PRIVACY POLICY

Last Updated: June 15, 2018

We respect your privacy and are committed to the protection of your Personal Information and any other data that you choose to provide to us through our website. This Privacy Policy describes the Personal Information that we may collect from you, or that you may provide to us when you visit the site, and our practices for collecting, using, maintaining, protecting, and disclosing such information.

Please note that this Privacy Policy applies only to information we collect through the site and through communications between you and the site. It does not apply to any other information or communications that may reference Aubert Wines.

Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Information (that is, information relating to an identified or identifiable natural person) and how we will treat it. If you do not agree with our policies and practices, do not use our site. By accessing or using this site, you agree to this Privacy Policy. We reserve the right to update or modify this Policy, so please be sure to review it from time to time. We will provide notice of changes, such as by posting a notice on the site or updating the “Last Updated” date at the beginning of this Policy. Your continued use of this site after we make changes is deemed to be acceptance of those changes.

Personal Information We Collect:
We do not collect Personal Information about you unless you choose to provide us with such information. If you register for our Emails (as defined below), sign up for our waiting list, or register as a member, we may collect Personal Information about you such as your name, date of birth, email address, phone number, and mailing address. Similarly, if you place an order, you will be asked to provide us with your name, date of birth, email address, telephone number, delivery address, billing address and credit card number and expiration date.

If you would prefer that we not collect Personal Information from you, please do not provide it. When you submit your Personal Information on our site, you are giving your consent to the collection, use, and disclosure of your Personal Information as set forth in this Privacy Policy.

We may also receive your Personal Information from various third parties that we engage to assist us with providing you products or services, including: delivery and address information from our carriers who deliver products to you; data analytics information from companies that provide us with data analytics services; and information on your account, payment and credit history, including information from credit bureaus and sources that we use to process payments. These third parties do not retain, share, store, or use your Personal Information for any secondary purposes.

How We Use the Personal Information We Collect:
We use your Personal Information for the following purposes: to review and respond to your questions; to fulfill your orders and process your payment information; to communicate with you about your orders or to update our records and maintain any online account you may have with us; to improve the products and services we provide and enable third parties to carry out technical, logistical or other functions on our behalf; to administer, safeguard, and improve our website; to protect our rights and the safety of others; and/or to comply with applicable law, court order, subpoena, or legal process served on us.

If you are an existing customer, have consented to receiving marketing communications, or have signed up for our waiting list, we may also use the information that you provide to us in order to create and deliver to you emails containing information about our products and/or services that we believe may be of interest to you (“Emails”). If you prefer not to receive our Emails, please do not register to receive them. If you do register and later decide that you would no longer like to receive these Emails, you may unsubscribe from our emails or communications at any time (see the “How You can Access and Control Your Information” Section below). Our Emails are administered through Campaign Monitor. As a result, your Personal Information, including your name and email address, will be disclosed to Campaign Monitor and will be used by Campaign Monitor pursuant to its privacy policy available at https://www.campaignmonitor.co... (the “Campaign Monitor Privacy Policy”). For questions, corrections, updates, deletions, or changes to any Personal Information held by Campaign Monitor, please refer to the Campaign Monitor Privacy Policy.

We may use third-party services to process purchases made through the site. Currently, our payment processors are Stripe and Figure. Your Personal Information may be disclosed to Stripe and used by Stripe pursuant to its privacy policy available at https://stripe.com/us/privacy/ (the “Stripe Privacy Policy”). Your Personal Information may also be disclosed to Figure and used by Figure pursuant to its privacy policy available at https://intercom.help/figureap... (the “Figure Privacy Policy”). For more information on how payments are handled, or to understand the data security and privacy afforded to your payment information, please refer to the Stripe Privacy Policy and the Figure Privacy Policy.

Legal Bases under GDPR:
If you are in the European Economic Area (“EEA”), we will collect and use your Personal Information only if we have one or more legal bases for doing so under the General Data Protection Regulation (“GDPR”). For the purposes of the remainder of this section, references to “you” refer to users of our site located within the EEA or other non-U.S. territories.

Our legal bases for the collection and use of your Personal Information depend on your interaction with us and our site. This means we collect and use your Personal Information only where: you have given your consent for one or more specific purposes; it is necessary to perform a contract we are about to enter into or have entered into with you; it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; it is necessary to protect the vital interests of you or another natural person; or it is necessary to comply with a legal obligation. We have indicated in italics the legal basis or bases on which we are relying following each purpose (see below). Where we are relying on consent as the legal basis, we will notify you and seek additional consent before using your Personal Information for a new purpose that is inconsistent with the original purpose for which we collected it. You can withdraw your consent at any time and we will then stop processing your information for that purpose.

