Privacy Policy

WineAccess is committed to protecting your privacy. You are important to us, and we will take special care to maintain your trust. In order to fully understand your rights, we encourage you to read this Privacy Policy and to consult our Platform Terms and Conditions. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in the Platform Terms and Conditions. Please direct questions regarding this Privacy Policy to help@wineaccess.com.

This Privacy Policy applies only to the WineAccess Platform. This Privacy Policy does not apply to any websites managed, maintained, and/or hosted by third parties not directly affiliated with WineAccess that you may visit, e.g., via a link provided through the Platform or on a website maintained by any third party. WineAccess does not control the privacy policies of other websites to which we may provide hyperlinks. We encourage you to learn more about the online privacy and data security policies of third party websites directly from such third parties, as their policies may differ from ours.

By submitting your information to us and by using the Platform, WineAccess will assume that you have read, understood, and consent to the Agreement, which includes this Privacy Policy, the Platform Terms and Conditions, and all other applicable WineAccess rules and policies. We also assume that you consent to WineAccess' use of your information as described in the Agreement. If you do not consent, you should not access or use the Platform.

Our Privacy Policy addresses the following questions:

When does WineAccess collect my personal information?

WineAccess gathers information from members and visitors in four ways: voluntary registration/email sign up, member submissions (such as ratings, reviews, purchasing requests), cookie technology and collections of Usage Data (as defined below).

Registration/Email Sign Up

When you register as a member of WineAccess or sign up to receive our email offers, we collect information that helps us identify you. The more information you provide, the better we can customize our services and your experience to suit your needs and preferences. Upon signing up for our email offers, we ask for your email address and zip code only. At the initial registration screen we ask for your name, alias, zip code, country, email address and password ("Account Information"). On occasion, we may also collect additional personal information if you choose to enter a contest or complete a survey form.

When you order products from us, we also ask for your name, shipping address, telephone number, and your credit card number, billing address, and expiration date (your "Order Information"). If you have chosen to receive our email offers and change your mind, visit the "Contact Info" page within the "My WineAccess" section of the Website to change your preferences. (Whenever you decide to change your preferences, please make sure to change your preferences for each account or e-mail address you have with us.)

Reviews

When you submit reviews about products or services, and when you participate in contests and members surveys, the information you provide may become public on the WineAccess Platform and on our partners' websites (e.g., wine retailers, wineries and wine experts.)

Cookies and Other Web Technology

We use cookies to store and track your preferences to provide you with a more personalized member experience. A cookie is a message sent to your browser from a Web server and stored on your computer's hard drive. Most Internet sites use cookies. You can set your browser preferences to reject all cookies, but this will prevent you from using most customized services, and you may have to repeatedly enter personal information in order to participate in various services or promotions. Cookies make your experience easier by saving your preferences and passwords. We also use cookies that contain no personal information at all. These cookies help us estimate our audience size, determine which areas of the WineAccess Website are the most popular, and serve targeted content. The Platform uses both first-party cookies (i.e., cookies that send data directly to WineAccess and agents and contractors acting on behalf of WineAccess, including cookies used to monitor, analyze, and administer the Platform) and third-party cookies (i.e., cookies that send data to our contractors for their commercial use). The cookies on our Platform may track Internet activity across different websites.

In some of our email messages, we may use a "click-through URL" linked to content on the Platform. When an End User clicks onto one of these URLs, the End User will pass through our server before arriving at the destination Web page. WineAccess tracks this click-through data to help us determine End User interest in certain subject matter and measure the effectiveness of these End User communications. You can avoid being tracked in this way by not clicking text or graphic links in emails from WineAccess.

We may use other web technology in order: (i) to advise us of what parts of the Platform End Users have visited, (ii) to measure the effectiveness of any searches End Users perform, and (iii) to enable us to send emails in a format that End Users can read and tell us whether such emails have been opened in order to ensure us that we are sending messages that are of interest to End Users.

Usage Data

When you visit the Website, whether you are logged in or just browsing without logging in, our servers automatically record information that your browser sends whenever you visit a website. The information sent automatically by your browser and the Mobile App is referred to as "Usage Data." This Usage Data may include information such as the manufacturer and model of your mobile device; your Internet Service Provider (ISP); your device's Internet Protocol ("IP") address (or other device identifier), browser type, and operating system; referring/exit pages; clickstream data; pages of the Website that you visit, the time spent on those pages, information you search for on the Platform, and Website access times and dates; and other statistics.

