THE INFORMATION WE COLLECT

We receive both information that is directly provided to us, such as personal information you provide when you visit the Services, and information that is passively or automatically collected from you, such as anonymous information collected from your browser or device. In this Privacy Policy, we refer to all of this as the "Information".

1. Information You Provide To Us. We collect information that you voluntarily give to us. For example, when you create an account to browse and purchase products in the shop, you provide us information, including your name, address, email address, telephone number, and credit card and billing information. We may also collect content you choose to post to our Services, like comments, product reviews and ratings, and videos and photos. At some Services, you can register, order products, enter contests, vote in polls or otherwise express an opinion, subscribe to one of our services such as our online newsletters or text message alerts, or participate in one of our online forums or communities.

At some Services, you may also be able to submit Information about other people. For example, you might submit a person's name and e-mail address to send an electronic gift card and, if you order a gift online and want it sent directly to the recipient, you might submit the recipient's name and address. This Information may include, for instance, a recipient's name, address, e-mail address, and telephone number.

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2. Information That is Passively or Automatically Collected. We, and our "Partners" who include TWC Affiliates, third party service providers, advertisers, advertising networks and platforms, agencies, and distribution or other partners may use automated means to collect various types of Information about you, your computer or other device used to access our Services. A representative, non-exhaustive list of the types of automatically collected information may include: network or Internet protocol address and type of browser you are using (e.g., Chrome, Safari, Firefox, Internet Explorer), the type of operating system you are using, (e.g., Microsoft Windows or Mac OS), the name of your Internet service provider (e.g., Comcast, Verizon or AT&T) and domains used by such providers, mobile network, device identifiers (such as an Apple IDFA or an Android Advertising ID), device settings, browser settings, the web pages of the Services you have visited, Services visited before and after you visit a Service, the type of handheld or mobile device used to view the Service (e.g., iOS, Android), location information, and the content and advertisements you have accessed, seen, forwarded and/or clicked on. Please see our Section titled Cookies, and Other User and Ad-Targeting Technologies for more information about how the foregoing Information may be collected and used.

3. Geo-location Information. If you are accessing a Service from a mobile device or through a mobile application, you may be asked to share your precise (GPS level) geo-location information with us so we can customize your experience on our Services or on other Services, when we work with a Partner such as a third party mobile ad platform. If you agree to such collection, in most cases, you will be able to turn off such data collection at any time by accessing the privacy settings of your mobile device and/or through the settings in the applicable mobile application.

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4. Information Collected By and From Social Media Services and Other Third Party Platforms. You also can engage with our content on or through social media services or other third party platforms, such as Facebook, and applications. When you engage with our content on or through social media services or other third party platforms, plug-ins, integrations or applications, you may allow us to have access to certain Information in your profile. This may include your name, e-mail address, photo, gender, birthday, location, an ID associated with the applicable third party platform or social media account user files, like photos and videos, your list of friends or connections, people you follow and/or who follow you, or your posts or "likes." For a description on how social media services and other third party platforms, plug-ins, integrations or applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings.

​When we interact with you through our content on third party websites, applications, integrations or platforms, we may obtain any information regarding your interaction with that content, such as content you have viewed and information about advertisements within the content you have been shown or may have clicked on.

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5. Information From Other Sources. We may, on occasion, combine information we receive online with outside records and use such information in accordance with this Privacy Policy, such as to enhance our ability to market to you products or services that may be of interest to you and to personalize your experience.​

CONSENT

Your use of our services requires us to collect and use your Information in the manner outlined by this Privacy Policy. By agreeing to the terms of this Privacy Policy, you consent for us to collect and use your Information listed in the previous section (“The Information We Collect”) for the purposes listed in the following section (“How We Use the Information”). You may withdraw your consent at any time; however, some of our services may be unavailable to you following the withdrawal of your consent. When you withdraw your consent, we will remove all of your Information that is not otherwise necessary for us to retain.

