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Pri­va­cy Policy

We believe that car­ing for each oth­er comes first.

O’NEILL BEV­ER­AGES CO. LLC PRI­VA­CY POLICY

Last mod­i­fied: Novem­ber 3rd, 2023

Cal­i­for­nia Pri­va­cy Rights Notice found here: Link

INTRO­DUC­TION

O’Neill Bev­er­ages Co. LLC (here­inafter​“O’Neill”) and its brands, affil­i­ates, sub­sidiaries, com­pa­nies and/​or their relat­ed brands (col­lec­tive­ly referred to here as​“we,”​“our,”) cre­at­ed this Pri­va­cy Pol­i­cy to inform our web­site users, club mem­bers, event registrants/​participants, newsletter/​information recip­i­ents, pro­mo­tion, con­test, sweep­stakes or cam­paign par­tic­i­pants, online com­mu­ni­ty par­tic­i­pants, those who cor­re­spond with us via SMS (text mes­sage), those who pur­chase or inquire about our prod­ucts and ser­vices and oth­ers (col­lec­tive­ly referred to as​“you”) about our prac­tices regard­ing col­lec­tion, use and dis­clo­sure of per­son­al­ly iden­ti­fi­able infor­ma­tion (“per­son­al infor­ma­tion”) that you pro­vide to us or we col­lect from you. All ref­er­ences to our​“web­site” in this Pri­va­cy Pol­i­cy include any of our affil­i­at­ed sites linked to our web­site as well as any of our affil­i­at­ed mobile applications.

This Pri­va­cy Pol­i­cy does not apply to infor­ma­tion col­lect­ed by any third par­ty (oth­er than our affil­i­ates, sub­sidiaries, and data ser­vice providers), includ­ing through any appli­ca­tion or con­tent (includ­ing adver­tis­ing), whether or not such is linked to, or acces­si­ble from or on, our web­sites or apps.

If you are a cur­rent or for­mer employ­ee, job appli­cant, or inde­pen­dent con­trac­tor of O’Neill, addi­tion­al poli­cies may apply. 


YOUR CAL­I­FOR­NIA PRI­VA­CY RIGHTS

Cal­i­for­nia state law con­fers cer­tain rights relat­ing to the per­son­al infor­ma­tion of its res­i­dents. If you are a Cal­i­for­nia res­i­dent, please see our Cal­i­for­nia Pri­va­cy Rights Notice here: Link

If you are a cur­rent or for­mer employ­ee, job appli­cant, or inde­pen­dent con­trac­tor of O’Neill, please see our Employ­ee Pri­va­cy Notice locat­ed here: Link, or on Paylocity.

YOUR CON­SENT

Please review this Pri­va­cy Pol­i­cy peri­od­i­cal­ly. You should read this entire Pri­va­cy Pol­i­cy before sub­mit­ting infor­ma­tion, includ­ing per­son­al infor­ma­tion, to us in any form. When­ev­er you sub­mit per­son­al infor­ma­tion to us, whether online or offline, you con­sent to the col­lec­tion, use, and dis­clo­sure of that infor­ma­tion in accor­dance with this Pri­va­cy Policy.

All per­son­al infor­ma­tion may be used for the pur­pos­es stat­ed in this Pri­va­cy Pol­i­cy. We may make full use of all infor­ma­tion that is de-iden­ti­fied, aggre­gat­ed, or oth­er­wise not in a per­son­al­ly iden­ti­fi­able form.

NO DATA COL­LECT­ED FROM PEO­PLE UNDER LEGAL DRINK­ING AGE

We com­ply with the require­ments of the Children’s Online Pri­va­cy Pro­tec­tion Act (“COP­PA”) and oth­er applic­a­ble pri­va­cy laws. This web­site is main­tained strict­ly for indi­vid­u­als who are of legal age to con­sume alco­holic bev­er­ages under applic­a­ble law. As a result, we do not request or know­ing­ly col­lect per­son­al infor­ma­tion from indi­vid­u­als under legal drink­ing age. If you are not of legal drink­ing age, you should not access the website.

INFOR­MA­TION COL­LEC­TION AND USE

We may col­lect per­son­al infor­ma­tion (includ­ing, with­out lim­i­ta­tion, age, birth­date, address, email address, IP address, phone num­ber, social media account infor­ma­tion, geo­graph­ic loca­tion, and com­mer­cial infor­ma­tion) from you both online and offline. Any per­son­al infor­ma­tion we col­lect will be used as indi­cat­ed in this Pri­va­cy Policy. 

Offline, we may receive infor­ma­tion from you through tele­phone, writ­ten cor­re­spon­dence, or oth­er com­mu­ni­ca­tion meth­ods, and in per­son, includ­ing at our winer­ies, tast­ing rooms, or retail loca­tions. Online, we may receive infor­ma­tion through our web­site, an affil­i­at­ed site, a brand page on a com­mu­ni­ty web­site or social media site or through sim­i­lar online avenues, email, and via mobile phone appli­ca­tions or SMS (text mes­sage) cor­re­spon­dence. In many cas­es, such infor­ma­tion will be col­lect­ed direct­ly from you, such as through a trans­ac­tion or inquiry (includ­ing via a tele­phone call or SMS cor­re­spon­dence) or your sub­mis­sion of a form, reg­is­tra­tion or com­mu­ni­ca­tion to us. Infor­ma­tion may also be gath­ered from third-par­­ty sources (includ­ing with­out lim­i­ta­tion, our third-par­­ty ser­vice providers (such as mar­ket­ing and ful­fill­ment com­pa­nies), opt-in lists, con­sumer report­ing agen­cies, oth­er com­pa­nies and refer­rals) and through your activ­i­ties and inter­ac­tions with us, includ­ing, with­out lim­i­ta­tion, your online activ­i­ty on our web­site and social media pages. We may com­bine data col­lect­ed from these dis­parate sources unless we tell you oth­er­wise. Any of your per­son­al infor­ma­tion or oth­er infor­ma­tion gath­ered by one of our brands may be shared with and used by any of our oth­er brands in accor­dance with this Pri­va­cy Pol­i­cy. To see a com­plete list of what we col­lect and how we use this data, please see Annex 1 below.

