Winter Wine Company

Privacy Policy

Your Privacy Rights
Winter Wine Company Privacy Policy
Effective as of September 23, 2023

Our Commitment to Privacy
Protecting your privacy is important to us. This privacy policy explains how Winter Wine Company (“WWC”) collects, uses and safeguards information you provide to us on this Site, at the Winery, or that you have otherwise given us which personally identifies you, as well as general, non-personal information that is automatically collected from our Site. This policy does not, however, govern the terms of our relationship or constitute any representation or warranty. The terms of our relationship are governed by our Terms and Conditions, which you can find HERE.  The terms “the Winery,” “Site,” “us” or “we” refer to WWC and/or its subsidiaries or affiliates (“Affiliates”), and this website. The terms “you”, “your” or “customer” refer to the user or viewer of this Site or customer of the Winery. Please read this privacy policy carefully. If you do not agree to our practices, please do not register, subscribe, create an account, make purchases, or otherwise interact with this Site. By visiting and using the features on the Site (including mailing list sign up, wine club sign up, event registration, other Site features and browsing), or by providing us with your personal information, you agree to this privacy policy.

We are based in California, and this policy incorporates protections for California residents provided under the California Consumer Privacy Act of 2018, as amended by Proposition 24 and the California Privacy Rights Act of 2020 (collectively, the “CCPA”). Since we care about your privacy, we provide the same rights to all of our customers whether or not they are California residents. As discussed further below under Legal Disclaimers, your use of this Site and our services are subject to California and United States law.
Summary of Your Rights
If you ever have any questions about how we use and store your personal information, you can submit those questions to us at info@winterwineco.com. Below is a non-exhaustive summary of the rights you have in this policy. This summary is only for your convenience: it does not change the details, exceptions and legal obligations that apply to these items set out in more detail below:

  • We do not and will not sell your data to any Third Parties for their marketing purposes. We share your personal information only with certain of our Service Providers and Contractors to carry out our business with you.
  • You may request that we correct or delete the personal information you provided to us at any time by sending your request to info@winterwineco.com or by 970-282-7006, and we will correct or delete it (unless there is a specific reason we need to keep it).
  • You may opt out of receiving marketing e-mails or the use of your personal data by us for direct marketing purposes. To opt out of the use of your personal data for this purpose, contact us at info@winterwineco.com or by 970-282-7006. But you may miss out on allocations, offers, events.
  • Up to twice a year, you may ask us about the personal information that we collect and store, by contacting us at 970-282-7006
  • We do not and have not sold, shared, or disclosed customers’ personal information for any purposes to anyone other than our Service Providers and Contractors.
  • You cannot object to our sharing your information with our Service Providers and Contractors, such as shipping companies, credit card processors to facilitate your transactions, but be assured that our agreements with those providers prevent them from using your personal information for any other purposes.
  • We use cookies to make our website work and to enhance your experience, as well as for our marketing purposes. You may manage your cookies, ‘Do Not Track,’ and similar technologies by accessing your browser’s preference/settings menu. If you reject cookies, the Site may not work fully and you won’t be able to order anything online.
  • You have a right not to receive any discriminatory treatment by the Winery for the exercise of the privacy rights conferred by the CCPA.

NOTICE OF COLLECTION

Who is Collecting Your Data
WWC controls the data that is collected on the Site. You can contact us at info@winterwineco.com

Sources of Collection
We collect information from you when you provide it to us directly, both in person or via the internet or other communications, and collect certain technical information from your devices, as discussed in further detail below.

Categories of Information We Collect
We collect and store certain personal information about you at various points in order to provide you with products and services.

California defines certain categories of “personal information,” and we collect the following categories as defined by the CCPA:

(A) Identifiers such as name, residence address, internet protocol address, and email address;

(B) Other identifiers including credit card numbers or other payment information;

(C) Age/date of birth;

(D) Commercial information such as purchase history;

(F) Internet activity information such as interactions with our communications and our website;

(G) Geolocation of electronic device accessing our website (we collect only general locations and do not collect your precise location);

(K) Inferences drawn from any of the information above to create a consumer profile.

We may also collect non-personal or de-identified information from you including, but not limited to, demographic data. Unless otherwise required by applicable law, we may use and share this information, which does not personally identify you, for any purpose.

Why WWC Collects Your Information
We collect your information for the categories of business purposes listed below:

COMMUNICATIONS
We collect your information to manage our relationship with you and send you communications.

TRANSACTIONS
We need your personal information to process your orders and are required to provide your information to certain of our service providers and contractors in order to process transactions.

AGE VERIFICATION
You must be of legal age to use the Site or to purchase any alcoholic beverage. If you wish to purchase any alcohol containing beverage from us, you may be required to provide personal information sufficient to verify that you are over 21 years of age. If you do not provide information to verify that you are of legal age, we cannot provide any services to you. We also cannot ship any product to you if you do not provide an address at which a person over the legal age is available to receive the product.

