Our Commitment to Your Privacy
Summary of how we use your information
- We will use your information in order to comply with your requests, correspond with you, administer our sweepstakes and competitions, and process and fulfill any wine orders you make with us or with our related companies.
- This information will be shared with our related companies.
- Where we market to you, you can opt-out of such marketing communications at any time. Additional details on how you may opt-out are set out below.
Information you give us
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:
- when you transact with us online, over the phone or in person;
- when you enter a promotion or competition conducted by us (including via our websites or through social media sites);
- when you visit and/or register to use one of our websites or when you participate in discussion boards or other social media functions on our websites; or
- when you contact us to request information or support in relation to our company, our products or our services (including about our brands, product quality, visiting our sites or employment opportunities).
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.
Technical and Navigational Information
- technical information such as your computer’s IP address, hardware type, browser type, device identifier and screen type/resolution;
- general location data based on your device or IP address;
- any technical errors or exceptions; and
- information about your visit such as the products you viewed or searched for, the length of your visit, page load speed, and the pages that you visited.
We use the following categories of tracking technologies on our websites:
- Strictly Necessary tracking technology – these technologies are essential in order to enable you to move around our websites and use their features.
- Performance related tracking technology – these technologies collect anonymous information on how people use our websites. The data stored by these technologies never shows personal information from which your individual identity can be established.
- Functionality related tracking technology – these technologies remember choices you make such as the country you visit our websites from, your completion of the age verification check and language preferences. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these technologies collect may be anonymized and they cannot track your browsing activity on other sites.
- Targeting or advertising related tracking technology – these technologies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of an advertising campaign
- Commerce related technologies – these technologies are essential in order to enable a functional online shopping experience across our websites, stores, and payment/checkout.
“Do Not Track” Signals
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.
Categories of Personal Information we collect
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:
- Identifiers. Identifiers include your name, address, phone number, IP address, or other similar identifiers. We may supplement the information you provide to us with data we obtain or receive from third parties, such as our affiliates, marketing firms, data vendors or address verification services. For example, if you change your address and fail to advise us, we may verify your address through a third party address verification company. We may combine information we collect online with information we collect offline.
- Some Personal Information included in this category may overlap with other categories.
- Individualized information. Your name, contact information, email address, age or date of birth, payment information, shipment address, employment (if applicable), and other information, including a username and password.
- Protected classification characteristics under state or federal law. Your age, national origin, marital status, gender, or veteran or military status.
- Commercial information. The products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other similar network activity. Our website collects certain information as part of the technology we use to run our website. This technical information may also include Personal Information about you. This information will be handled just like all other Personal Information we collect.
- Geolocation data.For example, the location of your device or computer.
- Professional or employment-related information.For example, if you provide any company information on the “Contact Us” page or you apply for a job with TFE.
- Inferences drawn from other Personal Information.For example, information about your purchase preferences.
Our use of your information
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:
- To fulfill or meet the reason you provided the information. For example, if you provide your personal information to purchase our products, we will use that information to process and manage your order. If you provide your details to apply for a job with TFE, we will use those details to process your application for employment;
- To provide, support, personalize, and develop our Website, products, and services and to help us gain a better understanding of your likes and dislikes in order to improve our websites and the services we offer;
- To help maintain the safety, security, and integrity of our Website, products and services, databases, and other technology assets, and business;
- To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (where we do not need your consent);
- To allow you to participate in interactive features of our websites and administering our promotions and competitions;
- To verify that you are of legal drinking age in your jurisdiction (if applicable);
- To make suggestions and recommendations to you and other users of our websites about goods or services that may interest you or them;
- To fulfill a contract we may have with you, such as where you make a purchase from us or enter one of our competitions;
- To produce consumer insights (e.g., general research on our consumers; conduct consumer testing, surveys, and panels; data analytics and modeling);
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TFE’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by TFE about our Website users is among the assets transferred;
- As described to you when collecting your personal information.
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.
Opting-out of direct marketing
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.
How long we keep your information
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.
Our disclosure of your information
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:
- at your instruction;
- where we are required or authorized by law to do so, for example to law enforcement agencies;
- where third parties appointed by us require access to personal information held by us to perform services (in which case we require these third parties to keep that personal information confidential and not to use or disclose it for any purpose other than the purpose of performing those services). The types of third parties we may transfer information to include vendors, service providers, agencies and other partners who globally support our business and help us administer certain activities on our behalf, such as providing technical infrastructure services, marketing services, customer service, data hosting and management services, processing credit card payments services for us, and providing logistics and delivery services to help us deliver our products and services; or
- to our related companies in order to operate our global business and in accordance with the law.
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.
Your rights in relation to your information
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.
Your Rights Under “Shine the Light”
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.
Effective Date of Policy