ShareVino Privacy Policy

Effective Date:: 1 July 2024

Welcome to ShareVino! Before you use our Platform and Services, please read this Privacy Policy carefully.

Introduction

This Privacy Policy explains how ShareVino collects, uses, discloses, and otherwise processes personal or other information related to our Platform. It does not cover or address the privacy practices of wineries, restaurants, or other Partners, including their authorized licensees and franchisees, which may or may not be available on our Platform.

By accessing or using the Platform, you agree that you have read, understood, and agree to this Policy, including to our collection, storage, use, and disclosure of your personal or other information as described in this Privacy Policy and our Terms of Use.

The terms and conditions of the Privacy Policy are incorporated into the Terms of Use by reference and are available on our website at https://sharevino.co/terms-of-use. The provisions of the Terms of Use apply to the Privacy Policy in their entirety, and in case of any discrepancy between the terms of the Privacy Policy and the terms of the Terms of Use, it shall be resolved according to the terms of the Terms of Use.

Definitions

• (a) Affiliate means any entity that directly or indirectly controls, is controlled by, or is under common control with the subject entity. “Control,” for purposes of this definition, means direct or indirect ownership or control of more than 50% of the voting interests of the subject entity.
• (b) CCPA means the California Consumer Privacy Act of 2018, Cal. Civ. Code §§ 1798.100 et. Seq and its implementing regulations may be amended from time to time.
• (c) Customer means User, Registered User, or representatives of a Partner, who, one way or another (e.g., through access to the Platform, registration on the Platform, communication with ShareVino, or direct transfer), provides Personal Data to ShareVino.
• (d) The terms Controller, Member State, Processor, Processing, and Supervisory Authority shall have the same meaning as in the GDPR. The terms Business, Business Purpose, Consumer, and Service Provider shall have the same meaning as in the CCPA. For the purpose of clarity, within this Policy, “Controller” shall also mean “Business,” and “Processor” shall also mean “Service Provider,” to the extent that the CCPA applies. In the same manner, the Processor’s Sub-processor shall also refer to the term of the Service Provider.
• (e) Data Protection Laws means all applicable and binding privacy and data protection laws and regulations, including those of the United States of America, the European Union, the European Economic Area and their Member States, Switzerland, the United Kingdom, Canada, Israel, and, including the GDPR, the UK GDPR, and the CCPA, applicable to, and in effect at the time of, the Processing of Personal Data hereunder.
• (f) GDPR means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of personal data and the free movement of such data.
• (g) Personal Data or Personal Information means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to or with an identified or identifiable natural person or Consumer, which is processed by us solely on behalf of Consumer under this Privacy Policy and the Agreement.
• (h) Standard Contractual Clauses means:
  • (i) in respect of transfers of Personal Data subject to the GDPR, the Standard Contractual Clauses between controllers and processors (located here), and between processors and processors (located here) as approved by the European Commission Implementing Decision (EU) 2021/914 of 4 June 2021, including all Annexes I, II and V thereto, (”EU SCCs”).
• (i) Sub-processor means any third party that carries out specific processing activities for personal data under ShareVino's instruction.
• (j) UK GDPR means the Data Protection Act 2018, as well as the GDPR as it forms part of the law of England and Wales, Scotland, and Northern Ireland under section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy, and Electronic Communications (Amendments, etc.) (EU Exit) Regulations 2019 (SI 2019/419).

Personal Information We Collect

1. 1.1 Data provided directly by you

   • Contact and profile information: When you create an Account, complete your Account profile, sign up for a mailing list, access the Platform, or otherwise communicate or interact with us or the Platform, we may collect information from you, such as your name, phone number, e-mail address, IP address, physical address, cookie ID, advertising identifier of your phone, etc. We use this contact and profile information to (i) create and personalize your Account; (ii) communicate with you directly about the Services as well as about any questions, issues, or concerns you or other users may have; (iii) fulfill your order; (iv) send you marketing communications per your preferences; (v) improve the Platform and Services, and (vi) analyze the data and, unless restricted by applicable laws, make available aggregated data to our Partners and Registered Users.
   • Payment information: When you submit an order (e.g., purchase a plan), you may be required to provide payment information such as your credit card, debit card, gift card, promo code, or credit details. For Accounts used for business purposes, we may also have corporate credit card numbers or other payment account numbers. We use this payment information to fulfill your order, complete the transaction, and detect and prevent fraud. Our payments are processed through Stripe, and your personal data will be processed per Stripe’s privacy notice, found here: https://stripe.com/privacy, to which you agree by accessing or making payment.
   • Transaction information: When you submit an order, we collect information, including the items, such as plans purchased, the date and time of your transaction, special instructions, or rewards or promotions you redeem as part of a loyalty or rewards program. We use this transaction information to fulfill your order, update your rewards, detect and prevent fraud, personalize your experience, perform analytics/identify usage trends and inform our advertising and marketing.
   • Communications, Participation, and Other Content: We maintain all communications resulting from your interactions with us or Partners by email, phone, mail, or chat (e.g., WhatsApp, Viber). We also record comments and opinions you express when responding to surveys or participating in promotions we run. We use all of the foregoing communications to address your questions, issues, and concerns and provide other related customer support services for safety and security purposes, to improve our Services, and for analytics.
   • Other information you provide: With your permission, we may access your photos or contact list from your mobile device, Facebook Messenger account, or email account to enable you to share content or promotions or invite your friends to connect with our Services, including through our friend referral program. If you are placing an order online, Partners may also collect the information contained on your government-issued identification card for age verification purposes to complete the service.

