PRIVACY POLICY

Last updated: 01/01/2025

Your privacy is important to us. As such, it is the policy of World of Wine, Ltd. and our affiliates (“World of Wine,” “we,” “our,” or “us”), to collect, process, and retain personal information responsibly in the course of providing information and services to direct customers, customers which we are servicing pursuant to an order fulfillment obligation, newsletter recipients, and social media connections, including when visiting or using our website and engaging our online services (collectively, the “Services”). Simply put, we are passionate about and in the business of selling exceptional and distinctive wine. This policy describes how we will use your personal information to achieve our primary goal: providing users with best-in-class wine buying opportunities.

This privacy policy describes our collection and use of personal information about you, including on our websites, blogs, message boards, social media pages, apps, and services we may provide that link to this policy. We may also offer additional wine-related services that have their own privacy policies. In these cases, please refer to the privacy policy associated with the service you are using for the governing privacy policy. For the purposes of this policy, personal information is defined as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person.

Information We Collect About You

Voluntarily Provided Information
Categories of personal information we may collect about you include:

• Full name
• Email address
• Postal/residential address
• Date of birth
• Phone number
• Billing information and payment details
• Username/customer number and password
• Other information that although not requested you provide via the Services or via other contact methods, including via email or our Contact Us form

Please see How We Use Personal Information below for additional information on the categories of personal information that we collect.

We collect many of the types of personal information listed above directly from you when you use the Services or otherwise interact with us. When we are fulfilling an order in partnership with a third-party (e.g. a partner marketplace with or for whom we perform order fulfillment services) we may collect the types of personal information listed above either directly from you or receive your personal information via the partner marketplace or third party. In some cases, if you are paying for services, you may be required to provide credit card information or financial account information for billing purposes to a third-party payment processor.
We also collect personal information when you voluntarily provide it or make it available to us by (1) logging into, creating an account on one of our online Services, or registering for a newsletter or other communication; (2) providing feedback to us through a feedback tool or other communication method such as email. Each manner in which we collect personal information about you occurs only when you voluntarily provide information to us or to a third-party partner with or for whom we are performing wine order fulfillment.

Information Created in the Course of Your Use of the Services
 

Cookies and Automatically Collected Information
We may collect the following personal information automatically through your use of the online Services:

• Browser information such as type and version
• Browsing activity such as page impressions and length of stay on pages
• Device information such as operating system and unique identifiers
• IP/MAC address
• Dates and times of access
• Websites that are accessed via our website

For certain online Services, we also use cookies and similar technologies to enhance the usability of our website, track web traffic and advertising. We and our service providers and third-party advertisement servers may use cookies and similar technologies to, over time, collect information about your usage of our online Services and across different websites that have a business relationship with us or one of our service providers or third-party advertisement servers. Cookies are text files that are transferred to your computer’s hard drive as you navigate our Site and other sites. We use cookies to help us show advertisements on other websites likely to be more interesting to you; to compile aggregate data about site traffic and site interaction; and to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services, site experiences, and tools in the future. To make choices about interest-based ads from participating third parties, please visit the Digital Advertising Alliance (DAA) consumer opt out page.

Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. You may be able to adjust the preferences on your browser or device to change your devices acceptance of cookies, but doing so may limit our ability to provide content tailored to you. You can find more information regarding management of your cookies at About Cookies.

We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how we do so in this privacy policy. For more information about do not track, visit www.allaboutdnt.org.
 

Third-Party Websites or Services
We may provide links to third-party websites or payment processors. You acknowledge that such links are provided for your convenience only and do not constitute an endorsement by us of such third-party websites or services. Since we do not control these third-party websites or services, we are not responsible for the contents or security of any linked-to third-party websites, any hyperlink in a linked-to website, or payment processing services. We assume no responsibility for the privacy practices of such websites and third-party services. We strongly recommend that you review the privacy policies of all third-party websites and services.

