Updated November 10th, 2020
1. What is this document and why should you read it?
We know that personal information is important to you, and we want you to know that we take your privacy seriously.
Please take a moment to read this policy. It explains what we do with personal information about you, and what measures we take to protect your privacy.
In short, WIne Club Development Group LLC and its business assets and subsidiaries, including Enoteca Direct, collect various types of personal information from you. We collect this information when you visit one of our websites, when you contact us, when you sign up to receive special offers or promotions, when you place an order from us, when you make a payment to us, or when you apply to us for a job.
With respect to personal information we collect about you, you may be entitled to certain rights, so we encourage you to read this policy carefully, and to contact us if you have any questions.
2. What is personal "information"?
When we use the term "personal information" (otherwise known as "personal data" or "personally identifiable information") we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It is a broad definition, and includes pieces of information like your name, address, telephone number, or email address.
Certain pieces of information that are not personal information include publicly available information, deidentified information, or aggregate information. By "aggregate information" or "deidentified information," we mean information that does not allow us to identify or contact a specific individual. For example, the number of users of our websites is aggregate information which does not reveal who those users are.
3. What personal information do we collect and why?
Whenever we collect personal information about you, we do so in accordance with the principles outlined in this policy and applicable law. Note that while we may use terms like "lawful basis" from a particular law, it does not necessarily mean that the specific law applies to us. In addition, we strive to be as transparent as possible, even more than what the law requires at times.
We typically collect your personal information directly from you (for example, when you purchase one of our products). We may also collect personal data about you from third parties (that is, individuals and organizations that are not part of Wine Group Development LLC).
INFORMATION WE COLLECT
If you sign up for our mailing list or reach out via a contact form, we may collect your name, email address, phone number, address, and/or any other information you provide us through our various contact forms.
This information is necessary to send you the information you have requested. We may also use this information to promote and market our current and future products and services; to inform you of upcoming events, special promotions and offers, discounts, and other matters that may we think may be of interest to you.
Consent; it is in our legitimate interest to advertise our products and services.
If you purchase a product from us, or make a payment to us, we may collect your name, age and date of birth, email, postal address (billing and shipping), phone number, product preferences, credit or debit card number, signature, or IP address (if the purchase is made over one of our websites).
This information is necessary to process your order. We may also use this information to promote and market our current and future products and services; to inform you of upcoming events, special promotions and offers, discounts, and other matters that may we think may be of interest to you.
Consent; it is necessary for us to take steps at your request to enter into or perform on the sales contract with you; it is in our legitimate interest to advertise our products and services.
4. Who do we share personal information about you with, and why?
We may share information among our affiliates.
In addition, the broad classes of third-parties to which we may transfer personal information about you include: payment processors; accountants; lawyers; marketing firms engaged by us to keep you aware of upcoming events or new products/services, and to provide analytics information to us; freight carriers or brokers involved in the delivery of our products to you; and contract compliance companies engaged to ensure payments received from you, or made to you by us, are consistent with the terms or our agreements with you. We also transfer some personal information about you to governmental authorities (including tax authorities) where required by, or in order to comply with, law.
We do not and will not sell personal information about you.
We will endeavor to ensure that all non-governmental third parties to which we transfer personal information about you agree, as part of their contract with us, to treat personal information about you in accordance with applicable privacy laws.
From time to time, we may also be required to provide your personal information to other persons, such as in the event that we sell any business or assets (in which case we may disclose your personal information to the prospective buyer of such business or assets) or if we, or substantially all of our assets, are acquired by a third party (in which case personal information held by us about you will be one of the transferred assets) or if we are required to disclose your personal information in connection with any legal proceedings or requirements (such as to our lawyers, government agencies, courts or tribunals).
5. Where do we keep personal information about you and how long do we keep it for?
We store personal information about you in physical files or on computer systems operated by or under the instruction of Wine Club Development Group, and/or at our facilities in the United States. We will maintain personal information about you for as long as necessary in connection with both our and your legal rights and obligations, and in accordance with our current or future records retention schedule.
