The Wine Group LLC wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect or you provide through our websites that link to this Privacy Policy (the “Sites”). By using our Services, you agree to this Privacy Policy.
Last Updated: September 18, 2020
Personal Information
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. Personal Information we may collect includes:
Use of Personal Information
We and our service providers may use Personal Information:
Disclosure of Personal Information
Your Personal Information may be disclosed:
We may also use and disclose your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law and respond to requests from public and government authorities; (b) to enforce our terms and conditions; and (c) to protect and/or defend our rights, privacy, safety or property, and/or that of our affiliates, you, or others.
Online Activity Information
“Online Activity Information” means the following:
Collection of Online Activity Information
We and our service providers may collect Online Activity Information:
Other Information
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. Other Information we may collect includes:
Please note that we may use and disclose Other Information for any purpose.
Collection of Other Information
Third Party Advertisers
We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites, based on information relating to your access to and use of the Services and other websites. To do so, these companies may place or recognize a unique cookie on your browser (including through use of pixel tags). If you would like more information about this practice and to learn about your choices in connection with these practices, please visit http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/.
Third Party Services
This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site, social media platform or service to which the Services link. Please review any third-party privacy policies to learn how they handle your Personal Information. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.
Security
We use reasonable organizational, technical and administrative measures designed to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.
Choices and Access
If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by using the opt-out mechanism contained in each such email.
If you would like to update Personal Information that you have provided to us, you may contact us in accordance with the “Contacting Us” section below.
Use of Services by Minors
The Services are not directed to individuals under the age of twenty-one (21). We do not knowingly collect Personal Information from individuals under 21, and we request that individuals under 21 do not use or access the Services and that they do not provide Personal Information through the Services.
Jurisdictional Issues
The Services are controlled and operated by us from the United States, and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States.
Last Updated: September 18, 2020
Benziger has prepared this California Consumer Privacy Act (“CCPA”) Privacy Notice (the “Notice”) to inform California residents of (1) the information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household (“Personal Information”) that we collect and how we use and disclose that information, and (2) the privacy rights California residents may have relating to their Personal Information and how those rights can be exercised.
This Notice is incorporated into and forms part of our Privacy Policy. By accessing or using the Service, you agree to the practices described in this Notice. If you do not agree to this Notice, please do not access the Site or otherwise use the Services.
Personal Information Collection and Disclosure
The following tables below are intended to provide additional information about our collection and disclosure of Personal Information which we may have collected from you within the past 12 months. Nothing in this Notice limits our ability to use or disclose information as described in our Privacy Policy.
Personal Information Collected From Customers and Site Visitors
Category of Personal Information | Categories of Sources From Which Personal Information May Have Been Collected | Business or Commercial Purpose for Collecting and Sharing the Category of Personal Information | Categories of Other Entities We Share Personal Information With |
Identification Information
Examples: real name, postal address, email address, phone number, account name and signature |
Directly from you when you interact with the Services
From social media platforms and similar services |
For our business purposes, such as to respond to your inquiries, fulfill your requests, and complete your purchases.