We may use your Personal Information: to review and respond to your questions (with your consent); to fulfill your orders and process your payment information (perform a contract); to communicate with you about your orders or to update our records and maintain any online account you may have with us (perform a contract/with your consent); to improve the products and services we provide and enable third parties to carry out technical, logistical or other functions on our behalf (for our legitimate interests); to administer, safeguard, and improve the site (for our legitimate interests); to protect our rights and the safety of others (for our legitimate interests); and/or to comply with applicable law, court order, subpoena, or legal process served on us (to comply with legal obligations).

How We Collect and Use Non-Personal Information:
We may collect non-personal information, or data in a form that does not, on its own, permit direct association with any individual. For example, we may use automatic data collection technologies to collect and store details of how you use our site. This “usage data” is limited to information related to your interactions with our site. The technologies we use for usage data collection include:

Cookies
Cookies may be issued when you visit our site. We may place a cookie on your computer or device so we can recognize you as a return user and personalize your experience and your use of our site. We also use cookies to help us understand how you engage with our site. You can accept or reject cookies by adjusting your web browser controls. For more information about cookies and instructions on how to adjust your browser settings to accept, delete or reject cookies, see www.allaboutcookies.org.

Third-Party Services
We use third-party analytics services, including Google Analytics, FullStory, and others, to collect information about your use of our site and enable us to improve our site. We use the information we receive from third-party analytics services to maintain and improve the site and our products and services. Google Analytics, FullStory and other third-party analytics services use cookies and similar technologies to collect information about use of our site and to report trends to us, without identifying individuals.

Google’s ability to use and share information collected by Google Analytics about your access and use of the site is restricted by the Google Analytics Terms of Website, available at http://www.google.com/analytics/terms/us.html, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

FullStory’s use of information collected through its analytics tools is set forth in the FullStory privacy policy available at https://www.fullstory.com/legal/privacy. You may also opt-out of FullStory by following the instructions in FullStory’s privacy policy. To opt out, please visit the FullStory Opt-Out Page, available at: https://www.fullstory.com/optout.

Click-through URLs
If you “opt in” to receive emails from us, our emails may use a “click-through URL” linked to content on our site. When you click one of these URLs, they pass through a separate web server before arriving at the destination page on our site. We use this click-through data to help us understand how recipients respond to our emails. If you prefer not to be tracked in this way, please do not click text or graphic links in emails that you receive from us.

Log Files
We gather certain information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type, and internet service provider (ISP). We use this information, which is not linked to Personal Information, to analyze trends, to administer our site and to track users’ movements around our site.

Web Beacons
Pages of our site and our Emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to count users who have visited those pages or opened an Email and for other related website statistics, for example.

Please be aware that we do not currently honor “do not track” requests.

Disclosure of Information We Collect:
We do not rent or sell your Personal Information to anyone. We may share and disclose information (including Personal Information) that we collect or you provide us in the following limited circumstances:

Agents and Service Providers
We may share your information with third party agents and service providers who we employ to perform tasks on our behalf and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them. These companies include, for example, our data analytics services (e.g., Google Analytics, FullStory), payment processor/e-commerce platform (e.g., Figure, Stripe), email service provider (e.g., Campaign Monitor)], and shipping services (e.g., Wineshipping, FedEx, UPS, All Ways Cool, 55 Degrees, Vinfolio, Aero Packing).

Protection of Aubert Wines and Others
We reserve the right to access, read, preserve, and disclose any information as necessary to enforce or apply our agreements, including for billing and collection purposes, or protect our rights or property, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our employees, grantees, donors, or others.

Disclosures for National Security or Law Enforcement
Under certain circumstances, we may be required to disclose your Personal Information in response to valid requests by public authorities, including to meet national security or law enforcement requirements, or to comply with any court order, law, or legal process.

Storage and Transfer of Information We Collect:
The information we collect or you provide us may be transferred to—and maintained on—computers located outside of your state, province, country, or other governmental jurisdiction where data protection laws may be different from those of your jurisdiction. By providing information on our site, you hereby expressly consent to such a transfer for the purposes described herein.

For users of our site located within the EEA or other non-U.S. territories, please note that if we receive your Personal Information in the United States and subsequently transfer that information to a third party agent or service provider for processing, we remain responsible for ensuring that such third party agent or service provider processes your Personal Information in accordance with the standard required by the GDPR.

How You can Access and Control Your Information:
You may access the Personal Information you have submitted to us, delete or make changes to such information, and unsubscribe from receiving future Emails from us at any time by contacting us at:

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