Privacy Policy

WineDirect, Inc.

Last revised: August 24, 2011

This Privacy Policy ("Privacy Policy") covers WineDirect, Inc.’s (“WineDirect, we, us, or our”) treatment of personally identifiable information collected by or submitted to WineDirect, including information submitted via the Internet, by telephone, mail or otherwise. All references to WineDirect℠ in this Privacy Policy are intended to be inclusive of authorized use of any WineDirect owned, hosted and/or operated web sites or services (collectively, the “Sites”), including but not limited to, "Call for Wine", “WineDirect Fulfillment”, “WineDirect eCommerce”, and “Wine Link”.  WineDirect respects your desire for privacy and will make reasonable efforts to use personally identifiable information in accordance with this Privacy Policy. Because this Privacy Policy addresses WineDirect’s use of personally identifiable information, WineDirect suggests that you review this Privacy Policy carefully. Note that to the extent any portions of the following Privacy Policy are inconsistent with applicable law or regulations, or to the extent you provide your express consent for uses not specifically described below, then such laws or regulations, or your express consent, will govern WineDirect’s use of your personally identifiable information.

INFORMATION COLLECTION

General

It is the policy of WineDirect that no part of any data uploaded by WineDirect Clients (“Clients”) in the course of using any of the Sites will be used for commercial purposes, given to other companies or associations or otherwise made available for use by any entity. The issue of assuring the privacy of Clients using the Sites, their customer and sales data, and the privacy of their customers is of critical importance to us. To the extent WineDirect views any data uploaded to our Sites, it is always viewed as anonymous and aggregate data and never individual data or data associated with a particular Sites’ user. Subject to the other statements in this Privacy Policy, WineDirect’s policy is not to request or collect especially sensitive personally identifiable information, such as religious preferences, racial or ethnic background or other similar forms of data. WineDirect collects personally identifiable information that you provide to us, and that you provide to our Clients who in turn provide it to us, over the Internet, by email, regular mail, or by phone, or that we may receive from third parties that give your information to us through other legal means. For the purposes set forth in greater detail below, WineDirect may collect information in any of the following categories: your name, physical address, email address, phone numbers, date of birth, personal interests or preferences, information regarding your interest, purchase or use of WineDirect’s or our Clients’ services or products, and other information relevant to responding to your inquiries and providing services to our Clients and business partners. In connection with the following, WineDirect may collect financial information from or about you, such as credit card numbers, billing addresses, expiration dates, and etc., in order to facilitate the billing and payment of your accounts and purchases from WineDirect or our clients. For information you submit directly to WineDirect, we will generally attempt to notify you which categories of information are required and which are optional. If you do not wish to provide us information that WineDirect requests, then you should not provide such information. However, please be aware that if you do not provide us with certain information that we require, then we may not be able to respond to your requests, process your inquiries, bill or pay you in accordance with your proposed contracts with us, or provide you complete services. If you have any concerns about the nature of the information WineDirect collects, you may contact us at the address as set forth below.

Certain Other Forms of Information Collected on the Internet

Use Data

If you use our Sites, WineDirect may collect non-personally identifiable information about your use of the Sites (such as IP addresses, domains, browser type and version, and operating system) ("Use Data").

