Skip to content
Shop more on AsEver.com

Privacy Notice

PLEASE READ: As Ever Enterprises, LLC and As ever (the “Winery”) will both process information you provide on this website, and related platforms (the “Website”). As Ever Enterprises, LLC and the Winery separately control and process your data for their own purposes as described in each of the two, separate privacy notices on this page. To learn more about As Ever Enterprises, LLC’s privacy practices with respect to the Website, click here; to learn more about The Winery’s privacy practices with respect to the Website, click here.

The personal information you submit to the Website is subject to both of these notices and controlled separately by each entity. As such, any data subject rights request, marketing opt-out, or other related inquiry must be addressed with each entity separately as described in each notice.

You must be at least 21 years of age (or the age of legal consumption in your jurisdiction) to interact with the Website, its contents, and its services.

Please check each notice periodically for any updates.

As Ever Enterprises, LLC Privacy Notice

Last updated July 1, 2025

This privacy notice ("Notice") gives you information on how As Ever Enterprises, LLC (the “Company”) collects and processes your personal information through your use of the Website and through any other interactions or communications with the Company (collectively, the "Company Services").

The Website is operated by the Winery, which is located in Calistoga, California with a mailing address at 548 Market Street #59205, San Francisco, California 94503, United States. The Winery has a limited license to use certain material in connection with the Website and the products sold herein. The Winery is the merchant of record for all transactions and will be the company that you contract with for any purchase of Website products and will handle and process your payment. As Ever Enterprises, LLC does not sell alcohol.

This Notice explains how the Company may use, collect, and store your information as you engage with the Website.

To see Company’s California Consumer Privacy Act (CCPA) Privacy Notice, including "Notice at Collection" details, see the "Supplemental Privacy Disclosures for US Residents" section.

Click on the links below to jump to each section:

The Type of Information Collected

The Company and/or its Providers (as defined in the "Disclosure of Information" section below) may collect certain information and/or content from and about you, including the following:

  • Identifiers and contact data such as name, e-mail address, postal address, postal code, and telephone number (including mobile phone number) when you submit it to the Company.
  • Information you submit, provide, or post such as when you contact the Company, complete surveys, respond to emails, or register with the Company. Additionally, the Website requires you to disclose your date of birth and/or age in order to gain access and in order to meet the Company’s obligations under the law; you submit this information voluntarily.
  • The Company collects and develops inferences. Using the other pieces of personal information collected about you, the Company may draw inferences about you, reflecting what the Company believes to be your preferences, characteristics, predispositions, and attitudes.

If you submit any personal information relating to other people in connection with the Website, you represent that you have the authority to do so and to permit the Company to use the information in accordance with this Notice.

How the Company Collects Information

The Company uses different methods to collect personal information from and about you including through:

  • Your interactions with the Company. For example, when you contact the Company or sign up for its newsletter.
  • Third parties. The Company may collect information from its service providers or partners, including its Providers and social media platforms.
  • Company combines information. The Company may combine information it gets from another party with information the Company already has. The Company may also aggregate your information with other individuals’ information to understand preferences and trends over time.

How Company Uses Information

The law in certain jurisdictions requires the Company to have a legal basis for collecting and using your personal information. Where applicable, the Company relies on one or more of the following legal bases:

  • Legitimate interests: The Company may use your personal information where it is necessary to conduct its business and pursue its legitimate interests where such legitimate interests are not overridden by your interests or fundamental rights and freedoms.
  • To protect vital interest of you or another person: The Company may use your personal information to prevent harm, help ensure safety, or respond to emergencies where necessary.
  • Legal obligation: The Company may use your personal information where it is necessary for compliance with a legal obligation that the Company is subject to.
  • Consent: The Company relies on consent where the Company has obtained your active agreement to use your personal information for a specified purpose, for example, if you subscribe to an email newsletter.

The information the Company collects may be used to communicate with you, provide and promote the products and services that the Company offers or promotes, and to process and respond to your inquiries. The information the Company collects may also be used to administer the Company Services, market to you, test and improve products and services when you answer a survey, analyze data the Company collects, identify and market to other potential customers, and develop new goods and services. This information may also be used to allow you to participate in polls, sweepstakes, promotions, and contests and to administer these activities. This information may be used to communicate with you if the Company offers a loyalty program.

The Company may also use personal information as may be necessary or appropriate for certain essential purposes, including: to comply with applicable law and legal process; to respond to requests from public and government authorities, including public and government authorities outside your country of residence; to detect, prevent, or investigate potential security incidents or fraud; to facilitate the functionality of the Company Services; to provide important product safety information and notice of product recalls on behalf of the Winery; to enforce the Company’s terms and conditions; to protect the Company’s operations or those of the Company’s Affiliates; to protect the Company’s rights, privacy, safety or property, security and/or that of Company’s Affiliates, you or others; and to allow the Company to pursue available remedies or limit the damages that the Company may sustain.

If offered by the Website, you may wish to sign up to receive the Company newsletter or other promotional offers via email. You can unsubscribe from any such communications at any time by clicking on the “unsubscribe” link in the footer of the email, by contacting the Company at Privacy@AsEver.com, or by following such other instructions as may be provided to unsubscribe/stop messaging. Please note that if you unsubscribe from the Company’s marketing and promotional emails, the Company may still send you transactional emails. These messages include responses to your questions and updates on your purchases.

Cookies & Other Technologies

The Winery controls the use of cookies and other technologies on the Website.

