Privacy Policy - Deutsch Family Wine & Spirits

Effective Date: May 1, 2023

This Privacy Policy describes how Deutsch Family Wine & Spirits (“DFWS,” “we,” “us,” or “our”) collects, uses, retains, and discloses your information. We also describe the rights and choices you have regarding our use of your information. This Privacy Policy applies to the information that we collect about you online and offline, including users of the DFWS websites listed below (collectively, the “Websites”), the DFWS mobile app (“Mobile App”), any other electronic or digital products made available by DFWS, and our direct interaction with you (collectively, our “Services”).

The Websites are:

As used in this Privacy Policy, “personal information” includes “Personal Data” as such term is defined under the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”).

This Privacy Policy is effective May 1, 2023.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

OUR ROLE IN DATA PROCESSING

The entity responsible for the collection and use (processing) of your personal information is Deutsch Family Wine & Spirits. You can contact DFWS by email at notices@deutschfamily.com or by mail at 201 Tresser Blvd, Suite 500, Stamford, CT 06901-3434. DFWS is a controller under the UK General Data Protection Regulation and/or EU General Data Protection Regulation (collectively, “GDPR” or “EU data protection law”).

1. PERSONAL INFORMATION WE COLLECT, HOW WE USE IT, HOW LONG WE KEEP IT, AND HOW WE SHARE IT

When you interact with our Services, we collect your personal information. Personal information is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Please note that we need certain types of information so that we can provide certain Services to you. If you do not provide us with certain information, or ask us to delete it, you may no longer be able to access or use our Services. For example, if you are a customer but do not provide us with your billing information, we won’t be able to fulfill your orders.

Data Retention. Except as otherwise described below, we will retain the information collected about you for as long as legally required, as long as necessary for the business purpose for which it was collected, or until we receive a request to delete the information.

A. When you visit our Websites

Apply for a position at DFWS. When you apply for a job at DFWS, we will collect through our third-party application tracking provider (Paycom) your personal identifiers (name, age, email address, mailing address, and telephone number) your professional or employment information (resume, employment history, and desired salary), criminal record information (if applicable), and protected classifications (gender, race, ethnicity, veteran status, and disability status (if provided)). We use this personal information to assess and manage your application with DFWS and as necessary to comply with the law. We keep this information for as long as necessary to process your application, consider you for future employment, and if you become an employee, then for the duration of your employ at DFWS. We share this information with our recruiting software provider, Paycom, who helps us track applicants from the hiring stage onboarding and employment. For additional information on our applicant privacy practices, please see our Applicant Privacy Notice. For additional information on Paycom’s privacy practices, please see their Privacy Policy. To the extent EU data protection law applies, the legal basis for this processing is to perform a contract with you.
Contact Us. When you complete the “Get In Touch” form on our Websites, we will collect your identifiers (name, email address), inquiry area (media, retail, distributor, human resources, consumer), and anything you include in the “Message” field. When you click the “Contact Us” button on one of our websites, we will collect your identifiers (name and email address) and any other information you wish to include in your communication. We will use this information to respond to your message. To the extent EU data protection law applies, the legal basis for this processing is to perform a contract with you. We will also use your identifiers (email address), if you are resident of the EU – with your consent, to communicate with you in the future about products and services in which you may be interested. You can unsubscribe to any future marketing messages by clicking the “UNSUBSCRIBE” button located in each email. Please note, we will continue to send you emails about your inquiry, and the products and services that you requested. We will share your email address with our third party email marketing provider to send these marketing messages to you. Our communications may contain tracking technologies to analyze whether a predefined action took place by a recipient, such as opening our communications, in order to better adapt and distribute our communications. When you opt-in to our marketing communications, you are opting into the use of these technologies. You can disable tracking by disabling the display of images by default in your email program.
Live Chat. When you use the Live Chat functionality of the Websites, we will collect your identifiers (name, email address, telephone number), and any information you disclose in your communications with us. We will use this information to process your request, troubleshoot, and assist you with your inquiry. We will share your communications with our third-party live chat provider to facilitate the live chat functionality of our Websites.
Store Locator. When you utilize the store locator function on our Websites, we will collect the city or postal code entered into the location field. We will use this information to identify the store closest to the location you entered and may share the information with our third party Store Locator vendor, Grappos, to assist with the store location process. For additional information on Grappos’ privacy practices, please see their Privacy Policy. To the extent EU data protection law applies, the legal basis for the processing of this information is to fulfill a contract with you.
Subscribe to our Mailing List. When you subscribe to our mailing list, we collect your personal identifiers (name, email address, contact type) and your notification preferences. We use this personal information to fulfill your request to receive email alerts with our company press releases. To the extent EU data protection law applies, the legal basis for the processing of this information is your consent.
Make a purchase. To facilitate your purchases on the Websites (as applicable), we will collect, through our third party payment processor, your personal identifiers (name, physical address, and email address) and customer records information (payment card number, expiration date, and CVV), and any order comments you choose to include. We will use this personal information to process your payment for the requested product or service, fulfill and manage purchases, orders, payments, and returns or exchanges. We share this information with our order fulfillment partners, which will assist with processing of your order. To the extent EU data protection law applies, the legal basis for the processing of this information is to fulfil a contract with you.
Enter the Websites. When you enter our Websites, we will collect your date of birth. We collect this information to confirm you are of legal age to purchase alcohol and comply with our legal obligations. To the extent EU data protection law applies, the legal basis for the processing of this information is to comply with our legal obligation.