How We Use Personal Information
We may use your personal information for the Purpose, including as follows:

• Identification and authentication: We use your identification information to verify your identity when you access and use the Services. This is so we can comply with our contractual obligations to you. We may also use identification information for marketing, ordering data, and customer service purposes.
• Operating the Services and Providing Other Services to You: We process your personal information to provide the Services you have requested and other services for which we have an agreement with you or which you request. This is so we can comply with our contractual obligations to you.
• Improving our Services: We may analyze information about how you use the Services to provide an improved experience for our customers of all our Services, including product testing and site analytics. It is in our legitimate business interests to use the information provided to us for this purpose, so we can understand any issues with the Services and improve them.
• Communicating with you: We may use your personal information when we communicate with you, for example if we are providing information about changes to the terms and conditions of services or if you contact us with questions. It is in our legitimate interests that we are able to provide you with appropriate responses and provide you with notices about the Services.
• Marketing: We may use your personal information to send you wine-buying newsletters or information about us or third-party wine offerings and services that may be of interest to you. We also have automated marketing emails set up for individuals who opt in or who have otherwise consented to receive marketing materials from us. We may also analyze user personal information in order to better understand our users and their wine purchasing interests and inform our marketing strategies. It is in our legitimate business interests to provide more relevant and interesting advertising messages. Where required by law, we will obtain your consent before sending such marketing messages.
• Exercising our rights: We may use your personal information to exercise our legal rights where it is necessary to do so, for example to detect, prevent and respond to fraud claims, intellectual property infringement claims or violations of law or our applicable policies and Terms of Use.
• Complying with our obligations: We may process your personal information to, for example, carry out sales and use tax reporting, compliance verifications (i.e. age or residency restrictions), fraud prevention checks or comply with other legal or regulatory requirements, where this is explicitly required by law.
• Customizing your experience: When you use the Services, we may use your personal information to improve your experience of the Services, such as by providing relevant interactive or personalized elements on the online Services and providing you with content based on your interests and order history.
• De-identified information: We may also anonymize your personal information in such a way that you may not reasonably be re-identified by us or any other company and may use this anonymized information for any other purpose.

Disclosures of Personal Information
We may share your personal information with third parties under the following circumstances:
• Service providers and business partners: Always with the purpose of fulfilling your orders or providing wine-buying options of interest to you, we may share your personal information with our service providers and business partners that perform order collection, marketing services and other business operations for or in partnership with us. Our third-party email platform collects contact information and online sales order information. Further, our third-party backend system stores customers’ information when they register an account. When we share your personal information with them, our service providers and partners are contractually obligated to adhere to this privacy policy and may not use your personal information for their own, unrelated purposes.

• Affiliates: Always with the purpose of fulfilling your orders or providing best-in-class wine-buying options of interest to you, we may share your personal information with our affiliates.
• Where required by law: We may share your personal information with law enforcement agencies, courts, other government authorities or other third parties when necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights.
• In the context of a transaction: We may share your personal information with potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell or transfer all or a portion of our assets or business. Should such a corporate sale or transfer occur, we will use reasonable efforts to obligate the entity to which we transfer your personal information to use it in a manner that is consistent with this privacy policy.

We may also share de-identified aggregate information that may not reasonably be re-identified by us or any other company with third parties and advertisers so they can measure the effectiveness of any advertisements viewed in connection with our Services. For example, we may tell advertisers the number of users who clicked on a particular advertisement.
 

Sale, Rental or Sharing of Personal Information
We do not sell, swap, or rent your personal information. Neither do we authorize any third party to use personal information submitted by users of our Services for the third party’s own, unrelated purposes.

Location Specific Privacy Notices

Notice to California Residents

The California Consumer Privacy Act (CCPA) provides California residents with certain rights regarding their personal information (subject to certain limitations at law). The following section describes your CCPA rights and explains how to exercise those rights.

Right to Access and Portability
California residents have the right to request certain information about our collection and use of their personal information over the last twelve (12) months. Once we receive and verify a user’s identity and California residency, we will disclose to you the following:

• The categories of personal information we collected about you;
• The categories of sources for the personal information we collected about you;
• Our business or commercial purpose for collecting or selling that personal information;
• The categories of third parties with whom we share that personal information;
• The specific pieces of personal information we collected about you (also called a data portability request); and
• If we disclose your personal information for a business purpose, identifying the personal information categories disclosed.