Disclosure of Information

The Company may disclose your information for certain purposes and to third parties, as described below:

  • The Company may share your information among entities under control of one or more of the persons or entities that owns or controls the Company ("Affiliates" and together with the Company, "Company Entities"), as well as with owners of Company Entities and affiliates and joint venture partners of Company  Entities, for or in connection with all purposes described in this Notice.
  • The Company may use other companies, agents, or contractors ("Providers") to perform services on the Company’s behalf or to help the Company provide the Company Services to you. For example, the Company may use Providers to provide infrastructure and IT services (like hosting the Company Services), or to facilitate commercial transactions. The Company may share your information with Providers and authorize Providers to use information on the Company’s behalf to provide their services. The Company and its Providers may also disclose and otherwise use information where The Company or they reasonably believe such disclosure is needed to (A) satisfy any applicable law, regulation, legal process, or governmental request, (B) enforce this Notice, including investigation of potential violations thereof, (C) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, or (D) protect against harm to the rights, property or safety of Company Entities, content partners, users or the public, as required or permitted by law.
  • The Company may share information with third parties and partners, including, for example, those who co-sponsor a promotion or promote Company products. Some of these third parties and partners may send you information about products and services by mail, email, or text message. They may share your information with other third parties. The Company may also share the above categories of personal information with companies that help the Company with its marketing efforts, including social media platforms, advertising networks, and ad tech companies. For example, the Company may share email addresses or other contact information with social media platforms so they can serve the Company’s advertising to you on their platform. Personal information received by the Company’s partners and other parties may also be subject to their privacy policies.
  • If all or any part of the Company’s business is acquired by a third party, the Company may include personal information as part of that transaction, which may include some or all categories of your personal information. The Company may also share your personal information if there is a change to the Company’s corporate structure. The Company may also share your information with third parties as they conduct diligence of the Company’s corporate changes.
  • If, in the course of sharing information, the Company transfers personal information to countries outside your region, the Company will take steps to ensure that the information is transferred in accordance with this Notice and in accordance with the applicable laws on data protection.

International Data Transfers

Personal information the Company collects from you may be transferred to, processed in, or stored in the United States or another destination outside of the EEA, UK, Canada, or other regions with comprehensive data protection laws. As a result, this information may be subject to access by and disclosure to government and law enforcement agencies in those countries according to their laws. If, in the course of sharing information, the Company transfers personal information to countries outside your region, the Company will take steps to ensure that the information is transferred in accordance with this Notice and in accordance with the applicable laws on data protection, including appropriate EU/UK standard contractual clauses. Please contact the Company if you would like more details about the Company’s safeguards for data transfers.

Security Practices

The Company uses administrative, logical, physical and managerial measures to help safeguard your information against loss, theft and unauthorized access, use and modification. Even though the Company has taken steps to help protect the information in the Company’s control, you should know that the Company cannot fully eliminate security risks associated with personal information. No security measures can provide absolute protection. The Company cannot ensure or warrant the security of any information you provide to the Company.

Your Information and Rights

By law, you may have certain rights when it comes to your personal information. The rights you have depend on the jurisdiction in which you are based. Some of these rights apply generally, while others will only apply in certain circumstances. Further information and advice about your rights can be obtained from the data protection regulator in your country. For all rights, the Company usually acts on requests and provides information free of charge, but, where allowed under the law, the Company may charge a reasonable fee to cover its administrative costs of providing the information for baseless or excessive/repeated requests, or further copies of the same information. Alternatively, the Company may be entitled to refuse to act on the request in some circumstances. The Company will try to respond as soon as it can. Generally, this will be within one month from when the Company receives your request but, if the request is going to take longer to deal with, the Company will come back to you and let you know. The Company may need to request specific information from you to help it verify and confirm your identity.

You may request to exercise the following rights:

  • Right to be informed. You have the right to be provided with clear, transparent, and easily understandable information about how the Company uses your information and your rights. This is why the Company is providing you with the information in this Notice.
  • Right of access. You can request access to your personal information and check that the Company is lawfully processing it.
  • Right to rectification. You can correct or update out-of-date or inaccurate personal information the Company holds about you.
  • Right to erasure. You can request removal or deletion of your personal information, where there is no compelling reason for the Company to keep using it.
  • Right to restrict processing. You have rights to 'block' or suppress further use of your information. When processing is restricted, the Company can still store your information, but may not use it further.
  • Right to data portability. You have rights to obtain and reuse your personal information for your own purposes across different services.
  • Right to object to processing. You can object to certain types of processing, including processing for direct marketing or where the Company is relying on its legitimate interests.
  • Right to lodge a complaint. You have the right to complain to a data protection authority about the Company’s collection and use of your personal information.
  • Right to withdraw consent. If the Company has collected and processed your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing the Company conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You can request to exercise these rights only where the Company has received a verified request from you. To make requests, or if you have any other question regarding the Company’s privacy practices, please contact the Company at Privacy@AsEver.com with the subject PRIVACY REQUEST. The Company responds to all requests it receives from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

You may also opt out of promotional emails. You may choose to provide the Company with your email address for the purpose of allowing the Company and its Affiliates to send communications and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, the Company may still send you service-related communications. 

Data Retention

The Company may retain information as required or permitted by applicable laws and regulations, including to honor your choices and to fulfill the purposes described in this Notice. Specifically, the Company retains information for its legitimate interests and business purposes, such as operating, maintaining and improving the Company’s services; complying with its legal obligations; and exercising its legal rights and remedies, including enforcing the Company’s terms of use. The Company’s retention of information is based on many factors such as your relationship with As Ever Enterprises, LLC; the nature of the information; compliance with the Company’s legal obligations; defending or resolving actual or anticipated legal claims. The Company may take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.

Changes to this Notice

From time to time, the Company may change or update this Notice. The Company will post an updated copy on the Website and update the "Last Updated" date at the beginning of this Notice. Please check the Website periodically for updates.

Third Party Websites

The Website may contain links to other websites owned and operated by third parties ("Third Party Website(s)"). These links are provided to you by the Winery as a convenience only and visiting any Third Party Website is at your own risk. The Company is not responsible for the content on such Third Party Websites, and the Company makes no representations or warranties with respect thereto. Your access and use of any such Third Party Websites is subject to their terms of use and privacy policies.

Contact Us

If you have questions about the Company’s collection, use, and disclosure of your personal information or the privacy practices described in this Notice, you may contact us at Privacy@AsEver.com.

Supplemental Privacy Disclosures for US Residents

These disclosures apply to consumers who reside in states that have adopted comprehensive consumer privacy laws that are in effect (collectively "US State Privacy Laws") and supplements this Notice, to the extent applicable. Because of differences in certain state laws, this supplement is broken into two sections, California Consumer Privacy Act (CCPA) Specific Notices, applicable to California residents only, and other State Specific Sections, which may apply to residents of one or more states with consumer privacy laws requiring such information.