HOW WE USE THE INFORMATION

When you provide information from your social media account, it can help enable us to do things like (1) give you exclusive content, (2) personalize your online experience with us within and outside our Services, (3) contact you through the social media service or directly by sending you the latest news, special offerings, and rewards, and (4) enable you to share your experience and content via social media services. When you provide information about yourself to us through an application, through our Services, or on social media services or other third party platforms, it may be publicly viewed by other members of these services and we cannot prevent further use of the information by third parties.

We or a Partner may use "cookies" or similar technologies to associate certain of the Information with a unique identifier that then associates the Information with your device or browser. For information about how these technologies work and how we may use them, please go to Section IV, titled Cookies, And Other User And Ad-Targeting Technologies. Sometimes, we may associate cookies with the Information, including de-identified, "hashed," or anonymous versions of Information you have provided (such as during registration), in order to send or help our Partners send ads and offers based on your presumed interests or demographic information.

We may combine any of the Information we collect, for any of the above purposes, and may sometimes enhance the Information with other information that we obtain from third party sources. Please also be aware that if you choose to submit Information or content for publication (e.g., a letter to our editors, comments sent to our television personalities, a posting to a blog or a discussion board, or a video), we may publish that Information and content, along with other Information about you (such as your name, screen name or location). Likewise, if you register and create a profile with our Service, the screen name you select as well as other content you submit to your profile (e.g., photos, comments, video, reviews) will be displayed publicly on the Service, is searchable, can be found by third parties and may be reused and redistributed by us in our sole discretion. See our Terms of Use for details on our use of content you submit.

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Providing Products and Services

We may use the information we collect about you to:

provide you with our products, programs, and services;

process your transactions, track and ship orders;

administer surveys, sweepstakes or contests;

fulfill your requests regarding the Services, including requests for newsletters and notifications;

respond to your inquiries about our offerings;

customize or personalize ads, offers and content made available to you based on your visits to and/or usage of the Services or other online or mobile websites, applications, platforms or services, and analyze the performance of those ads, offers and content, as well as your interaction with them;

prevent fraud or potentially illegal activities (including, without limitation, copyright infringement) on or through the Services;

protect the safety of our Users;

provide, personalize, and improve our offerings and Services; and

offer you other products, programs or services from us and our affiliates, business partners, and selected third parties that we believe may be of interest to you.

​Communicating With You

We use the information we collect about you to communicate with you, including via email, phone, SMS text message or push notifications, as you decide, for reasons such as:

to enforce the legal terms (including without limitation our policies and terms of service) that govern your use of our Services, and/or for the purposes for which you provided the Information;

to confirm purchases you have made through our Services;

to confirm that your purchases have shipped;

to invite you to review purchases made via the Services;

to notify you of items left in your shopping cart;

to notify you when you have won a contest or sweepstakes;

to notify you when we make changes to our user agreements;

to fulfill a request by you for an online newsletter;

to provide you with product recommendations;

to provide you with access to personalized information based on your location;

to contact you about your account with us; and

to offer you other products, programs or services from us and our affiliates, business partners, and selected third parties that we believe may be of interest to you.

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Improving and Personalizing the Service

We use aggregate information about you and non-personal information that we collect to improve the design, functionality and content of our Services, and to enable us to personalize your experience with our Services and offerings. We use this information to (i) provide, maintain, personalize, protect, improve, and develop our products, programs, and services and to operate our business, (ii) to analyze usage and performance of our Services, and (iii) for us and our affiliates, business partners, and selected third parties to offer you products, programs, or services.

Retaining Your Information

We only retain your data for as long as it is necessary to service your account, to promote our legitimate business interests, and to comply with our legal and contractual obligations. You may request that we remove your data at any time by emailing info@winecollective.vin.

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​INFORMATION SHARING AND DISCLOSURE

We may disclose the Information as follows:

1. To service providers or Partners that we have engaged to perform business-related functions on our behalf. This may include service providers that: (a) conduct research and analytics; (b) create content; (c) provide customer, technical or operational support; (d) conduct or support marketing (such as email or advertising platforms); (e) fulfill orders and user requests; (f) handle payments; (g) host our Services, forums and online communities; (h) administer contests; (i) maintain databases; (j) send or support online or mobile advertising; and (k) otherwise support our Services.