We may use the infor­ma­tion we col­lect from you to:

  • Respond to or fol­low up on your com­ments, inquiries, or requests; 
  • Com­mu­ni­cate with you about your account or the use of our websites;
  • Pro­vide prod­ucts or ser­vices that you have ordered or to process your order trans­ac­tions and con­tact you regard­ing your order;
  • Invite and help you to par­tic­i­pate in online and offline events, activ­i­ties, and/​or clubs; 
  • Improve the qual­i­ty of our web­site, ser­vices, and prod­ucts and tai­lor them to your preferences;
  • Send pro­mo­tion­al com­mu­ni­ca­tions or offers (unless you have request­ed that we do not send such communications); 
  • Per­mit you to par­tic­i­pate in and to oth­er­wise admin­is­ter sweep­stakes, pro­mo­tions, cam­paigns, and contests; 
  • And as oth­er­wise spec­i­fied in this Pri­va­cy Pol­i­cy and/​or at the point of per­son­al infor­ma­tion collection. 

In addi­tion to pro­mo­tion­al com­mu­ni­ca­tions or offers you have opt­ed in to receive or have not opt­ed out from receiv­ing, we may use your con­tact infor­ma­tion to tell you about oth­er prod­ucts and ser­vices (includ­ing those of our oth­er brands, affil­i­ates, and com­pa­nies) that we believe might be of inter­est. If at any time you do not want com­mu­ni­ca­tions from us for pro­mo­tion­al pur­pos­es, you can opt out by fol­low­ing the instruc­tions pro­vid­ed in those com­mu­ni­ca­tions or send­ing an email to the email address list­ed on the brand website. 

This opt-out does not apply to infor­ma­tion pro­vid­ed to us as a result of a prod­uct pur­chase, prod­uct ser­vice expe­ri­ence, or oth­er sim­i­lar trans­ac­tion. In addi­tion, we may use your infor­ma­tion for com­pli­ance with our com­pa­ny poli­cies and pro­ce­dures, for account­ing and finan­cial pur­pos­es, and as oth­er­wise described above. If you do not pro­vide this infor­ma­tion, we may not be able to ful­fill the applic­a­ble pur­pose of col­lec­tion, such as to respond to your queries or pro­vide our web­site to you. 

How We Dis­close Your Per­son­al Infor­ma­tion.

The per­son­al infor­ma­tion you pro­vide is held by O’Neill or an agent of O’Neill and may be used by our affil­i­ates, part­ners, agents, or licensees. Your infor­ma­tion will not be sold, shared, exchanged, or oth­er­wise dis­trib­uted to unaf­fil­i­at­ed third par­ties except to the extent required by law or as out­lined below.

Our busi­ness part­ners. We use mar­ket­ing and adver­tis­ing part­ners and we share cook­ies, IP address­es, and device iden­ti­fiers with them for a busi­ness pur­pose so that they can help us pro­mote our ser­vices. We may share your per­son­al infor­ma­tion with them for gen­er­al busi­ness admin­is­tra­tion pur­pos­es and oth­er pur­pos­es described herein. 

Agents/​Service Providers. We may dis­close per­son­al infor­ma­tion you pro­vide to any of our oth­er brands and to ser­vice providers that we use to sup­port our busi­ness and oper­a­tions (e.g., deliv­ery ser­vices, finan­cial insti­tu­tions, ful­fill­ment ser­vices, tech­ni­cal sup­port, adver­tis­ing, pub­lic rela­tions, media and mar­ket­ing ser­vices, sweep­stakes, pro­mo­tions, cam­paigns and con­test-relat­ed ser­vices, e‑commerce and oth­er web-relat­ed ser­vices such as web host­ing and web mon­i­tor­ing ser­vices and event-relat­ed ser­vices such as online and offline data cap­ture) who have agreed to keep the infor­ma­tion con­fi­den­tial and use it only to pro­vide the applic­a­ble service(s). In some cas­es, we work with oth­er com­pa­nies who help to gath­er infor­ma­tion from you or help us to com­mu­ni­cate with you. 

Third par­ties. We may share your per­son­al infor­ma­tion with social media plat­forms such as Face­book and Insta­gram and with Google Ana­lyt­ics to serve you adver­tise­ments on our behalf and to pro­vide ana­lyt­ics ser­vices. Depend­ing on your place of res­i­dence, the cir­cum­stances, and the con­trac­tu­al oblig­a­tions in place, this shar­ing may be con­sid­ered a sale” or shar­ing,” and you may have the right to request that we stop such shar­ing as set forth in this Pri­va­cy Pol­i­cy. For more infor­ma­tion on this type of shar­ing and how you may opt out, see the Third Par­ty Adver­tis­ing and Ana­lyt­ics Dis­claimers” sec­tion below.

Legal mat­ters. We may also dis­close per­son­al infor­ma­tion to third par­ties (includ­ing, with­out lim­i­ta­tion, gov­ern­men­tal agen­cies) if required to do so by law, reg­u­la­tion or court order; to respond to gov­ern­men­tal and/​or law enforce­ment requests; to iden­ti­fy, con­tact or bring legal action against some­one who may be caus­ing injury to or inter­fer­ing with our (or oth­ers’) rights or prop­er­ty; to sup­port any actu­al or threat­ened claim, defense or dec­la­ra­tion in a case or before any juris­dic­tion­al and/​or admin­is­tra­tive author­i­ty, arbi­tra­tion or medi­a­tion pan­el; or in con­nec­tion with dis­ci­pli­nary actions/​investigations. Like­wise, we may dis­close per­son­al infor­ma­tion to third par­ties in con­nec­tion with the sale, assign­ment or oth­er trans­fer of the busi­ness of our web­site or the sale, assign­ment, merg­er, reor­ga­ni­za­tion or oth­er trans­fer of any of our brands or companies.