   We may also use aggregate personal information for regulatory compliance, industry and market analysis, research, demographic profiling, marketing and advertising, and other business purposes as long as the end product does not uniquely identify you or any other Services user.

2. 1.2 Personal Information Generated and/or Automatically Collected during your Use of the Platform

   • Information about your device and its software:Information about your device and its software includes your IP address, browser type, internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to identify your browser, mobile device, or your Account (including, for example, a persistent device identifier or an Ad ID) and other similar information. We may also work with third-party partners to employ technologies, including statistical modeling tools, to recognize and contact you across multiple devices. We use this device and software information to diagnose and fix technology problems, serve you personalized advertising, personalize your experience, perform analytics/identify usage trends, and improve our products and Services.
   • Information about how you access and use our Services: Information about how you access and use our Services includes the site from which you came and the site to which you are going when you leave. In addition, we track the pages you visit on the Platform, the links you click on the Platform, whether you open emails or click the links contained in emails that we send, other actions you take on the Platform, and whether you access the Platform from multiple devices. We may also use the information about the way you access and use our Services to determine products and services that may be of interest to you, to improve our products and Services, to evaluate the success of our advertising and marketing campaigns, and to send you marketing communications.
   • Analytics information: We may collect analytics data or use third-party analytics tools, such as Google Analytics, Google Looker Studio, or others, to help us measure traffic and usage trends and the demographics of our users to improve our Services. You can learn more about Google's practices at http://www.google.com/policies/privacy/partners.
   • Location Information: In some cases, you provide your location information to us directly (e.g., when you choose your country). In other cases, we may collect your location through GPS, WIFI, wireless network triangulation, or other methods, or we may otherwise infer your location based on other information we collect. (For example, we can approximate your location using your IP address.) We use location information to customize content on our Services (e.g., show you the Partners that will service in your location and show you relevant Promotions), facilitate orders and Services, detect and prevent fraud, and measure traffic and analytics on the Services. If you have previously opted into ShareVino’s collection and use of location-based information through our mobile application, we may collect and store the precise location of your device when the app is running in the foreground or background of your device. You may opt out by adjusting the settings on your mobile device. We also use the Google Maps API to gather information about your location. Google uses various technologies to determine your location, including IP address, GPS, and other sensors that may, for example, provide Google with information on nearby devices, WIFI access points, and cell towers (see the Google privacy policy and the Google Maps terms of service to learn more).

   We typically collect the foregoing generated and/or automatically collected information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, mobile SDKs, location-identifying technologies, and similar technology (collectively “tracking technologies”), and we may use third-party partners or services to assist with this effort. Information we collect automatically about you or your device may be combined with other personal information we collect directly.

   We or Partners or other third-party partners may use the data collected automatically through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Platform; (b) provide custom personalized content and information; (c) identify and contact you across multiple devices; (d) provide and monitor the effectiveness of our Services; (e) perform analytics and detect usage patterns on our Services; (f) diagnose or fix technology problems; (g) detect or prevent fraud or other harmful activities; and (h) otherwise plan for and enhance our Services and for other internal purposes.

   What are Cookies?

   Cookies are small files containing a string of characters stored through the browser on your computer or mobile device (for example, Google Chrome or Safari). They allow websites to store information like user preferences. You can think of Cookies as providing a so-called memory for the website so that it can recognize you when you come back and throughout your browsing activity and use and respond appropriately to your selected preferences. Cookies are typically classified as either “session cookies,” which are automatically deleted when you close your browser, or “persistent cookies,” which will usually remain on your device until you delete them or they expire.

