Privacy and Security
Saratoga Wine Exchange Saratogawine.com. and its subsidiaries and corporate affiliates (collectively, "Saratogawine.com,” "our," "us," or "we") operate websites, provide products and services through mobile and other applications, and develop software. We refer to these as "site(s)," "service(s)," or "our sites and services."
1. Personal Information We Collect
Personal information is information that can be used to identify, locate, or contact an individual, and includes other information that may be associated with personal information. When you interact with our sites and services, depending on the site or service, we may ask for the following personal information directly from you:
- Contact Information allows us to communicate with you and generally includes your name, addresses, email addresses, social media website user account names, and/or telephone numbers.
- Payment Information needed to process payments such as your credit or debit card number, expiration date, and card verification number.
- Personal Profile or Service Information helps us with the administration and personalization of your personal profiles or services, such as areas of interest, information from social media interactions (such as Facebook, Twitter, or Google+), preferences, physical characteristics (such as height, weight), photographs and, biographical, information and/or demographic information (such as gender).
- Transaction Information about how you interact with and use our sites and services, email, other communications, and applications, and how you interact with merchants, business partners, and service providers.
- Geographic Location Information but only if your mobile or other device transmits location data and/or your IP address and you have activated a location-enabled site or service.
- Job-Search-Related Information for recruitment purposes and may include educational and employment background, driver's license number and social security number.
- Access to Your Data if you are our customer and use certain services or interactive tools or authorize us to retrieve information from another database, user, or other third parties on your behalf.
- Your Submissions help us with the administration of our sites and services and includes any information you voluntarily provide, generally through free-form text boxes, forums, uploading a document, or authorizing us to retrieve and import information from another user or third party on your behalf.
- Website Recording could require a third-party website recording service, which may record mouse movements, mouse clicks, page scrolling and any text keyed into website forms. Data that is collected by this recording service is used to improve our website usability and user experience. Password fields and financial data is not recorded or provided to Saratogawine.com. The information that is collected is stored and used for aggregated and statistical reporting and not shared with anyone else.
In each of the above instances, you will know what personal information we collect through our sites and services because you voluntarily and directly provide it.
2. How We Use Personal Information:
We may use information collected from you in one or more of the following ways:
- To enable site features such as geographically specific pricing or logging, and retrieving and providing analysis of data you choose to enter into the site,
- to send you important notices, such as communications about changes to your account, and our sites' and services' terms, conditions, or policies,
- to process payments and to send you emails, invoices, receipts, notices of delinquency, alerting you if we need different or updated payment card information or other communications in connection with processing and collecting payments,
- to solicit input and feedback to improve our sites and services and customize your user experience,
- to enable you to communicate with other site or service users via private messaging or other service specific communication channels,
- to contact you via email, telephone, text or chat in a manner required by law,
- to meet contractual obligations,
- to send you reminders, technical notices, updates, security alerts, support and administrative messages, and service bulletins,
- to inform you about new products or promotional offers, or other opportunities which we feel will be of interest to you, and to provide advertisements to you through our sites, U.S. mail, email messages, text messages, applications, or other methods of communication,
- to manage our sites' and services' administration, forum management, or fulfillment,
- to provide customer service and technical support,
- to administer surveys, sweepstakes, giveaways, contests, or similar promotions or events sponsored by us or our partners,
- for internal purposes such as auditing, data analysis, and research to improve our products, services, and communications,
- to allow you to apply for a job or sign up for special offers from third parties through our sites,
- to use anonymized personal information to run (or authorize third parties to run) statistical research on individual or aggregate trends.
In addition to the uses described above, we may use personal information that we collect for other purposes that are disclosed to you at the time we collect the information, or with your consent.
3. Sharing Personal Information
We may share personal information about you with third parties in the following circumstances:
- We may engage third parties to perform services on our behalf, including maintenance services, hosting, data storage, security, analytics and data analysis, payment processing, assisting in marketing efforts, email and text message distribution, customer service, providing certain interactive tools, and conducting surveys and so forth.