We (includ­ing any of our brands) may use your user-gen­er­at­ed con­tent you choose sub­mit to us includ­ing by dis­play­ing it on our sites and includ­ing for our pro­mo­tion­al purposes.

Busi­ness trans­fers. Where per­mit­ted by law, we may trans­fer your per­son­al infor­ma­tion to a third par­ty in the event of any reor­ga­ni­za­tion, merg­er, sale, joint ven­ture, assign­ment, trans­fer or oth­er dis­po­si­tion of all or any por­tion of our busi­ness, brands, affil­i­ates, sub­sidiaries, or oth­er assets.

How We Use Cook­ies and Oth­er Tech­nol­o­gy.

As you use our web­site, some infor­ma­tion can be​“pas­sive­ly” col­lect­ed using var­i­ous tech­nolo­gies, such as cook­ies, web bea­cons, and nav­i­ga­tion­al and loca­tion data col­lec­tion. Your Inter­net brows­er auto­mat­i­cal­ly trans­mits some of this infor­ma­tion, such as the URL of the web­site you just vis­it­ed and the Inter­net Pro­to­col (IP) address and brows­er ver­sion cur­rent­ly being used by your com­put­er. Such tech­nolo­gies help us to keep track of your inter­ac­tions with our web­site and pro­vide you with a more cus­tomized experience.

As is the case with many web­sites, our web­site may use cook­ies and oth­er auto­mat­ed infor­ma­tion col­lec­tion means. Cook­ies are infor­ma­tion about you from our web­site that is stored on your brows­er or hard dri­ve. Cook­ies save you time because you do not need to man­u­al­ly re-enter the infor­ma­tion stored on your hard dri­ve. Cook­ies also help us opti­mize and upgrade our web­site by show­ing when and how users use our web­site. You can set your brows­er to noti­fy you when a cook­ie is sent or refuse cook­ies alto­geth­er, but cer­tain fea­tures of our web­site might not work with­out cookies.

Our web­site may also use IP address­es for the same pur­pos­es iden­ti­fied above, as well as to ana­lyze trends, admin­is­ter our web­site, track users’ move­ments and online activ­i­ty, and gath­er demo­graph­ic infor­ma­tion for aggre­gate use.

We may use web bea­cons on our web­site to access and set cook­ies and oth­er­wise help us to bet­ter under­stand how users are mov­ing through our web­site. Infor­ma­tion pro­vid­ed by the web bea­con includes the computer’s IP address, the type of brows­er being used, and the time that the web bea­con was viewed. We may also use web bea­cons in emails and newslet­ters so that we know when such com­mu­ni­ca­tions have been opened and to oth­er­wise help us tai­lor our com­mu­ni­ca­tions to indi­vid­ual users.

Third Par­ty Adver­tis­ing and Ana­lyt­ics Dis­claimers.

We and/​or third par­ties includ­ing adver­tis­ing com­pa­nies, social net­work­ing sites, and ser­vice providers on our behalf, use cook­ies, web bea­cons, and oth­er sim­i­lar tech­nol­o­gy to col­lect infor­ma­tion for the pur­pos­es described in this Pri­va­cy Pol­i­cy includ­ing adver­tis­ing, ana­lyt­ics, online behav­ioral mar­ket­ing, mon­i­tor­ing per­for­mance, and improve­ment of our online ser­vices (traf­fic, errors, page load time, pop­u­lar pages, etc.).

You may opt out of behav­ioral remar­ket­ing as follows:

Google Ana­lyt­ics and Face­book Pix­el. We use Google Ana­lyt­ics and Face­book Pix­el to under­stand how our web­site, ser­vices, and prod­ucts per­form, how you use them, and to serve you with ads on third-par­ty web­sites and social net­work­ing sites like Face­book. To learn more about how Google process­es your data, please vis­it https://​www​.google​.com/​p​o​l​i​c​i​e​s​/​p​r​i​vacy/. To opt out of Google Ana­lyt­ics please vis­it https://​tools​.google​.com/​d​l​p​a​g​e​/​g​a​o​ptout. To learn more about how Face­book uses your data, please vis­it https://​www​.face​book​.com/​p​o​l​i​c​y.php.

Adver­tis­ing and Remar­ket­ing Ser­vices. We use remar­ket­ing ser­vices to inform, opti­mize and serve ads on third-par­ty web­sites such as Face­book to you based on your use of our web­site and social media. To under­stand more about Face­book adver­tis­ing and man­age your pref­er­ences, please vis­it https://​www​.face​book​.com/​a​b​o​u​t/ads. Login to Face­book and go to Set­tings > Ads > Ad Set­tings (web) or Ad Pref­er­ences > Ad Set­tings (app) for more infor­ma­tion. For more infor­ma­tion about tar­get­ed adver­tis­ing and to opt out of col­lec­tion of infor­ma­tion and ad tar­get­ing from third-par­ty web­sites, includ­ing Face­book and Google, please vis­it http://​www​.aboutads​.info/​c​h​oices. If you choose to opt out, you will con­tin­ue to receive adver­tise­ments, but they will not be tai­lored to your interests. 