   Cookies may be set by us (first-party Cookies) or by third-party providers who work with us (third-party Cookies), either for the duration of your visit (session Cookies) or for longer periods (persistent Cookies). The length of time a persistent Cookie stays on your device varies between Cookies. Please note that our access and control over such third-party Cookies, beyond the scope of our Services, is limited and subject to such other websites, services and providers’ own terms and policies.

   You are not obligated to accept all Cookies in order to visit the Platform, however, enabling Cookies may allow for a more personalized browsing experience and is required for some features and functionalities to work.

3. 1.3 Data from other sources

   • Information we receive from third-party sites you connect to our Services: We may receive personal information about you from third parties and combine that with information we collect through our Platform. For example, we may obtain information when you log in through a third-party social network or authentication service, such as Facebook or Google. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, address book, contacts, or other information. Similarly, when you interact with us through a social media site or third-party service, such as when you like, follow, or share ShareVino content on Facebook, Twitter, or other sites, we may receive information you permit the social network to share with third parties. The data we receive from these third-party sites is dependent upon that third party’s policies and your privacy settings on that third-party site.
   • Information we receive from affiliates or third parties: From time to time, we may receive information about you from our Partners in connection with our enterprise programs, from other ShareVino entities and affiliates, from co-marketing partners, service providers, and from other third parties. For example, if your company or organization participates in one of our enterprise programs, we may receive your information from that participating organization to set up your Accounts or for billing purposes. We may receive additional information about you, such as fraud detection information from third-party partners, and combine it with other information about you. We use this information from affiliates or third parties to create your Accounts, to contact you, to send you advertising or promotional materials, or to personalize our Services, to protect against bot attacks and account takeovers, and to better understand the demographics of our users.

We do not control, supervise, or respond to how the third parties providing your information process your personal information, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

How We Use Your Personal Information

1. 2.1. Provide, maintain, improve, and develop the Platform and Services

   We may use the personal information to provide, maintain, improve, and develop the Platform and Services. For example, we:

   1. Enable you to create Accounts or otherwise access and use the Platform and Services (e.g., remember information so that you will not have to re-enter it during your visit or the next time you visit),
   2. Fulfill your requests and process payments (e.g., to allow you to order wine from Restaurants, or to provide you with information that you request),
   3. Provide custom, personalized content and information (e.g. “most popular near you” and “since you enjoy” or “we think you may like this” features),
   4. Perform analytics, detect activity patterns on our Platform and Services, and otherwise research usage, and share this data with our Partners and Users, and
   5. Test and develop new features and functionality and otherwise enhance the Platform and Services.

   2.2. Maintain the safety, stability and security of our Platform and Services.

   We may use the personal information to maintain the safety and security of our Platform and Services. For example, we:

   1. Detect or prevent fraud, abuse or other harmful activities,
   2. Diagnose or fix technology problems,
   3. Conduct security investigations and risk assessments, and
   4. Improve and enforce our security measures.

   2.3. Communications with you to provide support and other important messages.

   We may use personal information to communicate important messages to you and/or to provide you with support. For example, we might send you service-related emails or messages (e.g., user Account verification, changes or updates to features of the Platform or Services, technical and security notices) and other communications from or about ShareVino.

   2.4. Provide, personalize, measure and improve our advertising and marketing.

   We may use personal information to provide, personalize, measure and improve our advertising and marketing. For example, we:

   1. Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by ShareVino or its third-party partners,
   2. Inform you of products, programs, services, and promotions that we believe may be of interest to you, including, without limitation, through emails and push notifications,
   3. Permit you to refer us to your friends so we may send them a promotional offer through the Platform. If you wish to use this feature, you may be required to provide us with, and we may use, your friend’s name, email address, and other information you share with us. By using this functionality, you affirm that you are entitled to use and provide us with your friend’s name and email address for this purpose. We will use that information to send an email inviting the friend to visit the Platform and for any other purposes disclosed at the time of your participation in the program,
   4. Determine the effectiveness of our Platform and our promotional campaigns and
   5. Identify and contact you across multiple devices.

   2.5. Legal and regulatory requirements and proceedings.

   We may use the personal information in connection with legal and regulatory proceedings and requirements. For example, we may need personal information to enforce our corporate reporting obligations, or to comply with applicable laws.

   2.6. Enforce our rights.

   When you access or use our Platform or Services, you are bound by our Terms of Use and this Privacy Policy. To ensure you comply with them, we may use your personal information to monitor, investigate, prevent and/or mitigate violations of our Terms of Use as well as enforce our agreements with third parties and business partners.

   2.7. Other purposes disclosed at the time of collection.

   From time to time, we may use personal information for a specific purpose not contemplated by this Privacy Policy. In such an event, we will specifically disclose that use to you.