Create an Account. When you create an account in our Services, we collect from you, your personal identifiers (name, email address, address, date of birth and telephone number, if provided) and account login information (selected username and password). We use this personal information to create your account, process and fulfill your orders, communicate with you about the Services, and facilitate your access to our Services. To the extent EU data protection law applies, the legal basis for the processing of this information is to fulfil a contract with you.
Join our Club. When you become a member of one of our Clubs, we collect from you your personal identifiers (name, date of birth, phone number, and shipping address) and financial information (debit card information or credit card information). We use this personal information to enroll you in one of our Clubs, to process and fulfill your order subscription, communicate with you about the Services, and to facilitate access to our Services. To the extent EU data protection law applies, the legal basis for this performance of a contract. If you choose to opt-in to receiving marketing and promotional materials, we will send you emails that may be of interest to you related to our services and the Club. You may unsubscribe to these emails at any time by clicking the unsubscribe button at the bottom of the email. To the extent EU data protection law applies, the legal basis for the processing of this information is to fulfil a contract with you.

Interact with us on social media. When you interact with our fan page on social networking websites, such as Facebook, YouTube, Instagram, and Twitter (each a “Fan Page”) (collectively “Fan Pages”), we collect basic engagement metrics and use it to tailor content and marketing and use it to improve user experience as set forth in this section. Please note that we do not control the use or storage of the information that you have posted to any social networking websites. This information is collected and processed by the social networking websites for their own purposes, including marketing. For more information on how Facebook, YouTube, and Instagram use your personal information, please see Facebook’s Privacy Policy, YouTube’s Privacy Policy, Instagram’s Privacy Policy, and Twitter’s Privacy Policy.

Facebook, YouTube, and Instagram (the “Social Networks”) process personal information in the USA where the laws may be less protective than in your country of residence. For example, in accordance with U.S. laws, in certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in other countries may be entitled to access your personal data.

Fan Pages. When interacting with our Fan Pages, we collect, from you, your personal identifiers (name and email address) and visual information (photograph (i.e. profile picture)), as well as any information that you provide when interacting with our Fan Pages (e.g., commenting, sharing, and rating). We use this information to advertise our products, and to communicate with users. To the extent EU data protection law applies, the legal basis for the processing is your consent. We also collect, from you, your personal identifiers (name and email address) if you sign up for one of our promotions or submit information to us through social media sites to enroll you in the promotion or communicate with you based on your submission to us. To the extent EU data protection law applies, the legal basis for this processing is the performance of a contract. See the Notice of Financial Incentive below for more information on financial incentives related to promotions.

Because our Fan Pages are publicly accessible, when you use them to interact with other users, for example by posting, leaving comments or liking or sharing posts, any personal information that you post in them or provide when registering can be viewed by others or used by them as they see fit.

The content posted on our Fan Pages or other public areas of social networking websites can be deleted in the same way as other content that you have created. If at any time you want content posted to be deleted, please email your request to info@deutschfamily.com.

Community Management. With the help of a third party, we collect, from you, your contact, including “likes”, shares, messages, and other interactions with the content, in order to analyze and evaluate how our content is perceived, to learn from it, to improve our public relations efforts, and to create lookalike audiences. We use this information to create advertisements that match our Fan Page, to disseminate them via Facebook based on demographic data, and to target individuals that have similar interests, behavior or characteristics as the people we already have targeted. To the extent EU data protection law applies, the legal basis for analyzing your content and creating advertisements is our legitimate interest in organizing, facilitating, and optimizing communication with our users and the general public. If you object to this processing of your personal information, you can submit your objection via email to info@deutschfamily.com.