6. How do we keep personal information about you secure?
We have reasonable measures in place to prevent personal information from being accidentally lost, used, or accessed in an unauthorized way. We limit access to personal information to those who have a business need for such access. Those individuals who process personal information on our behalf may do so only in an authorized manner. They are also subject to a duty of confidentiality. We have policies in place that regulate how employees within Wine Club Development Group LLC must handle data, including personal information. We limit access to our premises and to our computer networks, and we take reasonable steps to safeguard against unauthorized access to such premises and networks. We have procedures in place to manage any suspected data security breach and will notify you and any applicable regulator of a suspected data security breach consistent with legal requirements.
7. What are your rights in relation to personal information about you and how can you exercise them?
You may have various rights with respect to the information we have about you depending on the particular information and the context in which it was obtained. These rights are defined under a variety of privacy laws and regulations, each of which may or may not be applicable to our relationship with you or certain information we have about you. We may choose to offer these rights to you in the interests of transparency and as an enhanced service to you, even if we are not required to under applicable law.
Privacy Rights under the California Consumer Privacy Act
For residents of California, you may have the rights described below with respect to personal information about you. Subject to certain conditions and limitations, you may have the following rights with respect to personal information about you: Right of access – You may be entitled to request that we disclose to you: (a) personal information we have collected about you; (b) the categories of sources from which the information was collected; (c) the purposes of collecting the information; (d) the categories of third parties we have shared the information with; and (e) the categories of personal information that have been shared with third parties for a business purpose. Data solely retained for data backup purposes is principally excluded.
Right of data portability – In some instances, you may have the right to receive the information about you in a portable and readily usable format. Before providing this information, we must be able to verify your identity. Data solely retained for data backup purposes is principally excluded.
Right to have personal data erased – Subject to certain conditions, you may be entitled to request that we delete personal information about you. Before deleting information, we must be able to verify your identity. We will not delete personal information about you when the information is required to fulfill a legal obligation, is necessary to exercise or defend legal claims, or where we are required or permitted to retain the information by law. For example, we cannot delete information about you while continuing to maintain the mortgage insurance policy relating to your loan. Data solely retained for data backup purposes is principally excluded.
Without prejudice to any other administrative or judicial remedy you might have, you may have the right to lodge a complaint with regulators where you live if you believe that we have infringed applicable privacy or data protection requirements when processing personal information about you.
If you chose to exercise any of these rights, to the extent that they apply, U.S. state law prohibits us from discriminating against you on the basis of choosing to exercise your privacy rights. We may, however, charge a different rate or provide a different level of service to the extent permitted by law.
8. How do I submit a privacy request?
Requests to exercise your privacy rights as noted above, to the extent applicable, may be made by contacting us at 408-402-5842 or through email at email@example.com.
Before providing information you request in accordance with your rights, we must be able to verify your identity. In order to verify your identity, you will need to submit information about yourself. We will match this information against information we have previously collected about you to verify your identity and your request. To the extent you maintain an account with us, we will require you to login to that account as part of submitting your request. If we are unable to verify your identity as part of your request, we will not be able to satisfy your request. We are not obligated to collect additional information in order to enable you to verify your identity. For deletion requests, you will be required to submit a verifiable request for deletion and then to confirm separately that you want personal information about you deleted.
If you would like to appoint an authorized agent to make a request on your behalf, and that agent is not already authorized to access your account in your profile, please submit a notarized special power of attorney, or a signed letter from an attorney representing you, identifying the agent and authorizing them to submit requests and receive information on your behalf. We may require you to verify your identity with us directly before we provide any requested information to your approved agent.
9. Where can I find out more?
If you have any questions, concerns, complaints or suggestions regarding this privacy notice, have any requests related to your personal data pursuant to applicable laws, or otherwise need to contact us, you may do so by contacting us at firstname.lastname@example.org.
10. Changes to this Privacy Notice
We may change this privacy notice at any time, and in accordance with applicable law. We will post the revised policy to our website. The date this notice was last revised will appear at the top of the page.
11. Direct Mailings
To opt-out of receiving our direct mail, you may send us an email at email@example.com, call us at 408-402-5842, or send a written request to 534 N Santa Cruz Ave, Los Gatos, CA 95030. We will honor those requests, but please understand that it may take 60-180 days for such mailings to end.