WINE TRADERS INTERNATIONAL (hereinafter "Winery") and its brands, affiliates, subsidiaries, companies and/or their related brands (collectively referred to here as "we," "our," or "us") created this Privacy Policy to inform our website users, club members, event registrants/participants, newsletter/information recipients, promotion, contest, sweepstakes or campaign participants, online community participants, those who correspond with us via SMS (text message), those who purchase or inquire about our products and services and others (collectively referred to as "customers") about our practices regarding collection, use and disclosure of personally identifiable information ("personal data") that we collect from them. All references to our "website" in this Privacy Policy includes any of our affiliated microsites linked to our website as well as any of our affiliated mobile applications.
This Privacy Policy does not apply, however, to Winery employees, employment applicants, suppliers, distributors or trade contacts except when they are acting in a "customer" capacity; in all other circumstances, other policies apply. This Privacy Policy also does not apply to any of our other websites that contain a separate privacy policy.
While our website or other materials may include links or references to non- Winery websites, materials or entities, this Privacy Policy does not apply to any data that may be collected through those non- Winery sites, materials or entities, unless otherwise indicated. This includes any websites of affiliated entities. We may update this Privacy Policy from time to time, as specified in the "Changes to This Privacy Policy" section below.
Your Consent You should read this entire Privacy Policy before submitting information to us or using our website. Whenever you submit information via our website or otherwise to us, whether online or offline, you consent to the collection, use and disclosure of that information in accordance with this Privacy Policy.
Intended Audience of Websites Given the nature of our business, our website is intended only for individuals who are of legal drinking age. As a result, our website does not request or knowingly collect personal data from individuals under the legal drinking age. If you are not of legal drinking age, you should not visit or use our website.
Information Collection and Use We may collect personal data (including, without limitation, age, birthdate, address, email address, phone number, Facebook, Instagram or Twitter account information, and geographic location) from customers both online and offline. Online, we may collect information through our website, an affiliated site (such as a promotional microsite linked to our site), a brand page on a community website (such as Facebook or the like) or through similar online avenues, and via mobile phone applications or SMS (text message) correspondence. In many cases, such information will be collected directly from you, such as through a transaction or inquiry (including via a telephone call or SMS correspondence) or your submission of a form, registration or communication to us. Information may also be gathered from our affiliates, companies and their related brands and from third-party sources (including without limitation, our third-party service providers (such as marketing and fulfillment companies), opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals) and through your activities and interactions with us, including, without limitation, your online activity on our website. We may combine data collected from these disparate sources unless we tell you otherwise. Any of your personal data or other information gathered by one of our brands may be shared with and used by any of our other brands in accordance with this Privacy Policy. As you use our website, some information can be "passively" collected using various technologies, such as cookies, web beacons and navigational and location data collection (clickstream, log files, server logs). Your Internet browser automatically transmits some of this information, such as the URL of the website you just visited and the Internet Protocol (IP) address and browser version currently being used by your computer. Such technologies help us to keep track of your interactions with our website and provide you with a more customized experience.
We use personal data about customers for a wide range of purposes. We use it to respond to your requests (including requests for newsletter subscriptions, materials, coupons/rebates/discounts and so on); to provide products or services that you have ordered; to process your order transactions and contact you regarding your order; to invite and help you to participate in a range of online and offline events, activities and/or clubs; to allow you to post information and other content online; to improve our products, services and websites; to follow up with you after you have communicated with us or submitted information to us; to send promotional communications or offers (unless you have requested that we not send such communications); for marketing, research and legal purposes and other purposes (including, without limitation, call center recordings); to permit you to participate in and to otherwise administer sweepstakes, promotions, campaigns and contests; to allow you to contact another person; to address your interests and concerns; and as otherwise specified in this Privacy Policy and/or at the point of personal data collection.
We may disclose personal data you provide to any of our other brands and to our affiliates, companies and/or their related brands, and to consultants, service providers, promotional partners and contractors that we use to support our business and operations (e.g., delivery services, financial institutions, fulfillment services, technical support, advertising, public relations, media and marketing services, sweepstakes, promotions, campaigns and contest-related services, call-in centers, e-commerce and other web-related services such as web hosting and web monitoring services and event-related services such as online and offline data capture) who have agreed to keep the information confidential and use it only to provide the applicable service(s). In some cases, we work with other companies who help to gather information from you or help us to communicate with you. For example, our mobile applications or SMS correspondence campaigns may be administered by a third-party service provider. Where the law allows it, we may share customers' personal data with affiliates, companies and/or their related brands or selected third-party partners to enable them to market their or other selected third parties' products and services to you. You may let us know that you do not want your personal data shared in this way by contacting us via our website. We may also disclose personal data to 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; 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; or in connection with disciplinary actions/investigations. Likewise, we may disclose personal data to third parties in connection with the sale, assignment or other transfer of the business of our website or the sale, assignment, merger, reorganization or other transfer of any of our brands or companies.
The recipients of customers' personal data, and more generally these disclosures, may be located in the United States or other jurisdictions that might not provide a level of protection equivalent to the laws in your jurisdiction. By submitting personal data to us, you consent to the transfer of such personal data outside your jurisdiction. We may make full use of all information that is de-identified or otherwise not in personally identifiable form. We (including any of our other brands) may also make full use of all user-generated content you submit to us.
Security Measures & Data Protection We take appropriate technical and organizational security measures to protect personal data from loss, misuse, unauthorized access, disclosure, or alteration. Please keep in mind, however, there is no such thing as perfect security, and no Internet transmission is ever completely secure or error-free. Moreover, you are responsible for maintaining the confidentiality of any user name and password you use, if applicable.
This website is hosted on our web servers in the United States. If you are located in a non-US jurisdiction, your provision of personal data to our website constitutes your transfer of such data to the United States, a jurisdiction that may not provide an equivalent level of data protection to the laws in your home country. It's Your Choice: Contact Preferences; Opt-In and Opt-Out We want to keep in touch with you in ways that you find to be beneficial. If you don't want us to use your contact information to communicate with you for promotional purposes (such as to tell you about other products and services that might be of interest or to offer coupons/discounts), please tell us that when you provide your contact information. You can also let us know your preference later by contacting us as specified in the "Contact Us" section of our website. Keep in mind that these preferences regarding promotional contacts do not mean that we might not contact you for other reasons, such as those related to an order you placed, an inquiry you made, a message that a friend or acquaintance requested be delivered (such as through our tell-a-friend/invite-a-friend features), a newsletter to which you may have subscribed, a membership you undertook, an event for which you registered, a legally required notice and so on. Access To keep personal data provided by you accurate, current and complete, please contact us as specified in the "Contact Us" section. We can then take appropriate steps to update or correct such information in our possession or to delete your information from our contact list.
Changes to This Privacy Policy This Privacy Policy may be revised from time to time for any reason. If this Privacy 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. Any such changes will automatically apply to all uses of our website and collection and use of your personal data by us, on or after such effective date (until such time as this Privacy Policy is subsequently revised. If you don't want us to use your personal data according to the terms of the new policy, you can opt-out by contacting us via the website. Be sure to check the Privacy Policy whenever you submit personal data or use our website or social media accounts. The effective date of this Privacy Policy is October 2017.