California Consumer Privacy Act (CCPA) Specific Privacy Notice

Notice at Collection

At or before the time of collection, the California Consumer Privacy Act ("CCPA") requires businesses to provide a notice of certain practices, including the categories of personal information collected and the purpose for which such information is collected or used (as stated in the "Personal Information The Company Collects" and "Use of CCPA Personal Information" sections of the Privacy Notice), whether such information is "sold or shared" (as stated in the "Categories of CCPA Personal Information Sold or Shared" section), and the criteria used to determine how long such information is retained (in the "Data Retention" section). The Company has provided these details throughout this section of the Privacy Notice.

Personal Information The Company Collects. The Company collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("CCPA personal information"). The Company has collected categories of CCPA personal information noted in the "The Type of Information Collected" section of this Notice within the last twelve (12) months.

Use of CCPA Personal Information. The Company uses categories of CCPA personal information listed above for the purposes noted in the "How the Company Uses Information" section of this Notice.

Categories of CCPA Personal Information Disclosed for a Business Purpose. The Company discloses the categories of CCPA personal information noted in "The Type of Information Collected" section of this Notice for business purposes, including, for example, the following categories of third parties: Providers, other Company Entities, an entity engaged in connection with a business transfer, law enforcement, courts, governments and regulatory agencies.

Sources of CCPA Personal Information. The Company explains our sources of information in the "The Type of Information Collected" section of this Notice.

Sensitive CCPA Personal Information. We may collect Site account login credentials and certain payment details, which may be considered Sensitive Personal Information as defined by the CCPA. We do not use or disclose Sensitive Personal Information for any purpose inconsistent with the CCPA.

Data Retention. The Company may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for the Company’s billing or records purposes and to fulfill the purposes described in this Notice. Specifically, the Company retains information for its legitimate interests and business purposes, such as operating, maintaining and improving its services; complying with its legal obligations; and exercising its legal rights and remedies, including enforcing its terms of use. The Company’s retention of information is based on many factors such as your relationship with As Ever Enterprises, LLC; the nature of the information; compliance with the Company’s legal obligations; defending or resolving actual or anticipated legal claims. The Company may take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.

Your California Privacy Rights. California residents have certain rights with respect to your personal information, subject to the exceptions provided under California law:

  • Right to Know/Access. You have the right to request that the Company disclose: the categories and specific pieces of personal information the Company has collected about you; the categories of sources from which personal information are collected; the Company’s business or commercial purpose for collecting, using, disclosing, selling or sharing personal information; the categories of third parties to whom the Company discloses, sells, or shares personal information; and the categories of personal information the Company has disclosed, sold, or shared about you for a business or commercial purpose. You also have a right to confirm whether the Company processes your personal information, and to access and receive a copy of the specific personal information the Company has collected about you.
  • Right to Correction. You have a right to request correction of any inaccurate personal information the Company holds about you.
  • Right to Deletion. You have a right to request deletion of your personal information, subject to exceptions under applicable laws.

You can assert these rights only where the Company has received a verified request from you. To make requests, or if you have a question regarding the Company’s privacy practices, please contact Privacy@AsEver.com.

  • California Do Not Sell or Share My Personal Information. The Company may engage in certain marketing activities that may be considered "selling" or "sharing" for purposes of CCPA. Do not sell or share requests specific to Company can be sent to Privacy@AsEver.com. 
  • Authorized Agents. You have the right to exercise the rights described in this section using an authorized agent acting on your behalf. They can submit a request on your behalf to Privacy@AsEver.com along with a statement, certifying as may be required, that the agent is authorized to act on your behalf. In order to verify the request, the Company may ask you to verify your identity and your authorization of the agent to make requests on your behalf.
  • Right to Non Discrimination. You have a right not to be subject to discriminatory treatment for exercising any of your rights described under this section. The Company will not discriminate against you based on your exercise of any of your rights.

The Company may deny certain requests, or fulfill a request only in part, based on the Company’s legal rights and obligations. For example, the Company may retain personal information as permitted by law, such as for audit purposes, to maintain an active account, and facilitate your requests.

You may file an appeal of the Company’s decision refusing your request to exercise your rights under this Section. Requests to change the Company’s policies or practices are not grounds for appeal. You may request an appeal of such decision by contacting the Company at Privacy@AsEver.com.

California Shine the Light. If you reside in California, you also have the right to ask the Company one time each year if the Company has disclosed personal information to third parties for their direct marketing purposes. To make a request, please send an email to Privacy@AsEver.com with the subject CALIFORNIA SHINE THE LIGHT REQUEST. Indicate in your letter that you are a California resident making a "Shine the Light" inquiry.

Personal Information Rights under US State Privacy Laws

This section applies to residents of US States outside of California that have adopted US State Privacy Laws, including Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia.

Sale and Use of Personal Information for Targeted Advertising Purposes. The Company may engage in certain marketing activities that may be considered ""targeted advertising" (as those terms are defined under applicable US State Privacy Laws).

The Company’s practices regarding targeted advertising may depend on how you interact with the Company, the services you use, and the choices you make.

Use of De-Identified Information. The Company may de-identify personal information in a secure manner when the Company determines it is appropriate as part of its business operations. The Company takes reasonable measures to maintain and use the information in a de-identified manner. The Company does not make any attempts to re-identify such information, except as permitted under applicable law.

Other Personal Information Rights under Applicable US State Privacy Laws. The Company may make the following requests in connection with your personal information, subject to the exceptions provided under the applicable US State Privacy Laws:

  • You may request to confirm whether or not the Company processes your personal information as well as to access and receive a copy of the specific personal information the Company has collected about you.
  • You may request for the Company to delete personal information the Company maintains about you.
  • You may request that the Company correct any inaccurate personal information the Company holds about you.

You can assert these rights only where the Company has received a verified request from you. The Company will take reasonable steps to verify your identity prior to responding to requests. Verification steps may vary depending on the sensitivity of the personal information and whether you have an account with the Company. To make requests, or if you have a question regarding the Company’s privacy practices, please email Privacy@AsEver.com with the subject PRIVACY REQUEST.

