Rombauer Vineyards® Privacy Policy

Updated December 30, 2022

Rombauer Vineyards® (“Rombauer”) is committed to protecting your privacy. The information that you provide to Rombauer Vineyards, 3522 Silverado Trail North, St. Helena, CA 94574 (sometimes referred to as “we”, “us” or “our”) is utilized in order for us to (among other things) provide you with the highest level of customer service reflective of the quality of our brands.

This Privacy Policy (“Policy”) applies to our offline and online data collection practices, including when you visit our website at www.rombauer.com or the websites of any of our affiliates (collectively the “Site”), inquire about our products or services, make a purchase from us, visit our vineyards or tasting rooms, subscribe to our mailing lists or to our wine club programs or when you engage with us via email or on social media.

This Policy is subject to our Terms of Use located at: https://rombauer.com/footer/policies/. We may update this Policy from time to time, as specified in the “Changes to This Privacy Policy” section below.

California state law confers certain rights relating to personal information to its residents. If you are a California resident, please also see our California Consumer Privacy Section in this Policy located here

If you are an employee or job applicant for Rombauer in California, please see the Rombauer Privacy Notice for California Employees and Job Applicants.

Your Consent

Please review this Policy periodically. You should read this entire Policy before submitting information, including personal information, to us in any form or using our Site. Whenever you submit personal information to us, you consent to the collection, use, disclosure, transfer, and storage of that information in accordance with this Policy.

All personal information may be used for the purposes stated in this Policy. We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form. We may also make full use of all user-generated content you submit to us, in accordance with our Terms of Use.

COLLECTION OF PERSONAL INFORMATION

We collect personal information using three methods: 1) from you when you choose to voluntarily provide it; 2) using automated technology, including when you visit our Site or interact with our electronic advertisements or communications; and 3) using third party sources including but not limited to service providers, entities providing data analysis and analytics, social media and social networking websites and other entities. To see a complete list of what we collect, and how we use and disclose this data, please see our Annex 1.

Personal Information

Rombauer collects Personal Information, such as: your name; signature; mailing address; telephone number; email address; date of birth; credit card information; location; products or services purchased, obtained, considered, reviewed or other purchasing or consuming habits; photographs, video, and face; or your geolocation.

We collect information about you through your browser, computer hardware and software. This information can include your IP address, your device information, domain name, browsers you used to access our Site and services, web pages viewed, time spent on web pages, link clicks, transactions entered into and site-navigation pattern. This information is used by Rombauer for the improvement of our Site. This site is being monitored by one or more third-party monitoring software(s), including website analytics and chat functions, and may capture information about your visit that will help us improve the quality of our service.

We may combine data collected from third party sources.

HOW WE USE YOUR PERSONAL INFORMATION

We use Personal Information of customers for a wide range of purposes, including:

To respond to and fulfill your requests, purchase orders, and wine club orders, follow up with you after you have communicated with us or submitted information to us, and to provide products or services that you have ordered;

To process your order transactions, contact you regarding your order, and deliver products to you;

To improve our products, services, Site, and social media;

To provide you with a customized user experience;

To send promotional communications or offers regarding our products and services (unless you have requested that we not send such communications);
To authenticate your account credentials and identify you, as necessary to log you in and/or ensure the security of your account;

For marketing, research, legal, and other business purposes;

To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies;
To maintain and preserve the safety of our guests, premises, property, and products; and,
To Improve our premises and your customer experience;
As otherwise specified at the point of collection.

Email/Text Marketing

If you no longer wish to receive email marketing communications from us, you may unsubscribe from receiving marketing-related emails by using the unsubscribe method provided in our communications (e.g., by clicking on the “unsubscribe” link in the email to unsubscribe). Please note that unsubscribing from our promotional material will not prevent us from contacting you for other reasons, such as order confirmations, responses to customer service inquiries, or information about an event for which you have registered.

Alternatively, to the extent that applicable law requires your prior opt-in consent to receive marketing and promotional emails, we will ask for your consent and you can choose not to opt-in.

You may also choose to participate in certain text or SMS/MMS marketing. If you opt in to such marketing, we may collect and use certain personal information, including phone number, email, product browsing behavior, purchase behavior, device type, cellular carrier, and location to contact you and provide you marketing, communications, or promotions.

