Wine Insiders Privacy Policy

Last updated April 18, 2023

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This website (collectively, with all other web pages and websites related to Wine Insiders, the "Site") is operated by Drinks Insiders, LLC (referred to herein as the "Company," "we," "our" or "us"). We are committed to protecting the privacy and security of your personal information. Please also visit the Wine Insiders Terms and Conditions for explanation of additional terms governing your use of the Site and the purchase of associated products. Capitalized terms used but not defined herein shall have the meanings ascribed to them in the Terms and Conditions.

This privacy policy (the "Privacy Policy") sets forth our data collection, use, security and sharing practices and applies when you access or use the Site, communicate with us through our customer support channels or via social media, use the Site's interactive features designed to facilitate interaction between you, Wine Insiders and other users of the Site such as product reviews, blogs and associated comment sections located in designated areas of the Site, or otherwise interact with us. Through use of the Site, we market wines and related products directly to consumers and provide consumers an opportunity to buy wine and related products from Licensed Retailers in their respective states (collectively the "Wine Services"). The sale and delivery of your order will be executed and fulfilled by licensed third-party retail entities that hold valid licenses issued by state alcohol beverage agencies allowing for the legal sale of wine (the "Licensed Retailers" or "Licensed Retailer"). The Site is directed to adults aged 21 or older, you must be at least 21 years of age to make a purchase through the Site and to receive delivery of the products purchased, and a valid government-issued ID will be required upon delivery.

Please read the terms of this Privacy Policy carefully. If you do not agree to the terms in their entirety, you may not access or otherwise use the Site or its offerings.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy. If we make material changes, we will provide you with additional notice (such as by adding a statement to our Site or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

We are not responsible for the content on, or the privacy practices of, any third-party website not owned or operated by us to which this Site links or that link to this Site. If you visit, or submit information to, any of those websites your visit and information are governed by the privacy statements of the third parties who own or operate those websites. We encourage you to carefully read the privacy statements of any website you visit.

INFORMATION WE COLLECT

The information we collect about you depends on how you interact with us. In this section, we describe the categories of information we collect.

• Identifiers such as name, email address, age and/or date of birth, billing address, shipping address, telephone number, online identifiers like user account name, and unique identifiers that we use for advertising purposes. If you make a gift purchase for someone else, we may collect the name, email address, age and/or date of birth, shipping address and telephone number of the gift recipient, as well as other information you choose to share with us.
• Contact information such as your email, billing address, delivery or shipping address, and phone number.
• Payment information: if you make a purchase through the Site, we work with a third-party payment processor to collect and process your payment information such as credit, debit, or other payment card numbers.
• Commercial and transaction information such as your purchase and transaction history, product details, purchase price, and the date and time of the transaction.
• Account information including your username, password, purchase information, address information, email and text communication preferences including your communication preferences relating to orders, marketing, and other activities.
• Online and technical information such as your IP address and device or other persistent identifiers, device characteristics, browser type and version, operating system, Internet service provider, other browsing data, data related to your viewing of (and interactions with) our advertisements, referring and exit pages, platform type, and other information that we collect using cookies, pixels, beacons, and other similar technologies to understand your interactions with our Site, including your browsing behavior, purchase behavior, and other engagement with our Site.
• Site usage information including information about how you use our Site, access times and length of stay, click data, items you place in your cart, specific pages accessed, search terms you used to reach our Site, links clicked and search terms input at the Site.
• Communication preferences including your preferences in receiving marketing.
• Audio information, such as recordings of your voice when you contact our customer service.
• Optional user content you may choose to provide, such as product reviews, comments, inquiries, responses to surveys or quizzes, sweepstakes entries, and the content of communications with our customer support team.
• Inferences including information derived from other information that we have collected. We create inferred and derived data elements by analyzing your transaction history in combination with other information we have collected about you to personalize product offerings, your shopping experience, marketing messages and promotional offers.

