Last Modified: January 2020
CALIFORNIA CONSUMER PRIVACY ACT (CCPA)
PH complies with the California Consumer Privacy Act (CCPA) and our privacy notice can be read here.
NOT DIRECTED TO INDIVIDUALS UNDER THE LEGAL DRINKING AGE
Our Sites are not intended for people under the legal drinking age of 21. We do not seek or knowingly collect any Personal Data from or about individuals under the age of 21. If we become aware that we have unknowingly collected Personal Data from an individual under the legal drinking age, we will make commercially reasonable efforts to delete such information from our database.
PH uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. PH cannot, however, ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once PH receives your transmission of information, we make commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
If PH learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. PH may post a notice on the Sites if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us. You may submit any questions you may have about our security procedures by emailing us at email@example.com.
INFORMATION WE COLLECT
1. Information You Provide Us
You can ask to see your Personal Data. If you want to review, verify or correct your Personal Data, please contact the Company by emailing us at firstname.lastname@example.org.
When requesting access to your Personal Data, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the Personal Data that we hold about you. We may charge you a fee to access your Personal Data; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact the Company.
Your right to access the Personal Data that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the Personal Data that we hold about you. In addition, the Personal Data may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
2. Information We Collect Through Automated Means
When you use our Services, we collect certain internet or other electronic network activity information automatically that may constitute Personal Data, as described in this section. As discussed further below, we and our service providers (which are third party companies that work on our behalf), may use a variety of technologies, including cookies and similar tools, to assist in collecting this information. We collect information on your use of the Services, such as pages visited, links clicked, non-sensitive text entered, and mouse movements, as well as information such as the referring URL, browser, browser language, operating system, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and Internet Protocol (“IP”) address. We use publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address. We use the term “Usage Data” to refer to this information about your use of any Site that we collect. Our purpose in collecting Usage Data is to better understand how our visitors use the Sites and may utilize it to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Sites; (b); (c) monitor the effectiveness of marketing campaigns; (d) monitor aggregate metrics such as total number of visitors, pages viewed, etc.; and (e) track your activity on the Sites.
3. Information We Collect From Our Partners
We perform ongoing demographic data gathering and analysis to complete data profiles and better understand our customers. Our purpose in collecting demographic data and completing customer profiles is to better understand our customers and provide the best experiences, services and products in our offerings. We collect information that may constitute Personal Data, such as names, email addresses, phone numbers and addresses.
4. Business Purposes
We collect this Personal Data to fulfill contracts, comply with laws and for our legitimate business interests. Our purposes for collecting and using this information include:
Performing a contract with you or to take steps at your request before entering into a contract
Complying with legal or regulatory obligations or in response to law enforcement request
Other legitimate interests and business purposes, such as:
To process your transactions, maintain or service your account(s), communicate with you, schedule tastings, offer you discounts through our wine clubs, manage records, respond to court orders and legal investigations, and administer and provide services to you;
To offer our services to you, to improve and customize our services for you and to understand how our services are used; and
To operate, maintain and improve the Sites, for example by conducting analytics
In some cases, we rely on your consent for processing your Personal Data, but only in those cases where we specifically ask for your consent.
DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
PH may release personally identifiable information and/or non-personally-identifiable information if required to do so by law, or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. Copyright Law), respond to a court order, subpoena, or search warrant, or have a good faith belief that access, preservation, or disclosure of such information is reasonably necessary to protect the rights, property, or safety of our Company, its customers, or the public, or that it is appropriate or necessary to take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Sites, and to protect the rights, property, or personal safety of PH, our users or others.
We may track visits to the pages and links on our websites so we can make decisions about the design and usage of the Sites. We may choose to share this aggregate and de-identified information on consumer behavior to third parties.
COOKIES AND RELATED TECHNOLOGIES
As part of our ongoing efforts to ensure the best possible experience for all users of our Sites, we may use “cookies” and related technologies, such as tags, SDKs, tracking pixels, and other similar technologies to collect the information described in “Information We Collect Through Automated Means.” “Cookies” are small pieces of information (a small text file containing a string of alphanumeric characters) that are sent to your computer that uniquely identifies your browser. PH may use both session cookies and persistent cookies. A persistent cookie remains after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the Sites. Persistent cookies can be removed by following your web browser help file directions. A session cookie is temporary and disappears after you close your browser. Cookies enable us to provide special features such as storing items in your shopping cart between visits, tailoring products or services offered to you based on past preferences or geographic location. Most Web browsers automatically accept cookies but allow you to turn off cookies as part of the browser options. Even without cookies, you can still use most of the features of our Sites, but you will be unable to place items in your shopping cart or make purchases.
NOTICE CONCERNING DO NOT TRACK
Do Not Track is a privacy preference that users can set in certain web browsers. We do not currently track you over time and across third party websites to provide targeted advertising and therefore the Sites do not respond to Do Not Track signals.
LINKS TO OTHER SITES
OTHER CALIFORNIA PRIVACY RIGHTS
In addition to the rights already described, California law permits customers in California to request certain details about how their information is shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business must either provide this information or permit California customers to opt in to, or opt out of, this type of sharing.
If you are a California resident, you may opt out of such future sharing of your personal information (as defined by the California Shine the Light Act) by contacting us at email@example.com with the phrase “Do Not Share” in the subject line.
INDIVIDUALS WITH DISABILITIES
SPECIAL NOTE TO INTERNATIONAL USERS
UPDATES TO THIS POLICY
IN THE EVENT OF MERGER, SALE, OR BANKRUPTCY
In the event that PH is acquired by or merged with a third party entity, it reserves the right, in any of these circumstances, to transfer or assign the information (including personally identifiable information) it has collected from its users as part of such merger, acquisition, sale, or other change of control. In the unlikely event of PH’s bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, PH may not be able to control how your personally identifiable information is treated, transferred, or used.