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

Service Providers and Contractors

We disclose Personal Information you provide to consultants, service providers, and contractors that we use to support our business and operations who have agreed to keep the information confidential and use it only to provide the applicable service(s) such as vendors that help us communicate with you, vendors that host our website and data, security and fraud detection vendors.

Outside Parties

We disclose Personal Information to third parties we work with who help us gather information from you and communicate with you which may include payment processors, entities that provide sweepstakes/contests sponsorship, social media companies, companies providing data analytics, targeted advertising, or online behavioral marketing services.

Legal Obligations

We may disclose Personal Information to outside parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our (or others’) rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations.

Sale or Corporate Restructuring

We may disclose Personal Information to third parties in connection with the sale, assignment or other transfer of the business of our website or the sale, assignment, merger, reorganization or other transfer of our brand or company.

HOW WE USE “COOKIES AND OTHER TECHNOLOGY”

As you enter the Site, our server records and monitors your IP address and uses it to develop statistical analysis. These analyses assist us in refining and adapting the content and design of our site. The use of IP addresses also enables us to prevent malicious Internet users from masquerading as other users. Automated technology collects information from your computer or mobile device and includes cookies, web beacons, local shared objects, or other similar technology. A cookie is a small piece of information sent by a website that is saved on your hard drive by your computer’s browser. A “web beacon” is a small object or image that is embedded into a web page, application, or email and is used to track activity. They are also sometimes referred to as pixels and tags.

As you access or use our Site, we and/or third parties may collect information using cookies, web beacons, pixels, and navigational and location data collection (clickstream, log files, server logs) for the purposes described in this Policy. Such automated technologies further help us to keep track of your interactions with our website and provide you with a more customized experience.

To find more information about cookies please visit www.allaboutcookies.org. Most browsers are initially set to allow cookies, but also offer the option to restrict cookies or warn you of their use. By disabling cookies, you won’t be able to enjoy the convenience provided by our customization.

THIRD PARTY ADVERTISING AND ANALYTICS DISCLAIMERS

We and/or third parties including advertising companies, social networking sites, and service providers on our behalf, use cookies, web beacons and other similar technology, to collect information for the purposes described in this Policy including advertising, analytics, online behavioral marketing, monitoring performance and improvement of our online services (traffic, errors, page load time, popular pages, etc.).

You may opt out of behavioral remarketing as follows:

Google Analytics and Facebook Pixel: 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. To learn more about how Google processes your data, please visit https://www.google.com/policies/privacy/. To opt out of Google Analytics please visit https://tools.google.com/dlpage/gaoptout. To learn more about how Facebook uses your data, please visit https://www.facebook.com/policy.php.

Advertising and Remarketing Services: We use remarketing services to inform, optimize, and serve ads on third-party websites such as Facebook to you based on your use of our Site and social media. To understand more about Facebook advertising and manage your preferences, please visit https://www.facebook.com/about/ads. Login to Facebook and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app) for more information. For more information about targeted advertising and to opt out of collection of information and ad targeting from third party websites, including Facebook and Google, please visit http://www.aboutads.info/choices. If you choose to opt out, you will continue to receive advertisements but they will not be tailored to your interests.

Digital Advertising Alliance

You can also opt out from companies like Google, Instagram, Pinterest, Facebook and other participating companies through the Digital Advertising Alliance in the USA: http://www.aboutads.info/choices/. You can also opt out of participating companies from the Digital Advertising Alliance of Canada in Canada: http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe: http://www.youronlinechoices.eu/, or opt out using your mobile device settings.

Website Chat Function

Our website chat function is operated by RedChirp. When you use our website chat function, your personal information, including identifiers and contact information, as well as the content of your chat communications will be recorded by Rombauer and/or our service providers. We will use the information collected to provide you with services requested and communicate with you on related topics.

RETENTION OF PERSONAL INFORMATION

We will retain your personal information (collected through offline and online methods) only for as long as it is necessary for the purposes described in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. For more information regarding retention of personal information see Annex 1.