Facebook Messenger. When using Facebook messenger, Facebook collects, automatically, your internet or other electronic network activity information (IP address, date and time of the server request, time zone, specific browser or app function, access status, amount of data transferred, browser or app from which the Request comes, device type, operating system used, and its interface (e.g. Android or IOS), language, version of the operating system, and device identifiers). We do not use this information; its use is governed by Facebook’s Privacy Policy.

Contests or Sweepstakes. When you participate in a contest or sweepstakes on our Fan Pages, we collect, from you, your personal identifiers (name, email address, telephone number, and physical address (if provided)), and your visual identifiers (photograph (i.e., profile picture)). We use this information to manage your entry, communicate with you about your entry, and to run the sweepstakes or contest. We also use this information to create unique offers to enhance your customer experience. To the extent EU data protection law applies, the legal basis for the processing is that it is necessary for the performance of a contract. If you do not provide this information, it would not be possible for you to participate in the sweepstakes or contest. If it is necessary to send non-cash prizes, we will forward your information to a shipping service provider.

Events and Photos. At events, photos and video recordings may be made (possibly by a photographer commissioned by us), in which you may also be shown. If you are the central subject of a recording, the photographer will ask you before the recording/taking the photo whether you agree and consent.

We use the photos for our public relations and marketing on our various media/digital media outlets. To the extent EU data protection law applies, the legal basis for processing your photos where you are the subject is your consent. You can revoke your consent with effect going forward by emailing us at info@deutschfamily.com. The legal basis for taking and publishing photos where you are in the background is our legitimate interest in public relations. If you object to this processing of your personal information and believe you have an overriding interest, you can submit your objection via email to info@deutschfamily.com.

Facebook Page Insights. When you visit our Facebook Fan Page, Facebook records your IP address and other information about your usage behavior on our Facebook Fan Page. Facebook collects, through trackers in the browser of your device or via the advertising ID (IDFA from Apple or GAID from Google), when you open the Facebook app through your mobile device (e.g. smartphone or tablet). Facebook uses this information to provide us with statistical evaluations of the use of our Facebook Fan Page. We receive this information directly from Facebook, in the form of aggregated data and anonymous statistics regarding certain data points, such as: age; gender; city/country; device; inquiries from fans about other Facebook fan pages; region and language settings of the users; proportion of men and women; the number of people reached; clicks on posts, “Likes” and reactions; comments and shared content; and total video views. We use this information to analyze and improve the advertising campaigns we conduct through our Facebook Fan Page. We do not collect or process any other personal information in connection with Facebook’s “Page Insights” function.

To the extent EU data protection law applies, we are joint controllers with Facebook for this processing. To the extent EU data protection law applies, the legal basis for this processing is our legitimate interest in statistical evaluation of users on our Facebook Fan Page for the improvement and adjustment of our advertising measures based on the information collected. If you object to this processing of your personal information and believe you have an overriding interest, you can submit your objection via email to info@deutschfamily.com.

We do not retain this information independently. For information on data protection and the storage period on Facebook in relation to its “Page Insights” function, see here and Facebook’s Privacy Policy. It has been contractually agreed with Facebook that Facebook is responsible for providing you with information about the processing for Page Insights.

Information Processed Solely by Facebook. We do not know how Facebook uses personal information for its own purposes, how long the personal information is stored on Facebook or whether Facebook data is passed on to third parties.

If you are currently logged in to Facebook as a user, Facebook automatically collects, through trackers on your device, your Facebook ID or a link between the Facebook ID and the advertising ID (IDFA from Apple or GAID from Google) when you open the Facebook app through your mobile device (e.g. smartphone or tablet). This enables Facebook to understand that you have visited our Facebook Fan Page along with other Facebook pages that you have clicked on, whether you clicked on Facebook buttons integrated into websites that partner with Facebook, and other online interactions that report user data to Facebook. Based on this data, content or advertising tailored to you can be offered.

You can find more information about the personal information collected by Facebook, how it is used and how long it is stored by visiting Facebook’s Privacy Policy.

Interact with the Services. In addition to the personal information you provide, we also collect information automatically via cookies, pixels, and other tracking technologies as you use the Services. To the extent EU data protection law applies to placement of cookies on our Services, the legal basis for this processing is your consent. You may withdraw your consent at any time with effect moving forward by visiting our cookie management platform. To the extent EU data protection law applies to the further processing of information collected through the analytics cookies, pixels, and other technologies on the Services, the legal basis for this processing is your consent. You may withdraw your consent at any time with effect moving forward and can do so by visiting our cookie management platform. To the extent EU data protection law applies, the legal basis for the placement and access of strictly necessary cookies is the performance of a contract. These cookies are necessary to provide the Services to you.