Some of the information about you may include personal information that can be used to identify you, like name, address, and email address. In certain states, the definition of personal information may be broader and include things like IP address, mobile device ID, and unique identifiers used by cookies. When the information we collect about you is considered personal information under applicable law, we treat it as personal information.

Personal information does not include data where your identity has been removed so that we can no longer identify you or that we aggregate so that you can no longer be identified, which we may use for any purpose.

HOW WE COLLECT YOUR INFORMATION

The following are examples of ways we may collect your information:

Directly From You

We collect information you provide directly to us, such as when you create an account, add items to your cart on our Site, place an order, make a payment, ask to receive emails or text messages, contact customer service, submit comments or reviews, respond to surveys, enter into sweepstakes or other programs, provide product reviews, submit comments or inquiries to us, communicate with our customer support team, interact with us on social media, submit a search on our Site, or otherwise contact us. With respect to your credit card information, when you make a purchase on the Site, your payment information is passed directly to our credit card processor in an encrypted format. We do not store your credit card information but, instead, receive a token that we match to your order to complete the transaction. We may ask you for information when you enter a promotion or sweepstake offered by us, sign up for an event sponsored by us, or when you report a problem to us.

From Your Device

Our computer servers automatically record information that your browser sends whenever you access or use the Site, make a purchase, or interact with our communications. Like most other websites, we collect certain information about your interactions with us automatically, including through the use of cookies, web beacons and other technologies throughout the Site.

From Other Sources

We may collect information about you, such as your name, email address, shipping and/or residence address, websites you visited, product preferences, product purchases, your user ID and/or user name associated with Social Media, any information or content you have permitted Social Media to share with us, such as your profile picture, friends lists, and any information you have made public in connection with Social Media, from other sources, including from:

• Other customers who provide information about you, such as to send you a gift or when they sign up for a refer-a-friend program.
• Order processing service providers, such as fraud prevention and fulfillment and delivery partners.
• Social media platforms, when you access our social media pages and communicate with us on third-party social media websites such as Facebook®, Instagram®, Pinterest®, SnapChat® , TikTok®, or Twitter® (collectively, "Social Media ").
• Unaffiliated third parties, such as marketing and advertising companies, ad networks, data co-ops and market research companies, data analytics providers, data enrichment providers, and consumer research providers. We may also receive information about you from commercially available sources such as data aggregators and public databases.

Information We Derive or Infer

We may derive information or draw inferences about you based on the information we collect. For example, we may draw inferences about your approximate location based on your IP address or infer that you are interested in certain products based on your browsing behavior and past purchases.

COOKIES AND OTHER SIMILAR TECHNOLOGIES

Cookies: A cookie is a small data file that is stored by your browser on your device. We use cookies to deliver a better experience on our Site and for other analytical purposes, such as:

• To learn about how you interact with our Site
• To detect and prevent fraud
• To conduct analytics activities
• To improve our websites and services
• To facilitate Interest Based Advertising

In many cases, the data collected through these cookies is controlled by us, but in some cases the data collected through use of these cookies is controlled by our vendors or other third parties. Cookies may remain on your device for an extended period. If you use your browser’s method of blocking or removing cookies, some, but not all, types of cookies may be deleted and/or blocked. If you delete or block cookies, some functionality on our Site may not work properly.

Other Tracking Technologies: In addition to cookies, we may use other types of tracking technologies in connection with our Site, advertisements, and other digital service offerings. Like with cookies, the data collected through these other types of tracking technologies is in many cases controlled by us. However, in some cases the data collected through these other technologies is controlled by our vendors or other third parties.

Web Beacons: Web beacons are embedded images or objects that are used on web pages or emails. Examples of why we may use web beacons include:

• For business analytics purposes, such as understanding the number of people who visit our Site or view specific content within a webpage
• To improve our Site and services
• To detect and prevent fraud
• To verify system and server integrity

Embedded Scripts: We may use embedded scripts that collect information about your interactions with our Site and advertisements. These scripts are temporarily loaded into your web browser and are active only while you are connected to our Site or advertisement.