If you are a consumer in a jurisdiction that recognizes the ability to use an authorized agent and wish to contact the Comany through an authorized agent, the authorized agent can submit a request on your behalf at Privacy@AsEver.com along with a statement signed by you certifying that the agent is authorized to act on your behalf. In order to verify the request and your identity, the Company may ask you to verify your identity.

If you are in a jurisdiction that recognizes your ability to appeal a decision the Company has made in connection with your attempt to assert a right under applicable US State Privacy Laws, you may file an appeal of the Company’s decision refusing your request to exercise your rights under this Privacy Notice. Requests to change the Company’s policies or practices are not grounds for appeal. You may request an appeal of such decision by contacting the Company at Privacy@AsEver.com. Please provide the state that you are writing from, accompanied with documentation you may have regarding the matter you are appealing. Your jurisdiction may allow you to file a complaint with the state’s Attorney General’s Office regarding any concerns with the result of your appeal request.

Your Nevada privacy rights. If you are a Nevada resident, you can request that the Company not "sell" your "covered information" (as defined in applicable Nevada law). To make such a request, you may send an email to Privacy@AsEver.com with the subject NEVADA PRIVACY REQUEST.

Personal Information Rights Under Canadian Law

This section applies to residents of Canada.

Residents of Canada have privacy rights that may vary based on the province/territory in which you live. Under certain circumstances and subject to applicable laws, supported by a written request and proof of identification, you may:

  • access the personal information about you that the Company has collected, used or disclosed,
  • ask that such information be corrected, and/or
  • withdraw your consent to the Company’s disclosure or use of your information. Withdrawing your consent will not affect the lawfulness of any processing the Company conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

As required or permitted by applicable law, you may be entitled to additional rights, including:

  • the right to control the dissemination of your personal information;
  • the right to receive computerized information collected from you in a structured, commonly used and technological format and to have this information transferred directly to another organization;
  • the right to be informed of and submit observations regarding automated decision-making; and
  • the right to request further information about personal information processing.

Finally, you also have a right to lodge a complaint with a competent data protection authority, in particular in the region where you normally reside, where the Company is based or where an alleged infringement of data protection law has taken place.

To exercise any of these rights, please contact the Company as set forth in the "Contact Us" section above.

Use of De-Identified Information. The Company may de-identify personal information in a secure manner when the Company determines it is appropriate as part of the Company’s business operations. The Company takes reasonable measures to maintain and use the information in a de-identified manner. The Company does not make any attempts to re-identify such information, except as permitted under applicable law.

As ever Privacy Notice

Last updated July 1, 2025

This privacy notice ("Notice") gives you information on how As ever (the "Winery") collects and processes your personal information through your use of the Website and through any other interactions or communications with the Winery (collectively, the "Services").

By using, engaging with, browsing on, and/or purchasing items via the Website, or otherwise contacting the Winery or using its Services, you agree to this Notice. If you do not accept this Notice and/or any updates to this Notice, please do not access or shop via the Website or use its Services. For clarity, residents of the European Economic Area ("EEA") and the United Kingdom ("UK") are deemed to have acknowledged (rather than agreed to) this Notice.

The Website is operated by the Winery, which is located in Calistoga, California with a mailing address at 548 Market Street #59205, San Francisco, California 94503, United States. The Winery has a limited license to use certain copyrighted material in connection with the Website and the products sold herein. The Winery is the merchant of record for all transactions and will be the company that you contract with for any purchase of Website products and will handle and process your payment.

This Notice explains how your information may be used, collected, and stored as you engage with the Website. Please also refer to the Terms of Use for more details on terms and conditions governing your visits to the Website, as well as purchases made.

You must be at least 21 years of age (or the age of legal consumption in your jurisdiction) to interact with the Website, its contents, and its services.

For questions about privacy practices, this Website, or this Notice, please email at WineWebsitePrivacy@AsEver.com.

To see this Website’s California Consumer Privacy Act (CCPA) Privacy Notice, including "Notice at Collection" details, see the "Supplemental Privacy Disclosures for US Residents" section.

Click on the links below to jump to each section:

The Type of Information Collected

The Winery and its Providers (as defined in the "Disclosure of Information" section below) may collect certain information and/or content from and about you, including the following:

  • Identifiers and contact data such as name, e-mail address, postal address, postal code, telephone number (including mobile phone number), and IP address.
  • Commercial and transaction information such as products considered or purchased, as well as payment information; this may include things like size or style choices, as well as overall shopping or purchase habits.
  • Internet or other electronic network activity information such as identifiers from the devices you use to connect, the type of computer operating system, characteristics about the networks you use when you connect to the Website, referral URLs, information collected via cookies and other technologies as described below, statistics on page views or interactions with activities, browser and web server log information, the date, time, and location of your visit, log files, analytics, and your interactions with the Website and emails and other communications the Winery and its Providers may send to you.
  • Geolocation data such as IP address and shipping address.
  • Website account login credentials and payment details such as a credit card number.
  • Information you submit, provide, or post such as when you contact the Winery, complete surveys, respond to emails, or register with the Winery. Additionally, the Website may require you to disclose your date of birth and/or age in order to gain access and in order to meet the Winery’s obligations under the law; you submit this information voluntarily.
  • The Winery collects and develops inferences. Using the other pieces of personal information collected about you, the Winery may draw inferences about you, reflecting what the Winery believes to be your preferences, characteristics, predispositions, and attitudes.

If you submit any personal information relating to other people in connection with the Website, you represent that you have the authority to do so and to permit the Winery to use the information in accordance with this Notice.

How The Winery Collects Information

The Winery uses different methods to collect personal information from and about you including through:

  • Your interactions with the Winery. For example, when you register for an account with the Winery, contact the Winery, or purchase items via the Website.
  • Automated technologies. The Winery may collect personal data via cookies and other tracking technologies on its Website. Please see the "Cookies & Other Technologies" section of this Notice to learn more.
  • Third parties. The Winery may collect information from its service providers or partners, including its Providers and social media platforms.
  • The Winery combines information. The Winery may combine information it gets from another party with information the Winery already has. The Winery may also aggregate your information with other individuals’ information to understand preferences and trends over time.