- When you communicate with us by email, submit an online form through the site, request a quote or information, purchase a product or service, or otherwise submit a request through the Site, the personal information you provide may be shared with third parties to process or respond to your request, provide you with the products or services you requested or complete a transaction.
- Your personal information, and the contents of all of your online communications on or through our sites and services may be accessed and monitored as necessary to operate our sites and perform our services, and may be disclosed:
- to satisfy any applicable laws or regulations,
- to defend ourselves in litigation or regulatory action,
- when we have a good faith belief that we are required to disclose the information in response to legal process (for example, a subpoena, court order, or search warrant),
- where we believe our sites and services are being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and risk management, and
- when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally.
- In the event of a merger, acquisition, debt financing, restructuring, sale of Saratogawine.com assets by or with another company, or a similar corporate transaction takes place, we may need to disclose and transfer all information about you, including personal information, to the successor company.
- We may share information about you with Saratogawine.com’s subsidiaries and affiliates and companies acquired by or merged with Saratogawine.com and its affiliates, including without limitation, to enable such acquired or merged companies to advertise to you products and services in which you may be interested.
- We may share personal information about you for any other purpose(s) disclosed to you at the time we collect your information or with your consent.
4. Other Information We Automatically Collect and Cookies
We, or our third-party service providers, may also collect and store certain technical information when you use our sites and services. For example, our servers receive and automatically collect information about your computer and browser, including, for instance, your IP address, browser type, the domain name from which you accessed the site or service, device size, and other software or hardware information. If you access our sites and services from a mobile or other devices, we may collect a unique device identifier assigned to that device (UDID), type of device, general GPS location, or other transactional information for that device in order to serve content to it and to improve your experience in using the sites or services.
In addition, we, or our third-party service providers, may collect other non-personal information about you and how you use our sites, including but not limited to, the date and time you visit the sites, the areas or pages of the sites that you visit, the amount of time you spend viewing the sites, the number of times you return to the sites, visits to sites outside our network, preferred language, and other click-stream data. We and our third-party service providers may use non-personal information for any purpose, including, to make the sites and services more useful for users. Non-personal information may be shared with partners who referred you to our site(s), who may use the data for their business purposes, including to optimize for other users who they refer to our site(s). Non-personal information may also be shared with partners who help us deliver ads to you on websites not controlled by us, for instance, when we put a pixel on a conversion page on our site and a marketing partner uses that to optimize what traffic they send to us, or using another example, when we create a re-targeting list through DFP Small Business by Google or placing a partners’ pixel on our sites, and then delivering targeted ads across the Internet.
What is a cookie?
A cookie is a small file that is placed onto your device, and that is managed by your browser. Cookies were designed for websites to remember useful information (such as items in a shopping cart) and enable our sites or services to function. For example, cookies enable us to identify your device and enable you to easily share content on our sites and services, and help us serve relevant ads to you.
What types of cookies do we use?
We use two types: persistent cookies and session cookies. A persistent cookie helps us recognize you as a user. After you sign in, a persistent cookie stays in your browser and will be read by our site when you return to the site. Session cookies only last for as long as the session (usually the current visit to a site or a browser session).
We also have implemented and use Google Analytics Display Advertising, specifically the Demographics and Interest Reporting feature, to advertise online, sell advertising, and develop content.
We also may use other tracking programs that can provide cookie-equivalent functionality.
How are cookies used for advertising purposes?
Cookies combined with ad technology such as web beacons, pixels, and anonymous ad network tags help us serve relevant ads to you more effectively. They also help us collect aggregated auditing, research, and reporting for advertisers. Pixels, which are invisible tags placed on our websites, help us understand and improve our service, show you ads, and know when content has been shown to you. Please note that because our pages include advertisements, your web browser may request advertisements and web beacons directly from ad network servers, and these networks can view, edit, or set their own cookies, just as if you had requested a web page from their site.
Do Not Track
We do not currently actively respond to "Do Not Track" browser signals or mechanisms that indicate a request to disable online tracking of individual users who use our sites and services.
