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PRIVACY POLICY

Trinchero Family Estates and your privacy

Trinchero Family Estates and its related entities and brands (TFE, we or us) are committed to protecting the privacy of individuals’ personal information. This policy (“Privacy Policy”) provides you with details on the information we collect from you and the uses we make of your personal information. We will only collect, use or disclose personal information in accordance with relevant laws and this privacy policy. Please do not provide us with your personal information if you are not of legal age to purchase alcohol in the jurisdiction where you live or if you do not agree to the terms in this policy.

We encourage you to read this Privacy Policy to learn more about what information of yours we collect, how we use it, and how you can “opt-out” of receiving communications from us. Additionally, this Privacy Policy includes information about how we endeavor to protect your information. If you have questions about our collection and use of your information, please contact us at info@menageatroiswines.com.

This Privacy Policy is subject to our Terms and Conditions of Use.

Summary of how we use your information

  • We will use your information in order to comply with your requests, correspond with you, administer our sweepstakes and competitions, and process and fulfill any wine orders you make with us or with our related companies.
  • This information will be shared with our related companies.
  • Where we rely on your consent (such as to send you marketing information), you can withdraw this consent at any time. Additional details on how you may withdraw your consent are set out below.

Information you give us

You provide us with information about yourself when corresponding with us, participating on our social media sites, entering our promotions and other competitions, buying our wines or when using or registering on our websites. This may include:

  • when you transact with us online, over the phone or in person;
  • when you enter a promotion or competition conducted by us (including via our websites or through social media sites);
  • when you visit and/or register to use one of our websites or when you participate in discussion boards or other social media functions on our websites; or
  • when you contact us to request information or support in relation to our company, our products or our services (including about our brands, product quality, visiting our sites or employment opportunities).

If you buy wine from us online for example, we will require you to provide us with your name, address, and phone number so we can process your order and deliver your wine to you. We will also require your date of birth to verify that you are of legal drinking age, as well as your credit card number and related information to process the sale.

Information collected by us and our use of cookies

Apart from the information you give us directly, we also automatically collect non personally identifiable information about you when you visit our websites, including through the use of cookies. The information we collect is:

  • technical information such as your computer’s IP address, hardware type, browser type, device identifier and screen type/resolution;
  • general location data based on your device or IP address;
  • any technical errors or exceptions; and
  • information about your visit such as the products you viewed or searched for, the length of your visit, page load speed, and the pages that you visited.

We use the following categories of tracking technologies on our websites:

  • Strictly Necessary tracking technology - these technologies are essential in order to enable you to move around our websites and use their features.
  • Performance related tracking technology - these technologies collect anonymous information on how people use our websites. The data stored by these technologies never shows personal information from which your individual identity can be established.
  • Functionality related tracking technology – these technologies remember choices you make such as the country you visit our websites from, your completion of the age verification check and language preferences. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these technologies collect may be anonymized and they cannot track your browsing activity on other sites.
  • Targeting or advertising related tracking technology – these technologies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of an advertising campaign.
  • Commerce related technologies – these technologies are essential in order to enable a functional online shopping experience across our websites, stores, and payment/checkout.

If you prefer not to receive cookies you can adjust your Internet browser to refuse cookies or to warn you when cookies are being used. However, some parts of our websites will not function if cookies are turned off. We therefore strongly recommend that you leave cookies fully functional.

For California residents, additional information regarding the categories of personal information we collect is found in the “Your California Privacy Rights” Section below.

Our use of your information

We will not use your information to carry out electronic marketing unless we have your consent. If you receive electronic communications from us, we will always provide you with an opportunity to unsubscribe from receiving further information from us by clicking on the unsubscribe link provided in the communication.