How The Winery Uses Information

The law in certain jurisdictions requires the Winery to have a legal basis for collecting and using your personal information. Where applicable, the Winery relies on one or more of the following legal bases:

  • Performance of a contract with you: The Winery may use your personal information where the Winery needs to perform the contract it is about to enter into or has entered into with you.
  • Legitimate interests: The Winery may use your personal information where it is necessary to conduct the Winery’s business and pursue its legitimate interests where such legitimate interests are not overridden by your interests or fundamental rights and freedoms.
  • To protect vital interest of you or another person: The Winery may use your personal information to prevent harm, help ensure safety, or respond to emergencies where necessary.
  • Legal obligation: The Winery may use your personal information where it is necessary for compliance with a legal obligation that the Winery is subject to.
  • Consent: The Winery relies on consent where it has obtained your active agreement to use your personal information for a specified purpose, for example, if you subscribe to an email newsletter.

The information the Winery collects may be used to communicate with you, provide and promote the products and services that the Winery offers, and to process and complete your transactions, purchases, returns, and inquiries. The information the Winery collects may also be used to administer the Website and Services, personalize goods and services to you, market to you, test and improve products and services, analyze data the Winery collects, identify and market to other potential customers, and develop new goods and services. This information may also be used to allow you to participate in polls, sweepstakes, promotions, and contests and to administer these activities. This information may be used to establish your account with the Website or communicate with you if the Winery offers a loyalty program.

The Winery may also use personal information as may be necessary or appropriate for certain essential purposes, including: to comply with applicable law and legal process; to respond to requests from public and government authorities, including public and government authorities outside your country of residence; to detect, prevent, or investigate potential security incidents or fraud; to facilitate the functionality of the Website; to provide important product safety information and notice of product recalls; to enforce the Winery’s terms and conditions; to protect the Winery’s operations or those of its Affiliates; to protect the Winery’s rights, privacy, safety or property, security and/or that of its Affiliates, you or others; and to allow the Winery to pursue available remedies or limit the damages that the Winery may sustain.

If offered by the Website, you may wish to sign up to receive the Website newsletter or other promotional offers via email. You can unsubscribe from any such communications at any time by clicking on the “unsubscribe” link in the footer of the email, by emailing WineWebsitePrivacy@AsEver.com, or by following such other instructions as may be provided to unsubscribe/stop messaging. Please note that if you unsubscribe from the Winery’s marketing and promotional emails, the Winery may still send you transactional emails. These messages include responses to your questions and updates on your purchases.

For information about how the Winery uses cookies and other technologies and your choices associated with those technologies, see the "Cookies & Other Technologies" section of this Notice below.

Cookies & Other Technologies

The Website uses cookies and other technologies for various reasons, like making it easy to access the Winery’s services by remembering you when you return; to personalize content and advertising and assist in marketing campaigns; to improve the functionality of the Website; to provide, analyze, understand and enhance the use of the Winery’s Services; to enforce the Winery’s terms; to prevent fraud; to improve site performance, monitor visitor traffic and actions on the Website; to deliver and tailor marketing or advertising on the Website and on third party sites; for measurement of advertising performance; and to understand interactions with the Winery’s emails, marketing, and online ads on third party sites.

A cookie is a small file of letters and numbers that the Winery stores on your device when you browse and use the Website and online services. In addition to cookies, the Website may use other technologies like scripts, plugins, tags, device fingerprints, Local Stored Objects, beacons, and pixels. Like cookies, these other technologies may store small amounts of data on your device. Web beacons (also known as clear gifs or pixel tags) often work in conjunction with cookies.

You can modify your browser settings to control whether your computer or other device accepts or declines cookies. If you choose to decline cookies you may not be able to use certain features of the Website, or certain Website functionality. You can delete cookies from your browser; however, that means that any settings or preferences managed by those cookies will also be deleted and you may need to recreate them. Depending on your mobile device, you may not be able to control tracking technologies through settings. The emails the Winery sends may include a web beacon or similar technology that lets the Winery know if you received or opened the email and whether you clicked on any of the links in the email.

For more information about cookies set through the Winery’s Website, as well as other types of online tracking (including the collection of information by third parties about your online activities over time and across third-party web sites or online services for online interest based advertising), and to exercise choices regarding them, click on the Cookie Preferences link in the footer of any Website page. At this time, the Winery does not respond to web browser "do not track" signals.

Google Analytics. The Website may use Google Analytics, a web analytics service offered by Google. Google Analytics assists the Winery in gathering analytics and statistical data in connection with the Website. Google processes this information on the Winery’s behalf to analyze the usage of the Website, create reports on the Website activities, and provide other services related to the Website and internet usage for the Winery. If you have any questions or concerns with regard to Google Analytics’ privacy practices, or would like information about the options Google offers to control these practices, you can review their privacy policy at https://policies.google.com/privacy.

Social Partners. If you interact with the Website on social media platforms (e.g., Meta platforms like Facebook or Instagram, TikTok, Twitter, Pinterest, Snap), the Website may collect your public profile information, which includes your username, as well as first and last name. The Website might also collect other information from the Facebook platform specifically; if so, you will be prompted about what specific information will be collected when you connect to the Website for the first time.

Social plugins. The Website may give you the option to share information by email, social or other sharing applications, using the clients and applications on your smart device. Social plugins (including those offered by Facebook, Twitter, Instagram, and Pinterest) allow you to share information on those platforms. Social plugins and social applications are operated by the social network themselves and are subject to their terms of use and privacy policies.