We use essential, functional, analytics, and advertising cookies to collect your internet or other electronic network activity information (device, usage, location information (determined through your IP address), such as your browsing history, configuration, unique online identifiers, and interactions with our ads on third-party websites), when you interact with the Services (“Online Web Behavior Data”). We use this information to: (i) provide the Services; (ii) track you within the Services; (iii) enhance user experience; (iv) conduct analytics to improve the Services; (v) prevent fraudulent use of the Services and detect unlawful activity; (vi) diagnosis and repair Services errors, and, in cases of abuse, track and mitigate the abuse; and (vii) provide targeted advertising. To the extent EU data protection law applies, the legal basis for this processing is your consent to our use of non-essential cookies. To revoke your consent to our use of non-essential cookies, please visit our cookie management platform. Third party marketing and analytics cookies and the use of the information to market to you across different web pages and social media platforms may be considered sharing under the California Privacy Rights Act (“CPRA”). To opt out of this sharing, please visit Do Not Sell or Share My Personal Information.

In particular, below are the third party marketing and analytics cookies and tracking technologies on our Websites:

Google Analytics. We use Google Analytics to collect information on your use of the Services for its improvement. To collect this information, Google Analytics installs cookies on your browser or reads cookies that are already there. Google Analytics also receives information about you from applications you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personal information. Google’s ability to use and share information collected by Google Analytics about your visits to our Websites or to another application which partners with Google is restricted by the Google Analytics Terms of Use and Privacy Policy. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on, which can be accessed here. To revoke your consent to our use of Google Analytics cookies, please visit our cookie management platform. To opt out of this sharing, please visit Do Not Sell or Share My Personal Information.
DoubleClick. We utilize DoubleClick by Google to serve ads based on a user’s prior visits to our Websites. Each visitor to our Websites receives a different cookie, and the information collected by the cookie is used to generate conversion statistics and allows us to see the total number of individuals who clicked on our ads. DoubleClick enables Google and its partners to serve ads to you based on your visits to our Websites in addition to other websites on the Internet. Please review Google’s Privacy Policy for additional information on how Google uses the information collected. To revoke your consent to our use of DoubleClick by Google, please visit our cookie management platform. To opt out of targeted advertising by Google and this sharing, you can go to Google’s Ad Settings, or you can install the DoubleClick opt-out add-on, or visit Do Not Sell or Share My Personal Information.
Bing Ads. Bing Ads is a remarketing service provided by Microsoft. We use Bing Ads to serve you advertisements based on your past visits to our Websites. You can visit Microsoft to learn more about its privacy practices. To opt out of Bing Ads, you can follow these instructions. To revoke your consent to our use of Bing Ads, please visit our cookie management platform. To opt out, you can visit Do Not Sell or Share My Personal Information.
YouTube. We use YouTube (owned by Google) as our video platform to embed content from YouTube on our Websites. YouTube places its own cookies on your device when you visit parts of our Websites where a YouTube video is embedded. YouTube uses these cookies to track viewing statistics and assign a unique identifier to the device on which the video is viewed, enabling YouTube to recognize the device. This data is collected by Google. Google can use this data to show relevant advertising and for its own promotional purposes in accordance with Google’s Privacy Policy. The Google cookies also allow YouTube and its partners to show you advertisements on and outside of YouTube. This may be deemed sharing under the CPRA. To opt out of this sharing and displaying of YouTube ads, visit Your data in YouTube, where you can clear and control the information YouTube collects on you. To revoke your consent, please visit our cookie management platform. To opt out, you can visit Do Not Sell or Share My Personal Information.
Facebook Pixel. We use Facebook Pixel to customize our advertising and to serve you ads on your social media based on your browsing behavior. This allows your behavior to be tracked after you have been redirected to our Websites by clicking on a Facebook ad. Facebook stores cookies on your device to enable us to measure the effectiveness of Facebook ads for statistical and market research purposes. We do not have access to the information collected through Facebook’s cookies. However, the information collected via Facebook, on the Website as well as other websites on which Facebook’s cookies are installed, is also stored and processed by Facebook. Facebook may link this information to your Facebook account and also use it for its own promotional purposes in accordance with Facebook’s Data Usage Policy. The Facebook cookies also allow Facebook and its partners to show you advertisements on and outside of Facebook. This may be deemed sharing under the CPRA. To revoke your consent, please visit our cookie management platform. To opt out, you can visit Do Not Sell or Share My Personal Information.