Intended Audience of Websites; COPPA Compliance

We are in compliance with the requirements of the Children’s Online Privacy Protection Act (“COPPA”). Our Site and social media accounts are not intended for people under the legal drinking age and as a result, We will not knowingly collect information from minors in the United States or elsewhere with or without the consent of their parents or guardians. If you are not 21 or older, you should not visit or use our Site or social media accounts.

Security

For your security, Our web-based ordering system utilizes the most up-to-date Secure Socket Layer (SSL) technology. This software ensures that all sales transaction information is transferred safely via encrypted methods.

All orders placed on this Site require a credit card. Upon submitting an order, all credit card numbers are transmitted via secure and encrypted methods. If desired, credit card numbers can be kept on file for future purchases. For your security, these credit card numbers are stored in secure, encrypted databases.

The transmission of information via the internet is not completely secure. Although we strive to protect your personal information in accordance with this Policy, we will not be liable for disclosure of personal information obtained due to errors in transmission or security breaches.

External Links

We may make available third party applications through our Site and social media applications for your use. Links to such applications, any other websites included in this Site or links on our social media accounts operate with privacy policies beyond our control. Unless otherwise indicated, once you have left our Site or our social media account, all use of information you provide is governed by the privacy policy of the other website’s or social media account’s operators. We are not responsible for any transactions that occur between you and a third-party website or social media account.

Governing Law

This Policy and our privacy practices will be subject exclusively to the laws of the State of California, United States of America. We make no representation that this Policy and its practices comply with the laws of any other jurisdiction.

Contact Us

If you have any questions or concerns about this Policy, please contact us at [email protected].

CALIFORNIA CONSUMERS ONLY: Your California Privacy Rights

This Privacy Rights Act Notice (“Notice”) provides additional information to California residents whose Personal Information is collected by Rombauer pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). If you are not a California resident, this Notice does not apply to you. Please visit our Privacy Policy (“Policy”) for more information. Any capitalized terms undefined in this Notice have the same definition as the Policy.

RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, DISCLOSED, OR SOLD AND SHARED

Information Collected

In the preceding 12 months, we have collected the categories of personal information about California consumers as described in Annex 1 to this Notice. To review these categories click here:

Business-to-Business (“B2B”) Information

If you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship, we collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating that business relationship. We use that information for internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship. We do not disclose that information outside our business relationship without your consent. See Annex 1 for more details.

Information Sold or Shared

As explained in Annex 1 of this Policy, we share your data with third party partners such as social networking sites and advertising companies in order to serve you with ads tailored to your preferences across various platforms. This type of sharing may be considered “selling” or “sharing” under the CPRA. You can control the information shared about you and request an opt-out as explained below.

We have sold or shared the following categories of personal information for a business or commercial purpose in the preceding 12 months.

Personal Identifiers
Commercial Information
Internet Activity

We have disclosed the following categories of personal information for a business or commercial purpose in the preceding 12 months:

Personal Identifiers
Commercial Information
Internet Activity

We do not knowingly sell or share the personal information of individuals under 16 years of age without affirmative authorization.

For details regarding the categories of third parties with whom we have shared, sold, or disclosed personal information, please see Annex 1

Requests to Know

You have the right to request that we disclose personal information we collect about you.

To make a request for any of the information set forth above (a “Request to Know”), please submit a verifiable consumer request pursuant to the instructions below. You may only make a Request to Know twice within a 12-month period. We will acknowledge your Request to Know within 10 days and will attempt to respond substantively within 45-90 days.

The Request to Know must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request.

You can make a Request to Know the personal information we have about you in the following ways:

Enter your request here
You may also make a request by phone by contacting us at 866.280.2582.

Once we receive your Request to Know, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. If you are an account holder, making a request through your account is sufficient for verification purposes. If you do not have an account with us, you will be asked to provide us with two or three pieces of information that will help us to verify your identification.

RIGHT TO KNOW SENSITIVE PERSONAL INFORMATION COLLECTED

We collect and use your Sensitive Personal Information as described in Annex 1.

We do not collect or process sensitive personal information for the purpose of inferring characteristics.

RIGHT TO REQUEST DELETION OF PERSONAL INFORMATION

You have the right to request the deletion of your personal information collected or maintained by us (“Request to Delete”), subject to certain exceptions permitted by law.

