O’NEILL BEV­ER­AGES CO. LLC PRI­VA­CY POLICY

Last mod­i­fied: Novem­ber 3^rd, 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.

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