MARKETING
We also use the information we collect for our marketing purposes. Certain portions of this information are made available to our Affiliate wineries, so that your experience with WWC can be recognized by those Affiliates. If you would like to opt out of our use of your information for marketing purposes, or to be removed from our email list, you may contact us at info@winterwineco.com . Even if you opt out, we may still send emails to you concerning specific transactions or other non-marketing related messages. Our service providers are not permitted to use your information for their own marketing purposes, unless they have an independent relationship to you and have obtained your information from another source.

TECHNOLOGY
When you visit the Site, we may collect personal information including your IP address as well as some basic non-personal information about you and your browser. Examples of such non-personal information that is collected include what type of browser and operating system you are using, how long you remained on our Site and what pages you looked at while here. This non-personal information is anonymous and helps us understand how visitors browse our Site, so that we can make their shopping experience better. We do not make any efforts to identify you from this non-personal information. We use Service Providers and Contractors for these services discussed more below.

SITE ACCESS
We collect your username and password to access the Site when you have an account. You are responsible for maintaining the confidentiality of your user name and password. You shall be responsible for all uses of your user name and password, whether or not authorized by you. You agree to immediately notify us of any unauthorized use of your user name or password.

SERVICE PROVIDERS AND CONTRACTORS
We collect and provide your information to certain of our service providers and contractors to assist us with communicating with you, processing orders and shipments, and our internal business analysis.

How Long We Keep Your Information
We will retain your information for as long as your account is active or as necessary to provide you services and to maintain a record of your transactions for financial reporting and compliance purposes. If you wish to cancel your account, please contact us at info@winterwineco.com. We will keep your order history (but not payment information) on file indefinitely so that we can always provide you with information on what you ordered previously unless you ask us to delete it.

Your Rights to Access, Correct, or Delete Your Data
If you so desire, we will provide you with a copy of your account data or delete your account at your request. Up to twice a year, you may ask us whether we are collecting, storing, using, disclosing or selling your personal information, what categories and specific pieces of personal information of yours we are collecting and storing, the categories of sources from which our personal information is collected, the business or commercial purpose for collecting your personal information, and whom we may have shared your information with. You may request a copy of the personal information we have about you by contacting us at info@winterwineco.com . If you request specific pieces of information, to verify your request you will need to provide this declaration to us via mail at info@winterwineco.com.

If you note any errors or omissions in your information, we will correct that information at your request, which you can make to the same email or phone number.

If you would like us to delete your data, please contact us at info@winterwineco.com. We will direct our service providers or contractors to delete your information as well if you request. Depending on the nature of the data that you request we delete, we may require you provide two or more data points that match the information in our file.  Note that even if you request deletion, we may continue to retain and use information as may be authorized or necessary under California Law. While you have the right to request that we delete the personal information you provide to us and we will not discriminate against you for exercising any rights that you have, we may no longer be able to sell you any alcohol containing beverages if you ask us to delete your information showing you are of legal age or are in a location where it is legal for us to sell to you, and you may need to make other arrangements to verify your age and location to facilitate transactions.

We will work diligently to respond to your requests and will provide you with a free response to any of the above requests within 45 days. We will need to verify your identity for purposes of such a request. If you have an account on the Site, we will verify your request for information through your account. If you do not have an account, we will verify your request depending on the nature of the request. If you request to know the categories of information, we will request that you provide two pieces of information that match our records, which may vary depending on the information we have on file. If you request to know specific pieces of information, we will require additional verification to match three pieces of information on file, as well as a signed declaration. If you would like to designate an authorized agent to make such a request or your behalf you may do so by providing us with written permission of such authorization, or your agent must provide proof of a power of attorney.

In order to ensure protection of your information from fraudulent requests, we require you provide us with additional information to verify your identity should you wish to access or delete your data. For your protection, in the event the requisite verification is not satisfied, we may deny the request for access to your account data or to delete your account.

Protecting Your Information
We make every effort to ensure that any data that we store about you is kept behind a secure firewall and is not accessible to the public in any way. Any payment information (such as credit card number) that we collect from you is encrypted/tokenized. We do everything in our power to protect user data offline as well by restricting access to information to only those employees (for example, a Customer Care representative) who need the information to perform a specific job. All employees are kept up to date on our security and privacy practices and are aware of the importance of keeping customer data secure and safe at all times. We also outsource certain of our data processing operations to Service Providers and Contractors as discussed below, and we have agreements with those service providers that require them to maintain security over your information. We do not collect any Sensitive Information as defined by the CCPA.