To control the information collected about you using cookies and other technologies, please see our Cookie Notice. In general, to disable cookies and limit the collection and use of information through them, you can set your browser to refuse cookies or indicate when a cookie is being sent. When you opt-out an opt-out cookie will be placed on your device. The opt-out cookie is browser and device specific and will only last until cookies are cleared from your browser or device. You can also manage your cookie preferences via our cookie management platform.
We will combine the personal data that you have provided when interacting with the Services with your Online Web Behavior Data and with data obtained from third-party data providers. The data obtained from third parties consist of data that have been collected through cookies and may include information regarding your personal preferences, demographics and content consumption, including your browser history. Such data will be provided to us in aggregated form, and the Online Web Behavior Data and the third-party data is combined by matching your unique online identifier collected through cookies. To the extent EU data protection law applies, the legal basis for this processing is our legitimate interest offering relevant products and services to you. The purpose of combining this data is to enrich your Online Web Behavior Data and create segments to provide you with personalized marketing on our own website, as well as on other websites that you visit. The segments may, for example, be based on your estimated age, education, income and product preferences. Profiling is always conducted on a group level, which means that you will receive the same type of marketing as other individuals included in that same segment. To the extent EU data protection law applies, the legal basis for this processing is our legitimate interest offering relevant products and services to you. You have the right to restrict this processing for marketing purposes under EU data protection law. To exercise this right, please email us at Info@deutschfamily.com. You can opt out of this categorization by visiting Do Not Sell or Share My Personal Information. If you do so, you will still receive advertisements, but they will not be targeted.
We may also aggregate, de-identify, and/or anonymize any information collected through the Services in such a way that we cannot reasonably link information to you or your device. We may use such aggregate, de-identified, or anonymous information for any purpose, including without limitation for research and marketing purposes.

B. Participate in a business-to-business relationship with DFWS.

We will collect your identifiers (business representative name, business email address, business address, business telephone number), financial information (bank account number and routing number, or credit card number, expiration date, CVV, ZIP code). We will use this information to facilitate the business relationship, communicate with you regarding our business relationship, and process any payment you make to us. To the extent EU data protection law applies, the legal basis for the processing of this information is to fulfil a contract with you.

C. When you use the Mobile App

Create an Account. When you set up an account in the Mobile App, we will collect your identifiers (name, email address, telephone number, user ID, and password). At your option, we may also collect your profile picture, if you add one to your account. We will use this information to create your account and profile. To the extent EU data protection law applies, the legal basis for the processing of this information is to fulfil a contract with you.
Communicate with participants within the Mobile App. If you decide to communicate with other attendees, we will collect your communications within the Mobile App to facilitate your communication with other attendees. To the extent EU data protection law applies, the legal basis for the processing of this information is to fulfil a contract with you.
Contribute Content. If you contribute content to the Mobile App, we will collect such content (e.g., photographs and videos). We will use this to facilitate social engagement within the Mobile App among users. This information will be shared within the Mobile App with all other attendees of the event or meeting for which you are registered. To the extent EU data protection applies, the legal basis of this processing is our legitimate interest in providing an interactive and social event platform for users.
Collect Data Automatically. In addition to the personal information identified above, when you use the Mobile App, we and our third-party provider collects your internet and other electronic network activity via SDKs to make the Mobile App work as you expect it to and to provide enhanced functionality as described below. Some of the SDKs we use will store and retrieve information on your device, like a cookie or other similar tracker would.

Essential SDKs. We use essential SDKs which are necessary for the mobile application to function. If you do not provide this information, we would not be able to provide the Mobile Application.
Performance SDKs. When you use the Mobile App, we automatically collect, through our third party SDK provider, your internet and other electronic network activity regarding your device and use of the Mobile App. DFWS uses the information to test the performance of and improve the Mobile Appl for all users. This information is shared with our third party SDK provider on an aggregated and anonymized basis.

D. Interact with us at in-person events and opt in to receive text messages from us.

When you interact with us at in-person events (i.e., festivals, product samplings, etc.) and opt in to receive emails and/or text messages from us, we collect, from you, your personal identifiers (name, telephone number, email address, etc.) and the contents of any email or text message communications you send to or receive from us. We use this information to send you transactional and marketing emails and/or text messages and to act on any instruction provided by you in your email or text communications to us. To the extent EU data protection law applies, the legal basis for this processing is your consent. You can revoke your consent at any time with effect moving forward by replying STOP to any email or text message you receive from us. Reply HELP for help. Consent is not a condition of purchase. Message frequency varies. Message and data rates may apply. For additional information, please see our Terms and Conditions.