Right to Deletion
The CCPA provides California residents the right to request that we permanently delete any personal information about you that we collect and retain, subject to certain exceptions. Once we receive and verify your request, we will delete (and, as applicable, direct our service providers to delete) your personal information from our records, unless an exception applies.

In respect to deletion request exceptions, we may deny a deletion request if retaining the personal information is necessary to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity;
• Debug products to identify and repair errors that impair existing intended functionality;
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
• Enable solely internal uses of the personal information that are reasonably aligned with consumer expectations;
• Comply with a legal obligation and requests from law enforcement agencies; and
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Correct Inaccurate Personal Information
To exercise the right to access and/or correct inaccurate personal information, please submit a request via e-mail using the How to Contact Us information below.

Verification of a California Consumer Request
An access, deletion, and/or correction requests may be submitted by a California resident or a person registered with the California Secretary of State that is authorized to act on their behalf. These requests for access, deletion, and/or correction, can only be made twice during a twelve (12) month period, and must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information (or an authorized representative); and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your (or an authorized representative’s) request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Authorized Representative

A California resident may use an authorized representative to submit a right to access, correct, or delete request. To use an authorized representative for this purpose, the California resident must provide the representative with written authorization. In addition, the California resident may be required to verify their own identity with us. We may deny a request from a representative that does not submit proof that they have been authorized by the California resident to act on their behalf. Such requirements, however, will not apply where a California resident has provided the authorized representative with power of attorney pursuant to Cal. Prob. Code Sections 4000 to 4465.

How to Exercise Privacy Rights
If you have any questions or comments, or would like to exercise any of your rights, please contact us via e-mail using the information in the How to Contact Us section below.

Timeframe for Responding to Requests
We will respond to your request within thirty (30) days of receipt.
The period of response may be extended to sixty (60) or ninety (90) days if more time is required to fulfill your request. In that event, we will inform you of the reason and a timeframe for a response in writing. After verification, we will deliver the requested information to you in a portable, easily readable electronic format.

Fee
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

No Discrimination
The CCPA prohibits a business from discriminating against California residents for exercising the rights outlined above. We will not discriminate against you for submitting such requests by:

• Denying goods or services to you;
• Charging different prices or rates for goods or services, including through the use of discounts, benefits, or other penalties;
• Providing a different level or quality of goods or services; and
• Suggesting a different price or quality of goods or services will apply if rights are exercised.

No Financial Incentive
We do not offer any financial incentives or price or service differences in an attempt to influence a resident’s decision whether or not to exercise a right afforded to the consumer under the CCPA.

Right to Opt-Out of the Sale of Your Information
We do not sell data, as it is defined in the CCPA, will not sell personal information in the future, and in the preceding twelve (12) months, have not sold any personal information.

Notice to Colorado Residents
Under Colorado’s Consumer Privacy Act (CPA), Colorado residents have certain rights around our collection, use, and sharing of their Personal Information.
We do not currently sell any Personal Information we collect to any third parties. If we were to do so in the future, we will update this Privacy Policy, and provide Colorado residents with the opportunity to opt-out of the sale of their Personal Information. We also do not engage in profiling in furtherance of decisions that produce legal or similar significant effects.

We may work with advertisers and analytics service providers to target our advertisements elsewhere online, and to provide us information on the effectiveness of our advertisements and Site traffic. As a Colorado resident you have the right to opt-out of such targeted advertising.

We collect various categories of Personal Information depending on how you choose to engage with us as described in the Information We Collect About You section above. The Disclosures of Personal Information section above also describes how and under what circumstances Personal Information may be shared with third parties.

If you are a resident of Colorado, you have the right to (1) request to know what Personal Information has been collected about you, and to access that information; (2) request to correct inaccuracies in your Personal Information; (3) request deletion of your Personal Information (exceptions under the CPA and other laws may allow us to retain and use your Personal Information notwithstanding your deletion request); and (4) obtain a copy of your Personal Information.

If you have any questions or comments, or would like to exercise any of your rights, please contact us using the e-mail in the How to Contact Us section below.

