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This Privacy Notice applies to the personal information collected in connection with WSJwine, including through the WSJwine website www.wsjwine.com (the "Site"). The Site is operated by Direct Wines, Inc. ("Direct Wines"), which partners with Dow Jones & Company, Inc. and its subsidiaries ("Dow Jones"), to offer WSJwine (collectively, "we", "us", "our"). The Privacy Notice describes the types of personal information we may collect, how we may use the information, with whom we may share it, and the choices available to you regarding our use of the information. We also describe the measures we take to safeguard your personal information and how you can contact us about our privacy practices. This Site is directed solely to consumers in the United States.
INFORMATION WE OBTAIN
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.
When you visit our Site or otherwise contact us, we may obtain certain personal information about you, including:
(a) (b) (c) (d) (e) (f) (g)
Depending on the activity, some of the personal information we collect is required and some are 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. For example, you must provide age related information to use our Site or order products.
Information We Obtain By Automated Means
When you visit our Site or interact with emails we send to you, we may obtain certain information by automated means, such as cookies, web beacons, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server.
We may use these automated technologies on our Site and in our emails to you to collect information about your device, browsing actions, and usage patterns. The information we obtain in this manner may include your device IP address, identifiers associated with your devices, types of devices you use to connect to our Site, web browser characteristics, operating system, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of visits to our Site. These technologies help us (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with our Site and our email communications; (3) tailor our Site around your preferences; (4) measure the usability of our Site and the effectiveness of our communications; and (5) otherwise manage and enhance our Site and services, and help ensure they are working properly.
Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features on our Site. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.
Our Site is not designed to respond to "do not track" signals from browsers.
HOW WE USE THE INFORMATION WE OBTAIN
We may use your personal information to:
We also may use the information in other ways for which we provide specific notice at the time of collection.
We may use third-party analytics services on our Site. The information we obtain through our Site may be disclosed to or collected directly by these services. To learn more about Google Analytics, please visit https://www.google.com/policies/privacy/partners/.
Dow Jones and Direct Wines may share certain information we obtain about you through WSJwine with each other and with our affiliates and subsidiaries. We also may share certain information we obtain about you through WSJwine with wineries and retailers with which we work to enable you to order products and for the wineries and retailers to fulfill such orders. We further may share the information we obtain about you with service providers and other entities to perform certain services on our behalf. We do not authorize our service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.
In addition, we may disclose personal information (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; or (5) in connection with an investigation of suspected or actual illegal activity.
We reserve the right to transfer any personal information we have about you in the event we sell or transfer (or contemplate the sale or transfer of) all or a portion of our business or assets (including in the event of a merger, consolidation, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).
YOUR RIGHTS AND CHOICES
We offer you certain choices regarding the personal information we collect from you in connection with WSJwine. To update your preferences, limit the communications you receive from us, or submit a request, please contact us as indicated in the "How To Contact Us" section of this Privacy Notice. You can unsubscribe from our marketing mailing lists by following the "Unsubscribe" link in our emails or contacting us as specified in the "How To Contact Us" section below. We will apply your preferences going forward.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.
You also may view and update the personal information that you provide to us to create your WSJwine account. The information will be available to view and update by visiting the Site and entering your WSJwine account log-in information. If you choose not to create a WSJwine account and instead place orders through the Site as a guest, you may view or update your personal information by contacting us as indicated in the “How to Contact Us” section of this Privacy Notice.
If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Notice called California Consumer Privacy Statement.
HOW WE PROTECT PERSONAL INFORMATION
We maintain administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Our Site is directed to adults 21 years of age or older. We do not knowingly collect personal information online from children under the age of 13.
OTHER ONLINE SERVICES AND THIRD-PARTY FEATURES
For your convenience and information, our Site may provide links to other websites or offer features provided by other online services. For example, we may permit you to log in to your WSJwine account via social networks. These third-party websites and online services may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, is subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked third-party website or online service is not owned or controlled by us, we are not responsible for these third parties’ information practices.
UPDATES TO OUR PRIVACY NOTICE
This Privacy Notice may be updated periodically and to reflect changes in our personal information practices. We will indicate at the top of the Privacy Notice when it was most recently updated.
HOW TO CONTACT US
If you have any questions or comments about this Privacy Notice, please email us at email@example.com or by phone at 1-877-975-9463. You also may write to:
WSJwine from The Wall Street Journal
Attn: Customer Service PO Box 6821
Scarborough, ME 04070
CALIFORNIA CONSUMER PRIVACY STATEMENT
This California Consumer Privacy Statement ("Statement") supplements the WSJwine Privacy Notice. It applies solely to California consumers and addresses personal information we collect online and offline. This Statement does not apply to our personnel or job applicants.
This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the "CCPA").
We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:(a) (b) (c) (d) (e) (f) (g) (h)
We may use (and may have used during the 12-month period prior to the effective date of this Statement) your personal information for the purposes described in the WSJwine Privacy Notice and for the following business purposes specified in the CCPA:
During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:(a) (b) (c) (d) (e) (f) (g) (h) (i) (j) (k) 3.
We may allow certain third parties (such as online advertising services) to collect your personal information via automated technologies on our Site in exchange for non-monetary consideration. We may share the categories of personal information listed below for online advertising purposes. You have the right to opt-out of such disclosures of your information, which may be considered a "sale" under California law.
During the 12-month period prior to the effective date of this Statement, we may have sold the following categories of personal information to the following categories of third parties:
|Category of Personal Information||Category of Third Party|
|Identifiers||Third parties for their direct marketing
|Commercial Information||Third parties for their direct marketing
|Online Activity||Data analytics providers|
We do not have actual knowledge that we sell personal information of minors under 16 years of age.
During the 12-month period prior to the effective date of this Statement, we may have disclosed personal information about you with the following categories of third parties:5.
You have certain choices regarding the personal information we obtain about you in connection with WSJwine, as described below.
How to Submit a Request. To submit an access or deletion request, click here or email us at firstname.lastname@example.org. To submit a Shine the Light request, email us at email@example.com. To opt out of the sale of your personal information, click on this link: Do Not Sell My Personal Information or email us at firstname.lastname@example.org Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a request related to your personal information. To submit a request as an authorized agent on behalf of a consumer, email us at email@example.com and provide us with documentation establishing that you are an authorized agent. For questions or concerns about our privacy practices, please contact us as described in the Contact Us section of our Privacy Notice.
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we may verify your identity by requiring you to sign in to your account. If you do not have an account with us and you request access to or deletion of your personal information, we may require you to provide any of the following information: your name, email address, billing and shipping address, telephone numbers, or date of birth. In addition, if you do not have an account and you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Additional Information. If you choose to exercise any of your right under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
EFFECTIVE DATE OF POLICY