Last modified: June 2020
Information We Collect
INFORMATION YOU PROVIDE TO US
We collect information directly from you. For example, we collect information when you make a purchase, request an emailed purchase receipt, sign up for our wine club, book a tasting reservation, purchase event tickets, or register for an online account. We collect information when you sign up to receive news, notifications, or other communications from us. We also collect information when you engage with us on social media, fill out a form, or participate in a survey or promotion. We also collect information when you engage with us using the Contact Us instructions below, and through the technology we use in our services (see Cookies and Similar Technologies section below). The types of information we collect directly from you may include:
- Personal Identification Information such as your name, date of birth, and identity document (e.g., photo of your driver’s license).
- Contact Information such as your mailing and shipping addresses, email address, and phone number.
- Payment Information, including your payment card information and billing address.
- Demographic Data (such as your date of birth and zip code).
- Other Identifying Information that you voluntarily choose to provide to us, including without limitation unique identifiers such as passwords, and personal information in messages that you send to us and/or provide to our customer service team.
INFORMATION WE COLLECT AUTOMATICALLY
We automatically collect information about you when you access or use our Services or do business with us. For example, we collect:
- Purchase Information. When you make a purchase or receive a refund, we collect information about the transaction. This may include product details, purchase price, date, tender type and location of the transaction.
- Browsing and Usage Information. When you use our internet-based Services, some information is collected automatically, including as described in the Cookies and Similar Technologies section below. For example, when you visit our website, our server automatically logs your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language, the website you visited before our site, and your activity on our websites. We also collect information about what products and services you browse or express an interest in and we track your activity on our Services and websites where our advertising is served, such as which pages and ads you view or click on.
- Device Information. We collect information about the computer or mobile device you use to access our Services. This may include the hardware model, operating system and version, unique device identifiers, and mobile network information.
- Location Information. We may collect or infer information about your general location when you access or use the Services, visit our winery, or turn on Bluetooth, Wi-Fi or other geolocation functionality on your device. If you enable location services on your device, we collect more precise geolocation information. This lets us serve you the location of our winery and provide location-based services or functions. You can opt-out of the collection of precise geolocation information at any time (see Your Choices below for details).
- Chat Transcripts. We record chat transcripts and website sessions for a period of time when you interact with our customer support personnel.
We work with third-party companies for advertising purposes, including to: serve advertisements across the Internet; track and categorize your activity and interests over time on our website and mobile application, and on third-party websites and mobile applications; and to identify the different device(s) you use to access websites and mobile applications. We share information with these companies, and these companies may collect information—including automatically collected information when you use our website or mobile application—through the methods described in the Information We Collect Automatically section above. These third-party companies also may possess or obtain information about you from your interactions: directly with the third-party companies; with other websites, mobile applications, or companies that the third-party companies work with; or from your interactions with advertisements the third-party companies help to display to you. The information that these companies collect or that we share may be used to customize or personalize the advertisements that are displayed to you.
We do not sell, but may share personal information with the third-party companies we work with for our purposes, though in general we do not share personal information about you with third parties for third-party marketing or advertising purposes. We may also share other information at our discretion, including automatically collected information, which may be used by third parties for third-party marketing, advertising, and other purposes. For information about the choices you have about the online advertising practices described in this section, please see the Your Choices and Cookies and Similar Technologies sections below.
INFORMATION WE CREATE OR GENERATE
We infer new information from the information we collect, including using automated means to create or generate information about your likely preferences, interests, or other characteristics (“inferences”). For example, we may infer your city, state, and country location based on your IP address or zip code. We may also infer product or services that may interest you based on your prior purchases with us.
INFORMATION WE RECEIVE FROM OTHER SOURCES
We may collect information about you from other sources that we may combine or link with information we have about you. We may combine information that we have collected offline with information we collect online. In addition, we may collect information from:
USE OF INFORMATION
We do not sell the information we collect about you, but use it to help us operate our business. In particular, we use the information we collect (as described in Section 1 above) for the following purposes:
- Order Processing and Shipment. To process, and when requested, to fulfill, and ship your orders: All categories described in Section 1 above.
- Business Operations. To operate our business, such as: creating and maintaining your customer account, creating and maintaining club member accounts; billing, accounting, improving our internal operations; securing our systems, and detecting fraudulent or illegal activity; monitoring and analyzing trends, usage and activities in connection with our Services and wineries; and for any other business purpose permitted by law: All categories described in Section 1 above.