   2.8. Partners and Customers, subject to reasonable requirements and written agreements as required by ShareVino and consistent with the CCPA, and at Partner’s or Customers’ sole cost and expense, may audit, review, or if required by the CPPA, assess ShareVino not more than once every 12 months.

   Nothing under this Policy shall require ShareVino to disclose: (a) any data or information of any other customer of ShareVino or any third party; (b) any internal accounting or financial information; (c) any trade secret of ShareVino; or (d) any information that, in ShareVino’s reasonable opinion could: (i) compromise the security of ShareVino’s networks, systems, or premises; (ii) cause ShareVino to breach its security or privacy obligations to any third party; or (iii) any information sought for any reason other than the reasons outlined in this Policy. ShareVino may require an agreement to reasonable ShareVino (or its third-party auditor or assessor’s) terms and conditions prior to providing the ShareVino Audit Report to any applicable Customer or Partner.

   2.9. Deletion of Data.

   ShareVino will (a) as required by Applicable State Data Protection Laws applicable to Customer and at Customer’s direction, delete or return all Personal Data to the Customer at the end of the provision of Services or (b) as required by the CCPA, not retain, use, or disclose Personal Information upon termination or expiration of the relationship between the Customer and ShareVino. Nothing in this Section will require ShareVino to (i) delete or return data that it must retain pursuant to applicable Laws or (ii) return instead of destroying Personal Data to the extent that return is not technically feasible or return would impose substantial burdens, costs, or both upon ShareVino.

   2.10. Processing of Personal Data: Roles, Scope, and Responsibility under the CCPA.

   You acknowledge and agree that the Customer is the Controller of their Personal Data, and ShareVino is the Processor of That Data.

   Only to the extent necessary and proportionate, Customer as Controller instructs ShareVino to perform the following activities as Processor on behalf of Customer (collectively, the “Instructions”):

   1. Provide and update the Services as licensed, configured, and used by Customer and its users, including through Customer’s use of ShareVino settings, administrator controls or other Service functionality;
   2. Secure and real-time monitor the Services;
   3. Resolve issues, bugs, and errors;
   4. Provide Customer requested support, including applying knowledge gained from individual Customer support requests to benefit all ShareVino Customers but only to the extent such knowledge is anonymized; and
   5. Process Customer Personal Data, as well as any other documented instruction provided by Customer and acknowledged by ShareVino as constituting instructions.

   To the extent that ShareVino acts as a Processor of Customer Personal Data, ShareVino shall Process Customer Personal Data only per Customer’s Instructions. Customer shall ensure that its Instructions to ShareVino comply with all Laws, rules, and regulations applicable to the Customer's Personal Data and that the Processing of Customer’s Personal Data per Customer’s Instructions will not cause ShareVino to be in breach of Applicable State Data Protection Laws. Customer is solely responsible for the accuracy, quality, and legality of (i) the Customer Personal Data provided to ShareVino by or on behalf of Customer; (ii) how Customer acquired any such Customer Personal Data; and (iii) the Instructions it provides to ShareVino regarding the Processing of such Customer Personal Data. Customer shall not provide or make available to ShareVino any Customer Personal Data in violation of the Agreement or this Addendum.

   Customer authorizes ShareVino to conduct scanning and reporting of Personal Data in limited circumstances (e.g., to detect and report Child Sexual Abuse Material; to comply with other applicable Laws; to ensure compliance with ShareVino’s Acceptable Use Guidelines).

   2.11. Use of Cookies.

   Our use of analytics Cookies aims to monitor, study and analyze the use of our Services, and how we can improve individuals’ user experience and continue to improve our offerings and the overall performance of our Services.

   Our use of advertising Cookies aims to facilitate and optimize our marketing campaigns, ad management and sales operations, and manage and deliver advertisements for our products and services more effectively, including on other websites and applications.

   We may combine non-personally identifiable information collected through Cookies with other Personal Data that we have about you to improve your user experience, for example, to tell us who you are or whether you already have an account with us.

   We may also supplement the information we collect from you with information received from third parties in order to enhance our Services, or to offer you information that we believe may be of interest to you.

   Where we use Cookies to collect information that is personally identifiable or that can become personally identifiable if we combine it with other information, our Privacy Policy will apply in addition to this Cookie Policy.

   2.12. Cross-Border Data Transfers

   Transfers from the EEA, Switzerland, and the United Kingdom to countries that offer an adequate level of data protection. Personal Data may be transferred from EU Member States and Norway, Iceland and Liechtenstein (collectively, “EEA”), Switzerland and the United Kingdom (“UK”) to countries that offer an adequate level of data protection under or pursuant to the adequacy decisions published by the relevant authorities of the EEA, Switzerland, and/or the UK as relevant (for example to the United States), including similarly approved mechanisms and frameworks (“Adequacy Decisions”), as applicable, without any further safeguard being necessary. For the avoidance of doubt, “Adequacy Decisions” include the European Commission’s adequacy decision of 10 July 2023, establishing the EU-US Data Privacy Framework.