Disclosure of Information

The Winery may disclose your information for certain purposes and to third parties, as described below:

  • The Winery may share your information among entities under control of one or more of the persons or entities that owns or controls the Winery ("Affiliates" and together with the Winery, "Winery Entities"), as well as with owners of Winery Entities and affiliates and joint venture partners of Winery Entities, for or in connection with all purposes described in this Notice.
  • The Winery may use other companies, agents, or contractors ("Providers") to perform services on its behalf or to help the Winery to provide the Website, products, or Services to you. For example, the Winery may use Providers to provide infrastructure and IT services (like hosting the Website), or to facilitate commercial transactions. The Winery may share your information with Providers and authorize Providers to use information on the Winery’s behalf to provide their services. The Winery and its Providers may also disclose and otherwise use information where the Winery or such Providers reasonably believe such disclosure is needed to (A) satisfy any applicable law, regulation, legal process, or governmental request, (B) enforce this Notice, including investigation of potential violations thereof, (C) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, or (D) protect against harm to the rights, property or safety of Winery Entities, Winery content partners, users or the public, as required or permitted by law.
  • The Winery may share information with third parties and partners, including, for example, those who co-sponsor a promotion or promote the Winery’s products. Some of these third parties and partners may send you information about products and services by mail, email, or text message. They may share your information with other third parties. The Winery may also share the above categories of personal information with companies that help the Winery with its marketing efforts, including social media platforms, advertising networks, and ad tech companies. For example, the Winery may share email addresses or other contact information with social media platforms so they can serve the Winery’s advertising to you on their platform. Personal information received by the Winery’s partners and other parties may also be subject to their privacy policies.
  • If all or any part of the Winery’s business is acquired by a third party, the Winery may include personal information as part of that transaction, which may include some or all categories of your personal information. The Winery may also share your personal information if there is a change to the Winery’s corporate structure. The Winery may also share your information with third parties as they conduct diligence of the Winery’s corporate changes.
  • If, in the course of sharing information, the Winery transfers personal information to countries outside your region, the Winery will take steps to ensure that the information is transferred in accordance with this Notice and in accordance with the applicable laws on data protection.

International Data Transfers

Personal information the Winery collects from you may be transferred to, processed in, or stored in the United States or another destination outside of the EEA, UK, Canada, or other regions with comprehensive data protection laws. As a result, this information may be subject to access by and disclosure to government and law enforcement agencies in those countries according to their laws. If, in the course of sharing information, the Winery transfers personal information to countries outside your region, the Winery will take steps to ensure that the information is transferred in accordance with this Notice and in accordance with the applicable laws on data protection, including appropriate EU/UK standard contractual clauses. Please contact the Winery if you would like more details about its safeguards for data transfers.

Security Practices

The Winery uses administrative, logical, physical and managerial measures to help safeguard your information against loss, theft and unauthorized access, use and modification. Even though the Winery has taken steps to help protect the information in its control, you should know that it cannot fully eliminate security risks associated with personal information. No security measures can provide absolute protection. The Winery cannot ensure or warrant the security of any information you provide to the Winery.

Your Information and Rights

By law, you may have certain rights when it comes to your personal information. The rights you have depend on the jurisdiction in which you are based. Some of these rights apply generally, while others will only apply in certain circumstances. Further information and advice about your rights can be obtained from the data protection regulator in your country. For all rights, the Winery usually acts on requests and provides information free of charge, but, where allowed under the law, the Winery may charge a reasonable fee to cover its administrative costs of providing the information for baseless or excessive/repeated requests, or further copies of the same information. Alternatively, the Winery may be entitled to refuse to act on the request in some circumstances. The Winery will try to respond as soon as it can. Generally, this will be within one month from when the Winery receives your request but, if the request is going to take longer to deal with, the Winery will come back to you and let you know. The Winery may need to request specific information from you to help the Winery verify and confirm your identity.

You may request to exercise the following rights:

  • Right to be informed. You have the right to be provided with clear, transparent, and easily understandable information about how the Winery uses your information and your rights. This is why the Winery is providing you with the information in this Notice.
  • Right of access. You can request access to your personal information and check that the Winery is lawfully processing it.
  • Right to rectification. You can correct or update out-of-date or inaccurate personal information the Winery holds about you.
  • Right to erasure. The Winery can request removal or deletion of your personal information, where there is no compelling reason for the Winery to keep using it.
  • Right to restrict processing. You have rights to 'block' or suppress further use of your information. When processing is restricted, the Winery can still store your information, but may not use it further.
  • Right to data portability. You have rights to obtain and reuse your personal information for your own purposes across different services.
  • Right to object to processing. You can object to certain types of processing, including processing for direct marketing or where the Winery is relying on its legitimate interests.
  • Right to lodge a complaint. You have the right to complain to a data protection authority about the Winery’s collection and use of your personal information.
  • Right to withdraw consent. If the Winery has collected and processed your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing the Winery conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

You can request to exercise these rights only where the Winery receives a verified request from you. To make requests, or if you have any other question regarding the Winery’s privacy practices, please contact WineWebsitePrivacy@AsEver.com with the subject PRIVACY REQUEST. The Winery responds to all requests the Winery receives from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

You may also opt out of promotional emails and text messages. You may choose to provide the Winery with your email address for the purpose of allowing the Winery and its Affiliates to send communications and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, the Winery may still send you service-related communications. Additionally, if you receive a text message from the Winery that contains promotional information or other special offers, you can opt-out of receiving future text messages by replying “STOP.” After you text “STOP,” the Winery may send an SMS reply to confirm, at which point you will no longer receive SMS messages from the Winery. Carriers are not liable for delayed or undelivered messages. Message and data rates may apply. See the Winery’s Terms of Use for more information about the Winery’s Text Message Programs.

Data Retention

The Winery may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for the Winery’s billing or records purposes and to fulfill the purposes described in this Notice. Specifically, the Winery retains information for its legitimate interests and business purposes, such as operating, maintaining and improving the Winery’s services; complying with the Winery’s legal obligations; and exercising the Winery’s legal rights and remedies, including enforcing the Winery’s Terms of Use. The Winery’s retention of information is based on many factors such as your relationship with the Winery; the nature of the information; compliance with the Winery’s legal obligations; defending or resolving actual or anticipated legal claims. The Winery may take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.

Changes to this Notice

From time to time, the Winery may change or update this Notice. The Winery will post an updated copy on the Website and update the "Last Updated" date at the beginning of this Notice. Please check the Website periodically for updates.

Third Party Websites

The Website may contain links to other websites owned and operated by third parties ("Third Party Website(s)"). These links are provided to you as a convenience only and visiting any Third Party Website is at your own risk. The Winery is not responsible for the content on such Third Party Websites, and makes no representations or warranties with respect thereto. Your access and use of any such Third Party Websites is subject to their terms of use and privacy policies.