2. HOW WE SHARE AND DISCLOSE YOUR INFORMATION

We and our service providers will share the information we collect from and about you for the following business and operational purposes:

Service Providers: We may provide access to or share your information with select third parties who perform services on our behalf, such as sales, marketing, product content and features, advertising, analytics, research, customer service, delivery, data storage, security, fraud prevention, payment processing and order fulfillment, Mobile App developer, live chat provider, and legal services.
Affiliates and Subsidiaries: We provide access to or share your information with current or future affiliates and subsidiaries for the purposes described in this Privacy Policy.
Protection of DFWS and Others & Legal Compliance: We may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention, or disclosure is reasonably necessary to: (i) comply with law or legal process (e.g., a subpoena or court order); (ii) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (iii) respond to your requests for customer service; and/or (iv) protect the rights, property or personal safety of DFWS, its agents and affiliates, its users, and/or the public. This includes exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and similar purposes.
Business Transfers: We may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third party, customer information (including your email address) would likely be one of the transferred business assets.
Your Consent: If you have consented to our sharing of your information, we will also share your information consistent with your consent. You may withdraw your consent at any time.

Sharing in the Last Twelve (12) Months

We may share or disclose such aggregate or anonymous information with any third party, including advertisers, promotional partners, and sponsors.

For a Business Purpose. In the preceding twelve (12) months, DFWS has disclosed the following categories of personal information for a business purpose to the following categories of third parties:

We have disclosed your personal identifiers, internet and other network activity information, payment card or financial account information, and commercial information to service providers that perform Services on our behalf. These service providers include our data hosting service provider, marketing service providers, data analytics service providers, customer service providers, importers and distributors, shipping service providers, website development service providers, and payment processors.
We have disclosed your internet or other electronic network information to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair website errors that impair functionality.
We have disclosed your internet or other electronic network information and location information to our IT support and data analytics providers to maintain, improve, and upgrade DFWS Services.
We have disclosed your personal identifiers, internet and other network activity information, and any other information you disclose through the live chat function of our Websites to our third party live chat provider to facilitate your communication with us.

For a Sale/Sharing.

DFWS shares your identifiers, inferences drawn from your commercial information and internet or other electronic network activity information, commercial information, and internet or other electronic network activity information with its third party partners, sponsors, and advertisers (including social media platforms) to offer you products and services that may be of interest to you (i.e. targeted advertising), which may be co-branded or jointly offered by a partner. This use of your personal information may be considered a sale under the California Privacy Rights Act. To opt out of this sharing, follow the instruction in the “California Privacy Rights” section below or visit Do Not Sell or Share My Personal Information.
DFWS uses cookies and similar tracking technology on its websites. These cookies and technologies collect your internet and other electronic network activity and share it with the cookie or tracking technology provider to provide analytics on our Services. This use of your personal information may be considered a sale under the California Privacy Rights Act. To opt out of these cookies, visit Do Not Sell or Share My Personal Information.

We may share or disclose such aggregate or anonymous information with any third party, including advertisers, promotional partners, and sponsors

3. THIRD-PARTY LINKS AND FEATURES

The Services may contain links to third-party websites, third-party plug-ins (e.g., Facebook, Instagram, and Twitter). If you choose to use these websites, plug-ins, or services, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function. If you choose to use these services, we are not responsible for the content or practices of such third-party websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

4. YOUR RIGHTS & CHOICES REGARDING YOUR INFORMATION

Marketing Communications. If we send you marketing communications in your jurisdiction (based on our relationship with you, your consent, or applicable law), you may instruct us not to use your contact information to contact you by email or postal mail regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below. In commercial email messages, you can also opt-out by clicking the “UNSUBSCRIBE” button, or by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt-out of certain operational emails, such as those reflecting our relationship or transactions with you.
Correct or view your personal information. You may access your DFWS account to correct or view certain personal information of yours in our possession and which is associated with your profile.
Location settings. You can prevent your mobile device from sharing your location data by adjusting the permissions on your mobile device or within the Services.
Push notifications. If you have enabled push notifications, you may disable these at any time by updating your device settings.
Opt Out of Other Cookies. To set your cookie preferences or opt out of the sale/sharing of your information via cookies, please see our cookie management platform. All session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser’s directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/. Please note that each web browser is different. To find information relating to your browser, visit the browser developer’s website and mobile application. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our website may not function properly. If you choose to opt out, we will place an “opt-out cookie” on your device. The “opt-out cookie” is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences. By clicking on the “Opt-Out” links below, you will be directed to the respective third-party website where your computer will be scanned to determine who maintains cookies on you. At that time, you can either choose to opt out of all targeted advertising or you can choose to opt out of targeted advertising by selecting individual companies who maintain a cookie on your machine.

Association of National Advertisers opt-out registration: https://dmachoice.thedma.org/
Network Advertising Initiative (NAI) Opt-Out: https://www.networkadvertising.org/managing/opt_out.asp
Digital Advertising Alliance (DAA) Opt-Out: https://optout.aboutads.info
European Union (EU) /European Economic Area (EEA) Opt-Out: http://www.youronlinechoices.eu

Uninstall the Application. You can stop further collection of your personal information through the Mobile Application by uninstalling the Mobile Application.

5. ADDITIONAL INFORMATION FOR RESIDENTS OF CERTAIN JURISDICTIONS

Your local laws may entitle you to additional information or permit you to exercise certain rights with respect to the information we collect from and about you. Please note that your rights vary depending upon your location, and that we may request you provide us with information necessary to confirm your identity before responding to your request as required or permitted by applicable law. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you or to comply with a legal obligation. In some circumstances, if you still ask us to delete your information, you may no longer be able to access or use our Services.

Nevada Residents

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. We do not currently sell any of your personal information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales by contacting us at IT.Web@deutschfamily.com. Please include “Opt-Out Request Under Nevada Law” in the subject line of your message.

California Residents

Notice of Financial Incentive

Summary. We may offer discount codes or perks like a branded item in connection with you opting in to receive marketing emails, or participating in sweepstakes, contests, promotions, surveys, or research. You receive such discount codes or perks because we want to show you that we are excited you want to hear from us and because we hope you will want to buy our products.

Material Terms. The details of each program are contained in the program offering but in general, we invite you to provide us with your identifiers (name, email address, mailing address (as applicable), and affirmation of age) to participate in sweepstakes, contests, promotions, surveys, or research and we provide you with a sign of our appreciation such as a discount code or a perk like a branded item.

How To Opt In. You can opt in using a prompt on our websites that links to this notice.

Right to Withdraw. You can opt out of receiving marketing communications from us at any time by clicking on the unsubscribe link contained in our emails, or you may email us at IT.Web@deutschfamily.com.

Value of Financial Incentive. The incentives we offer in exchange for the opportunity to market to you may be a discount coupon that can be used when you buy products from us or a branded item. Details of the incentive will vary depending on market conditions at the time the incentive is offered, and the value of your data will also fluctuate. Under most circumstances, the value of your personal information is less than the incremental administrative costs of the marketing program, sweepstakes, contests, promotions, surveys, or research, including storage of your personal information. Retail prices for our products and branded items vary.

California Privacy Rights

The California Privacy Rights Act (CPRA) entitles California residents to certain rights. To the extent the CPRA applies to our processing of your personal information, you are entitled to the following rights:

Right to Access/Know. You have the right to request what personal information we have collected, used, disclosed, and sold about you, unless doing so proves impossible or would involve disproportionate effort.
Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. Once we receive your request to delete and confirm your identity, we will delete (and notify any service providers or third parties, who we have shared or sold your personal information to, to delete) your personal information, unless an exception applies under applicable law, including to comply with a legal obligation.
Right to Opt-Out of Sale/Sharing. You have the right to opt-out of the sale or sharing of your personal information to third parties. DFWS does not have actual knowledge that it sells or shares personal information of minors under the age of sixteen (16) years. To exercise your right to opt-out of the sale or sharing of your personal information visit Do Not Sell or Share My Personal Information.
Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, opt-out, correct, or limit use of sensitive personal information under the CPRA.
Right to correct: You have the right to correct inaccurate personal information that we collect or maintain.
Right to limit use of sensitive personal information: You have the right to limit the use of how we use your sensitive personal information. Sensitive information includes, for example, Social Security number, driver’s license number, biometric information, precise geolocation, and racial and ethnic origin. We do not use your sensitive information other than (i) to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; (ii) to prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information; or (iii) for short-term, transient use.

To exercise your right to access/know, correct, or delete your personal information, you may submit a request via email at IT.Web@deutschfamily.com. You can also exercise your rights by visiting our Privacy Rights Request page. For requests submitted via email, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information.

