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Malene Wines Privacy Policy

Last Updated: June 2020

Protecting your personal information is taken seriously at Malene Wines and Crimson Wine Group Ltd. (CWG) (collectively, “we”, “our”, or “us”). Privacy regulations require us to inform you of our practices regarding the collection, disclosure, and use of your personal information. We know that privacy is important to you, and we are committed to safeguarding your personal information. This Privacy Policy describes how we collect, use, and disclose information about you and your use of our websites, mobile applications, and other online features, products, and services that link to this Privacy Policy (each a “Service” or collectively, “our Services”). By visiting or using our Services, you signify your acceptance of this Privacy Policy and agree that we may collect, use, and disclose your personal information in accordance with this Privacy Policy.

Information We Collect

Information You Provide to Us

We collect information directly from you. For example, we collect information when you make a purchase, request an emailed purchase receipt, sign up for our wine club, book a tasting reservation, purchase event tickets, or register for an online account. We collect information when you sign up to receive news, notifications, or other communications from us. We also collect information when you engage with us on social media, fill out a form, or participate in a survey or promotion. We also collect information when you engage with us using the Contact Us instructions below, and through the technology we use in our services (see Cookies and Similar Technologies section below). The types of information we collect directly from you may include:

Information We Collect Automatically

We automatically collect information about you when you access or use our Services or do business with us. For example, we collect:

Online Advertising

We work with third-party companies for advertising purposes, including to: serve advertisements across the Internet; track and categorize your activity and interests over time on our website and mobile application, and on third-party websites and mobile applications; and to identify the different device(s) you use to access websites and mobile applications. We share information with these companies, and these companies may collect information—including automatically collected information when you use our website or mobile application—through the methods described in the Information We Collect Automatically section above. These third-party companies also may possess or obtain information about you from your interactions: directly with the third-party companies; with other websites, mobile applications, or companies that the third-party companies work with; or from your interactions with advertisements the third-party companies help to display to you. The information that these companies collect or that we share may be used to customize or personalize the advertisements that are displayed to you.
We do not sell, but may share personal information with the third-party companies we work with for our purposes, though in general we do not share personal information about you with third parties for third-party marketing or advertising purposes. We may also share other information at our discretion, including automatically collected information, which may be used by third parties for third-party marketing, advertising, and other purposes. For information about the choices you have about the online advertising practices described in this section, please see the Your Choices and Cookies and Similar Technologies sections below.

Information We Create or Generate

We infer new information from the information we collect, including using automated means to create or generate information about your likely preferences, interests, or other characteristics (“inferences”). For example, we may infer your city, state, and country location based on your IP address or zip code. We may also infer product or services that may interest you based on your prior purchases with us.

Information We Receive from Other Sources

We may collect information about you from other sources that we may combine or link with information we have about you. We may combine information that we have collected offline with information we collect online. In addition, we may collect information from:

Use of Information

We do not sell the information we collect about you, but use it to help us operate our business. In particular, we use the information we collect (as described in Section 1 above) for the following purposes:

In carrying out these purposes, we combine data we collect from different sources to give you a more seamless, consistent, and personalized experience.
We do not direct the Services to individuals under the age of twenty-one (21). We do not knowingly collect Personal Information from individuals under 21.

Sharing of Information

We share information as described in the Privacy Policy.

When you use our Services, we along with our third-party service providers may use cookies and similar technologies (e.g., web beacons, log files, and pixels) (collectively, “technology”). This technology involves placing small files on your device or browser that serve several purposes, such as remembering your preferences (e.g., language) and generally improving your experience on or with our Services. Specifically, we may use such technology for purposes such as to:

Where required by law, we collect your consent for the use of such technologies.

You can set our device or browser to accept or reject most cookies, or to notify you in most situations that a cookie is offered so that you can decide whether to accept it. However, if you block cookies, certain features on our Services may not function. Additionally, even if you block or delete Cookies, not all tracking will necessarily stop.

We do not guarantee that all of the third parties we work with will honor the elections you make using those options, but we strive to work with third parties that do.

Your Choices

Online Advertising

As mentioned above in the Cookies and Similar Technologies section, you have the choice to manage your third-party advertising preferences.

Your Rights

If you have created an online account with us and would like to update the information you have provided to us, you can access your account to view and make changes or corrections to your information. Depending on applicable law, you may have the right, and we also provide you with the opportunity to be informed of whether we are processing your information and to access correct, update, oppose, delete, block, limit or object, upon request and free of charge, to our use of your information to the extent required by applicable law. For specific information for California residents, please refer to the Information for California Residents section below.

For such inquiries, please contact us as detailed under the Contact Us heading below. We will try to comply with your request as soon as reasonably practicable and as required by applicable law. For specific information regarding our response time and format arising from requests from California residents, please refer to the Information for California Residents section below. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law. In any event, should you choose to exercise any of your rights as detailed above, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level of quality of products, based solely upon this request.

Security of Your Information

We take commercially reasonable technical, administrative, and physical security measures to protect your information, including generally accepted industry standards to protect the information submitted to us during transmission and once we receive it. When you provide us sensitive information (e.g., credit card number), we encrypt that information using secure socket layer technology (“SSL”) or similar technology. However, no method of transmission over the Internet, or method of electronic storage is 100% secure, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please contact us immediately as detailed under the Contact Us heading below.

Links to Other Websites

Our Services may contain links to other websites or services that are not owned or controlled by us, including but not limited to links to websites of our advertisers, sponsors, and partners. This Privacy Policy only applies to information collected by our Services. We have no control over these third-party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our Services. Your use of third-parties’ websites linked to our Services is at your own risk, so we encourage you to read the privacy policies of any linked third-party websites when you leave one of our Services.

No Data Collected from Children/Minors/Those Under the Legal Drinking Age

Our Services are intended only for those of legal drinking age and we do not knowingly collect information from individuals under the legal drinking age, children or minors. If we have actual knowledge that information about a child has been collected, we will take the appropriate steps to delete the information.

Information for California Residents

If you reside in California, we are required to provide additional information to you about how we use and disclose your Personal Information, and you may have additional rights regarding how we use your Personal Information pursuant to state-specific laws, including the California Consumer Privacy Act of 2018 (“CCPA”), the California Online Privacy Act (“CalOPPA”), and the “Shine the Light” law, codified in § 1798.83 of the California Civil Code (collectively, the “CA Privacy Laws”). Please see more information regarding the CA Privacy Laws below:

CCPA. Consistent with the Information We Collect section above; we collect certain categories and specific pieces of information about individuals that are considered “Personal Information” in California (“CA Personal Information”). For clarity, CA Personal information does not include:

As described in the Information We Collect section above, we may collect CA Personal Information from you and other third parties. We collect, share and disclose CA Personal Information for the business and commercial purposes described in the Use of Information and Sharing of Information sections above.

Subject to certain exceptions, as a California resident, you have the right under the CCPA to (i) access your CA Personal Information; (ii) obtain deletions of your CA Personal Information; (iii) receive information about the CA Personal Information about you that we have “sold” (as such term is defined under California law) to third parties within the past twelve (12) months; and (iv) opt-out of the “sale” of your CA Personal Information. Notwithstanding the foregoing, as described in the Use of Information section above, we have not sold and do not sell your CA Personal Information under any circumstances through your use of the Services.

Additional information regarding your rights, and the process by which you may exercise them, are more fully described below:

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. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

CalOPPA. Our Services and this Privacy Policy are provided in accordance with CalOPPA. We collect, use, and share your information as described in the Information We Collect, Use of Information, and Sharing of Information sections above, respectively.

Shine the Light. Under California’s “Shine the Light” law, if you are a California resident who provides Personal Information in obtaining products or services for personal, family, or household use, you may request to opt-out of such sharing by a winery at no-cost by following the instructions in the Your Choices and Your Rights sections above, or by contacting us as described in the Contact Us section below. Please be aware that your opt-out request will apply only to the sharing by that particular winery.

Exercising Other California Consumer Rights and Non-Discrimination. Should you wish exercise any other rights in addition to those detailed above with regard to your Personal Information, we will not discriminate against you with a different level or quality of products, based solely upon this request. Please see the Contact Us section below if you have questions or would like to exercise such rights.

Changes to this Privacy Policy

Except to the extent limited by applicable law, including without limitation the CA Privacy Laws, we reserve the right to update this Privacy Policy to reflect changes to our information practices by prominently posting notice of the update on our Services. Any updates will become effective immediately after posting the updates to the Privacy Policy and apply to all information collected about you. If we make any changes to this Privacy Policy that materially impact previously collected information about you, we will, to the extent that we have your email address, notify you by email.

Contact Us

If you have any questions about this Privacy Policy or information we have collected about you, or to exercise your rights as detailed above, please contact us by email at privacy@malenewines.com, by phone at 844.367.4500, or by postal mail at:

Crimson Wine Group Ltd.
Attn: Malene Wines Privacy
5901 Silverado Trail
Napa, CA 94558