Notice to Connecticut Residents
Under the Connecticut Data Privacy Act (CTDPA), which went into effect July 1, 2023, Connecticut residents have certain rights around our collection, use, and sharing of their Personal Information.

We do not currently sell any Personal Information we collect to any third parties. If we were to do so in the future, we will update this Privacy Policy, and provide Connecticut residents with the opportunity to opt-out of the sale of their Personal Information. We also do not engage in profiling in furtherance of decisions that produce legal or similar significant effects.

We may work with advertisers and analytics service providers to target our advertisements elsewhere online, and to provide us information on the effectiveness of our advertisements and Site traffic. As a Connecticut resident you have the right to opt-out of such targeted advertising.

If you are a resident of Connecticut, you have the right to (1) request to know what Personal Information has been collected about you, and to access that information; (2) request to correct inaccuracies in your Personal Information; (3) request deletion of your Personal Information (exceptions under CTDPA and other laws may allow us to retain and use certain Personal Information notwithstanding your deletion request); (4) obtain a copy of your Personal Information; and (5) opt out of targeted advertising.

If you have any questions or comments, or would like to exercise any of your rights, please contact us using the e-mail in the How to Contact Us section below.

Notice to Nevada Residents
Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt-out of the sale of certain information that the website operators may collect about them.

We do not presently sell any personal information we collect to any third parties. If we were to do so in the future, we will update this Policy, and provide Nevada residents with the opportunity to opt-out of the sale of their personal information.*

Notice to Virginia Residents
Under Virginia’s Consumer Data Protection Act (CDPA), Virginia residents have certain rights around our collection, use, and sharing of their Personal Information.
We do not currently sell any Personal Information we collect to any third parties. If we were to do so in the future, we will update this Policy, and provide Virginia residents with the opportunity to opt-out of sale of their Personal Information. We also do not engage in profiling in furtherance of decisions that produce legal or similar significant effects.

We may work with advertisers and analytics service providers to target our advertisements elsewhere online, and to provide us information on the effectiveness of our advertisements and Site traffic. As a Virginia resident you have the right to opt-out of such targeted advertising.

We collect various categories of Personal Information depending on how you choose to engage with us as described in the sections Information We Collect About You. Disclosures of Personal Information describes how and under what circumstances Personal Information may be shared with third parties.

If you are a resident of Virginia, you have the right to (1) request to know what Personal Information has been collected about you, and to access that information; (2) request to correct inaccuracies in your Personal Information; (3) request deletion of your Personal Information (exceptions under CDPA and other laws may allow the us to retain and use certain Personal Information notwithstanding your deletion request); (4) obtain a copy of your Personal Information; and (5) opt out of targeted advertising.

If you have any questions or comments, or would like to exercise any of your rights, please contact us via e-mail in the How to Contact Us section below.

Children’s Information
Our site is not directed at children nor users below the age of 21. Neither do we knowingly collect personal information from children nor users under the age of 21. If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us by using the information in the “Contacting Us” section, below, and we will take steps to remove such personal information from our systems.

Information Security and Storage
As part of our commitment to maintaining reasonable security, the organization has taken commercially reasonable steps to protect the information it has gathered about you, including but not limited to encrypting data at rest, providing employees or contractors access to data only on an as needed basis, and utilizing other security measures reasonably designed to protect your personal information.

We retain your personal information for as long as we have a relationship with you, and longer if for legitimate business purposes. When deciding how long to keep your personal information after our relationship with you has ended, we take into account our legal obligations. We may also retain records to investigate or defend against potential legal claims.

Customer Service and how to Acquire Additional Information
We are committed to providing every user with prompt, high-quality support at all times. Email is the primary form of contact for users with questions related to this policy and we encourage you to email us with questions, data privacy rights requests, and concerns at the address displayed in the How to Contact Us section below. Additional information can be found at

Changes to this Policy
This privacy policy may be amended from time to time. Any such changes will be posted on this page and the effective date of such changes reflected above as the date last updated.

Contacting Us
Use the contact form above if you have questions, concerns, or complaints about this privacy policy or our privacy practices or would like additional information about our privacy practices.