To make a Request to Delete, please submit a verifiable consumer request pursuant to the instructions below. We will acknowledge your Request to Delete within 10 days and will attempt to respond substantively within 45-90 days.

The Request to Delete must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request. Additionally, as permitted by law, if the information requested to be deleted is necessary for us to maintain, we will not be able to comply with your request. We will notify you if this is the case.

You can make a Request to Delete in the following ways:

Enter your request here
You may also make a request by phone by contacting us at 866.280.2582.

Once we receive your initial request to delete and your separate confirmation to delete, we will need to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. If you are an account holder, making a request through your account is sufficient for verification purposes. If you do not have an account with us, you should provide us with information that will help us to identify you.

We will retain correspondence, documents and information related to any Request to Know, Request to Delete, or Request to Opt-Out for 24 months as required by law.

RIGHT TO OPT-OUT OF SALE OR SHARING OF PERSONAL INFORMATION

You have the right to opt-out of the sale or sharing of your Personal Information. As explained in Annex 1 of this Policy, we share your data with third parties such as social networking sites and advertising companies, in order to serve you with ads tailored to your preferences across various platforms. This type of sharing may be considered “selling” or “sharing” under the CPRA. You can control the information shared about you and request an opt-out as explained below. We will process your Request to Opt-Out of sale within 15 days.

Requests to Opt Out Of a Sale or Share of Personal Information

You can make a Request to Opt Out in the following ways:

Enter your request here – Do Not Sell or Share My Info / Limit Use of Sensitive Information.
You may also make a request by phone by contacting us at 866.280.2582.

Opt-out Preference Signals

We have implemented technical measures to honor opt-out preference signals that you enable, including a Global Privacy Control. Opt-out preference signals are plug-ins available in certain browsers that signal to websites you visit of your preferences to opt out of the sale and sharing of certain personal information. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal. If you choose to use an opt-out preference signal, you will need to turn it on for each browser and each device you use. If you have enabled a valid opt-out preference signal device from your browser, we will not sell or share your personal information without first seeking your explicit consent.

This Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third-parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third-parties to learn about their privacy practices.

Cookies

As explained in our “Cookies and other technology” section (add link), you can opt out of cookies using your browser. You may also exercise your right to opt-out of cookies using our Cookie Preference Center.

Please Note:

Opt-outs are device and browser based. You must opt out on each device and each browser where you want your choice to apply.

Opt-outs maybe stored via cookies. If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.

We may still share your information with our service providers that help us perform functions that are necessary for our business such as vendors that host our website, credit card processors, analytics processors. These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.

You may still receive ads from us that are not tailored to your interests.

ADDITIONAL OPTIONS TO OPT-OUT OF SALE OR SHARING

In addition to the above options to opt out of the sale or sharing of your information under the CPRA and CCPA as described above, you have controls and choices with respect to collection and use of your information by third parties. These are summarized for you below. We do not control or maintain opt-out mechanisms for third party companies and are not responsible for their operation.

Advertising Opt-Out

You can opt out of sharing your information with third party companies engaged in targeted advertising including social networking sites such as Google and Facebook using the following tools: For websites: http://optout.aboutads.info/?c=2&lang=EN. For mobile apps: http://www.aboutads.info/appchoices

Google Opt-Out

If you would like to opt out of Google Analytics and Ads, you can. If you are on the web, you can opt out of Google Analytics by installing Google’s Opt Out browser add on: https://tools.google.com/dlpage/gaoptout, and you can opt out of interest-based Google ads using https://adssettings.google.com/u/0/authenticated.

Facebook Ad Preferences

To understand more about Facebook advertising and manage your preferences, please visit https://www.facebook.com/about/ads. Login to Facebook and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app) for more information.

RIGHT TO NON-DISCRIMINATION FOR EXERCISING CONSUMER PRIVACY RIGHTS

You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the California Consumer Privacy Act, including by exercising the rights specified herein.

RIGHT TO CORRECT

You have the right to request that we rectify inaccurate information about you.

Requests to Correct

To make a Request to Correct, please submit a verifiable consumer request pursuant to the instructions below. We will acknowledge your Request to Correct within 10 business days and we will attempt to respond substantively within 45-90 days.

