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Updated December 2020
Intended for Users 21+
The Platform is not directed to, and we do not knowingly collect personal information from, persons under the age of 21. If you are under 21 years of age and have entered this Platform by clicking "Yes" to the pop-up verification and stating that you are 21, you must immediately leave this Platform. Under no circumstances may you use this Platform or submit personal information to us if you are under 21 years of age. We are committed to compliance with all applicable regulations, laws, and rules, including those issued by the Wine Institute, ICAP, and COPPA.
What Information We Collect
We collect contact information. For example, if you sign up for a mailing list, create an account, or enter a promotion, you may be asked to provide your name, address, email, online identifier, username, cell phone number, and/or date of birth.
We collect information you submit or post. We collect information that you post in a public space on the Platform, submit requests or inquiries to us (e.g., to participate in our loyalty or rewards programs, a service request or product request), or information related to your social media activity (e.g., posts, photos, followers, social media handle). We also collect information when you contact us or when you apply for a job.
We collect demographic information. We may collect information like your gender and age. We may also collect your zip code.
We collect usage information. We may collect information about the browser you are using. We might look at what site you came from or what site you visit when you leave the Platform. If you are using a mobile app, we may collect location information, including your precise location, if you have enabled location services in your device settings. We may also collect device information, including IP address and device identifiers.
We collect certain information on interests and preferences. We may collect information on your interests (e.g., music or sports), preferences, and purchases.
How We Collect Information
We collect information from different sources and across devices. For example:
We collect information directly from you. If you choose not to provide the information that we ask for, it is possible that you may not be able to participate in an activity or experience the full functions of the Platform.
We collect information from you passively. For instance, we use certain standard web measurement and tracking technologies such as "cookies," web server logs, web beacons (also known as "action tags" or "one pixel .gif files"), clear GIFs or other statistics programs. We do this on our Platform (including mobile apps) and in emails that we send to you. We collect information about users over time when you use this Platform (including mobile apps). We have third parties collect information this way, as well. To learn more about these tools and how you can control them, click here. Your browser may have an option that allows you to accept cookies, reject cookies, or receive notification when a cookie is sent, but you should note that the use of such restrictive browser settings may limit your use of the Platform.
We get information about you from third parties. For example, our business partners may give us information about you. Social media platforms may also give us information about you.
We and our business partners may combine information. For example, we and our business partners combine information that we have collected offline with information we collect online. We and our business partners may combine information collected across different devices over time.
How We Use Information
We use your information for the following purposes:
to establish that you are of legal age to use our products and services;
to improve our products and services and to customize your experience with us;
to provide the products and services you request, including our loyalty and rewards programs;
to communicate with you about our relationship and respond to inquiries we receive from you or in connection with a transaction you initiate;
to analyze, manage and improve the Platform and our products and services, including by analyzing preferences, interests, and purchases;
to use it within Ladies of Leisure as we continue to work on being the world’s best wine company;
to notify you of special offers and other services that we believe may be of interest to you or to send you current mailings. To learn about your choices with regard to these communications, read the Choices section below;
to provide you with advertisements about goods and services that may be of interest to you;
to notify you that you have been selected as a winner of a contest or sweepstakes;
to help us protect the Platform and our customers;
to help us diagnose problems with our server or other technical issues relating to the performance of the Platform; or
for any other purpose as otherwise permitted by law or as stated at the time you provide your information.
Note about third-party uses: If you voluntarily disclose personal information (e.g., name, email address, personal photographs) in a community forum, such information may be collected and used by others and may result in unsolicited messages from other parties. We have no control over this type use of your personal information and are not responsible for that use.
How We Share Your Information
We may share the information we collect from and about you with third parties:
We share information with third parties who provide services on our behalf, such as vendors who send emails or serve advertisements for us, or who operate the Platform or run promotions on our behalf;
We share information to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, customers or other users of the Platform, or anyone else who could be harmed by such activities;
We share information to enforce the Terms and Conditions, take precautions against liability, investigate and defend against any third-party claims or allegations, and/or protect the security or integrity of the Platform;
We share information to respond to judicial process and provide information to law enforcement agencies in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law, or in the good-faith belief that such action is necessary to comply with state and federal laws;.
We share information within the Ladies of Leisure brand, which is listed here;
We share information with our business partners, such as companies that co-sponsor a promotion;
We may share information with any successor to all or part of our business or any entity that we acquire (for instance if part of our business is sold, we may give our customer list as part of that transaction);
We may share your information with creditors, if required, in the event of our bankruptcy, insolvency, or reorganization; and
We may share information for other reasons we disclose to you.
You Have Certain Choices About How We Use Your Information
You Can Control Tracking Tools and Third Party Advertising
We may use third-party companies and/or media partners to serve ads on our Platform and/or on the sites on which we advertise. We and these third party companies display interest-based advertising using information gathered about you over time across multiple or other platforms. In the course of serving advertisements, these companies may place or recognize a unique cookie on your browser. In addition, we may use web beacons provided by third-party advertising companies to help manage our online advertising. These web beacons enable us to recognize a browser’s cookie when a browser visits this Platform to learn which advertisements bring users to our Platform.
To learn more about these third-party companies, cookies and how to "opt-out" of this type of advertising, please go to http://www.aboutads.info/choices/.
This Platform complies with the self-regulatory principles of the Digital Advertising Alliance (DAA) Self-Regulatory Program for Online Behavioral Advertising, therefore some pages may contain icons that help users understand how information is being collected, and how to opt out of having their online behavior recorded and used for targeted advertising resulting therefrom.