To opt out of the sale or sharing of your personal information, visit Do Not Sell or Share My Personal Information, or, effective January 1, 2023 for California residents, utilize the opt out preference signal to instruct us to not sell or share any of your personal information collected online. The opt out preference signal will apply to the device, platform, or browser in which you utilize it. You can utilize the opt out preference signal by turning on the signal in your device, platform, or browser settings.

Using an Authorized Agent

Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. If a consumer is using an authorized agent to submit a CCPA/CPRA privacy request to know (disclosure report) or delete their personal information, the following is required.

Using an authorized agent without power of attorney to submit a request to know or delete
- Signed permission from the consumer authorizing the agent to submit the CPRA privacy request(s) on their behalf. Describe the type of privacy request(s) being requesting (know/disclosure report and/or deletion).
- The consumer must verify their own identity directly with the us by submitting information or documentation that provides sufficient proof of identification, such as a copy of a driver’s license, an identification card issued by the motor vehicle administration, or any other government issued identification.

Using an authorized agent with power of attorney to submit a request to know or delete: If you have provided the authorized agent with power of attorney pursuant to California Probate Code sections 4000 to 4465, provide only the following: the valid power of attorney executed lawfully under California Probate Code sections 4121 to 4130.

Using an authorized agent to submit an opt-out request: Please provide written permission, signed by the consumer, authorizing the agent to submit the opt-out request.

Individuals in the European Union/European Economic Area and United Kingdom

Individuals in the European Union are entitled to certain rights under the General Data Protection Regulation (GDPR) and UK GDPR. If our processing of your personal information is subject to the GDPR/UK GDPR, you may be entitled to the following rights:

Right to access. You have the right to ask us for copies of your personal information. This right has some exemptions, which means you may not always receive all the personal information we process.
Right to rectification. You have the right to ask us to rectify personal information you think is inaccurate or incomplete.
Right to erasure. You have the right to ask us to erase your personal information in certain circumstances.
Right to restrict processing. You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Right to object to processing. You have the right to object at any time, for reasons arising from your particular situation, to processing of your personal information, which is carried out on the basis of our legitimate interests.
Right to data portability. You have the right to ask that we transfer the personal information you gave us from one organization to another, or give it to you. However, this right only applies when: (i) you have provided your personal data to us; (ii) the legal basis for the processing is your consent or for the performance of a contract; and (iii) the processing is carried out by automated means.
Right to lodge a complaint. You have the right to lodge a complaint with the relevant Supervisory Authority.

To make exercises these rights, please contact us at IT.Web@deutschfamily.com and include “EU Data Subject Request” in the subject line or submit your request here.

Data Transfers

Please note that, in providing services to you, we may subcontract the processing of your data to, or otherwise share your data with, DFWS affiliates and subsidiaries, trusted service providers, and trusted business partners in countries other than your country of residence, including the United States, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of Services to you, the processing of transactions, and/or the provision of support services. When we transfer your personal information to a third country which has a lower level of protection of personal data than the EU/EEA, we use the standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal data.

If applicable, you may make a complaint to the data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.

6. CHILDREN’S PRIVACY

The Services are intended for adults only. We do not knowingly solicit any information from individuals under the age of sixteen (16) or people under the legal drinking age, nor do we knowingly market or otherwise target our websites or its products or services to children or people under the legal drinking age.

If we become aware that a visitor to our websites is under the legal drinking age in the relevant jurisdiction and has registered with the Services, we will remove his or her personal data from our files. We also comply with other age restrictions and requirements in accordance with applicable local laws.

If you believe we might have information from or about a child under the age of sixteen (16), please contact notices@deutschfamily.com.

7. 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, which is why we describe a variety of opt-out mechanisms above. However, we do not currently recognize or respond to browser-initiated DNT signals.

8. DATA SECURITY

We take measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or access. However, no method of transmission over the internet, and no means of electronic or physical storage, is absolutely secure. By using our Services, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services and that any such transmission is at your own risk. You are responsible for keeping your account information—and especially your login information—confidential. We ask you not to share your login credentials with anyone.

9. CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this Privacy Policy at any time. We will make the revised Privacy Policy accessible through the Services, so you should review the Privacy Policy periodically. You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective Date” at the beginning of this Privacy Policy. If we make a material change to this Privacy Policy, we will provide you with notice in accordance with legal requirements, and obtain your consent, if required.

10. CONTACT INFORMATION

If you wish to contact us regarding our information practices or in relation to this Privacy Policy, please contact us:

By Mail:

Deutsch Family Wine & Spirits,
Attn: deutschfamily.com Privacy Policy,
201 Tresser Blvd., Suite 500,
Stamford, CT 06901

By E-mail: notices@deutschfamily.com