Device and Activity Monitoring: We may use technologies that monitor and record your interactions with our Site, such as your keystrokes and click-related activity. These technologies may also collect and analyze information from your device, such your operating system, plug-ins, and system fonts. Examples of why we may monitor include:

• To troubleshoot
• To understand and improve our Site and services
• To customize your experience
• To respond to your inquiries and requests
• To detect and prevent fraud
• To detect security incidents and other malicious activity
• To verify system and server integrity

Third-Party Analytics: We may use Google Analytics or other analytics providers to obtain analytics information about our Site. These analytics providers may use cookies and other tracking technologies that help us analyze how you use or interact with our Site, services and advertisements.

More information about Google Analytics can be found in the Google Analytics Terms of Use and the Google Analytics Privacy Policy. You may exercise choices regarding the use of cookies from Google Analytics by downloading the Google Analytics Opt-out Browser Add-on which is available here.

HOW WE USE YOUR INFORMATION

We use the information we collect to provide the Wine Services and to process your order requests. We also use the information we collect to:

• Create and manage your online account; permit you to log into the Site.
• Complete the transactions you request, including, for example, to securely process your payment, process your order, verify your age, and provide customer service.
• Perform our contractual obligations, send cart reminders, and use your information as otherwise anticipated within the context of our ongoing business relationship.
• Communicate with you, including providing account notifications or order status updates, providing product recall notifications, confirming your preferences, engaging with you on social media, or providing you information about relevant programs, contests, sweepstakes or other promotions or offerings, and to tell you about products and services that may be of interest to you.
• Respond to your requests, inquiries, comments, and suggestions.
• Inform you of new products, services, promotions, and offers through email, postal mail, telephone or other means.
• Facilitate your engagement with us, including to enable you to post comments and reviews on our Site, to engage with other customers, and to post on social media.
• Improve our Site, the Wine Services, product offerings and your shopping experience.
• For other internal business purposes such as to authenticate users of our websites and applications.
• Offer contests, sweepstakes, loyalty or membership programs, or other promotions.
• Contact you with respect to your use of the Site, changes to the Privacy Policy or Terms and Conditions, and to send you other notices in order to comply with applicable laws and regulations.
• Tailor the content and information that we send or display to you, offer personalized recommendations, help, and instructions, and otherwise personalize your experience while using our Site and the Wine Services.
• For Interest-Based Advertising purposes.
• Provide you with customized content, and track orders and shopping cart items.
• Identify unique Site visitors.
• Administer the Site and monitor, audit, and analyze trends, usage, and activities in connection with our Site.
• Support our business operations and functions, including compliance, fraud prevention, marketing, security, and legal.
• Measure the effectiveness of the Site and our advertising and marketing.
• Carry out short-term activities and other internal uses related to the products or services you purchase from us or your ongoing relationship with us.
• Conduct internal research and development.
• Detect, investigate, and respond to security incidents and protect against illegal or objectionable activities, including the unauthorized use of our Site, and protect the rights and property of us and others.
• Debug, identify, and repair errors that impair existing intended functionality of our Site.
• Comply with our legal obligations, including those required for you to benefit from rights recognized by law, or any regulatory requirements or provisions.
• Conduct or administer surveys and other market research.
• For record keeping and auditing purposes.
• To update and maintain the accuracy of our information.
• For our internal business purposes.
• To conduct business analytics, for such purposes as forecasting and planning, developing statistics on engagement with our Site, and measuring how well marketing and promotional activities perform.
• For safety and security purposes, including to detect and respond to threats to our business and online operations, and prevent, investigate and prosecute fraud, and other criminal activities.
• For risk management, investigations, reporting and other legal and compliance reasons.
• For system administration and technology management, including optimizing our Site.
• Identifying prospective customers, business clients, suppliers, and other vendors.
• For quality control and training.
• Administer our relationships with customers, Licensed Retailers, and other vendors.
• In connection with mergers, acquisitions, divestitures, or similar corporate transactions
• For any other business purpose not prohibited by applicable law.
• To fulfill our legal obligations.
• To fulfill or meet the request for which the information is provided.
• To fulfill other notified purposes that we describe to you at the time we collect your information.

