For purposes of this Policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include de-identified or aggregated information, or public information lawfully available from governmental records or other public sources.
Personal Information We May Collect
We collect your personal information when you visit our Sites, create an account to use our services, request information about our services, or when you otherwise voluntarily provide information to us through the Sites.
The personal information we collect includes your name, email address, home or physical address, phone number, account number and password. We may also collect information about your cellar size and records of wine bottles added and removed from your cellar.
We may also collect personal information from you automatically, when you visit our Sites. This information may include your IP address, your device and browser type, and information about your interaction with our Sites.
How We May Use Your Personal Information
We have set out below, a description of the ways we use your personal information (referred to as “processing purposes” below), and, for individuals located in the EEA or the UK, we explain which of the legal bases we rely on to do so. If you choose not to provide us with your personal information, we may not be able to fulfil these processing purposes.
|Categories of Personal Information||Processing Purposes||Legal Basis (where you are located in the EEA or the UK)|
|Personal information; Internet or other electronic activity information||To provide our services to you: (i) assist you in managing your wine cellar and wine inventory; (ii) provide access, functionalities, and features of our services and Sites; (iii) communicate with you about your account, our Sites, and Policy changes; and (iv) carry out our obligations arising from any contracts entered into between you and us.||To manage and perform our contract with you.|
|Personal information; Internet or other electronic activity information||Information and monitoring purposes: (i) provide news, advertisements and/or other marketing promotions and offers about products or services we think may be of interest to you, including recommendations and suggestions related to food pairings with wines you may be interested in, suggestions for wines to explore, and offers to purchase wines or other products; (ii) notify you about changes to our services and Sites; (iii) to monitor and improve our Sites via tracking technologies; and (iv) for internal business analysis.||To pursue our legitimate interests to operate and improve our business, and to properly manage and administer our relationship with you.With your consent where required for direct marketing.|
|Personal information; Internet or other electronic activity information||Security: To ensure network and information security, including monitoring authorized access to our Sites for the purpose of preventing cyber-attacks, unauthorized use of our Sites, prevention or detection of crime, fraud, or other activities that violate our Terms and Conditions or that are illegal, and protection of your personal information.||To pursue our legitimate interests to ensure our Sites are safe and secure and to ensure they are used in accordance with our Terms and Conditions.|
|Personal information; Internet or other electronic activity information||Transactions: To enable any due diligence and other appraisals or evaluations for any actual or proposed merger, acquisition, financing transaction or joint venture contemplated by CellarEye.||To pursue our legitimate interests to administer the management of our business.|
|Personal information; Internet or other electronic activity information||Legal Claims: To defend and enforce our rights including, against legal claims that involve us, and to manage regulatory matters, investigations, data breaches, and/or data subject requests. To protect our rights and the rights and safety of our customers or others.||To comply with our legal obligations.
To pursue our legitimate interests to enforce or defend our rights and interests.
How We May Share Your Personal Information
We may share your personal information with service providers that help us operate our business, including through payment processing, managing customer information and providing customer service, facilitating services, facilitating email communications, providing security services and cloud-based data storage, hosting our Sites and assistance with other IT-related functions, advertising and marketing, providing analytics information, legal and accounting services, among other business functions.
We may also share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your personal information with third parties to help detect and protect against fraud or data security vulnerabilities. We may transfer your personal information to a third party in the event of an actual or proposed sale, merger, reorganization of our entity or other restructuring.
Cookies and Analytics
Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit www.allaboutcookies.org.
Types of Cookies Used
|cookieyes-consent||cellareye.com||1 year||This cookie is set for CookieYes to remember users' consent preferences so that their preferences are respected on subsequent visits to this site. It does not collect or store any personal information about the site visitors.|
|1 year 11 months||Cookie for Google Analytics. It is used to distinguish individual users by means of designation of a randomly generated number as client identifier, which allows calculation of visits and sessions.|
|1 year 11 months||Cookie for Google Analytics. It records a particular ID used to generate reports from data about website usage by the user.|
Do Not Track
We do not respond to Do Not Track (DNT) header signals at this time.
In accordance with applicable law, you may have certain privacy rights depending upon the jurisdiction in which you reside. However, please note that the below rights are not absolute and may be subject to limitations.
California Privacy Rights – California Shine the Light
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents that have an established business relationship with a business to annually request, free of charge, information about certain categories of personal information a business has disclosed to third parties for those parties’ direct marketing purposes in the preceding calendar year. We did not begin operating until September 2021. Separately, we do not disclose personal information to third parties for their direct marketing purposes.
EEA/UK Privacy Rights
If you are located in the EEA or the UK you have the following data privacy rights which may be subject to limitations / restrictions:
- The right to request access to your personal information;
- The right to request that your personal information be corrected or deleted;
- The right to request that we restrict our processing of your personal information;
- The right to object to the processing of your personal information where it is carried out (i) for our legitimate interests unless we can demonstrate compelling legitimate grounds for the processing, and/or (ii) for direct marketing purposes;
- The right to object to the processing of your personal information where that processing is carried out by legitimate interest (including, for direct marketing purposes) or withdraw consent to the processing of your personal information; and
- The right to request that personal information be provided to you or a third party in a machine-readable format.
Please contact us at email@example.com in case you wish to exercise any of these above rights.
Finally, you also have the right to file a complaint with the competent data protection authority if you believe we did not properly handle your personal information or did not respect your rights.
Personal Information of Minors
Our products and services are not directed to minors under the age of 13 and we do not knowingly collect the personal information of minors under 13.
How We Keep Your Personal Information Secure
We implement and maintain reasonable security measures appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. Those measures include administrative, physical and technical safeguards to protect the security, confidentiality and integrity of personal information. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.
International Data Transfers
Your personal information can be transferred to countries outside the EEA or the UK, including in countries that may not offer the same level of protection as in the EEA or the UK. We have put in place appropriate safeguards so that your personal information are and remain protected. These include implementing the Standard Contractual Clauses which may require the recipient to put in place supplementary measures to ensure an essentially equivalent level of protection is provided, as in the EEA or the UK. We will ensure that your rights and an adequate level of protection essentially equivalent to that ensured within the EEA or the UK are guaranteed. You may obtain further information and a copy of the relevant data transfer mechanisms that we have in place by contacting us at firstname.lastname@example.org.
Other Websites and Social Media Buttons
We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period, the amount, nature and sensitivity of the personal information are considered, together with the necessity and purposes for the processing (including, whether such purposes can be achieved through other means) and the potential risk of harm from unauthorized use or disclosure of the personal information. In exceptional cases (e.g., in pending litigation matters or where the law requires us to), your personal information may need to be kept for longer periods of time.
EEA/UK Data Protection Representative
If you are located in the EEA or the UK, you can contact our data protection representative Thomas Babin on matters related to the processing of personal information via the contact information below, or at email@example.com.
Changes to This Policy
If there are any questions regarding this Policy or to request a copy of this Policy in another format you may contact us using the information below.