In general, we use these technologies to remember you when you return to our sites, to understand and analyze trends, to monitor usage and administer the sites, to learn about user behavior on the sites, and gather demographic information about our user base as a whole, to customize content or offers on our sites and through our services, and to conduct research to improve our sites, content, and services.
5. User-Generated Content, Online Communities and Forums, Profiles, Surveys, Reviews, and Ratings
6. Accessing and Updating Personal Information
We encourage you to keep your personal information updated and accurate. We provide you with reasonable access to your personal information and the ability to review, correct, or delete it. You have several choices; for instance:
- You may correct or update your account information at any time by logging on to your account.
- You may subscribe or unsubscribe from email preferences at any time. (Please note if you resubscribe to our communications, you may receive direct, automated marketing, and or transactional messages).
- If you have additional questions about your options, contact us at email@example.com.
Protecting your privacy and security is important, and we also take reasonable steps to verify your identity before granting access to your data.
We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes).
7. Email and Other Communications
Our sites and services may allow us or other parties to communicate with you or other users through our in-product instant messaging services, service-branded emails, SMS and other electronic communication channels.
Rates. Standard message and data rates may apply to any messages sent by you or us. Please contact your wireless provider regarding text messaging or data rates and plans.
Security. You acknowledge and agree that the text messages are provided via wireless systems which use radios (and other means) to transmit communications over complex networks. We do not guarantee that your use of the text messaging service will be private or secure, and we are not liable to you for any lack of privacy or security you may experience. You are fully responsible for taking precautions and providing security measures best suited for your situation and intended use of the text messaging service(s).
Opting Out of Requested Communications
Requested communications include, for instance, email newsletters or software updates that may be expressly requested by you or which you consented to receive. After you request such communications, you may "opt-out" of receiving them by using one of the following methods:
- Select the email "opt-out" or "unsubscribe" link, or follow the opt-out instructions included in each email communication.
- To unsubscribe from text messages delivered to mobile devices, reply to the message with the words "STOP" or "END" or contact the applicable site or company affiliate.
- Email us at firstname.lastname@example.org. Please provide your name, contact information, and specific relevant information that you no longer wish to receive.
- To re-opt in, reply “START”, unless otherwise provided by the text messaging terms and conditions applicable to the text message program.
Opting Out of Transactional or Relationship Communications
Communications that are sent by or on behalf of a user are indicated as being "From" that user. Communications that are sent by us are indicated as being from us or one of our account or support specialists assigned to assist you. Either type of communication may be "real time" communications or communications triggered automatically upon the occurrence of certain events such as post-purchase, abandoned cart, and checkout sessions (post subscription). Email communications received from users and our administrative announcements are often transactional or relationship messages, such as order confirmations, order updates, reminders, account updates and cancellations. You may not be able to opt-out of receiving certain messages, although we may provide a means to modify the frequency of receiving them.
Opting Out of General or Promotional Communications
General communications provide information about products, services, and/or support and may include special offers, new product information, or invitations to participate in market research. You may opt-out of receiving these general communications by using one of the following methods:
- Select the email "opt-out" or "unsubscribe" link, or follow the opt-out instructions included in each email communication.
- To unsubscribe from text messages delivered to mobile devices, reply to the message with the words "STOP" or "END" or contact the applicable site or company affiliate.
- Email us at email@example.com. Please provide your name, relevant contact information, and specific relevant information about your privacy preferences.
8. Protecting Personal and Protected Information
The security of our sites and services and the information they store, process, and transmit is a top priority. To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of the information we collect, we deploy a wide range of technical, physical, and administrative safeguards, including Security, firewalls, system alerts, and other information system security technologies; secure facilities that restrict physical and network access; and regular evaluation and enhancement of our information technology systems, facilities, and information collection, storage, and processing practices. We seek to use reasonable and appropriate administrative, physical, technical, and data security procedures and controls to safeguard your personal and protected information against unauthorized access, disclosure, loss, misuse, and alteration. Under applicable law, we are required to apply reasonable and appropriate measures to safeguard the confidentiality, integrity, and availability of individually identifiable information residing on and processed by our sites and services.