2. In response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency's request or similar request.

3. With third parties in order to investigate, prevent, or take action (in our sole discretion) regarding potentially illegal activities, suspected fraud, situations involving potential threats to any person, us, or the Services, or violations of our policies, the law or our Terms of Use, to verify or enforce compliance with the policies governing our Services.

4. We may transfer some or all of your Information if we, or one of our business units, undergoes a business transition, like a merger, acquisition by another company, or sale of all or part of our assets, or if a substantial portion of our or of a business unit's assets is sold or merged in this way.

5. We may share the Information with TWC Affiliates, so they can provide, improve and communicate with you about their own, or their marketing partners' products and services. A representative list of our affiliates is available in the TWC Affiliates section below.

6. We may share the Information with unaffiliated Partners and third parties (e.g., our third party service providers, advertisers, advertising networks and platforms, agencies, other marketers, magazine publishers, retailers, participatory databases, and non-profit organizations) that wish to market products or services to you. If you wish to opt out from such sharing please visit the How to Contact Us/Opting Out of Marketing Communications section below for further instructions.

Please note that the Services covered by this Privacy Policy may offer content (e.g., contests, sweepstakes, promotions, games, applications, or social network integrations) that is sponsored by or co-branded with identified third parties. By virtue of these relationships, the third parties may obtain information from their visitors. We have no control over these third parties' use of this information, which is subject to their own privacy policies.

COOKIES AND OTHER USER AND AD-TARGETING TECHNOLOGIES

We use cookies and other technologies both to provide our Services to you and to advertise to you. We also may work with Partners to help them advertise to you when you visit other websites or mobile applications, and to help them perform user analytics. These technologies may also be used to analyze how our Users interact with advertising on our Services and elsewhere, and more generally, to learn more about our Users and what services or offers you might prefer to receive. We describe some of these technologies below.

1. Cookies. To enhance your online experience, we and our Partners use "cookies", "web beacons" or other tracking technologies. Cookies are text files placed in your computer's browser to store your preferences. We use cookies or other tracking technologies to understand Service and Internet usage and to improve or customize the products, content, offerings, services or advertisements on our Services.

We use cookies for the following purposes:

Required Functions. Certain cookies are required for the basic functionality of our shopping cart.

Analytics. We use cookies to track and collect data across our Store, which we review in order to provide a better shopping experience.

Marketing. We use cookies to provide you with relevant marketing materials from this Store.

Marketing Additional Services. We use cookies to alert our customers to additional services and products provided by third-parties.

These cookies contain no information intended to identify you personally. The cookies may be associated with de-identified demographic or other data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may share with a service provider solely in hashed, non-human readable form.

We, our third party service providers, advertisers, advertising networks and platforms, agencies, or our Partners also may use cookies or other tracking technologies to manage and measure the performance of advertisements displayed on or delivered by or through the TWC Network and/or other networks or Services.

These cookies may be stored on your computer when you visit our website for the following purposes:

to provide us with our core shopping cart functionality.

to analyze the use of our website.

to provide our customers with a wishlist feature and to notify customers when items are back in stock.

to provide recommended shopping suggestions.

to provide our shopping cart with the ability to geo-locate a user based on their IP Address.

to provide us with a content-delivery network for content on our store.

to provide us with a mailing list signup popup.

This also helps us, our service providers and Partners provide more relevant advertising.

2. Web Beacons. We and our Partners may also use "web beacons" or clear GIFs, or similar technologies, which are small pieces of code placed on a Service or in an email, to monitor the behavior and collect data about the visitors viewing a Service or email. For example, web beacons may be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that Service. Web beacons may also be used to provide information on the effectiveness of our email campaigns (e.g., open rates, clicks, forwards, etc.).