Usage Data also includes geolocation data. The Platform collects geolocation data in order to determine which products may or may not be available to sell into an End User's state or other jurisdiction.

We use Usage Data for technical administration of the Platform, including to monitor and analyze use of the Platform, to increase the functionality and user-friendliness of the Platform, and to better tailor the Platform to End Users' needs. Usage Data may be non-identifying or it may be associated with you. Whenever we associate Usage Data with personal information, we will treat it as personal information. For example, we may log IP addresses for the purposes of systems administration, or to report information in aggregate form to our retail partners and advertisers (e.g., how many visitors logged in to our Website) in a form that is not personally identifiable.

How is my personal information used?

Customized Look and Feel

WineAccess gathers personal information to provide you with an effortless End User experience. For instance, your personal information enables us to greet you when you return to our Platform and to provide you with specific information, such as the wines in your portfolio, as well as services we think will be of interest to you. We review our End Users' preferences, demographics, traffic patterns, and other information - as a whole - so that we can better understand who our audience is and what it wants.

Banner Advertising

Tracking End User preferences also helps us serve targeted advertising. Targeted ads are probably more interesting to you and are more productive for our advertisers. Please note that we do not share your personal information with advertisers. We, or third-party ad servers acting on our behalf, act as the middleman between you and the advertisers that want to reach you. Our third-party ad servers may have access to your personal information, but are bound by the terms of this Privacy Policy.

E-mail

If you register or sign up to access the Platform, from time to time we may e-mail you with informative messages about our products that may be of interest to you. We will not send you third party mailings unless you check the appropriate box when you register. If you elect to receive such offers when you register, you may update your profile at any time afterwards to discontinue such mailings. To update your member profile and/or opt in/out of receiving offers and mailings, please visit the "Contact Info" page within the "My WineAccess" section of the Website or click the "Unsubscribe" link at the bottom of any such mailing.

Who does WineAccess share information with?

We may share End User information in order to provide you with a more integrated and customized End User experience. As further described below, we will not disclose your personal information to third parties, except to the extent that you have consented to the such disclosure or to the extent necessary to provide you with a requested service; under circumstances required by law, to protect and defend our rights and property, to protect our End Users from misuse or unauthorized use of the WineAccess Platform, or to protect the personal safety or property of our End Users or the public; in connection with a business transfer; subject to the terms of a special service, sweepstakes, contest, or promotion; or as otherwise described in this Privacy Policy.

We work closely with certain business partners and vendors and we may provide End User information to our business partners and vendors so that they can offer or provide services to you. For example, we may employ third party companies and individuals for any of the following: to facilitate the Platform; to provide the Platform or portions of the Platform on our behalf; to perform related services, including without limitation, maintenance services, database management, fulfillment, web analytics, and improvement of the features or functionality; or to assist us in analyzing how the Platform is being used. Under certain circumstances, you may avoid having WineAccess share your information with its business partners and vendors by not granting WineAccess permission to share your information. Not granting WineAccess permission to share your information with its business partners or vendors may limit your access to their services through the Platform. We also disclose aggregated End User statistics in order to describe our services and audience to prospective partners, advertisers, and other third parties. However aggregate data is not traceable to you specifically.

We will disclose your personal information when we believe in good faith that any applicable law, regulation, or legal process requires it, or where we believe disclosure is necessary to protect or enforce our rights or the rights of another End User.

As we continue to develop our business, we may buy, sell, or share assets in connection with, for example, a merger, acquisition, reorganization, sale of assets, or bankruptcy. In such transactions, information about End Users generally is often a transferred business asset. In the event that WineAccess itself or substantially all of WineAccess's assets are acquired, information about our End Users, including personal information, may be one of the transferred assets.

Specific uses of personal information that vary from this Privacy Policy (if any) may apply to special services, sweepstakes, contests, or promotions WineAccess may offer from time to time. To the extent that you are notified of uses of your personal information which are different from those described in this Privacy Policy during your enrollment in any particular service, sweepstakes, contest, or promotion, the uses of which you are specifically notified will govern that service, sweepstakes, contest or promotion. Please be on the look-out for supplemental terms of service and privacy statements that apply to the services, sweepstakes, contests, or promotions for which you enroll or participate in.

