Your Privacy Rights
Effective as of 5 /5 /2022
Our Commitment to Privacy
We are based in California, and this policy incorporates protections for California residents provided under the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”). Since we care about your privacy, we provide the same rights to all of our customers whether or not they are California residents. As discussed further below under Legal Disclaimers, your use of this Site and our services are subject to California and United States law.
Summary of Your Rights
If you ever have any questions about how we use and store your personal information, you can submit those questions to us at firstname.lastname@example.org. Below is a non-exhaustive summary of the rights you have in this policy. This summary is only for your convenience: it does not change the details, exceptions, and legal obligations that apply to these items set out in more detail below:
You can opt-out of our selling or sharing your information for marketing purposes here.
You may request that we delete the personal information you provided to us at any time by sending your request to email@example.com or by (831) 455-9990, and we will delete it (unless there is a specific reason, we need to keep it).
You may opt-out of receiving marketing e-mails or the use of your personal data by us for direct marketing purposes. To opt-out of the use of your personal data for this purpose, contact us at firstname.lastname@example.org or by phone at (831) 455-9990. But you may miss out on specials, perks, allocations, offers, and events.
Up to twice a year, you may ask us about the personal information that we collect and store, by contacting us at (831) 455-9990.
You cannot object to our sharing your information with our Service Providers, such as shipping companies and credit card processors to facilitate your transactions but be assured that our agreements with those providers and California Consumer Privacy Regulations prevent them from using your personal information for any other purposes.
You have a right not to receive any discriminatory treatment by the Winery for the exercise of the privacy rights conferred by the CCPA.
NOTICE OF COLLECTION
Who is Collecting Your Data?
Cheers & Co. controls the data that is collected on the Site. You can contact us anytime at: email@example.com or (831) 455-9990.
Categories of Information We Collect
We collect and store certain personal information about you at various points in order to provide you with products and services. We collect this information from information that either you provide us directly or gathered from your devices. As discussed further below, we are required to collect certain information from you such as your age and residence in order to sell and ship you wine legally. We also use this information and additional information we collect to customize our services to your preferences and provide you with products and services that we believe will appeal to you.
California defines certain categories of “personal information.” We collect information that falls into these categories directly from you and your electronic devices, as well as from other publicly available sources:
(A) Identifiers such as name, residence address, internet protocol address, and email address.
(B) Additional identifiers including telephone number, credit card number, or other payment information.
(C) Age/date of birth.
(D) Commercial Information such as purchase history.
(F) Internet activity information such as interactions with our communications and our website;
(G) Geolocation of electronic devices accessing our website (we collect only general locations and do not collect your precise location);
(K) Inferences are drawn from any of the information above to create a consumer profile.
We share the information above with our service providers and contractors to carry out our business with you and for our internal purposes as discussed below.
We may also collect non-personal or de-identified information from you including, but not limited to, demographic data. Unless otherwise required by applicable law, we may use and share this information, which does not personally identify you, for any purpose.
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically collected information as “Device Information.” We collect device information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number). We refer to this information as “Order Information.”
Why We Collect Your Information
We collect your information to manage our relationship with you and send you communications, and for several our other business purposes, including the following:
You must be of legal age to use the Site or to purchase any alcoholic beverage. If you wish to purchase any alcohol-containing beverage from us, you may be required to provide personal information sufficient to verify that you are over 21 years of age. If you do not provide information to verify that you are of legal age, we cannot provide any services to you. We also cannot ship any product to you if you do not provide an address at which a person over the legal age is available to receive the product. We do not knowingly collect, nor do we sell personal information from individuals under 21, nor do we direct any of our content to individuals under 21. If we learn that we collected the personal information of a minor, we will take steps to delete the information as soon as possible.
We are required to collect and provide your information to certain of our service providers in order to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). We also use this order information to communicate with you about your transactions and to screen our orders for potential risk or fraud.
We also use the information we collect for our marketing purposes. This information may be made available to our Affiliate wineries, so that your experience with any of the Cheers & Co. brands can be recognized by those Affiliates. If you would like to opt out of our use of your information for marketing purposes, or to be removed from our email list, you may contact us at firstname.lastname@example.org. Even if you opt out, we may still send emails to you concerning specific transactions or other non-marketing related messages. Our service providers are not permitted to use your information for their own marketing purposes, unless they have an independent relationship to you and have obtained your information from another source.
When you visit the Site, we also collect some basic Device Information about you and your browser. Examples of such Device Information that is collected include what type of browser and operating system you are using, how long you remained on our Site and what pages you looked at while here. We use Google Analytics and Facebook Pixel to understand how our website, services, and products perform, how you use them, and to serve you with ads on third-party websites and social networking sites like Facebook.
“Do Not Sell My Personal Information”
We may on occasion offer you a discount in exchange for your agreement to allow us to obtain your personal information, such as if you register for an account or provide your email to our mailing list. The categories of information we are collecting that trigger the Financial Incentive are detailed above in the Categories of Information We Collect chart. This Financial Incentive is permitted under the California Consumer Privacy Act. Our Financial Incentive is based on a good faith estimate of the value of your personal information, as reflected in the discount provided. If you wish to opt-in to the Financial Incentive, you may do so by agreeing to register, subscribe, create an account, make purchases, provide us with your personal information, or otherwise interact with this Site and receive the Financial Incentive. If you wish to withdraw from the Financial Incentive, you may do so at any time by sending an email to us at email@example.com.