You can make a Request to Correct in the following ways:

Enter your request here
You may also make a request by phone by contacting us at 866.280.2582.

Once we receive your request to correct, we will need to verify that you are the person that is the subject of the request through the Verification Process.

We will review all information provided by you to us, to determine whether the information is inaccurate. We reserve the right to delete the information instead of correcting if such deletion does not impact you or you consent to the deletion.

We will inform you of our decision to deny or grant your request.

We will retain correspondence, documents and information related to any Request to Correct for 24 months as required by law.

RIGHT TO ACCESS INFORMATION ABOUT AUTOMATED DECISION MAKING AND THE RIGHT TO OPT-OUT OF AUTOMATED DECISION MAKING

Under California law, consumers can request access to information about automated decision making processes and may request to opt out of automated decision making in certain circumstances. We do not engage in automated decision making. For more information, please contact us at [email protected].

NOTICE OF FINANCIAL INCENTIVE

From time to time, Rombauer may provide financial incentives to consumers who elect to provide certain personal information. These incentives may result in differences in the prices of our products offered to consumers (e.g., discounts and other promotions). For example, the financial incentives we may provide include discounts based upon purchase activity or other periodic discounts for promotional purposes.

The material aspects of any financial incentive will be explained and described in its program terms or in the details of the incentive offer.

Participation in any financial incentive program is entirely optional and participants may withdraw from the program at any time. To opt-out of the program and forgo any ongoing incentives, please follow the instructions in the program’s terms and conditions, or contact us using the contact information below.

Each financial incentive or price or service difference related to the collection and use of personal information is based upon our reasonable, good-faith determination of the estimated value of such information to our business, taking into consideration the value of the offer itself and the anticipated revenue generation that may be realized by rewarding brand loyalty and repeat purchases.

RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information (collected through offline and online methods) for as long as it is necessary for the purposes set out in Annex 1 and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

AUTHORIZED AGENT INFORMATION

You may designate an authorized agent to make a request on your behalf under the California Consumer Privacy Act.

In order to allow an authorized agent to make a request on your behalf, please email us at [email protected] to provide your written request and consent to an authorized agent.

When your authorized agent makes a request related to your personal information, we will require the agent to provide the above written permission. We may also require that you verify your own identity directly with us at the time such a request is made.

California Do Not Track Notice: Because there are not yet common, industry accepted “do not track” standards and systems, our website does not respond to Do Not Track signals. In addition, we may allow third parties to collect personal information from your activity on our website, as described in the “Information Collection and Use” section above.

California Shine The Light Disclosure Information

Although we do not disclose to any third parties for their marketing purposes any personal information, California residents are entitled to receive the following disclosure information under California law:

Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. We will respond to such written requests within 30 days following receipt at the e-mail or mailing address specified below under “Contact Us”. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are required to respond to each customer only once per calendar year.

Changes to This Privacy Policy

This Policy may be revised from time to time for any reason. If this Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page. Be sure to check the Policy whenever you submit personal information to us.

CONTACT FOR MORE INFORMATION

For information and questions about the use of your personal information or this California Consumer Privacy Section or your rights under California law, you may contact us at [email protected].