Note that we do not control the privacy policies of our advertisers and other third party sites to which we provide banner ads and links. If you click-through a banner ad or link to and submit your information to an advertiser, you will be subject to their own privacy policies. We assume no responsibility or liability for these third party policies or the actions of non-affiliated third parties.

What are my options to control the use of my personal information?

Most browsers can be configured to reject cookies or alert you when cookies are being sent. You may cancel your registration to WineAccess and/or request the removal of your personal information from our member records by sending e-mail to help@wineaccess.com. We will send an email to confirm your request. After you respond, we will remove your information from our database. Residual information may remain in our archives and records, but this information will not be used for a commercial purpose (however we may notify you of major changes to our service from time to time). We reserve the right to maintain information on registered End Users who have violated our Platform Terms and Conditions or who have had their access to the WineAccess Platform blocked in order to detect repeat offenders.

Does the WineAccess Platform process my browser's Do Not Track signals?

Some Web browsers may be configured to send Do Not Track signals to websites, or users may use similar mechanisms, to indicate a user's preference that certain web technologies not be used to track the user's online activity. The Platform, including the Website, does not accept or process such Do Not Track signals or similar mechanisms.

What else should I know about my privacy?

You should be aware that if you voluntarily disclose personal information on-line in a public area, that information might be collected and used by others. We do not control the actions of our End Users. If you disclose personal information in a review, message board posting, or any other publicly accessible place on the WineAccess Platform, you do so at your own risk and you understand that your information may be collected and used by others to send you unsolicited messages, advertisements, or for other purposes.

Please remember that protection of your privacy begins with you. You are solely responsible for maintaining the secrecy of any password you use to register, and you should always be careful and responsible whenever disclosing information online.

By accessing and using the Platform, you acknowledge and agree that WineAccess controls and operates all parts of the Platform from its offices in the United States of America and that the Platform is intended for use by End Users located in the United States of America. Unless expressly stated to the contrary, WineAccess makes no representation that the Platform is appropriate or will be available for use in other locations. If you access the Platform from outside the United States, you acknowledge and agree that your information may be transferred to and maintained on computers and servers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Your consent to the Agreement followed by your submission of such information represents your agreement to the transfer of such information to the United States and the collection, use, and disclosure of your information in accordance with United States law and this Privacy Policy.

This Platform has security measures in place to protect the loss, misuse, and alteration of the information under our control. When you place orders or access your account information, we use a secure server. The secure server layer (SSL) encrypts all information you input before it is sent to us. All of the End User data we collect is similarly protected against unauthorized access.

Please note that no security system is impenetrable. Accordingly, we do not guarantee the security of our databases, nor that information you supply will not be intercepted while being transmitted to us over the Internet or other network. Any information you transmit to WineAccess, you do at your own risk. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting through the Platform in the most expedient time possible and without unreasonable delay, as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Links to Other Web Sites

The WineAccess Platform contain links to other sites, operated by third parties, that we think may be of interest to you. WineAccess encourages third parties to follow appropriate privacy standards and policies, but is not responsible for the actions of those third parties, the content of their websites, or any practices they may follow.

How do I accept this Privacy Policy?

By using the WineAccess Platform, you signify your acceptance of this Privacy Policy. If you do not agree or are not comfortable with this Privacy Policy, your only remedy is to discontinue use of the WineAccess Platform. We reserve the right to modify this Privacy Policy at any time. Your continued use of any portion of the WineAccess Platform following notification or posting of such changes will constitute your acceptance of those changes. If you have questions or concerns about our specific policies, please send an e-mail to help@wineaccess.com.

Use By Minors

The Platform is intended for use only by adults of legal age in the states or territories where they reside. Usage of the Platform by minors (including by children under the age of thirteen (13)) is not intended and a violation of the Agreement. If we believe that you are a minor, we may, at any time, in our sole discretion, and with or without notice: (i) terminate your access to or use of the Platform (or any portion, aspect, or feature of them), or (ii) delete any content or information that you have posted through the Platform.

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