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:
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.
We use the following categories of tracking technologies on our websites:
The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized, our Website is not compatible with DNT.
In order for you to place orders, make purchases, complete transactions, interact with TFE or have access to certain features of the Site, we may require you to register or provide certain Personal Information. Our Site has collected the following categories of Personal Information from consumers within the last twelve (12) months:
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 in the normal course of operating and managing our business. Generally, TFE uses Personal Information for the following reasons:
In some instances, the provision of information to us is mandatory. We will always ensure that the data we collect is reasonable and proportionate for the purposes it is collected, 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.
You have a right to opt-out of our marketing communications, 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 section.
With regard to the third-party tracking technologies noted earlier in this Policy, we and our third-party partners use information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
To learn how you can opt out of such advertising, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org/choices, and/or the DAA’s resources at https://www.aboutads.info/choices, and/or the TradeDesk’s resources at https://www.adsrvr.org.
Additionally, you may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by visiting NAI’s online resources at https://www.networkadvertising.org/choices.
TFE does not sell your Personal Information in the traditional sense of the word. However, certain US state laws (for example California) define the concept of “sell” to include activity like what is described when we share your Personal Information as part of our participation in affiliate advertising networks. To opt-out of this kind of sharing, you can use the methods described above.
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.
We will not disclose your personal information to third parties except as provided for in this Policy. Generally we will disclose Personal Information for any of the purposes described in this Policy and in the following circumstances:
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.
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).
TFE does not discriminate against Website visitors who choose to exercise their rights under any applicable data privacy law. Website visitors may generally exercise such rights at no charge. However, we reserve the right to charge a reasonable fee to cover our administrative costs of providing the information for baseless or excessive/repeated requests, or further copies of the same information. Alternatively, we may be entitled to refuse to act on the request.
To exercise any of these rights, you can get in touch with us using the details set in the Contact Us section.
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.
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.
In addition, you may exercise your access and deletion rights described above by submitting a verifiable consumer request to us by calling us at 800-967-4663 (toll-free).
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.
In addition to your rights under the CCPA, California Civil Code Section 1798.83 permits California residents to request information regarding our disclosure, if any, of their personal information to third parties for their direct marketing purposes. If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year (e.g., requests made in 2018 will receive information about 2017 sharing activities). To make such a request, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. You may make this request in writing via our Online Portal.