Cookies

A cookie is a small file stored on a user's computer that contains information about the user. WineDirect may use either session ID cookies and/or persistent cookies. For the session ID cookie, once a user closes the browser, the cookie simply terminates. A persistent cookie is a small text file stored on a user's hard drive for an extended period of time. Persistent cookies can be removed by following Internet browser help file directions. By showing how and when you use the Sites, cookies help us see which areas are popular and which are not and help in targeting information based on your interests. Cookies also allow us to store the personal preferences that you set during each visit to the Sites, which in turn allows us to speed up your future activities at the Sites. Most browsers are initially set to accept cookies. You can set your browser to notify you when you have received a cookie, giving you the opportunity to decide whether to accept it. You have the option to reject our cookies and still use our Sites, but you may not be able to access or use some of the features we offer on our Sites (including certain members-only functions and functions with respect to WineDirect’s referral programs). Our Sites include third–party advertising and links to other websites. Some of our business partners (e.g., advertisers) use cookies on our Sites. We have no access to or control over these cookies. These third–party websites and advertisers, or Internet advertising companies working on their behalf, sometimes use technology to send (or “serve”) the advertisements that appear on our website directly to your browser. They automatically receive your IP address when this happens. They may also use cookies, JavaScript, web beacons (also known as action tags or single–pixel gifs), and other technologies to measure the effectiveness of their ads and to personalize advertising content. We do not have access to or control over cookies or other features that they may use, and the information practices of these advertisers and third–party websites are not covered by this Privacy Policy. Please contact them directly for more information about their privacy practices.

Log Files

Like most standard website servers, our Sites use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track users’ movement and gather demographic information for aggregate use. IP addresses are not linked to personally identifiable sites.

USE OF INFORMATION

Use to Fulfill WineDirect’s Obligations and Your Requests

WineDirect will use your personally identifiable information to provide you with any information you request from us, including sales and marketing materials, and to address any communications that you may have initiated or authorized. WineDirect will also use your information to fulfill our obligations to you pursuant to any contracts or agreements that you may enter into with WineDirect, or in connection with any of our programs, events or promotions in which you register or participate. For example: If you are a prospective customer, WineDirect uses information you submit in connection with your inquiries, to establish and activate your account. We may also use your information to provide assistance or support with respect to your use of our services or Sites, to troubleshoot problems and to resolve disputes that may arise. Further, WineDirect may use your information to improve our content, advertising or services, or to analyze trends or to customize the display or format of our marketing content or Sites. From time to time, WineDirect may send you information about our services and offerings, and about certain products and services of selected third parties, in which we think you may be interested. WineDirect℠ will not use your information or send you information if you have notified us of your preference not to have your information so used, or not to receive such information, or when we are prohibited by law from doing so.

Use on Behalf of WineDirect's Clients

Frequently, WineDirect will receive your personally identifiable information from our Clients, who require that we use your information so that our Clients may fulfill their contractual obligations to you. This may include processing orders that you place with our Clients, sending you emails regarding your accounts and orders with our Clients, and giving you updates and announcements that you have authorized our Clients to provide you. This information may include: contact information such as name and shipping address; financial information such as credit card number, expiration date, billing address, and billing phone number. This information is used for billing purposes to verify that the customer is of legal age, and to fill customers' orders. If we encounter difficulty when processing an order, this contact information is used to contact the user. It is our policy to use your personally identifiable information consistent with the terms of the privacy policy of our Client who provided your information to us, but WineDirect relies on the representations of our Clients that they have received all proper consents to provide us your personally identifiable information and to use it in the manner in which they instruct us.

Sharing of Information

For the purposes described above and to the extent permitted by law and regulations, WineDirect may share your personally identifiable information with the following categories of entities: Our Clients on whose behalf you submit your information to us, or who originally submitted your information to us. Third parties that perform information processing on WineDirect’s (or our Clients’) behalf or that provide analyses of use of WineDirect’s or our Clients’ products, services or sites. Third parties that perform on WineDirect’s (or our Clients’) behalf, or that help us perform, WineDirect’s (or our Clients’) contractual obligations to you. In response to a request by law enforcement or other governmental personnel or court order or subpoena; if WineDirect is under a legal obligation to do so; to protect the integrity of our company if we believe that a user has committed unlawful or otherwise harmful acts; to protect our interests in connection with a legal proceeding; in emergency situations to protect health or safety; if we believe such disclosure is in your vital interest; or if we obtained your information from public sources. On rare occasions, to third parties with whom WineDirect has advertising or promotional relationships (provided that we are not otherwise restricted from making such disclosures). In connection with any merger or consolidation with, or sale of substantially all of WineDirect’s assets to, an affiliated entity or third party, in which case such other entity will be informed of its obligations with respect to your information under this Privacy Policy.