- Personalization. To understand you and your preferences to enhance your experience and enjoyment while visiting the winery and personalize your online experience and the advertisements you see when you use the Services or other platforms: identification information, contact information, demographic information, payment information, purchase information, browsing and usage information, device information, location information, inferences, and data sourced from other companies.
- Customer Support. To provide customer support and respond to your questions, process refunds, answer delivery questions: identification information, contact information, payment information, purchase information, location information, chat data, data sourced from other companies.
- Communications. To send you information and notices about your account or membership, such as updates, order confirmations, delivery and pickup notices, security alerts, and support and administrative messages: identification information, contact information, payment information, purchase information, browsing and usage information, device information, and location information.
- Marketing. To communicate with you about new products and services, offers, promotions, rewards, upcoming events, and other information about our products and services and those of other CWG wineries (see Your Choices below for details about changing your preferences for promotional communications): identification information, contact information, payment information, purchase information, location information, inferences, and data sourced from other companies.
- Advertising. To display advertising to you (see the Cookies and Similar Technologies section below for information about personalized advertising and your advertising choices): identification information, contact information, aggregated demographic information, purchase information, browsing and usage information, device information, location information, inferences, and data sources from other companies.
- For any other purpose described to you at the time information is collected: All categories described in Section 1 above.
In carrying out these purposes, we combine data we collect from different sources to give you a more seamless, consistent, and personalized experience.
We do not direct the Services to individuals under the age of twenty-one (21). We do not knowingly collect Personal Information from individuals under 21.
Sharing of Information
- Service Providers. We share information with our service providers that help us:
- process, fulfill, ship and deliver your orders.
- provide customer service and resolve complaints.
- analyze data of customer and club member activity.
- design and execute our marketing campaigns, administer our promotions, and provide advertising services.
- investigate and resolve claims.
- allow you to order products online and have them delivered.
- allow you to make tasting reservations or order event tickets online.
- Corporate Transactions. We may disclose information about you as part of a corporate transaction. This could be a merger, acquisition, joint venture, sale of company assets, reorganization, divestiture, bankruptcy or similar type of business transaction.
- Legally Required Disclosures, Other Uses and Disclosures. We share information about you as necessary to comply with applicable law or legal process, such as requests from authorities, regulators and courts. We share information to respond to complaints or legal claims or to protect the rights, property or personal safety of the CWG wineries, our customers, club members, employees or the public. We may also share aggregated or de-identified information that cannot reasonably be linked to you.
- Cookies and Similar Technologies
- Provide us with general analytics about our Services, including demographic information in a non-identifiable form, in order to improve our Services’ performance and customize users’ experience;
- Support security measures, such as requiring re-login into your account;
- Allow you to engage in our social media offerings on our Services (e.g., Facebook “Like” button); and
- More effectively market our Services and advertise other Services (including the Services of products from across our portfolio of brands) that may be of interest to you.
Where required by law, we collect your consent for the use of such technologies.
- Cookies. A cookie is a small text file saved on your device or browser. Some of these cookies are necessary for the functioning of our Services (known as “Strictly Necessary” cookies), while others are not (known as “Non-Essential” cookies). Some cookies (known as “persistent cookies”) will remain on your device until you delete them, while others (known as “session cookies”) are automatically erased when you exit your Internet browser.
You can set our device or browser to accept or reject most cookies, or to notify you in most situations that a cookie is offered so that you can decide whether to accept it. However, if you block cookies, certain features on our Services may not function. Additionally, even if you block or delete Cookies, not all tracking will necessarily stop.
- Online Advertising. You can manage third-party advertising preferences for some of the third parties we work with to serve advertising across the Internet by using the choices available at:
We do not guarantee that all of the third parties we work with will honor the elections you make using those options, but we strive to work with third parties that do.
- Log Files. We automatically gather log files, such as your IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data when you use our Services. We may combine information in log files with your information.
- Clear Gifs (Web Beacons/Embedded Pixels). Clear Gifs are embedded on our Services and are very small. The information collected by these technologies is associated with other technology and information, but only for internal purposes only.
- Email. If you no longer wish to receive email marketing communications from us, you may opt-out of receiving marketing-related emails by using the unsubscribe method provided in our communications (e.g., by clicking on the “unsubscribe” link in the email to unsubscribe). Alternatively, to the extent that applicable laws requires your prior opt-in consent to receive marketing and promotional emails, we will ask for your consent and you can choose not to opt-in.
- Text Messages. If you no longer want to receive text messages from us, reply STOP (or as otherwise instructed) in the text message. Alternatively, to the extent that applicable law requires your prior opt-in consent to receive text messages, we will ask for your consent and you can choose not to opt-in.