How Long We Keep Your Information
We will retain your information for as long as your account is active or as necessary to provide you services and to maintain a record of your transactions for financial reporting and compliance purposes. If you wish to cancel or delete your account, please contact us at firstname.lastname@example.org. We will keep your order history on file indefinitely so that we can always provide you with information on what you ordered previously unless you ask us to delete it.
Your Rights to Access, Correct, or Delete Your Data
If you so desire, we will provide you with a copy of your account data or delete your account at your request. Up to twice a year, you may ask us whether we are collecting, storing, using, disclosing or selling your personal information, what categories and specific pieces of personal information of yours we are collecting and storing, the categories of sources from which our personal information is collected, the business or commercial purpose for collecting your personal information, and whom we may have shared your information with.
You may request a copy of the categories of personal information we have about you by contacting us at email@example.com or by phone at (831) 455-9990. We may contact you further to verify your identity if we do not have sufficient proof in your request, such as the request being sent from your email address that matches the one, we have. If you request specific pieces of information, to verify your request you will need to provide a declaration to us via mail at 305 Hilltown Rd, Salinas, CA 93908. We will work diligently to respond to your requests and will provide you with a free response within 45 days.
If you would like us to delete your data, please contact us at firstname.lastname@example.org or by phone at (831) 455-9990. Depending on the nature of the data that you request we delete, we may require you to provide two or more data points that match the information in our file. Note that even if you request deletion, we may continue to retain and use information as may be authorized or necessary under California Law. While you have the right to request that we delete the personal information you provide to us and we will not discriminate against you for exercising any rights that you have, we may no longer be able to sell you any alcohol-containing beverages if you ask us to delete your information showing you are of legal age or are in a location where it is legal for us to sell to you, and you may need to make other arrangements to verify your age and location to facilitate transactions.
We will verify your identity for purposes of such a request to delete or a request to know. If you have an account on the Site, we will verify your request for information through your account. If you do not have an account, we will verify your request depending on the nature of the request. If you request to know the categories of information, we will request that you provide two pieces of information that match our records, which may vary depending on the information we have on file. If you request to know specific pieces of information, we will require additional verification to match three pieces of information on file, as well as a signed declaration. If you would like to designate an authorized agent to make such a request on your behalf you may do so by providing us with your signed permission for such authorization, verifying your identity with us as described above, and confirming that you provided the authorized agent permission to submit the request; or your agent must provide proof of a power of attorney.
In order to ensure the protection of your information from fraudulent requests, we require you to provide us with additional information to verify your identity should you wish to access or delete your data. For your protection, in the event the requisite verification is not satisfied, we may deny the request for access to your account data or to delete your account.
Protecting Your Information
We make every effort to ensure that any data that we store about you is kept behind a secure firewall and is not accessible to the public in any way. Any sensitive information (such as credit card number) that we collect from you is securely processed by our service providers. We protect user data offline as well by restricting access to information to only those employees (for example, a Customer Care representative) who need the information to perform a specific job. All employees are kept up to date on our security and privacy practices and are aware of the importance of always keeping customer data secure and safe. We also outsource certain of our data processing operations to third parties as discussed below, and we have agreements with those service providers that require them to maintain security over your information.>
Although we use our best efforts to protect the security of your information and our system, and we have agreements in place with our processors requiring them to do the same, no transmission via the internet or storage of data can be guaranteed to be 100% secure. As a result of this and other factors beyond our control, we cannot guarantee the security of the information that you transmit to or through our Site. Therefore, you assume that risk by using the Site.
If you have any questions about the security of our Site, please feel free to contact us at email@example.com
How We Share Your Information
We value your privacy, and we will never sell or rent any personal information to any Third Party for that Third Party’s marketing purposes.
We share your Personal Information with third parties to carry out our business with you and for our internal purposes, as described further above.
For example, we use Wine Direct to power our online stores--you can read more about how Wine Direct uses your Personal Information here: https://www.winedirect.com/privacy-policy
We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
To learn more about how Facebook uses your data, please visit https://www.facebook.com/policy.php.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or another lawful request for information we receive, or to otherwise protect our rights.
You can opt-out of sharing your information by using this form.
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiatives (“NAI”) educational page at
You can opt-out of targeted advertising by these providers:
FACEBOOK - https://www.facebook.com/settings/?tab=ads
PINTEREST - https://www.pinterest.com/settings/privacy
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/
Do Not Track Signals
Some browsers have incorporated “do not track” features to enable users to make privacy and security choices. By using these settings, your browser may send a signal to our website not to collect tracking information. The Site does not alter the collection of information from users through cookies if a “do not track” signal is received. Information tracked by the Site through cookies is discussed above.
Data of Minors
The Site is not directed at children and cannot be accessed by persons who do not verify that they are of legal drinking age. Our social media accounts are directed at those over the legal drinking age and not intended for use by minors. As a result, we will not knowingly collect information from minors of any age in the U.S., including those under 16, with or without consent from their parents or guardians.
Protecting the privacy of children is very important to us. If we learn that we collected the personal information of a minor, we will take steps to delete the information as soon as possible. If you believe we have inadvertently collected the personal information of your minor child, please contact us at firstname.lastname@example.org.
In addition to the use of your personal information for our business purposes, and subject to our not otherwise sharing or selling your data to Third Parties except as set forth above, Cheers & Co. reserves the right to disclose your personally identifiable information as allowed or required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or legal process served on our Site.
If you are a European resident, you have the right to access the personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. Those rights are equivalent to the rights discussed above provided for California residents, and that we provide to all of our customers. If you would like to exercise these rights, please contact us through the contact information below.
Additionally, if you are a European resident, we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
Privacy Policies Update
If you have any questions about this policy, you can reach us at email@example.com