Privacy Policy

This privacy policy applies to www.wine4winners.com owned and operated by Wine 4 Winners,
LLC (collectively, “We”, “Us”, “Our” or “Wine.com”). This Privacy Policy describes how Wine
4 Winners collects, uses, shares and secures the personal information you provide. It also
describes your choices regarding use, access and correction of your personal information.
Wine 4 Winners has agreed to notify users of:
1. What personally identifiable information Wine 4 Winners collects.
2. What personally identifiable information third parties collect through the Web site.
3. What organization collects the information.
4. How Wine 4 Winners uses the information.
5. With whom Wine 4 Winners may share user information.
6. What choices are available to users regarding collection, use and distribution of the
information.
7. What measures Wine 4 Winners takes to protect the information under its control.
8. How users can correct any inaccuracies in the information.

If you feel that our company is not abiding by its posted privacy policy, please contact the Wine
4 Winners Compliance Officer by email at info@wine4winners.com or by mail at Wine 4
Winners, LLC, 3940 Broad Street, Suite 7, #165, San Luis Obispo, CA 93401.

Information Collection and Use
Wine 4 Winners is the sole owner of the information collected on this site. We will not sell,
share, or rent this information to others in any way that varies from what is disclosed in this
statement. Wine 4 Winners collects information from our users at several different areas on our
site.
You may receive information regarding new features, services and special offers we think you'll
find valuable. We may also share information with carefully selected business partners. These
businesses may use the information we share to provide valuable opportunities and offers. If
you'd like to opt out of future mailings from Wine 4 Winners, LLC, follow the procedure
outlined in the Choice/Opt-out section below. When we present you with the opportunity to
receive marketing opportunities from our business partners we will not automatically subscribe
you for these promotions, rather we will provide you with the opportunity to opt-in to these third
party marketing programs.
Upon request, Wine 4 Winners will provide you with information about whether we hold any of
your personal information. You may also access the personally identifiable information you have

submitted to Wine 4 Winners by selecting “Your Account” and editing the information as it
exists in our system currently. You are also able to access your information in order to update or
delete it by sending us an email at info@ wine4winners.com . We will respond to your request
within a reasonable time frame.
We will retain your information for as long as your account is active or as needed to provide you
services. We will retain and use your information as necessary to comply with our legal
obligations, resolve disputes, and enforce our agreements.


Registration
No registration is required in order to use this website, though a user must create an account prior
to completing any purchase. Users are required to provide their name, date of birth, email
address, zip code, and a password of 6-16 characters in length. This information is necessary in
order for us to contact users about services on our site for which they have expressed interest. It
is optional for the user to provide a phone number, but we encourage you to do so in order to
have an alternate means of contact regarding an order.

Sharing Your Content and Information from the Wine 4
Winners Mobile App

You own all of the content and information you post on the Wine 4 Winners Mobile App. For
content that is covered by intellectual property rights, like photos (IP content), you specifically
give Wine 4 Winners a non-exclusive, transferable, sub-licensable, royalty-free, worldwide
license to use any IP content that you post on or in connection with the Wine 4 Winners App (IP
License).


Ordering
Wine 4 Winners order forms request data from users including: 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. This information is
harvested from a secure area and encrypted for our customers' protection. It is not sold or shared
with anyone else under any circumstances.


Gift Recipients
We collect contact information, such as name, shipping address and phone number, for gift
recipients to ensure correct gift delivery. We do not sell, share or rent any contact information for
gift recipients with third parties. We do not sell or rent any personally identifiable information

that you provide to us regarding gift recipients, but they may receive offers from us highlighting
new features, new products and services and special offers we think they will find of interest.
Also we may send marketing offers to gift recipients on behalf of ourselves and our business
partners. In connection with such offers, we allow gift recipients to opt out of receiving future
marketing-related mailings from us. Gift recipients may contact us at info@wine4winners.com to
request that we remove their email from our database.


Tracking Technologies
Wine 4 Winners and our partners use cookies or similar technologies to analyze trends,
administer the site, track users’ movements around the site and to gather demographic
information about our user base as a whole. We may receive reports based on the use of these
technologies by these companies on an individual as well as aggregated basis.
We use cookies for our shopping cart, to remember users’ settings (e.g. language preference) and
for authentication. Users can control the use of cookies at the individual browser level. If you
reject cookies, you may still use our site, but your ability to use some features or areas of our site
may be limited.


Log Files
As is true of most web sites, we gather certain information automatically and store it in log files.
This information may include internet protocol (IP) addresses, browser type, internet service
provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
We do not link this automatically collected data to other information we collect about you. Or
We may combine this automatically collected log information with other information we collect
about you. We do this to improve services we offer you, to improve marketing, analytics, or site
functionality.