Although we work hard to protect the security of your information and our system, and we have agreements in place with our Service Providers and Contractors requiring them to do the same, no transmission via the internet or storage of data can be guaranteed to be 100% secure. As a result of this and other factors beyond our control, we cannot guarantee the security of the information that you transmit to or through our Site. Therefore, you assume that risk by using the Site.

If you have any questions about the security of our Site, please feel free to contact us at info@winterwineco.com.

How We Share Your Information With Service Providers and Contractors
We value your privacy, and we will never sell, rent or share any personal information with any Third Party for that Third Party’s marketing purposes unless we are given explicit and affirmative authority to do so by you. Certain of our Affiliates have access to your personal information in the same systems as WWC and are subject to the same privacy policies and practices, and will also never sell or rent your personal information.

We work with Service Providers and Contractors to assist us to fulfill our sales and services to you and to process your data, including shipping companies, data hosts, credit card processors, and email management companies to host our databases, ship orders, process credit cards, bill users for goods and services. We require all such Service Providers and Contractors to keep any information they receive confidential, maintain the privacy of all our customers, and to use any information provided to only provide services on behalf of WWC. We have in the past and may continue to disclose for business purposes your personal information with these Service Providers and Contractors for the purposes discussed above.

From time to time, we may also employ other companies and individuals to perform services, to maintain and operate the Site, and to maintain certain features on the Site. To such parties, we may disclose non-personal information such as traffic patterns and website usage data, but in no event will we disclose any personal information. Third parties may also acquire browsing data or other information about your activity on the Site through cookies, as discussed below.

We also may employ Service Providers and Third Parties to analyze our sales data for internal purposes, in which case we may disclose information to such parties such as the wines purchased, the location of shipment, and the frequency of purchases. We additionally may enlist a Service Provider or Third Party to assist with marketing and sending member e-mails, in which case we will provide these third party vendors only with member e-mail addresses. Again, we require all such Service Providers and Third Parties to keep any information they receive confidential, maintain the privacy of all our customers, and to use any information provided for services on our and your behalf.

Cookies
Our Site uses cookies to speed navigation, keep track of items, and provide you with custom-tailored content. We also use cookies to remember some of the information you’ve given us so you don’t have to reenter it each time you visit the Site. By showing us how and when shoppers use the Site, cookies also help us see which areas are popular and which are not. Many improvements and updates to the Site are based on data such as total number of visitors and pages viewed. Most browsers are initially set to accept cookies. You may manage how your browser handles cookies and related technologies by adjusting your browser’s security and privacy settings. Refer to instructions related to your browser to learn about privacy and security settings that are available to you. The Site provides the opportunity for you to reject cookies and decline to use cookies in connection with your use of the site when you initially visit the Site. The cookies that we use do not allow other parties to collect personally identifiable information about your online activities over time and across different Web sites. Those third parties are discussed above. If you reject, block or delete cookies, you may not be able to use particular features of the Site or to take full advantage of features offered on the Site, and you will not be able to place an order on the Site.

Do Not Track Signals
Some browsers have incorporated “do not track” features to enable users to make privacy and security choices. By using these settings, your browser may send a signal to our website not to collect tracking information. The Site does not recognize “do not track” signals. Information tracked by the Site through cookies is discussed above.

No Information of Minors
The website is not directed at children and cannot be accessed by persons who do not verify that they are of legal drinking age. As a result, we will not knowingly collect information from minors or persons below legal drinking age in the U.S., including anyone under age 21.

Protecting the privacy of children is very important to us. If we learn that we collected the personal information of a minor or person under age 21, we will take steps to delete the information as soon as possible. If you believe we have inadvertently collected the personal information of your minor child, please contact us at info@winterwineco.com.

Legal Disclaimers
In addition to the use of your personal information for our business purposes, and subject to our not otherwise sharing or selling your data to Third Parties except as set forth above, WWC reserves the right to disclose your personally identifiable information as allowed or required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Site.

This Site may contain links to other sites. We are not responsible for the privacy practices of other sites. We encourage our users to be aware when they leave our Site and to read the privacy statements of each site that collects personally identifiable information. This privacy policy applies solely to information collected by this Site.

As set forth above, the Site is in, and this Privacy Policy is governed under the laws of California and the United States. Residents of the European Union may have certain additional rights, including the ability to request corrections to your personal data, which we will recognize if you contact us at info@winterwineco.com.

Privacy Policies Update
WWC reserves the right to modify this privacy statement at any time. We may periodically revise this privacy policy without notifying you of the changes, but will send an email to you if we have your email address on file/post a notice on our website/leave it up to you to check periodically if we make any material changes. It is up to you to consult this page to become aware of the changes. However, if we have your email address, we will notify you in the event we make any changes that substantially affect your rights to your personal data, specifically, if we intend to change our policy that we do not sell your personal information to any Third Party.

If you have any questions about this policy, you can reach us a info@winterwineco.com.

Privacy Policy was last updated September 18, 2023
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