We use third-party service providers to manage credit card and payment processing. These service providers are not permitted to store, retain, or use billing information except for the sole purpose of credit card and payment processing on our behalf. When you enter payment information to be processed by our third-party service providers, we encrypt the transmission of that information.
It is important to remember, however, that no system can guarantee 100% security at all times. Accordingly, we cannot guarantee the security of information stored on or transmitted to or from our services. We cannot assume responsibility or liability for unauthorized access to our servers and systems. When disclosing any personal or protected information, you should remain mindful of the fact that it is potentially accessible to the public and, consequently, can be collected and used by others without your consent. Accordingly, you should consider carefully if you want to submit sensitive information that you would not want to be disclosed to the public and should recognize that your use of the Internet and our sites and services is solely at your risk. You are ultimately responsible for maintaining the secrecy of all your personal information, including any protected information. We have no responsibility or liability to anyone for the security of your personal or protected information transmitted via the Internet.
Steps You Can Take
- Install malware detection programs that regularly scan your system and incoming traffic for malicious code such as computer viruses, worms, Trojan Horses, and spyware. Because viruses and malware are continuously created and modified, regular malware protection software typically requires frequent updates.
- Use a firewall to prevent unauthorized access to your device.
- Because malware often targets vulnerabilities in existing operating systems, browsers, plug-ins, and other programs, software vendors frequently update their products with security patches to guard against known or commonly exploited vulnerabilities. Vendors often try to alert their users and recommend immediate installation of these security patches.
- Use a strong password using a combination of letters and numbers that are not easily guessed. Do not share your password with others.
- If you use a shared device, always close all active programs and log out before leaving it unattended.
- Avoid using a public wireless network, if possible. If you do use a public network, use the most restrictive wireless network settings on your device.
- If you use file-sharing programs, be sure to restrict all other folders or directories to "no share."
- Be very cautious with any email requesting you to share personal information. On websites, look for the lock symbol on or near your browser's address bar which signifies a secure website before supplying personal information.
- Exercise care in selecting what information you share, particularly personal information
9. Linked Websites and Services
We may also provide social media features on our sites and services that enable you to share personal information with your social network(s) and to interact with our sites and services. Depending on the features, your use of these features may result in the collection or sharing of personal information about you. We encourage you to review the privacy policies and settings on the social media site(s) with which you interact.
10. Children's and Minor's Privacy
Our sites and services are intended for general audiences and are not targeted to children under 13. We do not knowingly collect personal information from children under the age of 13 or utilize plug-ins or ad networks that collect personal information through child-directed third-party websites or online services. If you are under 13, please do not disclose or provide any information. If we learn that we have collected personal information from a child under 13, we will take steps to promptly delete the information. Should this policy change, we would comply with the Children's Online Privacy Protection Act, which requires us to notify and obtain consent from a parent or guardian before we collect, use, and disclose the personal information of children who are under 13 years of age. We will not sell our products to any individual under the age of 21 in accordance with local, municipal, state, and federal laws and or regulations. Saratoga Wine Exchange, Saratogawine.com its subsidiaries, employees and affiliates will not be held liable for any attempts to circumvent said laws and or provisions.
11. International Users
We are headquartered in the United States. Our sites and services are hosted and administrated in the United States or hosted with cloud service providers who are headquartered in the United States or in other countries and are intended for users in the United States. If you are located outside the United States, be aware that information you provide to us or that we obtain as a result of your use of our sites and services may be processed in, transferred to, and stored in the United States and in any other countries from where our cloud service providers operate. Please be aware that the privacy laws and standards in certain countries may differ from those that apply in the country in which you reside. By using our sites and services or providing us with your information, you consent to the transfer of your information for processing and storage to the United States and any other country from where our cloud service providers operate.
12. California Privacy Rights
This section is provided pursuant to the California Consumer Privacy Act of 2018 (the “CCPA”) and other applicable California privacy laws. This section applies solely to our users who are California residents as defined under applicable California privacy laws.
12.1 Information We Collect
Within the last twelve (12) months, we have or may have collected the following categories of information from our users and/or consumers: identifiers, and personal information listed under Cal. Civ. Code § 1798.80(e); commercial information; biometric information; internet or other similar network activity; geolocation data; and inferences are drawn from any information identified in this section.
12.2 Categories of Sources from Which Information is Collected
We obtain the categories of personal information listed above from the following categories of sources:
- directly from users, such as you, as described above under “Personal Information We Collect”;
- indirectly from other users of our sites and services;
- indirectly from third-parties that interact with us in connection with the services that we perform; and
- directly and indirectly through cookies and other technologies, as described above under “Other Information We Automatically Collect And Cookies.”
12.3 Using and Sharing of Personal Information
The personal information described in the categories above may be used for the business purposes listed above under “How We Use Personal Information.”
We disclose your personal information for business purposes to the following categories of third parties: (a) service providers and (b) third parties to whom you authorize or direct us to disclose your personal information in connection with our sites and services. In the preceding twelve (12) months, we have disclosed the personal information described in the categories above for the business purposes listed above under “Sharing Personal Information.” We may also share personal information about you for any other purpose(s) disclosed to you at the time we collect your information or with your consent.
12.4 Personal Information “Sold” to Third Parties
In the preceding twelve (12) months, we have made available to our third-party marketing partners personal information included in the following categories: identifiers; commercial information; internet or other similar network activity information; and inferences drawn from such information.
We do not sell the personal information of consumers without the consumer's consent and affirmative authorization as required under the CCPA.
12.5 Your Rights under the CCPA
As of January 1, 2020, California residents, as defined under the CCPA, may take advantage of the following rights:
- Subject to certain exclusions under the CCPA, you have the right to opt-out of the sale of your personal information.
- You may request, up to two (2) times each year, that we disclose to you, once we receive and confirm your verifiable consumer request, the: (1) categories and specific pieces of personal information that we have collected about you; (2) categories of sources from which your personal information is collected; (3) business or commercial purpose for collecting your personal information; (4) categories of personal information that we disclosed for a business purpose; (5) categories of personal information that we hold about you; (6) categories of third-parties with whom we have shared your personal information; and (7) business or commercial purpose for selling your personal information.
- Subject to certain exceptions and up to two (2) times each year, you may request that we delete any of the personal information that we collected from you. Once we receive and confirmed your verifiable consumer request for deletion, we will delete (and direct our service providers to delete) such personal information from our records, unless an exception applies.
To exercise the access and deletion rights described above, please submit a request to us by either sending an email to firstname.lastname@example.org or filling out our contact form, with “California Privacy Rights” in the subject line.
You will be asked to provide certain identifying information, such as your name, email, and residency. While processing your request, we may ask you to provide further verifying documentation. We will only use personal information provided in a request to verify the requestor's identity or authority to make the request. 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. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide proof of written authorization to do so, and you must verify your identity directly with us unless the such authorized agent provides proof of a power of attorney pursuant to Probate Code sections 4000 to 4465.
We will not discriminate against you for exercising any of your rights under the CCPA. Accordingly, and unless permitted by the CCPA, we will not: deny you services; charge you different prices or rates for services; provide you a different level of service, or suggest that you may receive a different price or rate for services or a different level for services. We may charge a different price or rate or provide a different level of service if the difference is reasonably related to the value provided by your personal information.
12.7 Other Applicable California Privacy Laws
Section 1798.83 of the California Civil Code requires select businesses to disclose policies relating to the sharing of certain categories of your personal information with third parties. If you reside in California and you have provided us with your personal information, you may request information about our disclosures of certain categories of your personal information to third parties for direct marketing purposes. To make such a request, please fill out our contact form with “California Privacy Rights” in the subject line and allow 30 days for a response. We will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly or that do not have complete information.
In accordance with Section 22581 of the California Business and Professions Code if you are a California resident under the age of 18, you may request and obtain the removal of content or information you have publicly posted. To make such a request, please fill out our contact with “California Privacy Rights” in the subject line. Please specify the site(s) or service(s) to which your removal request relates, including any URLs where the content or information is posted and the specific content or information you posted for which you are requesting removal. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
15. Contacting Us