- Cookie Choices. To exercise choices regarding cookies set through our Services, as well as other types of online tracking and interest-based advertising, see the Cookies and Similar Technologies section above.
- Sharing with Third Parties. In addition to the above methods of exercising choice, to the extent required by applicable law, we also provide you the ability to opt-out of sharing your information with certain third parties for their own use by contacting us as detailed in the Contact Us section below.
As mentioned above in the Cookies and Similar Technologies section, you have the choice to manage your third-party advertising preferences.
If you have created an online account with us and would like to update the information you have provided to us, you can access your account to view and make changes or corrections to your information. Depending on applicable law, you may have the right, and we also provide you with the opportunity to be informed of whether we are processing your information and to access correct, update, oppose, delete, block, limit or object, upon request and free of charge, to our use of your information to the extent required by applicable law. For specific information for California residents, please refer to the Information for California Residents section below.
For such inquiries, please contact us as detailed under the Contact Us heading below. We will try to comply with your request as soon as reasonably practicable and as required by applicable law. For specific information regarding our response time and format arising from requests from California residents, please refer to the Information for California Residents section below. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law. In any event, should you choose to exercise any of your rights as detailed above, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level of quality of products, based solely upon this request.
Security of Your Information
We take commercially reasonable technical, administrative, and physical security measures to protect your information, including generally accepted industry standards to protect the information submitted to us during transmission and once we receive it. When you provide us sensitive information (e.g., credit card number), we encrypt that information using secure socket layer technology (“SSL”) or similar technology. However, no method of transmission over the Internet, or method of electronic storage is 100% secure, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please contact us immediately as detailed under the Contact Us heading below.
LINKS TO OTHER WEBSITES
NO DATA COLLECTED FROM CHILDREN/MINORS/THOSE UNDER THE LEGAL DRINKING AGE
Our Services are intended only for those of legal drinking age and we do not knowingly collect information from individuals under the legal drinking age, children or minors. If we have actual knowledge that information about a child has been collected, we will take the appropriate steps to delete the information.
Information for California Residents
If you reside in California, we are required to provide additional information to you about how we use and disclose your Personal Information, and you may have additional rights regarding how we use your Personal Information pursuant to state-specific laws, including the California Consumer Privacy Act of 2018 (“CCPA”), the California Online Privacy Act (“CalOPPA”), and the “Shine the Light” law, codified in § 1798.83 of the California Civil Code (collectively, the “CA Privacy Laws”). Please see more information regarding the CA Privacy Laws below:
CCPA. Consistent with the Information We Collect section above; we collect certain categories and specific pieces of information about individuals that are considered “Personal Information” in California (“CA Personal Information”). For clarity, CA Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
As described in the Information We Collect section above, we may collect CA Personal Information from you and other third parties. We collect, share and disclose CA Personal Information for the business and commercial purposes described in the Use of Information and Sharing of Information sections above.
Subject to certain exceptions, as a California resident, you have the right under the CCPA to (i) access your CA Personal Information; (ii) obtain deletions of your CA Personal Information; (iii) receive information about the CA Personal Information about you that we have “sold” (as such term is defined under California law) to third parties within the past twelve (12) months; and (iv) opt-out of the “sale” of your CA Personal Information. Notwithstanding the foregoing, as described in the Use of Information section above, we have not sold and do not sell your CA Personal Information under any circumstances through your use of the Services.
Additional information regarding your rights, and the process by which you may exercise them, are more fully described below:
- Access and Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- 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).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- Deletion Request Rights. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers 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, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech and/or ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal obligation; and
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Exercising Your Access, Portability, and Deletion Rights. To exercise the access, data portability, opt out, and deletion rights described above, please submit a verifiable consumer request to us as described in the Contact Us section below.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request 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 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. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
- Timing and Format of Our Response. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Shine the Light. Under California’s “Shine the Light” law, if you are a California resident who provides Personal Information in obtaining products or services for personal, family, or household use, you may request to opt-out of such sharing by a winery at no-cost by following the instructions in the Your Choices and Your Rights sections above, or by contacting us as described in the Contact Us section below. Please be aware that your opt-out request will apply only to the sharing by that particular winery.
Exercising Other California Consumer Rights and Non-Discrimination. Should you wish exercise any other rights in addition to those detailed above with regard to your Personal Information, we will not discriminate against you with a different level or quality of products, based solely upon this request. Please see the Contact Us section below if you have questions or would like to exercise such rights.
Crimson Wine Group Ltd.
Attn: Crimson Wine Group Privacy
2700 Napa Valley Corporate Drive, Ste. B
Napa, CA 94558