Sharing
We will not sell, share, or rent this information to others in any way that varies from what is
disclosed in this statement.
Wine 4 Winners will share aggregated demographic information with its partners and
advertisers. This is not linked to any personally identifiable that can identify any individual
person.
We may share your information with third parties who provide services on our behalf to help
with our business activities. These companies are authorized to use your personal information
only as necessary to provide these services to us. We use an outside shipping company to ship
orders, and a credit card processing company to bill users for goods and services. These
companies do not retain, share, store or use personally identifiable information for any secondary
purposes.

We value your privacy at Wine 4 Winners, and will never release any account information to
anyone outside of the necessary core groups that help our business function unless our customers
give us the authority to do so.


Legal Disclaimer
We reserve the right to disclose your personally identifiable information in response to lawful
requests by public authorities, including to meet national security or law enforcement
requirements and when we believe that disclosure is necessary to protect our rights and/or to
comply with a judicial or bankruptcy proceeding, court order, or legal process served on our
Web site. When we believe in good faith that disclosure is necessary to protect our rights, protect
your safety or the safety of others, investigate fraud, or respond to a government request and to
any other third party with your prior consent to do so.


Links
This web site contains links to other sites. Please be aware that Wine 4 Winners is not
responsible for the privacy practices of other sites. We encourage our users to be aware when
they leave our site and to read the privacy statements of each site that collects personally
identifiable information. This privacy statement applies solely to information collected by this
Web site.


Social Media Widgets
Our Web site includes Social Media Features, such as the Facebook Like button [and Widgets,
such as the Share this button or interactive mini-programs that run on our site]. These Features
may collect your IP address, which page you are visiting on our site, and may set a cookie to
enable the Feature to function properly. Social Media Features and Widgets are either hosted by
a third party or hosted directly on our Site. Your interactions with these Features are governed by
the privacy policy of the company providing it.


Emails
If a user wishes to subscribe to our emails we ask for contact information such as name and
email address. We may use your personally identifiable for purposes other than sending you
promotional materials. For example, we may use your information to complete transactions
requested by you, or to send you administrative communications about any account you may
have with us or about future changes to this Privacy Policy. You may also unsubscribe from
promotional Emails by emailing us at info@wine4winners.com

Security
When our order form asks users to enter sensitive information (such as credit card number and/or
social security number), that information is encrypted with the best encryption software in the
industry - SSL (Secure Socket Layers) provided by VeriSign, the premier encryption Software
Company available today. On a secure page such as our order form, the lock icon on the bottom
of Web browsers' switches to locked, as opposed to unlocked mode, and back to open mode
when you are just browsing.
We also do everything in our power to protect user data offline. All sensitive information is
restricted in our offices. Only employees who need the information to perform a specific job (for
example, a Customer Care representative) are granted access to personally identifiable
information, and are required to lock their station when they leave their station.
All employees are kept up to date on our security and privacy practices. Every quarter and
whenever new policies are implemented, our employees are reminded about the importance of
keeping customer data secure and safe at all times. The servers with personally identifiable
information are stored in a locked and secure environment.
If you have any questions about the security at our website, you can send an email to:
info@wine4winners.com


Sale of Our Company
As a natural consequence of the development of our company, we could be sold to another
company. In the event that another company acquires us or a significant portion of our assets is
sold to another company, all customer data including financial records and consumer information
collected on Wine 4 Winners may be transferred to the new company. You will be notified via of
any such change in ownership or control of your personally identifiable information.


Changes in this Privacy Statement
If we decide to change our privacy policy, we will post those changes to this privacy statement,
the home page, and other places we deem appropriate so that you are aware of what information
we collect, how we use it, and under what circumstances, if any, we disclose it.
We reserve the right to modify this privacy statement at any time, so please review it frequently.
If we make material changes to this policy, we will notify you here, by email, or by means of a
notice on our home page.

YOUR CALIFORNIA PRIVACY RIGHTS
Beginning on January 1, 2020, California Civil Code Section 1798.100 permits customers of
Wine 4 Winners (“you”) who are California residents: 1) The right to know what personal
information is being collected about you ; 2) The right to know whether your personal
information is sold or disclosed and to whom; 3) The right to Opt-Out of the sale of personal
information; 4) The right to access your personal information; 5) The right to equal service and
price after exercising your privacy rights.