Use of Use Data and other Internet-Based Information

WineDirect uses aggregated (i.e., non-personally identifiable) Use Data for purposes of site administration and to compile information about usage of our Sites. WineDirect may share aggregated information (which does not contain your personally identifiable information) with third parties, such as advertisers and marketing partners. We may combine personally identifiable information with Use Data to help us serve you better in connection with your use of our Sites, and to respond to your requests for technical assistance (e.g., WineDirect may record which WineDirect browser you use in order to help respond to your questions with difficulties using our Sites).

SECURITY

WineDirect takes appropriate technical and organizational measures to help prevent unauthorized access, maintain data security, and to make proper use of the information that we collect. But no transmission of data over the Internet is guaranteed to be completely secure, and WineDirect cannot guarantee the security of any information you provide to us. For example, third parties may unlawfully intercept or access transmissions or private communications. Therefore, although we use industry standard practices to protect your privacy, WineDirect does not promise or guarantee, and you should not expect, that your personally identifiable information or communications with us will always remain private.

MODIFYING OR DELETING PERSONALLY IDENTIFIABLE INFORMATION; OPT-OUT

WineDirect intends to keep your information accurate and up to date. You have the opportunity to review and correct any of your information that we may have, or to restrict the uses we make of your information. In order to review or correct your information that WineDirect has on file, please take the following steps: Contact WineDirect via email at info@winedirect.com. Give us your name and email address, together with any information that might help us more effectively serve or communicate with you. Let us know how we can help you. Let us know the most convenient way for WineDirect to communicate with you (email or phone). If you request that certain information be amended, IBG will use reasonable efforts to accommodate your request in a timely manner.

If you are a Client or otherwise have established a contractual relationship with WineDirect, there is certain information that we must maintain in order to properly service your account. WineDirect retains certain information in our sole discretion that we need to process your information in order to fulfill your requests and our contracts with you, to maintain our records in accordance with industry practices, to resolve disputes, to troubleshoot problems, to enforce this Privacy Policy, or for other valid business reasons; it is not WineDirect’s policy to retain more information for longer than is necessary. Please note that WineDirect will not remove your non-personally identifiable Use Data from our aggregated files. Furthermore, please be aware that even if you request that your information be removed from our systems, such information may never be completely removed due to technical and legal constraints, including backup and disaster recovery systems, as WineDirect has the need to keep some information to track and record your requests.

You may receive information regarding new features, services and special offers we think you'll find valuable. If you'd like to opt out of future mailings, contact WineDirect via email at info@winedirect.com.

NOTIFICATION OF CHANGES TO THIS PRIVACY POLICY

WineDirect may, at our sole discretion, revise this Privacy Policy at any time in a manner consistent with applicable law and regulations. When WineDirect revises this Privacy Policy, we will incorporate the revisions into this Privacy Policy and will revise the "last updated" date at the top of this page. Please check this Privacy Policy periodically for the most current version of WineDirect’s Privacy Policy to confirm your continued agreement with its terms, which will be inferred by your continued association with us following any such modifications.

MINORS WineDirect’s Sites are not directed toward individuals under twenty-one years old (“Minors”) nor do we knowingly collect information from Minors.

LINKS

WineDirect’s Sites may contain links to other sites. Please be aware that WineDirect is not responsible for the privacy practices of such other sites. WineDirect encourages our users to be aware when they leave our Sites and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by WineDirect Sites.

CONTACT INFORMATION

You may contact us at any address or number that WineDirect has provided to you, or, as a general matter, at the following:

WineDirect, Inc.
1190 Airport Blvd., Ste. 200
Napa, CA 94558
707-603-4000