Last Revised: October 18, 2019
Welcome to the WineCountry. WineCountry Media, LLC provides website content, features and other products and services when you visit or shop at our websites (including any related or successor websites) or through our mobile application.
- What are cookies? Cookies are small files that the Platform puts on your computer, which collect information that help us refine our Platform based on user preferences, make certain features of the Platform available to you and to help us track your use of the Platform. For further information about cookies, please see allaboutcookies.org.
- How can I manage cookies? By changing the preferences or options of your web browser, you can instruct it to accept all cookies, block certain cookies, require your permission before placing a cookie on your computer, or block all cookies from being placed on your computer. However, please note that if you block cookies from the Platform, you may not be able to use all of the functionality that we make available on this Platform.
Children: Our Platform is intended for users over the age of 18 and is not directed to children. We do not knowingly collect personal information from children. If we discover that we have collected personal information (as defined by the Children’s Online Privacy Protection Act) from children under 13 years of age, or personal data (as defined by the General Data Protection Regulation of the European Union) of children under the age of 16, we will use reasonable efforts to promptly delete such.
“Do Not Track” Signals: Certain web browsers have “Do Not Track” or similar settings, which allow you to tell the websites you visit that you do not want your activities on such websites tracked. Currently, the Platform does not respond to “Do Not Track” or similar settings, so your activities on the Platform may be tracked regardless of your browser settings.
What personal data do we collect? The categories of personal data (“Personal Data“) we collect on and through the Platform vary depending on your level of interaction with the Platform, specifically:
- When you visit the platform: When you visit and browse the pages on our Platform, the Google Analytics tool (described above) collects information about you, as described above and on the Google website. We use this information to see how you and other users engage with our Platform (e.g., how many unique users have visited the Platform, what websites they’ve visited, and how long they’ve stayed).
- Subscribing to Our Newsletter: When you subscribe to our newsletter, which provides information regarding our current offerings, promotions and upcoming items of interest, we collect your email address. We use this information to fulfill your newsletter subscription request.
- Registering for an Account: When you register for an account on the Site, we also collect your email address. We use this information to be able to provide you with the account.
- Making a Purchase of a Product, Reserving an Experience, or Purchasing a Covet Pass.
Product Purchase or Reserving Experience. When you purchase a product through the Platform (other than a purchase of an Experience or the Covet Pass) or reserve an Experience through the Platform, the following data is collected from you by our third-party payment processor (see below):
- Your full name;
- Your mailing address;
- Your email address;
- Your telephone number;
- Your credit card information (e.g., type of credit card, credit card number, name, expiration date, and CVV or similar code, as needed); and
- Your billing address.
We do not see any of this information until after a purchase is made, which is when our payment processor shares with us the information described in items #1-4 above, plus the type of credit card you have used (we do not see your other credit card information, nor your billing address).
How will we use your personal data? We will use the personal data we collect as follows:
- To Process Your Transactions: We use and share the personal data you give us to process the purchases of products and experiences that you’ve ordered, and to provide those products and experiences to you. For instance, if you purchase a Covet Pass, we may share your personal data to confirm that you are eligible to redeem a tasting at a given winery.
- To Update You About Us: We use the personal data you provide to us to let you know about what we’re doing and to inform you of opportunities that may be available to you. For instance, if you provide your email address to us, we may send email to you at that address. We may also provide that email address to our third-party vendors that help us with email correspondence, for the purpose of helping us send such email to you. If you click on a link in an email we send, we may elect to redirect you to a third-party vendor’s servers to register the link, and your clicking on the link may indicate to a third-party vendor and/or to us that you have clicked the link to visit the linked website.
- To Understand Our Customers: We use the data we collect, in aggregated form, to understand the demographics of our customer base For Covet Pass, we and the wineries at which you may have redeemed a tasting may share your name with one another to confirm (a) your Covet Pass validity and (b) whether any wine was purchased in connection with such tasting.
- To Improve Your Experience: We also use the personal data we collect to improve the Services, to administer your use of t he Services (including your account, if you have registered for one), to provide you with more relevant and desirable experiences, to provide information and recommendations to you regarding the Platform and Services, and to enable you to easily browse, offer (as applicable), and purchase experiences.
Third Parties: We do not sell or rent your personal data to any third parties, such as marketers.We do, however, share your personal data with third parties that we trust that provide services to us with respect to the Platform and Services, such as payment processors, credit bureaus, banks, verification services, companies that store our data on our behalf (e.g., on servers in data centers managed by a third parties), and other companies that provide services to us. We also provide your personal data to the Suppliers who offer Experiences to you through the Platform, as further described in the Terms of Service. We require that these third parties use and disclose your personal data only to the extent necessary to provide the services we have engaged them to provide. We require that, whether due to restrictions imposed by applicable law, participation in a common framework (e.g., PrivacyShield) or our contractual relationships, these third parties implement and maintain appropriate security measures to protect your personal data from unauthorized access or disclosure.
- Exceptions: In addition to the above, in certain circumstances, we may use and disclose the information we collect for the following purposes:
- To respond to your requests to us for information;
- To provide the Platform and Services to you, including to process, bill, and (if applicable) ship any of your purchases;
- To comply with applicable law, court order, subpoena, or other legal process;
- To help WCM, our affiliates, and suppliers to establish or exercise legal rights or defend against legal claims;
- To respond to any claim that any part of the Platform or Services violates the rights of third parties;
- To investigate, prevent, or take action with regard to illegal activity, suspected fraud, potential threat to the physical safety of any individual, violations of the Terms of Service, or as otherwise required by law;
- To investigate or take action with respect to any circumstance that could expose WCM or its affiliates to liability;
- To otherwise protect the rights of WCM, its affiliates, its users, and the public; and
- If WCM or any of its affiliates undergoes a sale, merger, reorganization, or other change of control, in which case we may release your information to the other company.
How long do we keep your personal data? We will store the personal data we collect from you for so long as we have a legitimate business need to do so (e.g., to complete transactions for you, to comply with applicable legal, tax, accounting or other regulatory requirements, or as may be needed with respect to pending litigation). After such time as we no longer have such business need, we will anonymize it or delete it from our systems. If you have any questions regarding our retention of your personal data, please contact us using the contact information noted below.
Marketing: We would like to send you information about products and services of ours that we think you might like. If you have agreed to receive marketing, you may always opt out at a later date. You have the right at any time to stop WCM from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us at the email address below.
What are your data protection rights? We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access: You have the right to request that we provide copies of your personal data to you. We may charge you a small fee for this service.
The right to rectification: If you believe that any personal data we have is inaccurate or incomplete, you have the right to request that we correct such personal data.
The right to erasure: You have the right to request that we erase your personal data, under certain conditions.
The right to restrict processing: You have the right to request that we restrict the processing of your personal data, under certain conditions.
The right to object to processing: You have the right to object to our processing of your personal data, under certain conditions.
The right to data portability: You have the right to request that we transfer your personal data to another organization, or directly to you, under certain conditions.
If you would like to make any of the above requests, please contact us at the email address below. We will endeavor to respond to you within one month of your request.
How to contact the appropriate authorities: If you are a resident of the European Economic Area (EEA) and believe your personal data is subject to the General Data Protection Regulation (GDPR), you may contact your local supervisory authority or the Information Commissioner’s Office.