By visiting the Service, whether as a registered user or otherwise, you acknowledge, and agree that you are giving us your consent to track your activities and your use of the Service through the technologies described above, as well as similar technologies developed in the future, and that we may use such tracking technologies in the emails we send to you.

Our unaffiliated Partners and third parties may themselves set and access their own tracking technologies when you visit our Services and they may have access to information about you and your online activities over time and across different websites or applications when you use the Service. Their use of such tracking technologies is not in our control and is subject to their own privacy policies.

3. Disabling Cookies. Most web browsers are set up to accept cookies. You may be able to set your browser to warn you before accepting certain cookies or to refuse certain cookies. However, if you disable the use of cookies in your web browser, some features of the Services may be difficult to use or inoperable.

We may work with certain third-party companies that use techniques other than HTTP cookies to recognize your computer or device and/or to collect and record information about your web surfing activity, including those integrated with our Services. Please keep in mind that your web browser may not permit you to block the use of these techniques, and those browser settings that block conventional cookies may have no effect on such techniques. To learn more about Interest-Based Advertising or to opt-out of this type of advertising by those third parties that are members of DAA's opt-out program, please go to http://www.aboutads.info.

YOUR AD CHOICES

Advertising enables us to provide the rich content for which Services on the TWC Network are known, and to provide much of this content free of cost to our Users. Thus, we strive to provide you with ads that are relevant to you and for products you may want.

You may find more information about entities involved in online advertising and additional choices you may make through the Network Advertising Initiative ("NAI") at the NAI Service, and the Digital Advertising Alliance (the "DAA") at the DAA consumer choice Service.

The tools provided on the DAA opt-out page and the NAI opt-out page are provided by third parties, not TWC. TWC does not control or operate these tools or the choices that advertisers and others provide through these tools.

When using a mobile application you may receive tailored in-application advertisements. Depending on your device, you may be able to reset your mobile device's advertising identifier at any time by accessing the privacy settings on your mobile device. In addition, each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices, provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact (or review the applicable privacy web page of) the applicable platform operator.

EU PRIVACY RIGHTS

Residents of the EU have certain rights afforded to them by the EU General Data Protection Regulation ((EU) 2016/679) (“GDPR”). Under the GDPR, we will honor your right to:

Request access to your Information. We will send you a copy of your Information that we have on record, which will enable you to check that we are using it within the lawful guidelines of this Privacy Policy.

Request correction of the Information that we hold about you.

Request erasure of your Information. As noted above, this may involve ending further participation in our programs.

Object to processing of your Information where we are relying on a legitimate interest of ours or a third party. You may object on grounds that you feel it impacts your fundamental rights and freedoms, or on grounds that we are using your Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your Information which override your rights and freedoms.

Request restriction of processing of your Information. You may make this request (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Information to you or a third party. We will provide to you, or a third party you have chosen, your Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

If you wish to exercise any of these rights, please contact us at info@wincollective.vin. We may need to request additional information from you to help us confirm your identity. Typically, you will not have to pay a fee to access your Information. However, we may charge a fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request. We try to respond to all legitimate requests within one month. It may take us longer to respond to your request if your request is particularly complex or if you have made multiple requests. In that case, we will notify you and keep you updated on the status of your request.

PRIVACY BY DESIGN STANDARD

As we carry out all of our operations and services, we are committed to protecting the privacy of your Information. To this end, no project or service shall be implemented without consideration of the risks to data privacy, and implementation of any necessary measures to protect your privacy rights.

OTHER IMPORTANT INFORMATION ABOUT YOUR PRIVACY

1. How We Respond to Do Not Track Signals

At this time, Services on the TWC Network do not recognize automated browser signals regarding tracking mechanisms, which may include "do not track" instructions.

2. Linked Services

Some of the Services contain links to or integrations with other services such as Facebook, Twitter, LinkedIn, and other media services and platforms whose information practices may be different than ours. Visitors should consult these other services' privacy notices as we have no control over information that is submitted to, or collected by, these third parties.