Data Analytics

We may use analytical tools to evaluate site performance through the use of aggregated data. We use both session and persistent cookies on our Site. (Session cookies expire at the end of a short period of time after you visit the Site. Persistent cookies, also called stored cookies, remain active until disabled through your browser settings or until a longer-term pre-set expiration date.) Please note that if you turn off cookies in your browser settings, you will not be able to shop from our Site.

We may also work with one or more data-modeling and/or data-append service which allows us to combine the information you have provided, or have permitted us to gather directly from you, including but not limited to your email, IP address(es) and/or other personal information, with other data, including offline data, in order to learn more about you.

Text Messaging

When you opt-in to receive text messages, you agree to receive recurring automated promotional and personalized marketing SMS and/or MMS text messages (such as cart reminders, for example) from Wine Insiders, including text messages that may be sent using an automatic telephone dialing system, to the mobile telephone number you provided when signing up or any other number that you designate. Consent to receive automated marketing text messages is not a condition of any purchase. Message and data rates may apply. See our Messaging Terms & Conditions and Messaging Privacy Policy, incorporated herein by this reference, for more information on our marketing text messages.

HOW WE SHARE YOUR INFORMATION

We may share your information as follows:

Licensed Retailers: We may share your information with the Licensed Retailers who sell you the products and fulfill your order.

Service Providers: We may share your information with vendors, service providers, and our affiliated companies that we engage to provide services to us on our behalf, such as support for the internal operations of our Site (including payment processors and third parties engaged in processing and fulfilling your order), electronic mail, postal mail, text messages, product and service delivery, conducting analysis to improve our services and Site, research, digital marketing, fulfilling orders you place, managing payments and answering your questions. Service providers only use the information they receive from us for the purposes specified in our contracts with them. We don’t allow them to retain, use, disclose or otherwise handle your personal information for their own purposes.

Related Companies: We may share your information with our parent company, Drinks Holdings, Inc. and its subsidiaries and affiliates that may use your personal information as described in this notice.

Ad Tech Companies and Other Providers: We may share limited personal information (such as a unique identification number and online and technical information) with ad tech companies and other online providers of services. When we share your information in this context, we follow applicable legal requirements, which may require that we provide opt-out rights or other individual rights.

Business Partners and Other Third Parties. Where we have the legal right, we may share or otherwise make your information available to business partners or other third parties for a business purpose that we have approved. When we disclose information in this context, we make sure that we comply with applicable legal requirements, which may include providing opt-out or other rights with respect to the shared data. We require that the recipients of this data protect such data, obey use restrictions, and comply with all applicable laws.

Co-Branded Offerings. Sometimes we may offer you a co-branded product, service, or other promotion in cooperation with another business. When we disclose your information to our co-branding partner in this context, we prohibit them from using the provided information for purposes outside of the co-branded offering. If you choose to take advantage of a co-branded offer, the information that you provide directly to our co-branding partner will be subject to their privacy notice and practices.

Legal Requirements and Government Authorities. We may share your personal information where we believe the disclosure is required by law, or otherwise necessary to comply with the law, regulatory requirements, requests from public authorities, or to enforce our agreements or policies, to protect our rights, the rights and property of customers, our partners or the public (including for fraud prevention purposes and to prevent, investigate and prosecute criminal activities).

Security and Safety Disclosures. Where permitted by applicable law, we may disclose your personal information to our related companies, affiliates and other persons and entities for the purpose of protecting the rights, safety, security, and property of customers, associates, and the public. We may also disclose this information to protect and enforce our rights (including for fraud prevention purposes and to prevent, investigate and prosecute criminal activities) and to assist others to do the same.