To opt out of having your online behavior collected for behavioral advertising purposes, go to https://optout.aboutads.info . These choices will apply to data collected from other browsers or devices for use on this device for interest-based advertising and other applicable uses. Certain choices you make may be browser-specific and/or device-specific.
Opting-Out of Receiving our Emails
To stop receiving our promotion emails, email us at firstname.lastname@example.org or click on the link provided at the bottom of each email communication. Even if you opt out of receiving promotional messages, we will still send you messages about your questions and purchases.
You can control tools on your mobile devices
For example, you can turn off push notifications from within a mobile app.
We take reasonable precautions and have implemented reasonable technical measures to protect against the risks of unauthorized access to, erroneous disclosure of, and unlawful interception of personal information submitted via the Platform or otherwise collected or possessed by Ladies of Leisure. However, the Internet is never 100% secure and we do not guarantee the security of any information transmitted over the Internet. Even after we receive your personal information, we cannot guarantee that your Personal Information may not be accessed, disclosed, altered, or destroyed as a result of a breach of our reasonable efforts or as a result of any other event beyond our reasonable control. Accordingly, we cannot and do not guarantee that your Personal Information is completely secure and safe from such risks. For the avoidance of doubt, we expressly disclaim any representation or warranty, whether express or implied, with respect to ensuring, guaranteeing or otherwise offering any definitive promise of security in connection with your information.
United States Only
California Privacy Rights and Supplemental California Privacy Notice
The California Consumer Privacy Act of 2018 ("CCPA") requires us to provide additional privacy-related information to residents of California.
The section entitled "What Information We Collect" above lists the categories of personal information we have collected about California residents in the preceding 12 months. These categories of personal information correspond with the following categories of personal information provided under the CCPA:
Identifiers including name, postal address, unique personal identifier, online identifier, username, IP address, email address and account name;
Information that identifies or is capable of being associated with you, including payment information, social media information, and, if you submit a resume when applying to work for us, information about your employment and employment history;
Information about products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;
Internet or other electronic network activity information;
If you submit a resume when applying to work for us with information about your education, such education information;
Inferences drawn from any of the information identified above reflecting your preferences and characteristics.
The section entitled "How We Collect Information" above lists the sources from which we collect personal information.
The section entitled "How We Use Information" above lists the business and commercial purposes for which we collect California residents’ personal information. As described above in the section entitled "How We Share Your Information", we also share and/or disclose your personal information as follows:
Sharing your personal information for business purposes: we may share the following categories of your personal information with service providers, third parties, business partners, public or government (including enforcement) authorities, creditors, and successors for our business purposes: identifiers, information capable of being associated with you, information about products and services, internet or other electronic activity information (as described above), information related to job applicants (if submitted), and inferences drawn from information about you. As described above, examples of business purposes include performing transactions, registering accounts, managing our relationship with you, and monitoring for security threats and fraud.
Sharing your personal information for commercial or other purposes: we may share the following categories of your personal information with third parties, business partners, and affiliates in a manner that constitutes a "sale" under California law: identifiers, information capable of being associated with you, information about products and services, internet or other electronic activity information (as described above), information related to job applicants (if submitted), and inferences drawn from information about you. This information may be shared for the following purposes: personalization, analytics, marketing, retargeting, and sales.
California Residents' Privacy Rights
Subject to certain exceptions and qualifications, as a California resident, you have the right to: (i) request access to your personal information; (ii) request deletion of your personal information; (iii) request information about the personal information about you that we have "sold" (as such term is defined under California law) to third parties within the past 12 months; and (iv) opt-out of the "sale" of your personal information, as detailed above.
Do Not Sell My Information. To opt-out of the "sale" of your personal information as described in this section, click here.
Exercising other California consumer rights. Should you wish to request the exercise of your other rights as detailed above with regard to your personal information, to the extent required by applicable law, we shall respond to your request to exercise your rights above upon your request submitted in to one of the options provided below in the "Contact Us" section. We may need to take steps, including to request additional information from you, to verify your identity. Please indicate in your request that you are a California resident making a “California privacy rights” inquiry.
Notice of Right to Opt-Out for California Residents
Your right to opt out of the sale of your personal information
Options for exercising right to opt out of “sales” of personal information
Please note that opting out of sales in the context of cookies will not stop us from presenting all advertisements to you on our online services. We may still present contextual or other advertisements to you that do not rely on “sales” to our advertising partners.
Other “Sales” - To exercise your right to opt out of any other “sales” of your personal information, please use one of the two options below. Please note that we may need to verify your identity before acting on a request.
Email request. Please email email@example.com and include “California Request to Opt-Out” in the subject line of your email.
From time to time, we may offer certain mobile applications, including iOS applications ("Apps"), for download. We will use commercially reasonable efforts, given the limitations imposed upon us by third party providers such as Apple Inc. and Google Inc., to clearly disclose what, if any information is collected by the particular App, how it is used, and with whom it is shared. Please note, certain practices are outside of our control, for example, tracking by Google, Inc., Apple, Inc., or your third party telecommunications carrier. WE are not responsible for the actions of such third parties. You should always read and understand the policies of any third party provider, such as Google with respect to Android apps and Apple with respect to IOS apps, and your wireless carrier, before making any purchase or downloading any app.
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©2020, Ladies of Leisure, LLC.
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