Disclosure requests or Deletion requests
You have the right to request the disclosure and/or deletion of your collected personal
information. Such requests will be fulfilled upon the receipt of a verified request. A verified
request will ask the customer to provide information required to verify their identity including,
but not limited to any three of the following: Name, Address, Previous Purchase, Email Address,
or Payment Method.
As California residents, you have the right to request the disclosure of the following:
1. The categories of personal information collected;
2. The sources of the personal information;
3. The business or commercial purpose of collecting;
4. The categories of third parties with whom Wine 4 Winners shares personal
information;
5. The specific personal information that was collected about you;
6. What categories of personal information that was sold (if any) and the category of
third party that it was sold to;
7. What category of personal information was disclosed for a business purpose.
Per the CCPA, at no point can we disclose your financial information or account password, even
upon a verified disclosure request. We do not possess the personal information of minors.
If you cannot be verified, we can either treat your request as a request to Opt-out, or we can
contact you for more information to verify your identity. You should expect a confirmation email
that your information has been deleted or disclosure of information within 45 days. Deletion
includes permanent deletion, de-identification, or aggregation of the information. Any
information stored on a back-up system or archive can be deleted whenever the system is next
used.
Once the verifiable request is received, the consumer’s personal information will be deleted from
the business records and we will direct our service providers to do the same from their records if
applicable. Limitations and exceptions apply:
We may rightfully retain your personal information if it is collected:

1. To complete transactions for goods or services, perform contracts, or for
anticipated ongoing relationships;
2. For the detection of protection from illegal activity or to assist prosecution;
3. To identify or repair errors;
4. For free speech or other rights provided by law;
5. For compliance with California Electronics Communications Privacy Act;
6. For compliance with the California Consumer Privacy Act;
7. For the engagement in statistical research in the public interest with consumer
informed consent;
8. For internal uses based on consumer’s relationship with the business;
9. For legal obligation compliance;
10. For otherwise internal uses in a legal matter in context with the reason that
consumer provided the information.


Making a Disclosure request or Deletion request
Such requests will be met upon the receipt of a verifiable request. To make such a request, please
call our customer service (805-883-3623), send an e-mail to info@wine4winners.com with
“Request for Disclosure” or “Request for Deletion” in the subject line, or write us at:
Privacy Officer
Wine 4 Winners, LLC,
3940 Broad Street,
Suite 7, #165,
San Luis Obispo, CA 93401.

Each consumer may make two such requests free of charge per 12-month period starting at first
request date, fees may apply if requests exceeds the allowed number.


Opt-Out Requests
You also have the right to Opt-Out of the selling, sharing, or renting of your personal
information. Selling personal information is defined as sharing information for any valuable
consideration. Opt-out requests will be completed upon the receipt of your Opt-Out request.
There is no verification needed for requests to Opt-out of the sale of personal information.
To submit an Opt-Out request, you may do so through the hyper link at the bottom of our
Homepage entitled “Do Not Sell My Personal Information” or by clicking here. There, you can
also view a list of our partners and reasons why your information has been “shared.” Please note
that no account is required in order to Opt-Out or to make a disclosure/deletion request. You can
also send an e-mail to info@wine4winners.com with “Opt-Out Request” in the subject line, call
us at (805-883-3623), or write us at:
Privacy Officer
Wine 4 Winners, LLC,

3940 Broad Street,
Suite 7, #165,
San Luis Obispo, CA 93401.


Information We Possess
Most of the personal information that Wine 4 Winners possesses is information provided to Wine
4 Winners by its customers. Information is gathered when an account is created for the purpose
of completing a transaction. This information includes: Name, Address, Email, Phone Number,
Credit/Debit card information, Order History, Username, and Password. Wine 4 Winners also
uses cookies, geolocation, and may use targeted advertising and track IP addresses. We “share”
information as defined by the CCPA with our analytics and advertising partners, as well as
partners that help our website function. We use your information to complete your transactions,
as well as for marketing, customer support, legal obligations, or other business purposes.


Authorized Agents
Requests can be made on your behalf by an authorized agent, however, verification of your
identity will be needed in these cases. This verification process may include a handwritten
statement authorizing your agent to act on your behalf in addition to the standard verification
process.


Right to Non-Discrimination
There will be no price increases, or any other action taken against a customer for exercising their
above rights as allowed by the CCPA.
Records indicating compliance with the CCPA, and any action taken to requests are kept for two
years.


CCPA 2020 Reporting Requirements
Requests to Know: 3 received; 2 complied; 1 denied due to failed verification; 23 day
compliance average.
Requests to Delete: 126 received; 59 complied; 67 denied due to failed verification or customer
converted to email opt-out only; 9 day compliance average.
Requests to Opt-Out: 277 received, 277 complied; 0 denied; 2 day compliance average.
The Privacy Notice posted on this site was updated on June 07, 2021.

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