Corporate Transaction. We may disclose personal information as part of any actual or contemplated merger, sale, transfer of assets, acquisition, bankruptcy, reorganization, dissolution or similar event, including related to due diligence conducted prior to such event, where permitted by law, and we may assign any of our rights and delegate any of our duties under this Privacy Policy at any time, without your consent, at our sole discretion. This Privacy Policy, along with the Terms and Conditions, will inure to the benefit of our successors, assigns and licensors, provided that any such party's use of your personal information complies with the terms and conditions of this Privacy Policy unless you consent to additional or different uses.

With Notice or Consent. We may also disclose information about you, including personal information, to other third parties, where we have provided specific notice to you or asked for your consent, as required by law.

Notwithstanding anything else in this notice, we may share data that has been aggregated or deidentified in such a manner that it is no longer considered personal information for any purpose without limitation. When we share aggregated or deidentified data, we require recipients to refrain from reidentifying the data and to pass this obligation on to downstream recipients. We may share non-personal information we collect from you with third parties without express notice to or consent from you, and we may exploit, use and disclose non-personal information without limitation of any kind.

INTEREST-BASED ADVERTISING AND ANALYTICS

Interest based advertising (also known as online behavioral advertising) occurs when advertisements are displayed to you based on information collected from your online interactions over time and across multiple websites that you visit, or across multiple devices or online services that you may use. Companies that engage in interest-based advertising use this information to predict your preferences and show you ads that are most likely to be of interest to you.

Some of the content, applications, and tracking technologies on our Site is controlled by third parties, which include ad tech companies or other online service providers that serve interest-based advertisements. We do not control these third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

For example, you can block the collection and use of information related to you by online platforms and ad tech companies for the purpose of serving interest-based advertising by visiting the following websites of the self-regulatory programs of which those companies are members:

• The NAI’s opt-out page is available here.
• The DAA’s opt-out page is available here.

You may still see “contextual” ads even if you opt out of interest-based ads. These ads, however, are based on the context of what you are looking at on the websites and pages you visit. Even if you opt out of interest-based ads you will still receive these non-personalized, contextual ads.

When you visit our Site, log in, register or open an email, cookies, ad beacons, and similar technologies may be used by our online data partners or vendors to associate these activities with information they or others have about you, including your email address. We, or service providers on our behalf, may then send communications and marketing to these email addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout. In addition, some of our advertising partners enable us to translate your email address or phone number into an identifier that can’t be used to identify you personally. Our advertising partners then use that unique identifier to show ads that are more relevant to you across the web.

HOW WE PROTECT YOUR INFORMATION

We implement and maintain reasonable security procedures and practices appropriate to the nature of the information we maintain, including appropriate technical, administrative, and physical measures designed to protect information from unauthorized or illegal access, destruction, use, modification, or disclosure. When you make an online purchase on the Site, we use Secure Socket Layer (SSL) software to protect your personal information. SSL software encrypts the personal information that is transmitted between you and our Site. We do not share your payment information with any third party except our payment processing provider for the purpose of processing your payment. While we strive to secure the information we collect, even reasonable security measures do not guarantee the security of information transmitted via the Internet. We cannot guarantee that information we seek to protect will be protected under all circumstances, including those beyond our reasonable control. You acknowledge and agree that you transmit information to us via our Site at your own risk. Additionally, if you share emails you receive from us with others, you may be unintentionally sharing your personal information contained in these emails with such parties, and you acknowledge that you will be sharing it at your own risk. You also play an important role in protecting your information. It is your responsibility to select a strong password, change it regularly, not reuse or share your password, and alert us if you have any concerns about unauthorized use of your account.

COMMUNICATION PREFERENCES

You may unsubscribe from our promotional emails or text messages at any time by following the instructions included in those communications. If you opt out of receiving emails, please allow up to ten (10) business days for the unsubscribe to take place. During that time, you may continue to receive emails from us that were already in process. Please note that even if you opt out, we may continue to contact you regarding your order, your participation in a Wine Program, your gift purchase or other transactions you initiate or initiated, or to respond to any inquiry or request you make to us.