Depend­ing on your place of res­i­dence, the cir­cum­stances, and the con­trac­tu­al oblig­a­tions in place, the above use of your infor­ma­tion may be con­sid­ered a sale” or shar­ing,” and you may have the right to request that we stop such shar­ing as set forth in this Pri­va­cy Pol­i­cy. You may opt out of this shar­ing by fill­ing out our online form avail­able here. Please also see the Opt-out Pref­er­ence Sig­nals” sec­tion and Annex 1 in our Cal­i­for­nia Pri­va­cy Rights Act Notice, below.

Dig­i­tal Adver­tis­ing Alliance. You can also opt out from com­pa­nies like Google, Insta­gram, Pin­ter­est, Face­book and oth­er par­tic­i­pat­ing com­pa­nies through the Dig­i­tal Adver­tis­ing Alliance in the USA: http://​www​.aboutads​.info/​c​h​oices.

Reten­tion of Per­son­al Infor­ma­tion.

We will retain your per­son­al infor­ma­tion (col­lect­ed through offline and online meth­ods) for as long as it is nec­es­sary for the pur­pos­es described in this Pri­va­cy Pol­i­cy. We will retain and use your per­son­al infor­ma­tion to the extent nec­es­sary to com­ply with our legal oblig­a­tions, resolve dis­putes, and enforce our legal agree­ments and policies. 

SECU­RI­TY

We take com­mer­cial­ly rea­son­able tech­ni­cal, admin­is­tra­tive, and phys­i­cal secu­ri­ty mea­sures to pro­tect per­son­al infor­ma­tion from loss, mis­use and unau­tho­rized access, dis­clo­sure, alter­ation or destruc­tion, whether in trans­mis­sion or stor­age includ­ing by pseu­do­nymiz­ing and/​or encrypt­ing data in cer­tain cas­es. How­ev­er, we can­not guar­an­tee com­plete secu­ri­ty because no method of trans­mis­sion over the Inter­net or method of elec­tron­ic stor­age is 100% secure. Any infor­ma­tion that you pro­vide to us is done so entire­ly at your own risk. More­over, you are respon­si­ble for main­tain­ing the con­fi­den­tial­i­ty of any user­name and pass­word you use. If you have rea­son to believe that your inter­ac­tion with us is no longer secure, please con­tact us at privacy@​ONeillWine.​com.

Links to Oth­er Web­sites.

Our web­site may con­tain links to third-par­ty web­sites or ser­vices that are not con­trolled by us. This Pri­va­cy Pol­i­cy only applies to infor­ma­tion col­lect­ed by us. We have no con­trol over third-par­ty web­sites or apps. Unless oth­er­wise indi­cat­ed, once you have left the web­site, all use of infor­ma­tion you pro­vide is gov­erned by the pri­va­cy pol­i­cy of the oth­er website’s oper­a­tors. O’Neill Bev­er­ages Co. LLC is not respon­si­ble for any trans­ac­tions that occur between you and a third-par­ty web­site or social media account.

IT’S YOUR CHOICE: CON­TACT PREF­ER­ENCES AND OPT-OUT

We want to keep in touch with you in ways that you find to be ben­e­fi­cial. If you don’t want us to use your con­tact infor­ma­tion to com­mu­ni­cate with you for pro­mo­tion­al pur­pos­es, please tell us that when you pro­vide your con­tact infor­ma­tion. If you decide at a lat­er time you do not want to receive pro­mo­tion­al com­mu­ni­ca­tions, you can com­mu­ni­cate this to us by fol­low­ing the instruc­tions in the com­mu­ni­ca­tions that we may send you. You can also com­mu­ni­cate with by email­ing the email address list­ed on the brand page(s) where you signed up to receive com­mu­ni­ca­tions or made a pur­chase request­ing to be opt­ed out of such com­mu­ni­ca­tions. Keep in mind that these pref­er­ences regard­ing pro­mo­tion­al con­tacts do not mean that we might not con­tact you for oth­er rea­sons, such as those relat­ed to an order you placed, an inquiry you made, a newslet­ter to which you may have sub­scribed, a mem­ber­ship you under­took, an event for which you reg­is­tered, or a legal­ly required notice.

SMS MES­SAG­ING OPT-OUT

If you have par­tic­i­pat­ed in our gen­er­al SMS cor­re­spon­dence cam­paign, you may opt-out by tex­ting​“STOP” to the short code pro­vid­ed in that mes­sage. Text​”HELP” to the code for help. Mes­sage and data rates may apply.

HOW TO CON­TACT US FOR MORE INFORMATION

If you have any ques­tions about this Pri­va­cy Pol­i­cy or our infor­ma­tion prac­tices, please con­tact us by call­ing or call­ing our toll-free num­ber at (888) 887‑9141 or by email­ing privacy@​ONeillwine.​com

CHANGES TO THIS PRI­VA­CY POLICY

This Pri­va­cy Pol­i­cy may be revised from time to time for any rea­son. If this Pri­va­cy Pol­i­cy changes, the revised pol­i­cy will include a new effec­tive date, and we will noti­fy you of such changes by post­ing the revised pol­i­cy on this page, which will be con­sid­ered effec­tive imme­di­ate­ly. Any such changes will auto­mat­i­cal­ly apply to all uses of our web­site and col­lec­tion and use of your per­son­al infor­ma­tion by us, on or after such effec­tive date (until such time as this Pri­va­cy Pol­i­cy is sub­se­quent­ly revised). If you don’t want us to use your per­son­al infor­ma­tion accord­ing to the new pol­i­cy, don’t sub­mit your per­son­al infor­ma­tion or vis­it our web­site. Be sure to check the Pri­va­cy Pol­i­cy when­ev­er you sub­mit per­son­al infor­ma­tion or use our website. 