Contact Us

If you have questions about the Winery’s collection, use, and disclosure of your personal information or the privacy practices described in this Notice, you may email WineWebsitePrivacy@AsEver.com.

Supplemental Privacy Disclosures for US Residents

These disclosures apply to consumers who reside in states that have adopted comprehensive consumer privacy laws that are in effect (collectively "US State Privacy Laws") and supplements this Notice, to the extent applicable. Because of differences in certain state laws, this supplement is broken into two sections, California Consumer Privacy Act (CCPA) Specific Notices, applicable to California residents only, and other State Specific Sections, which may apply to residents of one or more states with consumer privacy laws requiring such information.

California Consumer Privacy Act (CCPA) Specific Privacy Notice

Notice at Collection

At or before the time of collection, the California Consumer Privacy Act ("CCPA") requires businesses to provide a notice of certain practices, including the categories of personal information collected and the purpose for which such information is collected or used (as stated in the "Personal Information Collected By The Winery" and "Use of CCPA Personal Information" sections), whether such information is "sold or shared" (as stated in the "Categories of CCPA Personal Information Sold or Shared" section), and the criteria used to determine how long such information is retained (in the "Data Retention" section). The Winery has provided these details throughout this section of the Privacy Notice.

Personal Information Collected By The Winery. The Winery collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("CCPA personal information"). The Winery has collected categories of CCPA personal information noted in the "The Type of Information Collected" section of this Notice within the last twelve (12) months.

Use of CCPA Personal Information. The Winery uses categories of CCPA personal information listed above for the purposes noted in the "How The Winery Uses Information" section of this Notice.

Categories of CCPA Personal Information Disclosed for a Business Purpose. The Winery discloses the categories of CCPA personal information noted in "The Type of Information Collected" section of this Notice for business purposes, including, for example, the following categories of third parties: Providers, other Winery Entities, an entity engaged in connection with a business transfer, law enforcement, courts, governments and regulatory agencies.

Sources of CCPA Personal Information. The Winery explains its sources of information in the "The Type of Information Collected" section of this Notice.

Sensitive CCPA Personal Information. The Winery may collect Website account login credentials and certain payment details, which may be considered Sensitive Personal Information as defined by the CCPA. The Winery does not use or disclose Sensitive Personal Information for any purpose inconsistent with the CCPA.

Categories of CCPA Personal Information Sold or Shared. The Winery may engage in certain marketing activities (such as behavioral advertising promoting the Website through use of cookies) using identifiers, which may be considered "selling" or "sharing" for purposes of CCPA. If you do not wish for the Winery to sell or share your CCPA personal information, you can learn how to make applicable choices by clicking "Do Not Sell or Share My Personal Information". The Winery does not knowingly sell, share or use the personal information of minors under 16 years of age.

Data Retention. The Winery may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for the Winery’s billing or records purposes and to fulfill the purposes described in this Notice. Specifically, the Winery retains information for its legitimate interests and business purposes, such as operating, maintaining and improving its services; complying with its legal obligations; and exercising its legal rights and remedies, including enforcing its terms of use. The Winery’s retention of information is based on many factors such as your relationship the Winery; the nature of the information; compliance with the Winery’ legal obligations; defending or resolving actual or anticipated legal claims. The Winery may take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.

Your California Privacy Rights. California residents have certain rights with respect to your personal information, subject to the exceptions provided under the California law:

  • Right to Know/Access. You have the right to request that the Winery disclose: the categories and specific pieces of personal information the Winery has collected about you; the categories of sources from which personal information are collected; the Winery’s business or commercial purpose for collecting, using, disclosing, selling or sharing personal information; the categories of third parties to whom the Winery discloses, sells, or shares personal information; and the categories of personal information the Winery has disclosed, sold, or shared about you for a business or commercial purpose. You also have a right to confirm whether the Winery processes your personal information, and to access and receive a copy of the specific personal information the Winery has collected about you.
  • Right to Correction. The Winery has a right to request correction of any inaccurate personal information the Winery holds about you.
  • Right to Deletion. You have a right to request deletion of your personal information, subject to exceptions under applicable laws.

You can assert these rights only where the Winery has received a verified request from you. To make requests, or if you have a question regarding the Winery’s privacy practices, please email WineWebsitePrivacy@AsEver.com.

  • California Do Not Sell or Share My Personal Information. The Winery may engage in certain marketing activities that may be considered "selling" or "sharing" for purposes of CCPA. If you do not wish for the Winery to sell or share your CCPA personal information, you can learn how to make applicable choices by clicking "Do Not Sell or Share My Personal Information". To opt out of "sale" or "sharing" via cookie-based tracking, click on the "Cookie Preferences" link in the footer of any Website page and turn off all non-essential cookies or broadcast an opt-out preference signal recognized by the Winery, such as a Global Privacy Control signal, on browsers or browser extensions that support such a signal. Your selections are specific to the device, website, and browser you are using. Your selections are deleted whenever you clear your cookies or browser's cache.
  • Right to Limit the Use of Sensitive Personal Information. As described above, the Winery collects your Website account credentials and payment details, which could be considered types of Sensitive Personal Information as defined by the CCPA. However, the Winery uses these types of sensitive personal information only for the purpose of providing the Website; administering and operating its business; and other permitted purposes as described in this Privacy Notice and not for a purpose which would require offering a choice to limit its use under the CCPA.
  • Authorized Agents. You have the right to exercise the rights described in this section using an authorized agent acting on your behalf. They can submit a request on your behalf to WineWebsitePrivacy@AsEver.com along with a statement, certifying as may be required, that the agent is authorized to act on your behalf. In order to verify the request, the Winery may ask you to verify your identity and your authorization of the agent to make requests on your behalf.
  • Right to Non Discrimination. You have a right not to be subject to discriminatory treatment for exercising any of your rights described under this section. The Winery will not discriminate against you based on your exercise of any of your rights.

The Winery may deny certain requests, or fulfill a request only in part, based on its legal rights and obligations. For example, the Winery may retain personal information as permitted by law, such as for tax or other record keeping purposes, to maintain an active account, and to process transactions and facilitate customer requests.