   Direct Transfers from the EEA, Switzerland, and the United Kingdom to other countries. If the Processing of Personal Data by the Processor includes a direct transfer from Customer to ShareVino:

   1. from the EEA to other countries that have not been subject to a relevant Adequacy Decision, and such transfers are not performed through an alternative compliance mechanism recognized by Data Protection Laws (as may be adopted by Processor in its own discretion) (“EEA Transfer”), the terms set forth in the EU SCCs shall apply;
   2. from the UK to other countries which have not been subject to a relevant Adequacy Decision, and such transfers are not performed through an alternative compliance mechanism recognized by Data Protection Laws (as may be adopted by Processor in its own discretion) (“UK Transfer”);
   3. from Switzerland to other countries that have not been subject to a relevant Adequacy Decision, and such transfers are not performed through an alternative compliance mechanism recognized by Data Protection Laws (as may be adopted by Processor in its discretion) (“Switzerland Transfer”);
   4. the terms set forth in Annex V of the EU SCCs (Additional Safeguards) shall apply to any EEA Transfer, UK Transfer and Switzerland Transfer, where the Standard Contractual Clauses apply.

   Onward Transfers from the EEA, Switzerland and the United Kingdom to other countries. Where Processor onward transfers Personal Data from countries in the EEA, UK and Switzerland to authorized Sub-processors, including Processor Affiliates, in countries which are not subject to an Adequacy Decision (respectively, the Standard Contractual Clauses (Module 3) set out in the Annex of Commission Implementing Decision (EU) 2021/914 of 4 June 2021, and any applicable annexes thereto (“SCCs”)), the IDTA and/or the SCCs, as adjusted pursuant to the Swiss Federal Data Protection and Information Commissioner’s guidance of 27 August 2021 as between Processor and its respective Sub-processors and Subsidiaries, shall apply.

   Transfers from other countries: If the Processing of Personal Data by Processor includes a transfer of Personal Data by and/or mandated by the Customer to Processor from any other jurisdiction which mandates a particular compliance mechanism for the lawful transfer of such data be established, Customer shall notify Processor of such applicable requirements, and the Parties may seek to make any necessary amendments to this Policy.

2. Our Sharing and Disclosure of Personal Information

   We disclose personal information to the following types of third parties:

   3.1 Data Analytics for Partners

   We disclose personal information to the Partners you visit, and third parties engaged by those Partners (e.g., point of sale providers or their own delivery personnel) as needed to fulfill your orders, including communicating with you about the status of your order. If you make a purchase from a Partner that offers loyalty or rewards programs through our Platform, we may disclose your personal information to the Partner as needed to facilitate your participation in the Partner’s loyalty or rewards programs, including tracking points and redemptions. In some cases, you may also affirmatively opt in to share your information directly with the Partner as will be disclosed on the Platform.

   3.2 Other Third Parties necessary to complete your order or to enable your use of the Platform and Services

   In addition to Partners, we disclose personal information to other third parties as needed to provide a better experience on the Platform or Services or additional services, including, without limitation, delivery providers and payment processors, if any.

   3.3 Information provided to third parties in connection with our enterprise customers

   If your company or organization participates in one of our enterprise programs, we may share some of your information with that organization, including your name, ID number, contact details, order history, and other information as required to enable use by you and the organization of such Services.

   3.4 Service providers and contractors

   We disclose personal information to third parties that provide services for us or on our behalf, such as website hosting, data analysis, infrastructure provisioning, IT services, customer service, email delivery services, fraud detection, security monitoring, advertising, and marketing, and other similar services.

   3.5 Analytics providers

   We share personal information with third-party analytics providers to better understand the demographics of our users and visitors and to personalize, enhance, and improve our Platform and Services.

   3.6 Advertising, Marketing, and Promotions Providers

   We share personal information with third parties in connection with co-marketing activities, the development of customized and targeted marketing campaigns, to launch promotions, and for other similar advertising efforts. For example:

   • Promotional partners: We disclose personal information to third-party sponsors of promotions to provide contests, sweepstakes, joint promotional activities, or co-branded services, and such disclosure is necessary to fulfill your request or application. You should carefully review the rules and/or terms of each promotion in which you participate, as the promotion may contain additional important information about our, a sponsor's, and/or other third parties' use of your personal information. To the extent that the rules or terms of those promotions concerning the treatment of your personal information conflict with this Privacy Policy, the rules of those promotions will control.