CAL­I­FOR­NIA CON­SUMERS ONLY: YOUR CAL­I­FOR­NIA PRI­VA­CY RIGHTS

Last Mod­i­fied: June 5, 2023

This Cal­i­for­nia Pri­va­cy Rights Notice (“Notice”) pro­vides addi­tion­al infor­ma­tion to Cal­i­for­nia res­i­dents whose per­son­al infor­ma­tion is col­lect­ed by us pur­suant to Cal­i­for­nia law, includ­ing the Cal­i­for­nia Con­sumer Pri­va­cy Act (“CCPA”), as amend­ed by the Cal­i­for­nia Pri­va­cy Rights Act (“CPRA”). If you are not a Cal­i­for­nia res­i­dent, this Notice does not apply to you. Please vis­it our Pri­va­cy Pol­i­cy for more infor­ma­tion. Any cap­i­tal­ized terms unde­fined in this Notice have the same def­i­n­i­tion as the Pri­va­cy Policy.

The pur­pose of this Notice is to inform our web­site users, wine club mem­bers, event registrants/​participants, newsletter/​information recip­i­ents, pro­mo­tion, con­test, sweep­stakes or cam­paign par­tic­i­pants, online com­mu­ni­ty par­tic­i­pants, those who cor­re­spond with us via SMS (text mes­sage), those who pur­chase or inquire about our prod­ucts and ser­vices and oth­er Cal­i­for­nia res­i­dents from whom we may col­lect per­son­al infor­ma­tion, about our prac­tices regard­ing the col­lec­tion, use and dis­clo­sure of their per­son­al infor­ma­tion and cer­tain rights under Cal­i­for­nia law. This notice applies to both offline and online col­lec­tion of per­son­al infor­ma­tion and applies to O’Neill Bev­er­ages Co. LLC and our affil­i­ates and brands.

RIGHT TO KNOW ABOUT PER­SON­AL INFOR­MA­TION COL­LECT­ED, DIS­CLOSED OR SOLD AND SHARED

Infor­ma­tion col­lect­ed. In the pre­ced­ing 12 months, we have col­lect­ed the cat­e­gories of per­son­al infor­ma­tion about Cal­i­for­nia con­sumers as described in Annex 1 below.

Reten­tion of Per­son­al Infor­ma­tion. We retain your per­son­al infor­ma­tion for as long as need­ed to ful­fill the pur­pos­es out­lined in the Pri­va­cy Pol­i­cy and this Notice or per­mit­ted in light of the purpose(s) for which it was obtained. The cri­te­ria used to deter­mine our reten­tion peri­ods include our ongo­ing rela­tion­ship with you and any finan­cial or legal oblig­a­tion to which we are subject.

Busi­ness-to-Busi­ness Infor­ma­tion. If you are a con­tact per­son for any of our busi­ness part­ners, ven­dors, dis­trib­u­tors, sup­pli­ers, ser­vice providers, con­trac­tors, or oth­er enti­ties with which we have a busi­ness rela­tion­ship or poten­tial busi­ness rela­tion­ship, we col­lect the con­tact infor­ma­tion you pro­vide to us, includ­ing name, phone num­ber, address, email address and oth­er con­tact and rela­tion­ship infor­ma­tion con­sis­tent with your role in facil­i­tat­ing that busi­ness rela­tion­ship. We use that infor­ma­tion for inter­nal pur­pos­es, includ­ing to con­tact you, send and receive infor­ma­tion, and oth­er­wise facil­i­tate the busi­ness rela­tion­ship. We do not dis­close that infor­ma­tion out­side our busi­ness rela­tion­ship with­out your consent.

Infor­ma­tion sold or shared. We have not sold any per­son­al infor­ma­tion to third par­ties for a busi­ness or com­mer­cial pur­pose in the pre­ced­ing 12 months. Cer­tain net­work activ­i­ty, device infor­ma­tion, and com­mer­cial infor­ma­tion may be col­lect­ed by third par­ties such as Google Ana­lyt­ics and Meta via cook­ies and pix­els placed on our web­site which may con­sti­tute shar­ing” under the CPRA. For details and how to opt out of this shar­ing, please see the RIGHT TO OPT OUT OF SALE OR SHAR­ING OF PER­SON­AL INFOR­MA­TION” sec­tion, below.

Infor­ma­tion dis­closed for Busi­ness Pur­pos­es. We have dis­closed the fol­low­ing cat­e­gories of per­son­al infor­ma­tion to third par­ties in the pre­ced­ing 12 months:

  • Per­son­al Iden­ti­fiers (such as first and last name, address, email address, tele­phone num­ber, and oth­er con­tact information)
  • Com­mer­cial Infor­ma­tion (such as billing infor­ma­tion, address, or cred­it card number)
  • Internet/​Network Activ­i­ty (such as domain name and brows­ing history) 

Because our prod­ucts are strict­ly for indi­vid­u­als who are of legal age to con­sume alco­holic bev­er­ages under applic­a­ble law, we do not request, know­ing­ly col­lect, or sell or share per­son­al infor­ma­tion of indi­vid­u­als under legal drink­ing age. 

For details regard­ing the cat­e­gories of third par­ties to whom we have dis­closed per­son­al infor­ma­tion, please see Annex 1 below.

Requests to Know. You or your des­ig­nat­ed autho­rized agent have the right to request that we dis­close to you the fol­low­ing regard­ing the per­son­al infor­ma­tion we col­lect about you:

  • Cat­e­gories of per­son­al infor­ma­tion collected;
  • Sources of per­son­al infor­ma­tion collected; 
  • The busi­ness or com­mer­cial pur­pose for col­lect­ing or selling/​sharing per­son­al information;
  • The cat­e­gories of third par­ties with whom we share/​sell per­son­al infor­ma­tion; and
  • The spe­cif­ic pieces of per­son­al infor­ma­tion we have col­lect­ed about you over the last 12 months.

You also have a right to know if we have sold or dis­closed your per­son­al infor­ma­tion for a busi­ness pur­pose over the past 12 months and, if so, the cat­e­gories of per­son­al infor­ma­tion sold or dis­closed and the cat­e­gories of third par­ties to whom the per­son­al infor­ma­tion was sold or dis­closed, along with the busi­ness or com­mer­cial pur­pose for which the per­son­al infor­ma­tion was sold or disclosed.

To make a request for any of the infor­ma­tion set forth above (a Request to Know”), please sub­mit a request pur­suant to the instruc­tions below. You may only make a Request to Know twice with­in a 12-month peri­od. We will acknowl­edge your Request to Know with­in 10 days and will attempt to respond sub­stan­tive­ly with­in 45 – 90 days.

The Request to Know must pro­vide suf­fi­cient infor­ma­tion to allow us to ver­i­fy that you are the per­son about whom the per­son­al infor­ma­tion was col­lect­ed, sold or dis­closed and must con­tain suf­fi­cient detail to allow us to prop­er­ly under­stand, eval­u­ate and respond to your request. You may be asked to pro­vide addi­tion­al proof of iden­ti­fi­ca­tion so that we can ver­i­fy your iden­ti­ty and val­i­date the request. If we can­not ver­i­fy your iden­ti­ty, we may decline to hon­or your request.

You or your des­ig­nat­ed autho­rized agent can make a Request to Know the per­son­al infor­ma­tion we have about you by fill­ing out our online form avail­able here or call­ing us at 1−800−400−6628.

RIGHT TO KNOW ABOUT SEN­SI­TIVE PER­SON­AL INFOR­MA­TION COLLECTED

We col­lect and use your sen­si­tive per­son­al infor­ma­tion as described in Annex 1 below.

We do not col­lect or process sen­si­tive per­son­al infor­ma­tion for the pur­pose of infer­ring characteristics. 

RIGHT TO REQUEST DELE­TION OF PER­SON­AL INFORMATION

You or your des­ig­nat­ed autho­rized agent have the right to request dele­tion of your per­son­al infor­ma­tion col­lect­ed or main­tained by us (“Request to Delete”), sub­ject to cer­tain excep­tions per­mit­ted by law.

To make a Request to Delete, please sub­mit a request pur­suant to the instruc­tions below. We will acknowl­edge your Request to Delete with­in 10 days and will attempt to respond sub­stan­tive­ly with­in 45 – 90 days.

The Request to Delete must pro­vide suf­fi­cient infor­ma­tion to allow us to ver­i­fy that you are the per­son about whom the per­son­al infor­ma­tion was col­lect­ed, sold or dis­closed and must con­tain suf­fi­cient detail to allow us to prop­er­ly under­stand, eval­u­ate and respond to your request. You may be asked to pro­vide addi­tion­al proof of iden­ti­fi­ca­tion so that we can ver­i­fy your iden­ti­ty and val­i­date the request. If we can­not ver­i­fy your iden­ti­ty, we may decline to hon­or your request. Addi­tion­al­ly, as per­mit­ted by law, if the infor­ma­tion request­ed to be delet­ed is nec­es­sary for us to main­tain, we will not be able to com­ply with your request. We will noti­fy you if this is the case.

You or your des­ig­nat­ed autho­rized agent can make a Request to Delete the per­son­al infor­ma­tion we have about you by fill­ing out our online form avail­able here or call­ing us at 1−800−400−6628.

We will retain cor­re­spon­dence, doc­u­ments and infor­ma­tion relat­ed to any Request to Know, Request to Delete, or Request to Opt Out for 24 months as required by law.

RIGHT TO OPT OUT OF SALE OR SHAR­ING OF PER­SON­AL INFORMATION

You have the right to opt out of the sale or shar­ing, as defined by the CPRA, of your per­son­al infor­ma­tion. We do not and will not sell your per­son­al infor­ma­tion. As explained in Annex 1 below, we share your data with third par­ties such as social net­work­ing sites and adver­tis­ing com­pa­nies in order to serve you with ads tai­lored to your pref­er­ences across var­i­ous platforms. 

Opt-out Form. You may opt out of the shar­ing of your per­son­al infor­ma­tion by fill­ing out our online form avail­able here.

Opt-out Pref­er­ence Sig­nals. We hon­or opt-out pref­er­ence sig­nals that you enable (i.e., Glob­al Pri­va­cy Con­trol). Opt-out pref­er­ence sig­nals are plug-ins avail­able in cer­tain browsers that sig­nal to web­sites you vis­it of your pref­er­ences to opt out of the sale and shar­ing of cer­tain per­son­al infor­ma­tion. You can learn more here: https://​glob​al​pri​va​cy​con​trol​.org/. If you have enabled an opt-out pref­er­ence sig­nal device from your brows­er, we will not sell or share your per­son­al infor­ma­tion with­out first seek­ing your explic­it con­sent. Adjust­ing your set­tings to enable Glob­al Pri­va­cy Con­trol will only opt out of any shar­ing activ­i­ty on the brows­er and device you are using. We may con­tin­ue to col­lect and share per­son­al infor­ma­tion about you with oth­er third par­ties, includ­ing to con­tin­ue pro­vid­ing ser­vices to you where shar­ing of your per­son­al infor­ma­tion is for pur­pos­es oth­er than tar­get­ed adver­tis­ing and is per­mit­ted by law. Our web­site does not respond to Do Not Track sig­nals because there are no com­mon, indus­try accept­ed do not track” stan­dards and systems.

This Pri­va­cy Pol­i­cy does not apply to, and we are not respon­si­ble for, third-par­ty cook­ies, web bea­cons, or oth­er track­ing tech­nolo­gies, which are cov­ered by such third par­ties’ pri­va­cy poli­cies. For more infor­ma­tion, we encour­age you to check the pri­va­cy poli­cies of these third par­ties to learn about their pri­va­cy practices.