To send administrative information to you, such as changes to our terms, conditions, and policies, as well as marketing communications that we believe may be of interest. To personalize your experience on the Services by presenting products and offers tailored to you. To facilitate social sharing functionality. To allow you to participate in sweepstakes, contests, surveys and similar promotions and to administer these activities. For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, improving or modifying our Services, identifying usage trends, determining the effectiveness of promotional campaigns, and operating and expanding business activities, and similar purposes. |
Our affiliated companies and brands
To our service providers who provide services on our behalf for example website hosting, data analysis, payment processing, order fulfillment, outbound telesales, and other similar services. For more information on service providers see our privacy policy To third-party sponsors of sweepstakes, contests, surveys and similar promotions you choose to enter. To your friends associated with your social media account, to other website users and as well as to your social media account provider, when you choose to use the social sharing functionality. To providers of social media platforms and advertising networks in order for them to target and serve advertisements on our behalf. |
Category of Personal Information | Categories of Sources From Which Personal Information May Have Been Collected | Business or Commercial Purpose for Collecting and Sharing the Category of Personal Information | Categories of Other Entities We Share Personal Information With |
Identification Information
Social Security number (for sweepstakes and contest winners) |
Directly from you when you interact with the Services | To provide 1099 tax form for prizes over $600 | Prize fulfillment service providers for prizes over $600 |
Online Activity Information
Examples: device identifiers; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; other forms of persistent or probabilistic identifiers; Internet Protocol address; browsing and search history; and other information regarding your interaction with websites, applications or advertisements |
From you using cookies and similar technologies
From service providers and advertising networks collecting such information |
For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, improving or modifying our Services, identifying usage trends, determining the effectiveness of promotional campaigns, and operating and expanding business activities, and similar purposes. For more information of how we use online activity information see our privacy policy | To our service providers who provide services such as website hosting, data analysis, information technology and related infrastructure provision, and other similar services.
To providers of social media platforms and advertising networks in order for them to target and serve advertisements on our behalf. |
Category of Personal Information | Categories of Sources From Which Personal Information May Have Been Collected | Business or Commercial Purpose for Collecting and Sharing the Category of Personal Information | Categories of Other Entities We Share Personal Information With |
Financial Information
Examples: credit card number and/or debit card number |
Directly from you.
Outbound telesales and customer service provider |
To process your orders.
For our business purposes, such as fraud monitoring and prevention and security. |
To our service providers who provide services such as, payment processing, order fulfillment, credit card processing, auditing and other similar services.
Note: credit card/debit card information is tokenized and goes directly to service providers. |
Demographic Information
Age |
Directly from you | For our business purposes, such as to respond to your inquiries, fulfill your requests, and complete your purchases; to personalize your experience on the Services by presenting products and offers tailored to you; and to allow you to participate in sweepstakes, contests, surveys and similar promotions and to administer these activities. | To our service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, outbound telesales, email delivery, credit card processing, auditing and other similar services. |
Category of Personal Information | Categories of Sources From Which Personal Information May Have Been Collected | Business or Commercial Purpose for Collecting and Sharing the Category of Personal Information | Categories of Other Entities We Share Personal Information With |
Commercial Information
Examples: records of products purchased, obtained, or considered, and other purchasing histories or tendencies |
Directly from you
Outbound telesales and customer service providers |
To respond to your inquiries, fulfill your requests, and complete your purchases.
To send marketing communications that we believe may be of interest. To personalize your experience on the Services by presenting products and offers tailored to you. For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, improving or modifying our Services, identifying usage trends, determining the effectiveness of promotional campaigns, and operating and expanding business activities, and similar purposes. |
To our service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, outbound telesales, email delivery, credit card processing, auditing and other similar services. |
Additionally, we may disclose each of the above categories of Personal Information for Customers, Site Visitors and Applicants for Employment:
Your rights under the CCPA
Where provided for by law and subject to any applicable exceptions and exclusions, California residents may have the following rights:
How can a consumer with a disability access this Notice?
Consumers who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this Notice.
How to Submit a Request
To submit a request, click here or call our toll-free phone number 1-844-524-4386.
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 into your account. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may require you to provide additional Personal Information for verification and, in certain circumstances, sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. If we cannot verify your identity, we will not provide or delete your Personal Information.
Authorized Agents
You may submit a request through an authorized agent using the same methods available to you. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent signed permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above), and confirm that you have provided the agent permission to submit the request.
Additional Information
Employees and contractors are provided notice via different statements.
Contacting Us
If you have questions or concerns regarding this Notice or the practices described, please email us at privacy@benziger.com or call our toll-free phone number 1-844-524-4386.
Updates to this Privacy Policy
We may change this Privacy Policy from time to time without notice. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Sites. Your use of the Services following these changes means that you accept the revised Privacy Policy.
Contacting Us
If you have any questions about this Privacy Policy, please contact us at PrivacyPolicy@TheWineGroup.com.