3. International Transfer

By providing us with your personal data, you consent to our collection and use of your personal data for the limited purposes outlined by this privacy policy. We are a U.S.-based company, and our data centers are located in the United States. If you are a resident of the EU, you are entitled to all the rights and freedoms regarding your personal data outlined in the “EU Privacy Rights” section above. We will not transfer your data to a third party that does not respect these rights.

4. Data Security

Your security is important to us and we have put in place appropriate technical and organizational procedures designed to safeguard the information we collect through the Services. We have put in place physical, electronic, and managerial procedures designed to help prevent unauthorized access, to maintain data security, and to use correctly the Information we collect online. These safeguards vary based on the sensitivity of the Information that we collect and store.

Although we take appropriate measures to safeguard against unauthorized disclosures of Information, we cannot assure you that Information will never be disclosed, altered or destroyed in a manner that is inconsistent with this Privacy Policy. To help protect your information, you should not share your account information or password, reuse your password on other websites, or use a password you have used on other websites. For more information on password protection practices click here. If you share your account information or password with others or allow others to access your account, you will be responsible for their actions. While you are responsible for maintaining the confidentiality and security of your account information, if you become aware of a security issue affecting our Services or any authorized use of your account, please let us know immediately by contacting us at info@winecollective.vin.

5. How You Can Access or Correct Information

Access to certain personal Information that is collected from our Services and that we maintain may be available to you. For example, if you created a password-protected account within our Service, you can access that account to review the Information you provided.

You may also send an e-mail or letter to the following e-mail or street address requesting access to or correction of your personal Information. Please include your registration information for such service such as first name, last name and e-mail address in the request. We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account.

The Wine Collective

1700 W 41st St.

Suite 490

Baltimore, MD 21211

email: info@winecollective.vin

6. How to Contact Us/Opting Out of Marketing Communications

If you have any questions or concerns about the online Privacy Policy for this Service or its implementation, or if you would like to opt out from our sharing of your personal Information with unaffiliated third parties for the third parties' direct marketing purposes you may contact our Privacy Policy Coordinator at the above address or info@winecollective.vin and request that we opt you out of such sharing. We may ask you to provide additional information for identity verification purposes, or to verify that you are in possession of an applicable email account.

If you have signed up to receive our e-mails and prefer not to receive marketing information from this Service, follow the "unsubscribe" instructions provided on any marketing e-mail you receive from this Service. If you have signed up to receive text messages from us and no longer wish to receive such messages, you may follow the instructions to stop the delivery of such messages, which may include by replying "STOP" to the received text message.

7. California Residents - Your California Privacy Rights

California's "Shine the Light" law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the business' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Alternately, businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. As discussed above in How to Contact Us/Opting Out of Marketing Communications, if you wish to opt-out of our sharing of your personal Information with third parties for the third parties' direct marketing purposes or to find out more about your opt-out rights, please contact our Privacy Policy Coordinator as described above.

8. General Audience Service

We do not sell products for purchase by children. We sell products for purchase by adults. Therefore, we do not knowingly collect personal information from children under the age of 13.

DATA BREACH NOTIFICATION

In the event of any suspected data breach, we will notify you and any applicable regulator of a breach where we are legally required to do so. For EU data subjects, we shall notify the competent supervisory authority of any data breach that is likely to result in a risk to the rights and freedoms of natural persons within 72 hours of the breach, or else accompany our notification with reasons for the delay. This notification shall describe the nature of the Information at risk, including the categories and approximate number of data subjects concerned, the name and contact details of the data protection officer, the likely consequences of the breach, and the measures taken to address the breach. We will also notify you without undue delay of any data breach that is likely to result in a high risk to your rights and freedoms.

UPDATES AND EFFECTIVE DATE

From time to time, we may update this Privacy Policy. We will notify you about material changes by either sending an email message to the email address you most recently provided to us or by prominently posting a notice on our Service. We encourage you to periodically check back and review this policy so that you always will know what information we collect, how we use it, and with whom we share it.

The Privacy Policy posted on this Service was updated on March 29, 2020.