DATA RETENTION AND ACCOUNT DEACTIVATION

Our retention periods for personal data are based on business needs and legal and compliance requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the data was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired. When we no longer need to use your personal data, it is removed from our systems and records or it is anonymized so that you can no longer be identified from it. You can also deactivate your Wine Insiders account by emailing deactivate@wineinsiders.com.

CHILDREN’S PRIVACY

Our Site is directed to adults 21 years of age and older. We do not knowingly collect Personal Information from people under the age of 21, including children under the age of thirteen. If we become aware that we have collected Personal Information from a user who is under the age of thirteen, we will remove that child's personal information from our files.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This Privacy Notice for California residents supplements the information contained in our Privacy Policy and applies to residents of the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (as amended, and together with related regulations, the “CCPA”). Any terms defined in the CCPA shall have the same meaning when used in this notice. This notice does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

This notice applies to “personal information” that we collect, meaning information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include: publicly available information from government records; deidentified or aggregated consumer information; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA).

California Notice at Collection

We collect information to save you time and money, to deliver the products and services you request to enhance your ecommerce experience and support our business operations, in accordance with the terms of this Privacy Policy.

We collect the following categories of personal data: identifiers (such as your name, email, or IP address); commercial information (such as records of products you purchased); characteristics of protected classifications under California or U.S. federal law (such as your age); Internet or electronic network activity (such as information about your activity on our Site); geolocation data (such as your city of residence); audio, electronic, visual, or similar information (such as phone recordings when you call our customer service channels); and inferences drawn from your personal data to create a profile (such as your product preferences). For examples of the precise data points we collect, please see the Information We Collect section above. For examples of the sources of such data collection, please see the How We Collect Your Information section above. We use personal data for the business or commercial purposes described in the How We Use Your Information section above. We disclose personal data for the business purposes described in the How We Share Your Information section above.

Additionally, in the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:

Selling and Sharing Personal Data

While we do not sell or share your personal data with third parties in exchange for money, some of our advertising and analytics activities may constitute “sharing” or “selling” under California law. In order to operate our business; conduct business analytics; conduct marketing, personalization, and advertising; for interest-based advertising including cross-context advertising purposes; and to better understand, improve, and personalize our interactions with you, we have shared or sold the following categories of personal information to the following categories of third parties:

We do not use or disclose sensitive personal data for the purpose of inferring characteristics about you. We also do not knowingly sell personal data about consumers under the age of 21.

Your California Privacy Rights

You have the right to opt out of sale and sharing of your personal information at any time by clicking here. If you decide you want to opt back into the sale and sharing of your personal information after you have opted out, you may submit your request to privacy@wineinsiders.com. You can also opt out of certain sharing, sales, and targeted advertising by visiting our Site with a legally-recognized opt-out preference signal enabled (such as the Global Privacy Control). Please note that, depending on which legally-recognized opt-out preference signal you use and whether you are logged into your account with us, our processing of the signal may be limited to the specific browser or device that you are using. You may need to renew your opt-out choice if you use a different browser or device to access our Site or if you clear your cookies.

As a California resident, you also have the right to: (1) request correction of inaccurate personal data; (2) request deletion of your personal data (subject to certain exceptions); and (3) request to know more about and access your personal data, including in a portable format. With limited exceptions, you may only make a verifiable consumer request to correct, delete or know your personal information twice within a 12-month period. You also have the right to not to be discriminated against for exercising any of your CCPA rights.

Data Correction: To correct your personal data, please click here or log into your Wine Insiders account and update your information.

Data Deletion: To request deletion of your personal data, please submit your request to privacy@wineinsiders.com. Once we receive your request and verify your identity, we will review the request to see if an exception applies that allows us to retain some or all your information. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech or to ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct Licensed Retailers and our service providers to take similar action. If an exception applies, we will provide you information about that exception.

