Last Modified June 2021
At Aquilini Beverage Group (“ABG” or "we"), we are committed to protecting your privacy.
This policy describes the types of information we may collect from you or that you may provide when you visit the website aquilinibeveragegroup.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
- Participate in a sales or marketing promotion;
- In email, text, and other electronic messages between you and this Website;
- Subscribe to any of our mailing lists, newsletters, or wine-club programs; or
- Request a tasting, or sign up for any of our events.
We refer to these products and services collectively as the “Services.”
“Personal Data” means data that reasonably can be used to identify a living person, or that reasonably relates to a living person.
NOT DIRECTED TO INDIVIDUALS UNDER THE LEGAL DRINKING AGE
Our Website is not intended for anyone under 21 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at email@example.com.
INFORMATION WE COLLECT
Information You Provide Us
When you use our Services, you may provide us with information about you, including identifiers, such as your name, address, email address, phone number, date of birth, and commercial information such as credit card information and your purchasing or consuming histories. We use this information to process your requests and to communicate with you about your orders. Additionally, we may also use your name and contact information to notify you of changes to our Website, new wines and releases, special offers, and events we think you will find valuable or of interest. If you do not wish to receive this information via email, you may opt out by clicking the “Unsubscribe” link at the bottom of the email. Alternatively, you may send an email to firstname.lastname@example.org from the email address you would like removed and include the word “Unsubscribe” in the subject line.
Further information collected on or through our Website may include:
- Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, or posting material (if available). We may also ask you for information when you report a problem with our Website.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
- Your search queries on the Website.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
This information is collected directly from you when you provide it to us, automatically as you navigate through the site (information collected automatically may include usage details, IP addresses, and information collected through cookies), and from third parties, for example, our business partners.
Information We Collect Through Automated Means
When you use our Services, we collect certain internet or other electronic network activity information automatically as described in this section. As discussed further below, we and our service providers (which are third party companies that work on our behalf and include FullStory), may use a variety of technologies, including cookies and similar tools, to assist in collecting this information. We collect information on your use of the Services, such as pages visited, links clicked, non-sensitive text entered, and mouse movements, as well as information such as the referring URL, browser, operating system, and Internet Protocol (“IP”) address. We use publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address. We use the term “Usage Data” to refer to this information about your use of the Site that we collect. Our purpose in collecting Usage Data is to better understand how our visitors use the Site. We collect automatically information that may constitute Personal Data, such as IP addresses.
The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you or your company when you return to our Website.
Information We Collect From Our Partners
We perform ongoing demographic data gathering and analysis to complete data profiles and better understand our customers. Our purpose in collecting demographic data and completing customer profiles is to better understand our customers and provide the best experiences, services and products in our offerings. We collect information that may constitute Personal Data, such as names, email addresses, phone numbers and addresses.
We collect this Personal Data to fulfill contracts, comply with laws and for our legitimate business interests. Our purposes for collecting and using this information include:
- Performing a contract with you or to take steps at your request before entering into a contract.
- Complying with legal or regulatory obligations or in response to law enforcement requests.
- Other legitimate interests and business purposes, such as:
- For our everyday business purposes — such as to process your transactions, maintain or service your account(s), communicate with you.
- Schedule tastings, offer you discounts through our wine clubs, manage records, respond to court orders and legal investigations, and administer and provide services to you.
- For our marketing purposes — to offer our services to you, to improve and customize our services for you and to understand how our services are used to operate, maintain and improve the Website, for example by conducting analytics.
In some cases, we rely on your consent for processing your Personal Data, but only in those cases where we specifically ask for your consent.
DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
In addition to informing you about our own products and services, from time to time, we may also share your information with select marketing partners who offer products or services that we believe will be of interest to you. Although we do not disclose your Personal Information for money, we may share Personal Data with our marketing partners, who may provide referrals or other benefits to us, and to our data hygiene service provider(s) who update and augment customer data profiles. Our marketing partners may use this information to contact you directly regarding their own offers of interest. The Personal Data we may disclose include: name, mailing and email addresses, phone number and demographic data. Such disclosures could be considered “sales” under certain laws, including the Washington Consumer Privacy Act (“WCPA”). You may choose to opt-out of having your Personal Data shared with these third-party companies by sending an e-mail to email@example.com with the phrase “Do Not Share” in the subject line. We do not knowingly disclose Personal Data of minors under 16 years of age to third parties.