   • Ad networks and advertising partners: We work with third-party Ad Networks and Advertising Partners to deliver advertising and personalized content to you on our Platform and Services, on other sites and services you may use, and across other devices you may use. These parties may collect information directly from your browser or device when you visit the Platform through cookies or other tracking technologies. This collected information is used to provide and inform targeted advertising, as well as to provide advertising-related services, such as reporting, attribution, analytics, and market research.

   • Social networks: We disclose personal information, such as a unique identifier, hashed email address, or information automatically collected through tracking technologies, to social networks to display personalized advertising and content on those social networks.

   • Select restaurants and brands: We disclose personal information to select Partners and brands from which you have placed orders through the Platform, as well as their affiliates and third-party service providers. These Partners, brands, and their affiliates may use your information as permitted by their own privacy policies, which could include sending you marketing communications and other promotional content.

   3.7 Affiliate Sharing

   We share your personal information with other companies owned or controlled by ShareVino and other companies owned by or under common ownership as ShareVino, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns, for operational or business purposes or as otherwise described in this Privacy Policy.

   3.8 Public

   We make available through the Services certain features which may enable you to post information and materials, for example, ratings and reviews, photo uploads, and chat functionality. Please note that any information you provide in connection with such Services may be available to site visitors and to the general public. Please do not disclose your personal information in these public or interactive areas on the Services, and we urge you to exercise discretion and caution when deciding to disclose any other information and/or materials in these public or interactive areas on the Services.

   3.9 Business Transaction or Reorganization

   We may participate in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of all or a portion of company assets. We may disclose personal information to a third party during the negotiation of, in connection with, or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.

   3.10 Legal Obligations and Rights

   We disclose personal information to third parties, such as legal advisors and law enforcement, as required by law or subpoena, or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our Terms of Use or to protect the security or integrity of our Services; (c) detect, suppress, or prevent fraud or reduce credit risk and collect debts owed to us; and/or (d) exercise or protect the rights, property, or personal safety of ShareVino, our visitors, or others.

   3.11 Consent

   We may disclose personal information about you to other third parties with your consent.

Control Over Your Personal Information

Profile Settings

You may update your profile information in the Services account section.

Access to your Device Information and Push Notifications

You may control access to your device information or opt out of push notifications through your “Settings” app on your device. For instance, you can withdraw permission for the app to access your location data through your device settings, though we may continue to approximate your location based on your IP address or other means.

How to control your communications preferences

You can stop receiving promotional email communications by clicking on the “unsubscribe link” provided in such communications. You may not opt out of service-related communications (e.g., Account verification, transactional communications, changes/updates to features of the services, technical and security notices). You may also unsubscribe from receiving certain order-related text (SMS) or multimedia (MMS) messages by replying "STOP" to the number sending the message. Please see our Terms of Use for more information on communications from or on behalf of ShareVino.

You have the right to:

• Access personal data regarding you. You can always access your account to review the personal data we have collected about you. You may delete and amend the data collected. You also have the right to obtain a copy of the personal data free of charge. However, we may charge a fee corresponding to administrative costs if further copies of the information are requested or if the request is unfounded or excessive.

• Ask for rectification of incorrect or inaccurate data concerning you or to have incomplete personal data completed. You can use your access to your account to update your personal data.

• Ask for erasure of personal data regarding you (under certain circumstances).

• Ask for restrictions on the processing of your data (under certain circumstances).

• Object to the processing of your data for marketing purposes by withdrawing your personal consent.

• Object to processing based on our legitimate interest for reasons relating to your situation. Please note that we may continue to process your Personal Data, even if you have opposed the processing if we have compelling legitimate grounds for the processing which override your privacy interests. We will communicate any such decision to you promptly and explain our reasons.

• Lodge a complaint with your local Data Protection Authority or regulator if you have concerns about our data practices.

You can at any time withdraw your consent by deleting your profile or deleting your account in the in-app settings. When we receive a request to access, rectify, erase, or port data, we may ask you for additional information in order to confirm your identity and ensure data security. You can send a request at info@sharevino.co.

3. How We Store and Protect Your Information

   Data storage and transfer

   Your information collected through our Service is stored and processed using our Platform and Services such as AWS, Google, etc. If you create an Account on the Platform as a visitor from outside the United States by using and/or accessing the Platform or Services, you agree to this Privacy Policy and consent to the collection, transfer, storage, and processing of your information to and in the United States. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.