ANNEX ONE

Notice of Collection, Use, and Disclosure

See Privacy Policy here

Category	Examples	Collected From	Purposes	Disclosed to	Sold or Shared	Retention Period
Personal Identifiers Commercial Information	Name, signature, mailing address, telephone number, email address, date of birth, credit card information, and location. Products or services purchased, obtained, considered, reviewed or other purchasing or consuming habits.	You when you visit our Site (including your online activities on our Site), purchase a product (through our Site, in person, or on the phone), register for an account on our Site, join our wine club programs, enter a promotion or competition conducted by us, engage with us on social media, or otherwise interact with us through posting content on our Site, or communicating with us via phone or email, or our website chat function. We may also collect information from third party sources, such as third party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals.	To respond to and fulfill your requests, purchase orders, and wine club orders, follow up with you after you have communicated with us or submitted information to us, and to provide products or services that you have ordered; To process your order transactions, contact you regarding your order, and deliver products to you; To improve our products, services, Site, and social media; To provide you with a customized user experience; To send promotional communications or offers regarding our products and services (unless you have requested that we not send such communications); To authenticate your account credentials and identify you, as necessary to log you in and/or ensure the security of your account; For marketing, research, legal, and other business purposes; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.	Consultants, service providers, and contractors that we use to support our business and operations (e.g. hosting or operating our Site, data collection, reporting, ad response measurement, Site metrics and analytics, data analysis, delivering marketing messages and advertisements, processing credit card payments, and providing fraud detection services) who have agreed to keep the information confidential and use it only to provide the applicable services; Third party payment processors, including in connection with transactions where we require credit or debit card account information such as credit or payment card account information (including card number, expiration date, and security code); Third party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics, targeted advertising, or behavior remarketing, as explained further below; Third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; An acquirer or successor-in-interest in the event of a reorganization, merger, sale, change of control, consolidation, joint venture, assignment, transfer or other disposition of all or any part of Rombauer Vineyards, Inc. or its affiliates including any negotiation thereof; and Third party sponsors of contests, sweepstakes, discounts, and promotions that you enter into.	Yes, we share personal identifiers and commercial information with third parties we work with who help us gather information from you and communicate with you, including social media companies, and companies providing data analytics, targeted advertising, or online behavioral marketing services.	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
Internet/Network Activity	IP address, your device information, domain name, browsers you used to access our Site and services, webpages viewed, time spent on webpages, links clicks, transactions entered into and site-navigation patterns.	Your computer or mobile device, through your online activities and interactions with us, including, without limitation, your use of our services, your online activity on our Site, including our website chat function, and on our social media channels or through our third party sources. Third party sources include third party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals.	Analyze and track usage of our services and products including our Site and social media accounts; Determine the popularity of our products, Site, and services; Better understand how you use our Site and services; Improve our Site, services, and products; Provide you with a customized user experience; To send promotional communications or offers including invitations to events, taking surveys, and participating in promotions (unless you have requested that we not send such communications); For other marketing, research, legal, and other business purposes; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.	Consultants, service providers, and contractors that we use to support our business and operations; Third party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics, targeted advertising or behavior remarketing, as explained further below; and Third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; and An acquirer or successor-in-interest in the event of a reorganization, merger, sale, change of control, consolidation, joint venture, assignment, transfer or other disposition of all or any part of Rombauer Vineyards, Inc. or its affiliates including any negotiation thereof.	Yes, we share internet/network activity information with third parties we work with who help us gather information from you and communicate with you, including social media companies, and companies providing data analytics, targeted advertising, or online behavioral marketing services.	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
Biometric Information	photographs, video, and face.	Your in-person visit to our vineyards including but not limited to vineyard, winery, tasting room, winery events, and wine club pickups.	To maintain and preserve the safety of our guests, premises, property, and products; Improve our premises and your customer experience; For marketing and promotional purposes on our Site and social media; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.	Third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests.	No	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
Sensitive Personal Information	personal identification numbers, including driver’s license, passport, or state ID card numbers; account or debit or credit card numbers; or consumer’s geolocation.	You when you visit our Site (including your online activities on our Site), purchase a product (through our Site, in person, or on the phone), register for an account on our Site, join our wine club programs, enter a promotion or competition conducted by us, engage with us on social media, or otherwise interact with us through posting content on our Site, or communicating with us via phone or email, including our website chat function. We may also collect information from third party sources, such as third party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals. To prevent, detect, and investigate any security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted sensitive personal information. For purposes that do not infer characteristics about the consumer.	To respond to and fulfill your requests, purchase orders, and wine club orders, follow up with you after you have communicated with us or submitted information to us, and to provide products or services that you have ordered; To process your order transactions, contact you regarding your order, and deliver products to you; To improve our products, services, Site, and social media; To provide you with a customized user experience; To send promotional communications or offers regarding our products and services (unless you have requested that we not send such communications); To authenticate your account credentials and identify you, as necessary to log you in and/or ensure the security of your account; For marketing, research, legal, and other business purposes; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies		No	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
Business-to-Business (“B2B”) Information	Name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating the business relationship.	You, if you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship.	For internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship.	We do not disclose B2B Information outside our business relationship without your consent.	N	We will retain your B2B Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.