You may file an appeal of the Winery’s decision refusing your request to exercise your rights under this Section. Requests to change the Winery’s policies or practices are not grounds for appeal. You may request an appeal of such decision by emailing WineWebsitePrivacy@AsEver.com.

California Shine the Light. If you reside in California, you also have the right to ask the Winery one time each year if the Winery has disclosed personal information to third parties for their direct marketing purposes. To make a request, please send an email to WineWebsitePrivacy@AsEver.com with the subject CALIFORNIA SHINE THE LIGHT REQUEST. Indicate in your letter that you are a California resident making a "Shine the Light" inquiry.

Personal Information Rights under US State Privacy Laws

This section applies to residents of US States outside of California that have adopted US State Privacy Laws, including Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah and Virginia.

Sale and Use of Personal Information for Targeted Advertising Purposes. The Winery may engage in certain marketing activities that may be considered "selling," or "targeted advertising" (as those terms are defined under applicable US State Privacy Laws).

The Winery may "sell" certain categories of personal information in the "The Type of Information Collected" section. The Winery may "sell" these categories of personal information to the categories of third parties described in the "Disclosure of Information" section. The Winery’s practices regarding sale or targeted advertising may depend on how you interact with the Winery, the services you use, and the choices you make. If you do not wish for the Winery to sell or use your personal information for targeted advertising purposes, you can learn how to make applicable choices, including how to request to opt-out, by clicking the "Do Not Sell or Share My Personal Information" link in the footer of any Website page. To opt out of "sale" or "targeted advertising" via cookie-based tracking, click on the Cookie Preferences link in the footer of any Website page and turn off all non-essential cookies or broadcast an opt-out preference signal recognized by the Winery, such as a Global Privacy Control signal, on browsers or browser extensions that support such a signal. Your selections are specific to the device, website, and browser you are using. Your selections are deleted whenever you clear your cookies or browser’s cache.

Use of De-Identified Information. The Winery may de-identify personal information in a secure manner when the Winery determines it is appropriate as part of its business operations. The Winery takes reasonable measures to maintain and use the information in a de-identified manner. The Winery does not make any attempts to re-identify such information, except as permitted under applicable law.

Other Personal Information Rights under Applicable US State Privacy Laws. You may make the following requests in connection with your personal information, subject to the exceptions provided under the applicable US State Privacy Laws:

  • You may request to confirm whether or not the Winery processes your personal information as well as to access and receive a copy of the specific personal information the Winery has collected about you.
  • You may request that the Winery delete personal information the Winery maintains about you.
  • You may request that the Winery correct any inaccurate personal information the Winery holds about you.
  • You may request to opt-out of the Winery’s "sale" (as that term is defined under the applicable US State Privacy Law) or the Winery’s use of personal information for "targeted advertising" purposes. You can learn more by clicking the "Do Not Sell or Share My Personal Information" link located in the footer of any Website page.

You can assert these rights only where the Winery receives a verified request from you. The Winery will take reasonable steps to verify your identity prior to responding to requests. Verification steps may vary depending on the sensitivity of the personal information and whether you have an account with the Winery. To make requests, or if you have a question regarding the Winery’s privacy practices, please email WineWebsitePrivacy@AsEver.com with the subject PRIVACY REQUEST.

If you are a consumer in a jurisdiction that recognizes the ability to use an authorized agent and wish to contact the Winery through an authorized agent, the authorized agent can submit a request on your behalf at WineWebsitePrivacy@AsEver.com along with a statement signed by you certifying that the agent is authorized to act on your behalf. In order to verify the request and your identity, the Winery may ask you to verify your identity.

If you are in a jurisdiction that recognizes your ability to appeal a decision the Winery has made in connection with your attempt to assert a right under applicable US State Privacy Laws, you may file an appeal of the Winery’s decision refusing your request to exercise your rights under this Privacy Notice. Requests to change the Winery’s policies or practices are not grounds for appeal. You may request an appeal of such decision by emailing WineWebsitePrivacy@AsEver.com. Please provide the state that you are writing from, accompanied with documentation you may have regarding the matter you are appealing. Your jurisdiction may allow you to file a complaint with the state’s Attorney General’s Office regarding any concerns with the result of your appeal request.

Your Nevada privacy rights. If you are a Nevada resident, you can request that the Winery not "sell" your "covered information" (as defined in applicable Nevada law). To make such a request, you may send an email to WineWebsitePrivacy@AsEver.com with the subject NEVADA PRIVACY REQUEST.

Personal Information Rights Under Canadian Law

This section applies to residents of Canada.

Residents of Canada have privacy rights that may vary based on the province/territory in which you live. Under certain circumstances and subject to applicable laws, supported by a written request and proof of identification, you may:

  • access the personal information about you that the Winery has collected, used or disclosed,
  • ask that such information be corrected, and/or
  • withdraw your consent to the Winery’s disclosure or use of your information. Withdrawing your consent will not affect the lawfulness of any processing the Winery conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

The Winery’s practices regarding use of personal information for the purpose of targeted advertising may depend on how you interact with the Winery, the services you use, and the choices you make. If you do not wish for the Winery to use your personal information for targeted advertising purposes, you can learn how to make applicable choices, including how to request to opt-out, by clicking the "Do Not Sell or Share My Personal Information" link in the footer of any Website page.

As required or permitted by applicable law, you may be entitled to additional rights, including:

  • the right to control the dissemination of your personal information;
  • the right to receive computerized information collected from you in a structured, commonly used and technological format and to have this information transferred directly to another organization;
  • the right to be informed of and submit observations regarding automated decision-making; and
  • the right to request further information about personal information processing.

Finally, you also have a right to lodge a complaint with a competent data protection authority, in particular in the region where you normally reside, where the Winery is based or where an alleged infringement of data protection law has taken place.

To exercise any of these rights, please contact the Winery as set forth in the "Contact Us" section above.

Use of De-Identified Information. The Winery may de-identify personal information in a secure manner when it determines it is appropriate as part of its business operations. The Winery takes reasonable measures to maintain and use the information in a de-identified manner. The Winery does not make any attempts to re-identify such information, except as permitted under applicable law.