   Keeping your information safe

   We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Service. However, no security system is impenetrable, and we cannot guarantee the security of our systems. Please recognize that protecting your personal information is also your responsibility. Accordingly, we strongly recommend that you change your passwords often, use a combination of letters and numbers, make sure you use a secure browser, and otherwise take precautions when communicating your personal information on the internet. If you know or have reason to believe that your Account credentials have been lost, stolen, misappropriated, or otherwise compromised, or in case of any actual or suspected unauthorized use of your Account, please contact us following the instructions in the Contact Us section below.

   We store your personal data for as long as your account is active, but we may also keep your personal data to show in an anonymous and aggregated way after deactivation of your Account. We may also store some of your personal data to comply with our legal obligations. You may add or update certain information to your account. When you update information, however, we often maintain a copy of the unrevised information in systems back-ups for a period of time until our backup is updated with the latest version.

   You may request a deactivation of your account by following the instructions on the Platform. If you deactivate your account, we may not delete your information but hold it for you until such time as you either activate your account again or delete it. When you delete your account, we delete the data attached to your account, including your username. The username will be deleted from all reviews, and the activities, reviews, and information will be anonymized for future. Please note that some information may remain in our records after your account has been deleted and that we may only be able to delete this information later when updating our backups.

4. Children’s Personal Information

   Our websites and online Services are not directed to, and we do not intend to knowingly collect or solicit personal information from anyone under the legal age to use alcohol (typically 18 and 21 in the United States). The Platform is intended for use by adults of legal drinking age in the jurisdiction in which you reside. If we receive notice or reasonably believe that someone under the legal drinking age has provided us with personal information, we will promptly delete the account and all personal information provided to us. If you have a basis for believing that we have any information from a child under 18 or 21 respectively, please contact us at info@sharevino.co

5. Third-Party Websites

   Our websites and Services may include links to third-party websites, plug-ins, and applications. Except where we post a link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

Region Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions, or states. Please refer below for disclosures that may be applicable to you:

California

If you are a resident of the State of California, additional California-specific privacy disclosures may apply to you. Under California law, California residents who have an established business relationship with ShareVino may choose to opt out of ShareVino’s disclosure of personal information about them to third parties for direct marketing purposes. If you choose to opt out at any time after granting approval, please email info@sharevino.co.

Under the California Consumer Privacy Act (CCPA), California Residents have the right to request the following information by emailing info@sharevino.co, and ShareVino will provide such information to you upon verification of your request:

• The categories of personal information ShareVino collects about you
• The categories of sources from which your personal information is collected
• The business purpose for collecting your personal information
• The categories of third parties with whom ShareVino shares your personal information
• The specific pieces of personal information ShareVino has collected about you

Privacy Notice Section

• Categories of personal data: The categories of personal information ShareVino collects about you.
• The categories of sources from which your personal information is collected.
• Use of Information: The business purpose for collecting your personal information.
• Sharing of Data: The categories of third parties with whom ShareVino shares your personal information.

If you elect to exercise any of your rights under CCPA, ShareVino will not deny services, provide a different price or rate for our services, or provide a different level of service to you because you exercised such rights. Under the current definition of CCPA, ShareVino does not sell your personal information.

Nevada

If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect. To submit such a request, please contact us at info@sharevino.co with the subject line “Nevada opt-out.”

6. Updates to This Privacy Policy

   We will update this Privacy Policy from time to time. When we make changes to this Privacy Policy, we will change the "Effective" date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify you by email to your registered email address, by prominent posting on this website or our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Platform and/or Services will be subject to the revised Privacy Policy, and you will be understood to have consented to such changes.

Advertisement Policy

When you visit our Platform and use our Services, read our emails, or otherwise engage with us through a computer or mobile device, we automatically collect information about how you access and use the applicable Service and information about the device you use. For example, we may collect log data about your device and its software, such as your IP address, location data, operating system, unique device identifier such as an AdID, browser type, date/time of your visit, and other similar information. We typically collect this information about how you access and use the Service through various tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location-identifying technologies, mobile SDKs, and other similar technologies. This information allows us to authenticate users, enhance and personalize your user experience on our Platform, monitor, analyze, and improve our Platform and Services, serve you interest-based and other tailored advertising on our Platform and in our emails, track referrals to our Platform, deliver and measure the effectiveness of our advertising campaigns and/or our third-party partnerships, observe your behaviors and browsing activities on our Platform over time, better understand the interests of our customers and Platform visitors, and for any other purposes identified in our Privacy Policy.

Controlling Cookies, Tracking Technologies, and Flash Cookies

If you would prefer not to accept cookies, visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available. Most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing (i) - (iii) in the foregoing may negatively impact your experience using our online Services as some features and services on our online Services may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies, you may not be able to block non-cookie technologies, or the changes to your settings may have no effect.

Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about Flash objects—including managing privacy and storage settings for Flash cookies—on Adobe’s website or by clicking here. If you delete Flash objects from our Platform, you may not be able to access and use all or part of the Platform or benefit from the information and Services offered. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and whether you have performed certain functions with the email.

Third Parties and Interest-Based Advertising

We allow certain third-party partners (e.g., third-party online advertising networks and other third-party services) to place tracking technologies on our Platform, and we participate in interest-based advertising. Accordingly, we may share and/or permit third parties to collect information about your use of our Services over time so that they may play or display ads on our Platform, in our emails, or on other devices you may use and on other websites, apps, or services and advertising channels; monitor, analyze, and improve our Platform and Services; observe your behaviors and browsing activities over time on our Platform and other sites, as well as observe your interactions with ads; and otherwise better understand the interests of our customers and Platform visitors.

These third-party partners may collect information such as clickstream information, browser type, time and date you visited the Service, mobile device identifiers, your use of third-party applications, and/or precise geolocation data, and other information. We or our third-party partners may link your various devices so that content you see on one device can result in relevant advertising on another device. For example, we may share a common account identifier (such as a hashed email address or user ID) or work with third-party partners who use tracking technologies or statistical modeling tools to determine if two or more devices are linked to a single user or household. Our partners may use this information and may combine this information with information they collect directly or receive from other partners, both online and offline, so that they may recognize you across different channels and platforms, including computers, mobile devices, and smart TVs. This information is used 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.

Your Choices to Control Interest-Based Advertising

To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s (NAI) online resources at http://www.networkadvertising.org/choices and/or the Digital Advertising Alliance’s (DAA) resources at www.aboutads.info/choices. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use. You may also be able to limit interest-based advertising through the settings on your mobile device through the “tracking” settings (iOS) or by selecting “opt-out of interest-based ads” (Android). Additionally, you may be able to opt-out of some—but not all—interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

For desktop, some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again. Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online Services. It means that the online ads that you do see from DAA program participants may not be based on your interests. We are not responsible for the effectiveness of or compliance with any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online Services, including for analytics and fraud prevention and other non-advertising purposes.

Do Not Track

Although we do our best to honor the privacy preferences of our customers and Platform visitors, we may not be able to respond to “Do Not Track” signals from your browser at this time. If you do not agree with this, please let us know and in the meantime, you may stop using the Platform. Some web browsers may transmit “Do Not Track” signals to websites with which the browser communicates, telling the website not to follow its online movements. Because of differences in how web browsers interpret this feature and send those signals and lack of standardization, it is not always clear whether visitors and users intend for these signals to be transmitted or whether they are even aware of them. Therefore, as with many other reputable websites and online platforms, although we attempt to honor the privacy preferences of our customers and Platform visitors, we may not be able to respond to “Do Not Track” signals from your browser at this time. If you disagree with this, please let us know, and in the meantime, you may stop using the Platform. However, you can manage your Cookie preferences through your browser settings, including whether or not to accept them and how to remove them. Please remember that disabling Cookies may complicate or prevent you from using the Services.

Third-Party Partners

In addition to the above, the following is a sample of the third-party partners we work with (i) to provide interest-based advertising or who otherwise use tracking technologies on our Platform and Services and (ii) who offer you choices about the collection and/or use of your information.

Social Media

We display targeted advertising to you through social media platforms such as Facebook, Twitter, Instagram, and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Services while those users are on the social media platform or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of the social media companies that provide them.

If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks. You can learn more about advertising preferences by clicking on the links provided below. Please note that these links are provided for your convenience only; we do not control the content or features that may be available on these third-party services.

• Facebook: To learn more about your advertising preferences on Facebook Companies, click here..
• Twitter: To learn more about privacy controls for personalized ads on Twitter, click here..
• LinkedIn: To learn more about advertising preferences on LinkedIn, click here..

Google Analytics and Advertising

We use Google Analytics to recognize you and link the devices you use when you visit our Service on your browser or mobile device, login to your Account, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service.

The information generated by the Cookie is usually sent to and stored in a Google server in the USA. On behalf of ShareVino, Google will use the generated information to evaluate your use of the website, to compile reports on website activities, and to provide the website operator with additional services connected with the website and Internet use. The IP address transmitted by your browser in connection with Google Analytics is not collated with other data by Google.

For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses information from sites or apps that use our services”. You can learn about Google Analytics currently available opt-outs, including the Google Analytics Browser Ad-On, here. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.

Contact Us

If you have any questions or requests about this Privacy Policy or other privacy-related matters, please email info@sharevino.co. Email communications will not necessarily be secure; accordingly, please do not include credit card information and/or other sensitive personal information in your email correspondence with us. We never ask for such information over email.