Request To Know: To request to know what personal information we have collected about you, submit your request to privacy@wineinsiders.com. Once we receive your request and verify your identity (as described below), we will disclose to you: (a) the categories of personal information collected; (b) the categories of sources from which the personal information has been collected; (c) the business or commercial purpose for collecting or selling personal information; (d) the categories of third parties to whom we disclose your personal information; (e) the specific pieces of personal information we have collected about you; and (f) if we sold your personal information or shared your personal information for cross-context behavioral advertising, the categories of personal information we have sold or shared.

Verification: When you submit a request, you may be required to provide additional information to verify your identity. We may verify your request by asking you to provide information related to your recent interactions with us, such as your email address, shipping address, or order number. If we deny your request, you may appeal our decision by contacting us at privacy@wineinsiders.com.

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. Please do not provide any sensitive personal information in connection with such a request, such as a driver's license or other government-issued ID. In some cases, we may be required to contact the individual who is the subject of the request to verify his or her own identity or confirm you have permission to submit this request on that consumer’s behalf. If you are an authorized agent seeking to make a request, please send your request to privacy@wineinsiders.com.

Notice of Financial Incentives

From time to time, we offer financial incentives. For example, we may provide discounts or other benefits to customers who sign up to receive our marketing emails or text messages. When you participate in a financial incentive, we collect personal data from you, such as identifiers like your name, email address and telephone number. You can opt-in to a financial incentive by following the sign-up instructions, and you have the ability to opt out of the program by following the opt-out instructions. In some cases, we may provide additional terms and conditions for a financial incentive, which we will provide to you when you sign up. The value of your personal data is reasonably related to the value of the offer or discount presented to you.

NONDISCRIMINATION

We will not discriminate against you for exercising your privacy rights.

CONTACT INFORMATION

If you have any questions or comments about our Privacy Policy, you may contact us at 2355 Westwood Blvd #791, Los Angeles, CA 90064 or via email at privacy@wineinsiders.com.

USERS OUTSIDE OF THE UNITED STATES

Our Site is located within the United States. Your Personal Information will be processed and shared in the United States, where data protection and privacy regulations may provide different levels of protection compared with non-United States jurisdictions. If you are located in the European Union, the United Kingdom, 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 our Site or providing you with your information, you consent to this transfer of your information.

DISPUTES

Any disputes regarding this Privacy Policy are subject to our Terms and Conditions. This Privacy Policy, and any disputes arising out of it, will be governed by the laws of the State of California, regardless of its conflict of law principles. WHEN YOU AGREE TO THE TERMS OF THIS PRIVACY POLICY, YOU ARE AGREEING TO A DISPUTE RESOLUTION POLICY THAT INCLUDES, TO THE EXTENT PERMITTED BY LAW, (1) A REQUIREMENT TO ARBITRATE ANY CLAIM, DISPUTE OR CONTROVERSY, INCLUDING ALL STATUTORY CLAIMS AND ANY STATE OR FEDERAL CLAIMS, THAT MAY ARISE OUT OF OR RELATE TO THIS PRIVACY POLICY OR YOUR USE OF THE SITES. BY AGREEING TO ARBITRATION, YOU UNDERSTAND AND AGREE THAT YOU ARE WAIVING YOUR RIGHT TO MAINTAIN OTHER AVAILABLE RESOLUTION PROCESSES, SUCH AS A COURT ACTION OR ADMINISTRATIVE PROCEEDING, TO SETTLE YOUR DISPUTE; AND (2) A WAIVER OF ANY RIGHT TO BRING A CLASS ACTION OR PRIVATE ATTORNEY GENERAL CLAIM. SEE TERMS & CONDITIONS FOR MORE INFORMATION.

CHANGES TO THIS POLICY

We may change this Privacy Policy from time to time without notice to you. We encourage you to refer back to this policy periodically to ensure you are aware of our current policy. Your continued use of the Site following the posting of any amendment, modification or change to this Privacy Policy shall constitute your acceptance thereof.