Cook­ies. As explained in our How We Use Cook­ies and Oth­er Tech­nol­o­gy” sec­tion, you can opt out of cook­ies using your bro­kers. Please note:

  • Opt-outs are device- and brows­er-based. You must opt out on each device and each brows­er where you want your choice to apply.
  • Opt-outs may be stored via cook­ies. If you clear cook­ies, your opt-out may no longer be valid and you must opt out again where you want your choic­es to apply.
  • We may still share your per­son­al infor­ma­tion with our ser­vices providers that help us per­form func­tions that are nec­es­sary for our busi­ness such as ven­dors that host our web­site, cred­it card proces­sors and ana­lyt­ics proces­sors. These enti­ties are con­trac­tu­al­ly oblig­at­ed to keep this infor­ma­tion con­fi­den­tial and not use it for any pur­pose oth­er than for the ser­vices they pro­vide to our business. 
  • You may still receive ads from us that are not tai­lored to your interests.

Addi­tion­al Options to Opt Out of Sale or Sharing.

In addi­tion to the above options to opt out of the sale or shar­ing of your infor­ma­tion under the CPRA as described above, you have con­trols and choic­es with respect to col­lec­tion and use of your infor­ma­tion by third par­ties. These are sum­ma­rized for you below. We do not con­trol or main­tain opt-out mech­a­nisms for third-par­ty com­pa­nies and are not respon­si­ble for their operation.

Adver­tis­ing Opt Out. You can opt out of shar­ing your infor­ma­tion with third-par­ty com­pa­nies engaged in tar­get­ed adver­tis­ing includ­ing social net­work­ing sites such as Google and Face­book using the fol­low­ing tools: For web­sites: http://​optout​.aboutads​.info/​?​c​=​2​&​l​a​ng=EN. For mobile apps: http://​www​.aboutads​.info/​a​p​p​c​h​oices.

Google Opt Out. If you would like to opt out of Google Ana­lyt­ics and Ads, you can. If you are on the web, you can opt out of Google Ana­lyt­ics by installing Google’s Opt Out brows­er add on: https://​tools​.google​.com/​d​l​p​a​g​e​/​g​a​o​ptout, and you can opt out of inter­est-based Google ads using https://​ads​set​tings​.google​.com/​u​/​0​/​a​u​t​h​e​n​t​i​cated.

Face­book Ad Pref­er­ences. To under­stand more about Face­book adver­tis­ing and man­age your pref­er­ences, please vis­it https://​www​.face​book​.com/​a​b​o​u​t/ads. Login to Face­book and go to Set­tings > Ads > Ad Set­tings (web) or Ad Pref­er­ences > Ad Set­tings (app) for more information.

RIGHT TO CORRECT

You or your des­ig­nat­ed autho­rized agent have the right to request that we cor­rect in our records inac­cu­rate infor­ma­tion about you. To make a request to cor­rect inac­cu­rate infor­ma­tion about you (a Request to Cor­rect”), please sub­mit a request pur­suant to the instruc­tions below. We will acknowl­edge your Request to Cor­rect with­in 10 days and will attempt to respond sub­stan­tive­ly with­in 45 – 90 days.

The Request to Cor­rect must pro­vide suf­fi­cient infor­ma­tion to allow us to ver­i­fy that you are the per­son about whom the per­son­al infor­ma­tion was col­lect­ed, sold or dis­closed and must con­tain suf­fi­cient detail to allow us to prop­er­ly under­stand, eval­u­ate and respond to your request. You may be asked to pro­vide addi­tion­al proof of iden­ti­fi­ca­tion so that we can ver­i­fy your iden­ti­ty and val­i­date the request. If we can­not ver­i­fy your iden­ti­ty, we may decline to hon­or your request.

You or your des­ig­nat­ed autho­rized agent can make a Request to Cor­rect the per­son­al infor­ma­tion we have about you by fill­ing out our online form avail­able here or call­ing us at 1−800−400−6628.

We will retain cor­re­spon­dence, doc­u­ments, and infor­ma­tion relat­ed to any Request to Cor­rect for 24 months as required by law.

OTH­ER CAL­I­FOR­NIA PRI­VA­CY RIGHTS

Shine the Light Dis­clo­sure Infor­ma­tion. Although we don’t dis­close to any third par­ties for direct mar­ket­ing pur­pos­es any of your per­son­al infor­ma­tion, you are enti­tled to receive the fol­low­ing dis­clo­sure. If you are a res­i­dent of Cal­i­for­nia, you can request a notice iden­ti­fy­ing the cat­e­gories of per­son­al infor­ma­tion, as defined by Cal­i­for­nia Civ­il Code Sec­tion 1798.83, we share with our affil­i­ates and/​or third par­ties for their direct mar­ket­ing pur­pos­es and the con­tact infor­ma­tion for such affil­i­ates and/​or third par­ties. Please sub­mit your request to privacy@​OneillWine.​com.

Right to Non-Dis­crim­i­na­tion. If you choose to exer­cise any of the rights detailed in this Notice, we will not dis­crim­i­nate against you in any way as a result of that exer­cise, includ­ing by offer­ing you dif­fer­ent pric­ing or prod­ucts or by pro­vid­ing you with a dif­fer­ent lev­el of qual­i­ty of products. 

