PRIVACY POLICY

This Privacy Policy describes the information, including personally identifiable information, we collect when you sign up for, use, access or otherwise interact with any of our applications, products, services, or websites (collectively, “Services”) hosted by WineDirect , how we use and share that information, and your options. This policy applies to you, including visitors and consumers (“Users”), unless specified otherwise herein.  It applies to all information we collect through our Services, even if you have not signed up for an account or downloaded one of our applications. This policy does not, however, describe the practices of third parties that may collect information from you when you interact with them, including our use of WineDirect to accept payment for goods or services. We encourage you to ask them about their privacy practices before providing any information to them. To the extent any portions of the following policy are inconsistent with applicable law or regulations, or to the extent you provide your express consent for uses not specifically described herein, then such laws or regulations, or your express consent, will govern our use of your information.

We may change this policy from time to time, at our sole discretion. If we make changes, notification to you will be made by our posting the updated policy and revising the "Last Updated" date above. We encourage you to review the policy whenever you use our Services to stay informed about our information practices and about the options available to you.

COLLECTION OF INFORMATION

Information You Provide

We collect information you provide, such as when you sign up for an account, in the course of a transaction, or merely when you access our applications, websites, documentation, or Services. We may collect, but are not limited to collecting, the following:  basic user information such as your name, email address, mailing address, phone number, birth date; personal interests or preferences; or purchases or use of our products or services.   We may collect financial information from or about you, including bank account and payment card numbers and expiration dates; and other historical, contact, and demographic information relevant to responding to your inquiries and providing services to you, or third parties with whom we do business.  Our policy is not to request or collect especially sensitive personally identifiable information, such as religious preferences, racial or ethnic background or other similar forms of data.
 

Information We Collect from Your Use of the Services

We collect information about you when you use our Services, including as follows:

When you use our Services to make payments or money transfers, we collect information about when and where the transactions occurred, a description of the transactions, the payment or transfer amounts, billing and shipping information, and information about the devices and payment methods used to complete the transactions.  When one of our applications is open on your mobile device, we periodically receive information about the location of the device.   We collect device-specific information when you access our Services, including your hardware model, operating system and version, unique device identifiers, mobile network information, and information about the device's interaction with our Services. We may also identify other software running on the device (but will not collect any content from such software) for anti-fraud and malware-prevention purposes.

We may also collect non-personally identifiable information about your use of the Services, such as your access times, domains, browser type, version and language, operating system, and Internet Protocol (“IP”) addresses (together, “Use Data”).
 

Certain Other Forms of Information Collected

Cookies, Web Beacons, and Log Files

We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files that are stored on your hard drive or in device memory by a website. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. We may also collect information using web beacons. Web beacons are electronic images that may be used in our Services or emails. We may use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon.  Like most standard website servers, our Services use log files.  This includes IP addresses, browser type, internet service provider (“ISP”), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track users’ movement and gather demographic information for aggregate use.  IP addresses are not linked to personally identifiable sites.
 

Information We Collect From Other Sources

We may also collect information about you from third parties, including but not limited to third-party verification services, credit bureaus, mailing list providers, and publicly available sources. In some circumstances, this information may include your Social Security or taxpayer identification number.
 

Third-Party Advertising and Analytics

We may allow third parties to serve advertisements in connection with our Services and to provide analytics services. These third parties may use cookies, web beacons, and other technologies to collect information, such as your IP addresses, identifiers associated with your mobile device or applications on the device, the browsers you use to visit our Services, pages viewed, time spent on pages, links clicked, and conversion information. This information may be used by us, WineDirect and other companies to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your usage. We have no access or control over cookies or other features that third parties may use.  This policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies and we encourage you to check the privacy policies of these third parties to learn more about their privacy practices.

USE OF INFORMATION

We may use personal information about you as follows:

1. We use information about you to provide, maintain, and improve our Services and to deliver the information and support you request, including receipts, technical notices, security alerts, support and administrative messages;
2. We also use information about you to personalize the Services, or to fulfill our obligations to you pursuant to any contracts or agreements that you may enter into with us, or in connection with any of our programs, events or promotions in which you register or participate.  We may use your information to establish and activate your account, to provide assistance or support with respect to your use of our Services, to troubleshoot problems and to resolve disputes that may arise.  For example, when you sign up for an account, we may associate certain information with your new account, such as information about other accounts you have or had with companies hosted by WineDirect and prior transactions you made through the WineDirect -hosted Services;
3. We receive personally identifiable information from you which we require so that we may fulfill our contractual obligations to you.  This may include processing orders that you place, sending you emails regarding your accounts and orders, and giving you updates and announcements.  This information may include:  contact information such as name and shipping address; financial information such as credit card number, expiration date, billing address, and billing phone number.  This information is used for billing purposes to verify that you, the customer, is of legal age, and to fill customer’s orders.  It is our policy to use your personally identifiable information consistent with the terms of this privacy policy;
4. We may use the content within your database to populate orders across any other client in WineDirect , however, this will only happen if a credit card is used in a transaction and that same credit card has been used in other transactions across all WineDirect Clients;
5. We may use information we collect to send you news and information about our Services and to communicate with you about products, services, contests, promotions, incentives, and rewards offered by us and select partners;
6. We may use information about you to track and analyze trends and usage in connection with our Services; to improve content, advertising or Services, to process and deliver contest and promotion entries and rewards; to protect our rights or property; to verify your identity; to investigate and prevent fraud or other illegal activities; and for any other purpose disclosed to you in connection with our Services;
7. We may, or we may use third-party service providers to, process and store personal information in the United States and other countries;

SHARING OF INFORMATION

We may share personal information about you as follows:

1. With WineDirect clients with whom we use the content within your database to populate orders across any client in WineDirect ;
2. With third parties that provide information processing services to us, that maintain and improve our Services, including service providers who access information about you to perform services on our behalf (e.g., fraud prevention and verification services), and including financial institutions, processors, payment card associations, and other entities that are part of the payment or transfer process;
3. In response to a request by law enforcement or other governmental entity or court order or subpoena; if under a legal obligation to do so, to protect the integrity of our company if we believe that a user has committed unlawful or otherwise harmful acts; to protect our interest in connection with a legal proceeding; in emergency situation to protect health or safety; if we believe such disclosure is in your vital interest; or if we obtained your information from public sources;
4. In the event of a corporate transaction, such as a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of any or all of our assets or liabilities, in which some of the personal information that we hold may be among the assets or liabilities transferred to a buyer or other successor; in connection with, or during negotiations of, any merger, acquisition, sale of assets or liabilities or any line of business, change in ownership control, financing transaction, or in the unlikely event of a bankruptcy;
5. With third parties that run advertising campaigns, contests, special offers, or other events or activities in connection with our Services;
6. If we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request; to enforce applicable agreements or policies; to protect the security or integrity of our Services; and to protect us, our Sellers, end users, or the public from harm or illegal activities; and
7. With your consent.

We may also share aggregated, non-personally identifiable information with third parties.

SECURITY

We take appropriate and reasonable measures, including administrative, technical, and physical safeguards, to help protect personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction.  We will make all commercially reasonable efforts to keep the website secure from third party interference, including but not limited to unauthorized third party amendment of the website or third party access to any data not intended to be publicly available via the website.  However, no transmission of data over the internet is guaranteed to be completely secure, and we cannot guarantee the security of any information you provide to us.  Therefore, although we use industry standard practices to protect your privacy, we do not promise or guarantee, and you should not expect, that your personally identifiable information or communications with us will always remain private.  We will notify you immediately if any such third party interference occurs.

YOUR OPTIONS

We intend to keep your information secure, accurate and up-to-date.  You have the opportunity to review and correct any of your information we may have, or to restrict (“Opt-out”) of the uses we make of your information.  In order to review, correct, or restrict your information we have on file, please take the following steps:

Location Information

When you first launch our mobile applications, you will be asked to consent to the application's collection of location information. We currently require this location information in order to provide our Services, so if you do not consent to this collection, you cannot use our Services. If you initially consent to our collection of location information, you can subsequently stop our collection of location information at any time by changing the preferences on your mobile device. If you do so, the WineDirect application will no longer function. You may also stop our collection of location information by following the standard uninstall process to remove WineDirect applications from your device.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject cookies; however, our Services may not function properly if you do so.

Preferences

You may change or correct information about yourself by logging into your account at any time or by emailing us. You may also disconnect your credit card from populating your email address, first name and last name by going to this page: https://www.WineDirect .com/digital-opt-out and filling out the opt-out form online. We may retain archived copies of information about you and your transactions for a period of time that is consistent with applicable law.  You may opt-out of allowing us to use or share the content within your database to populate orders across any client in WineDirect , however, this may interrupt or restrict you use of the Services. You may opt out of receiving promotional emails or text messages from us, other WineDirect clients by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional communications, such as digital receipts and messages about your account or our ongoing business relations.

Your California Privacy Rights

California law permits residents of California to request certain details about information we disclose to third parties for direct marketing purposes. If you are a California resident and would like to request this information, please contact us.

MINORS

Our Services are not directed toward individuals under twenty-one years of age (“Minors”), nor do we knowingly collect information from Minors.

Contact

Please contact us with any questions or concerns regarding our policy. (707) 833-5501