We may use or disclose the personal information we collect for one or more of the following purposes in order to conduct our business and pursue our legitimate business interests (and where required, your consent):

  • To fulfill or meet the reason you provided the information. For example, if you provide your personal information to purchase our products, we will use that information to process and manage your order. If you provide your details to apply for a job with TFE, we will use those details to process your application for employment.
  • To provide, support, personalize, and develop our Website, products, and services and to help us gain a better understanding of your likes and dislikes in order to improve our websites and the services we offer.
  • To help maintain the safety, security, and integrity of our Website, products and services, databases, and other technology assets, and business.
  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (where we do not need your consent).
  • To allow you to participate in interactive features of our websites and administering our promotions and competitions.
  • To verify that you are of legal drinking age in your jurisdiction (if applicable).
  • To make suggestions and recommendations to you and other users of our websites about goods or services that may interest you or them.
  • To fulfil a contract we may have with you, such as where you make a purchase from us or enter one of our competitions.
  • In connection with legal claims, compliance, regulatory, and investigative purposes as necessary (including to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations).
  • To produce consumer insights (e.g., general research on our consumers; conduct consumer testing, surveys, and panels; data analytics and modeling).
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TFE's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by TFE about our Website users is among the assets transferred.

In some instances, the provision of information to us is mandatory. We will always ensure that we minimize the amount of data we collect and will only ask for data that we need to process your request.

TFE will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your information for other purposes, such as those set out above. You have an absolute right to opt-out of direct marketing, and to object to profiling we carry out for direct marketing purposes, at any time. You can do this by following the instructions in the communication (where this is an electronic message) or by contacting us using the details set out in the Contact Us page.

How long we keep your information

Generally, we will retain your personal information for the period necessary to fulfil the purposes for which your personal information has been collected (as outlined in this privacy policy) unless a longer retention period is required by law.

Where we process registration information, we retain this for as long as we consider that you are an active user of our sites.

Where we process personal information for marketing purposes or with your consent, we process the information until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your information indefinitely so that we can respect your request in future.

Our disclosure of your information

We will not disclose your personal information to third parties except:

  • with your consent;
  • where we are required or authorized by law to do so, for example to law enforcement agencies;
  • where third parties appointed by us require access to personal information held by us to perform services (in which case we require these third parties to keep that personal information confidential and not to use or disclose it for any purpose other than the purpose of performing those services). The types of third parties we may transfer information to include vendors, service providers, agencies and other partners who globally support our business and help us administer certain activities on our behalf, such as providing technical infrastructure services, marketing services, customer service, data hosting and management services, processing credit card payments services for us, and providing logistics and delivery services to help us deliver our products and services; or
  • to our related companies in order to operate our global business and in accordance with the law.

We may also transfer personal information to a related company or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets.

Our websites sometimes contain links to other websites. With the exception of other sites owned by us, we do not control the privacy practices of sites reached through links from our websites. If you have any questions about the privacy practices of those websites, then you should contact the relevant companies directly.

Your rights in relation to your information

Under applicable law, you may be entitled to ask us for a copy of the personal information we hold about you, including to correct, delete or restrict processing of your personal information. In some jurisdictions, applicable law may also entitle you ask us to transmit your data to another controller where the processing is based on your consent carried out by automated means, or entitle you to object to the processing of your personal information in certain circumstances (for example, where we don’t have to process the information to meet a contractual or other legal requirement, or where we are using the information for direct marketing or profiling). However, these rights may be limited (for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping).

To exercise any of these rights, you can get in touch with us using the details set in the Contact Us section.

Security

We take appropriate measures to keep your personal information secure. We have implemented appropriate physical and electronic procedures to protect the personal information we collect. If you have an account with us, you are responsible for maintaining the confidentiality of your account details including your password and are responsible for any activity under your account. We will not be responsible for any loss arising from your failure to comply with this obligation.

Due to its nature, transmission of information via the internet is not completely secure. Although we will protect your personal data in accordance with this Privacy Policy, we cannot guarantee the security of any data transmitted to our websites and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security measures to try to prevent unauthorized access.

Contact Us

If you have any questions or concerns about our collection, use or disclosure of personal information, wish to exercise your rights in relation to data protection or you wish to make a complaint in relation to our privacy practices, please visit our Privacy Portal link. If you have a complaint or concern about how we use your personal data, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You also have a right to lodge a complaint with your national data protection supervisory authority at any time.

Your California Privacy Rights (California Notice At Collection)

If you are an eligible California resident, the California Consumer Privacy Act (“CCPA”) provides you with specific rights with respect to our collection and use of your personal information over the past twelve months. This California Privacy Rights Section supplements this Privacy Policy and applies solely to eligible residents of California as of January 1, 2020. Any terms not defined in this section have the same meaning as defined in the CCPA.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, TFE's Website has collected the following categories of personal information from its consumers within the last twelve (12) months: