Effective Date: December 15th, 2019
Notice to California Residents – Your California Privacy Rights
1. Notice of Collection and Use of Personal Information
We may collect the following categories of personal information about you:
- Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, and similar technology; telephone number and other forms of persistent or probabilistic identifiers), online identifiers, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
- Secondary Identifiers: signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, other financial information, medical information, and health insurance information
- Protected Classifications: race, age, and gender
- Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
- Online Activity: internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
- Geolocation: geolocation data
- Sensory Information: audio, electronic, visual, and similar information
- Employment Information: professional or employment-related information
- Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, and attitudes.
We may use the categories of personal information listed above for certain business or commercial purposes, as described in this table:
|Purpose||Categories of Personal Information|
|Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders, transactions, refunds, returns, or exchanges, verifying customer information, processing payments, managing accounting, billing, and record keeping, advertising and marketing our products and services, administering contests, surveys, sweepstakes, and promotions, advertising or marketing third-party products or services, performing market and statistical research, developing new products or services, enhancing or improving Eroica Wine content, products, and services, resolving problems and complaints, complying with company policies, complying with legal requirements and government requests, providing analytics services, or providing similar services||Identifiers, Secondary Identifiers, Protected Classifications, Commercial Information, Online Activity, Geolocation, Sensory Information, Employment Information, and Inferences|
|Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance||Identifiers, Secondary Identifiers, Protected Classifications, and Commercial Information|
|Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction||Identifiers, Secondary Identifiers, Protected Classifications, Commercial Information, and Geolocation|
|Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity||Identifiers, Commercial Information, Online Activity, and Sensory Information|
|Debugging to identify and repair errors that impair existing intended functionality||Identifiers, Commercial Information, and Online Activity|
|Undertaking internal research for technological development and demonstration||Identifiers, Online Activity, Geolocation, and Inferences|
|Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us||Identifiers, Protected Classifications, Commercial Information, Online Activity, Geolocation, and Inferences|
2. Our Prior Collection, Use and Disclosure of Personal Information
a. Sources of Personal Information
We may have obtained personal information about you from various sources, as described below.
|Category of Source of Data Collection||Categories of Personal Information|
|From you and your device, for example, through your use of our websites, your use of our application(s), when you send us an email, use our services, or otherwise visit, contact or communicate with us||Identifiers, Secondary Identifiers, Protected Classifications, Commercial Information, Online Activity, Geolocation, Sensory Information, and Employment Information|
|Our data collection devices (e.g., iPad, paper signup form, etc.)||Identifiers, Secondary Identifiers, Protected Classifications, Commercial Information, Online Activity, Geolocation, and Employment Information|
|Our parent company||Identifiers, Secondary Identifiers, Commercial Information, and Geolocation|
|Our vendors and other business partners||Identifiers|
|From other individuals, such as when they refer you as a friend||Identifiers|
b. Sharing of Personal Information
We may have shared your personal information with certain categories of third parties, as described below.
|Category of Third Party||Categories of Personal Information|
|Our parent company||Identifiers; Secondary Identifiers, Protected Classifications, Commercial Information; Online Activity, Geolocation, and Employment Information|
|Our affiliates||Identifiers; Commercial Information; Online Activity, and Employment Information|
|Vendors, consultants and advisors who provide services on our behalf||Identifiers; Secondary Identifiers, Protected Classifications, Commercial Information; Online Activity, and Geolocation|
|Data analytics providers||Identifiers, Commercial Information, Online Activity, and Geolocation|
|Social networks||Identifiers, Commercial Information, and Online Activity|
|Advertising networks||Identifiers, Commercial Information, Online Activity, and Geolocation|
|Government entities, including regulatory agencies and law enforcement||Identifiers, Protected Classifications, and Geolocation|
c. Sale of Personal Information
- Identifiers, Commercial Information, Online Activity, and Geolocation
We do not collect and do not sell the personal information of minors under 21 years of age.
d. Disclosure of Personal Information for a Business Purpose
We may have disclosed to third parties the following categories of personal information for a business purpose:
- All the categories of personal information about you described in Section 1 above except for Inferences.
3. California Consumer Privacy Rights
You have certain choices regarding our use and disclosure of your personal information, as described below.
Rights Under the California Consumer Privacy Act of 2018
- Access: You may have the right to request that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
- Deletion: You have the right to request that we delete certain personal information we have collected from you.
- Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
How to Submit a Request: To submit an Access, Deletion, or Opt-Out of Sale request, please send us an email at Compliance@smwe.com with your full name and your e-mail address, call 1-800-267-6793, or visit Do Not Sell My Personal Information. Indicate that you are a California resident making a “California Consumer Privacy Act” inquiry and list which of the above rights you would like to exercise.
Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request to access or delete your personal information, we may require you to provide information such as: physical address, date of birth, and phone number. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion, or opt-out of sale request on your behalf, we may require you to provide the authorized agent written permission to do so, and, for access and deletion requests, we may also require you to verify your own identity directly with us (as described above). Additional Information: If you choose to exercise any of your rights under the California Consumer Privacy Act, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.
Rights Under California’s “Shine the Light” Law
If you reside in California, you have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties. To make such a request, please send us an email at Compliance@smwe.com or call 1-800-267-6793. Indicate that you are a California resident making a “Shine the Light” inquiry.
Privacy Notice to All Consumers
Personal Information We Collect About You
Personal Information We Collect About You
You may choose to provide personal information (such as your name, address, telephone number, and e-mail address) through our website. Below are the ways in which you may provide the information, the types of information you may submit, and the ways we may use that information. In addition to the uses described below, we may also use the information you submit for internal purposes. We may also receive personally identifiable information from our business partners.
If you communicate with us through the Contact Us link on our website (if applicable), we may ask you for information such as your name, email address, and telephone number so we can respond to your questions and comments. We may also use the information you provide to evaluate the quality of our products and to communicate with you about our products and services. If you decide to opt-out of any of the various ways we communicate with you, keep in mind that these preferences regarding promotional contacts do not mean that we might not contact you for other reasons, such as those related to an order you placed, an inquiry you made, a message that a friend or acquaintance requested be delivered (such as through our Forward to a Friend program), a newsletter to which you have subscribed, a membership you undertook, an event for which you registered, or a legally required notice.
Join Our Mailing List
On our website, if applicable, you may sign up to receive newsletters, exclusive offers and promotions, notice of special events, and product news. To sign up, we require your name, e-mail address, and zip code. We use your contact details to send you the information you request and communicate with you about our products and services. You may stop the delivery of future e-mail from us by clicking on the unsubscribe link provided, but note, it may take up to 10 business days to honor your request. By providing your personal information you consent to our transferring and processing it in the United States.
Wine Club Memberships and On-line Purchases
If you choose to make a purchase or join a wine club, we may collect information such as your name, address, phone number, email address, date of birth, credit or debit card information, and your purchase history with us. We use this information to process your order, communicate with you about our products and promotions, and collect feedback on your experience on this website. By providing your personal information, you consent to our transferring and processing it in the United States.
Other Website Features
Information We Collect by Automated Means
We collect certain information by automated means when you visit our website, such as how many users visited our website and the pages accessed. By collecting this information, we learn how to best tailor our website to our visitors. We collect this information through various means such as "cookies," "web beacons," and IP addresses as explained below.
We collect internet-related information from visitors to our website, including the referring URL, your IP address, which browser you used to come to the website, and the pages of our website that you viewed during your visit, for the purposes of system administration, to gather broad demographic information, and to monitor the level of activity on our website. We also utilize certain graphics in our email messages to determine things like which email messages were opened and how many times they were opened.
We have also implemented Google Demographics and Interest Reporting which, in the aggregate, groups our users into certain categories including: age ranges, gender, affinity categories, and in market segments.
Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all our website features.
Certain pages on our website may contain "web beacons" (also known as internet tags, pixel tags, and clear GIFs). Web beacons allow third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the third party.
An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the internet. When you visit our website, we may view the IP address of the device you use to connect to the internet. We use this information to determine the general physical location of the device and understand from what regions of the world our website visitors come. We may also use this information to enhance your experience on our website.
Our website is not directed at children, and as a result we will not knowingly collect information from anyone under the age of 21. We will not knowingly market alcoholic beverages to anyone under the legal purchase age. If we receive notice or believe that someone under the legal purchase age has provided us with personal information, we will make every reasonable effort to remove such personal information from our files or flag such personal information and retain it for the sole purpose of ensuring that it is not used any further.
Information We Share
Links to Third-Party Websites
From time to time, we may provide links to third-party websites. These websites may operate independently from Eroica and may have their own privacy policies in place, which we strongly suggest you review if you visit any linked website. To the extent any linked website you visit is owned or operated by someone other than Eroica, we are not responsible for its content or any use of the website.
How We Protect Personal Information
We maintain administrative, technical, and physical safeguards on this website to help protect against unauthorized disclosure, use, alteration, or destruction of the personal information you provide. We use secure socket layer (SSL) technology to help protect your credit card information as it is transmitted to us. You are responsible for maintaining the confidentiality of any user name and password you use.
Your personal information will be kept on servers in a physically and technologically secure environment located in the United States accessed only by authorized personnel or contractors who are bound to keep your information confidential. Any transmission of your credit card information will be encrypted. If you contact us regarding identity theft or some other form of unauthorized use of your data, we may disclose pertinent information to law enforcement agencies and other third parties with responsibility and authority to investigate such a claim.
How to Contact Us
14111 NE 145th St.
Woodinville, WA 98072