Notice of Finan­cial Incen­tive. We may offer you cer­tain pro­grams, ben­e­fits, or oth­er offer­ings relat­ed to the col­lec­tion or reten­tion of per­son­al infor­ma­tion that may be deemed a finan­cial incen­tive” under the CCPA that can result in dif­fer­ent prices, rates, or qual­i­ty lev­els. Con­sumers who elect to par­tic­i­pate in finan­cial incen­tive pro­grams (such as reward pro­grams, lim­it­ed-time pro­mo­tions, sweep­stakes, or con­tests) may be asked to pro­vide per­son­al infor­ma­tion such as your name, email address, phys­i­cal address, and/​or phone num­ber. We may also col­lect com­mer­cial infor­ma­tion such as cred­it card num­bers and pay­ment infor­ma­tion (in lim­it­ed cir­cum­stances), details of trans­ac­tions that you car­ry out through our ser­vices, includ­ing prod­ucts pur­chased or con­sid­ered, and wine club infor­ma­tion from con­sumers who elect to par­tic­i­pate in a rewards pro­gram. Any CCPA-per­mit­ted finan­cial incen­tive we offer will rea­son­ably relate to the val­ue of your per­son­al infor­ma­tion and con­tain writ­ten terms that describe the program’s mate­r­i­al aspects. Par­tic­i­pa­tion in a finan­cial incen­tive pro­gram requires your pri­or opt-in con­sent, which you may revoke at any time.

Annex 1

Category Examples Collected From Purposes Disclosed to Sold or Shared

Identifiers

Commercial Information

Birthdate, name, age gender, email address, mailing address, telephone number, social media handle and images.

Credit card number and payment information, in limited circumstances, details of transactions that you carry out through our services, including products purchased or considered, wine club information.

You, through a transaction, interaction, inquiry, or other communication with us.

Third-party sources including third-party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals.

Our third-party providers are bound by confidentiality obligations and are restricted to only using the data to provide our business with applicable services.

To respond to or follow up on your comments, inquiries, or requests and communicate with you about your account, our services, and products that may be of interest;

To process transactions, contact you regarding your order, and deliver products to you;

To improve our products, services, and website and to develop new products and services;

To send promotional communication or offers to you (unless you have requested that we do not);

For marketing, research, legal, and other business purposes;

To comply with our policies, procedures, and financial and legal obligations.

Business partners and service providers who perform functions on our behalf (e.g., hosting or operating our services, processing credit card payments, sending marketing communications, carrying out contests and sweepstakes, special offers, or promotions, processing job applications, data analysis, website and app metrics and analytics, providing fraud detection services, and other business support services) who have agreed to keep the information confidential and use it only to provide the applicable services;

Third-party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics, targeted advertising, or behavior remarketing, as explained in our Privacy Policy;

Third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests.

N

Audio/visual information

Video recordings of you when you visit one of our locations or call recordings when you call for customer service.

You, through a transaction, interaction, inquiry, or other communication with us.

For legal and other business purposes;

To comply with our policies, procedures, and financial and legal obligations.

Consultants, service providers, and contractors that we use to support our business and operations (e.g. providing security or fraud detection services) who have agreed to keep the information confidential and use it only to provide the applicable services; and

Other parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests.

N

Network activity

Device information

Geolocation data

IP address, your device identifier, domain name, browsers you used to access our website and services, webpages viewed, time spent on webpages, links clicked, search terms used, usage patterns, transactions entered into and site-navigation patterns.

We may also collect general geolocation data from your device with your consent in accordance with applicable law. If you do not consent to collection of this information, certain services such as personalized location-based services and content will not function properly. You can stop our collection of location data at any time by changing the preferences on your mobile device.

Your online activities and interactions with us, including on our social media channels or through our third-party sources.

Third-party sources including third-party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals.

Our third-party providers are bound by confidentiality obligations and are restricted to only using the data to provide our business with applicable services.

To analyze and track usage of our services and products including our website and social media accounts;

To provide location-based services and content;

To improve our website, services, and products, and tailor them to your preferences;

To send promotional communications or offers (unless you have requested that we not send such communications); and

For other marketing, research, legal, and other business purposes.

Business partners and service providers that we use to support our business and operations;

Third-party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics, targeted advertising, or behavior remarketing, as explained in our Privacy Policy;

Third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests.

N

Network activity

Device information

Commercial information

IP address, your device identifier, domain name, browsers you used to access our website and services, webpages viewed, time spent on webpages, links clicked, search terms used, usage patterns, transactions entered into and site-navigation patterns.

Commercial information limited to products purchased, viewed, or considered.

Your online activities and interactions with us, including on our social media channels or through our third-party sources.

Third-party sources via cookies and pixels placed on our website.

Depending on the circumstances and the contractual obligations in place, this sharing may be considered a “sale” or “sharing” under the CCPA and you may have the right to request that we stop such sharing as set forth above. Please see the section in the Notice above titled “Opt-out Preference Signals.”

To analyze and track usage of our services and products including our website and social media accounts;

To serve you personalized ads or customized offers to improve your shopping experiences on our website or elsewhere; and

For other marketing, research, legal, and other business purposes.

Third-party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics, targeted advertising, or behavior remarketing, as explained in our Privacy Policy.

Y

Sensitive personal information

Certain personal information we collect may be considered sensitive personal information under the CCPA, including: account or debit/credit card information for billing and transactional purposes; driver’s license or other identification card numbers for identity verification purposes; and geolocation data as discussed above.

We only use and disclose sensitive personal information as necessary in connection with the performance of services, provision of products, and in accordance with the law. We do not collect your sensitive personal information to infer characteristics about you.

You, through a transaction, interaction, inquiry, or other communication with us.

Your online activities and interactions with us, including on our social media channels or through our third-party sources.

To process transactions, contact you regarding your order, and deliver products to you;

To provide location-based services and content;

To authenticate your account credentials and identify you, as necessary to log you in and/or ensure the security of your account;

To comply with our policies, procedures, and financial and legal obligations;

For legal and other business purposes that do not involve inferring characteristics about you.

N

Business-to-business information

We collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating that business relationship.

From you, as a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship.

For internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship.

We do not disclose this information outside our business relationship without your consent.

N

By continuing to use our site, you agree to our Privacy Policy. You can learn more about how we use cookies by reviewing our Privacy Policy.

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