)
Please note that because we archive and keep track of past transactions, the Company will deny requests to delete information associated with past transactions or archived information on the Company Sites.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to at the Contact Information provided below or on at our website at: Deletion Request Link
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Our processes for verifying requests include matching identifying information that we already have on record to provide services to the customers.
We cannot respond to your 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. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 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 the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Right Not to Sell or Share Personal Information
You have the right to opt-out of us selling your personal information. The contributing of personal information to a cooperative database may be considered a sale of that information under the CCPA. For an opt-out request and additional information concerning your right to opt-out, click on this link: Do not sell my personal information. You may also contact us through the Contact Information provided below.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
(a) (b) (c) (d)
We do not want you to send to us any confidential or proprietary information through email or otherwise. Any information, materials, suggestions, ideas or comments sent to us will be considered non-confidential, and by submitting the same to us, you are giving us the absolute right to use, modify, reproduce, transmit, display and distribute the information for any purpose whatsoever, with no payment or other compensation to you. However, we will not use your name unless we are required by law to identify the source of the materials, information, suggestions, ideas or comments, or unless we first obtain your permission.
WSJwine from The Wall Street Journal
Attn: Customer Service PO Box 2470
Largo, FL 33779
EFFECTIVE DATE OF POLICY