Additionally, we may disclose your information to third parties for other business purposes, such as if we conclude that we are required by law or have a good faith belief that access, preservation, or disclosure of such information is reasonably necessary to protect the rights, property, or safety of our Company, its customers, or the public. We may also contract with other companies and individuals to perform certain functions and services, including processing, storing, tracking, and organizing information on our behalf. These service providers may have access to Personal Data to perform their functions, but are prohibited from using Personal Data for direct or indirect marketing purposes or for any purpose other than providing services to us. We may disclose your information to a third party in connection with a corporate reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or capital, including in connection with any bankruptcy or similar proceedings. Additionally, we may also disclose your Personal Information to enforce or apply our policies and other agreements, including for billing and collection purposes and if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Aquilini Beverage Group, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We may track visits to the pages and links on our Website so we can make decisions about the design and usage of the Website. We may choose to share this aggregate and de-identified information on consumer behavior to third parties.
COOKIES AND RELATED TECHNOLOGIES
As part of our ongoing efforts to ensure the best possible experience for all users of our Website, we may use “cookies” and related technologies, such as tags, SDKs, tracking pixels, and other similar technologies to collect the information described in “Information We Collect Through Automated Means.” “Cookies” are small pieces of information that are stored by your browser on your computer's hard drive. Cookies enable us to provide special features such as storing items in your shopping cart between visits, tailoring products or services offered to you based on past preferences or geographic location. Most Web browsers automatically accept cookies but allow you to turn off cookies as part of the browser options. Even without cookies, you can still use most of the features of our Website, but you will be unable to place items in your shopping cart or make purchases.
We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
ADVERTISING AND THIRD-PARTY DATA COLLECTION
NOTICE CONCERNING DO NOT TRACK
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Website for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. To learn more about Do Not Track, you can do so here.
LINKS TO OTHER WEBSITES
DATA SUBJECT RIGHTS
Depending on your residency, you may have certain data subject rights. These rights vary by state and country, but they may include the right to: (i) request additional disclosures about the Personal Data we collect, use, disclose and sell; (ii) request access to and rectification or erasure of your Personal Data; (iii) restrict or object to the processing of your Personal Data; (iv) opt-out of the sale of Personal Data; and (v) obtain a copy of their Personal Data in a portable format. Where we rely on consent as the basis for processing Personal Data, individuals have the right to withdraw their consent. You may also have the right to lodge a complaint about the processing of Personal Data with a data protection authority, including if we deny your request.
Aquilini Beverage Group will not discriminate against you for exercising any of these rights, for example, by charging a different price or denying goods or services. However, Aquilini Beverage Group may charge a different price or rate or provide a different level or quality of goods or services when that difference is reasonably related to the value provided to us by the data.
HOW TO EXERCISE DATA SUBJECT RIGHTS
If you wish to exercise any of these rights, please email firstname.lastname@example.org with the phrase “Data Subject Rights” in the subject line. We will review your requests and respond accordingly. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Additionally, if we retain your Personal Data only in de-identified form, we will not attempt to re-identify your data in response to a Data Subject Rights request.
If you make a request related to Personal Data about you, you will be required to supply a valid means of identification as a security precaution. We will follow-up all requests with a phone call from the appropriate member of our team to verify your identity, and if your identity is verifiable, we will proceed with processing the request as directed by applicable law. For requests related to particularly sensitive information, we may require additional proof of identification.
If you make a Data Subject Rights request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.
We will process your request within the time provided by applicable law.
ADDITIONAL PRIVACY RIGHTS
In addition to the rights already described, California law permits customers in California to request certain details about how their information is shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business must either provide this information or permit California customers to opt in to, or opt out of, this type of sharing.
We may from time to time elect to share certain information about you collected by us on the Service with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. If you are a California resident, you may opt out of such future sharing of your personal information (as defined by the California Shine the Light Act) by contacting us at email@example.com with the phrase “Do Not Share” in the subject line.