1. Collection of Information
- Commercial Information: When you make a purchase or return, we collect information about the transaction, such as product details, purchase price, and date and location of the transaction.
- Internet or Other Electronic Network Activity Information: We collect information related to your access to and use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
- Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
- Geolocation Information: We may derive the approximate location of your device from your IP address. In accordance with your device permissions, we may also collect information about the precise location of your device. You have the ability to stop the collection of precise location information at any time (see Your Choices below for details).
Finally, we may collect Other Content and Information you Share through the Services or Program when you submit information or content, such as by commenting on a blog or participating in online forums or communities, or when you otherwise interact with us.
We may also derive information or draw Inferences from you based on the information we or our partners collect. For example, we may make inferences about your location based on your IP address.
2. Information Use
We use your information for a variety of business and commercial purposes, including to:
- provide, maintain, and improve the Services;
- send you technical notices, updates, security alerts, and support and administrative messages;
- respond to your comments, questions, and requests, and to provide customer service;
- communicate with you about products, services, offers, promotions, rewards, and events offered by Wilson’s Spirits! and others, and provide news and information we think will be of interest to you;
- monitor and analyze trends, usage and activities in connection with our Services;
- detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Wilson’s Spirits!;
- facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;
- link or combine with information we get from our Services, and from others to help understand your needs and provide you with better service; maintain appropriate records for internal administrative purposes; and
- carry out any other purpose described to you at the time the information was collected or permitted by law.
3. Information Disclosure
With Service Providers. We may disclose your information to vendors, consultants and other service providers under contract who help with our business operations (such as fraud investigations, bill collection, payment processing, web hosting and operations of our Application, product fulfillment, shipment, recruitment, employment, research, IT, to process opt-out requests, to assist us in responding to consumer requests for access, deletion, or correction of information, direct mail and email distribution, site analytics and operations or legal and compliance services).
With Legal and Law Enforcement. We may share information collected about you with law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Wilson’s Spirits! customer to legal liability or if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
In Connection with a Change of Control. We may transfer or disclose your information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.
With your Consent. We may share your information with your consent or at your specific direction.
4. Additional Notice to California Residents
In accordance with the California Consumer Privacy Act (the “CCPA”), the following table summarizes our Personal Information collection, use, and sharing practices in the preceding twelve (12) months since we last updated this Privacy Notice on January 1, 2020.
Sale of Personal Information
We do not sell your Personal Information for money but we and our business partners use tracking technologies to help us to understand our customers, aggregate sales data, product preferences and services to enhance your online experience, and to customize our offerings in ways that may be deemed a “sale” of personal information under the California Consumer Privacy Protection Act (“CCPA”). This includes working with third parties such as ad networks which collect information via tracking technologies to personalize advertisements, provide us with data collection, reporting, and ad response measurement. To the extent we or our partners use such technologies on the Site, we offer an opt-out as discussed below in “Right to Opt-out of Sale of Personal Information”.
Your CCPA Rights
This Section lists the privacy-related rights (“Rights”) that California users have under the CCPA regarding their personal information. This Section describes your Rights and how to exercise those Rights.
Right to Know and Access:
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Right to Know, Access, and Delete below), we will disclose to you:
- The categories of personal information we collected about you
- The categories of sources for the personal information we collected about you
- Our business or commercial purpose for collecting or selling that personal information
- The categories of third parties with whom we share that personal information
- The specific pieces of personal information we collected about you (also called a data portability request)
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Right to Request Deletion:
You have the right to request that we delete any personal information we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Financial Incentives: However, we may offer you certain financial incentives permitted by the CCPA. They include the following:
- Promotions or Sweepstakes. We may offer sweepstakes or other promotions online or at participating stores. For more information on these events, please contact the participating stores or review the applicable rules and/or terms and conditions.
- Loyalty Program. Wilson’s Spirits offers a reward/loyalty program, where customers can earn rewards, accumulate points on purchases, access exclusive promos and be the first to know about new products and limited releases. You may cancel your membership at any time by contacting Wilson’s Spirits at firstname.lastname@example.org
How To Exercise Your Right to Know, Access, and Request Deletion
- How to Request Access to Personal Information: You may request access to your personal information twice in a 12-month period. To do so, please complete the webform in Wilson’s Spirits! Privacy Rights Portal or call (800) 789-8203. ClubBev! members can request access to their personal information at any time by logging into their accounts. In response, we will produce an Access Report detailing the personal information we have collected, disclosed, and/or sold about you. This Access Report will be delivered by mail or electronically at your request.
- Verification: Please note, we will take steps to verify your identity before fulfilling any of the above requests. If you maintain an account with us, we will verify your identity through existing authentication practices for the account (e.g., login and password). If you are not a registered member, we will verify your identity by matching two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification (e.g., browser or device ID).
Authorized Agents: You can use an authorized agent to make requests on your behalf. But we may require the agent to provide a written permission and verify his/her identity or demonstrate that he or she has power of attorney in connection with a request for access or deletion.
Do Not Track Signals: Our systems do not recognize “Do Not Track” signals to the extent received from a web browser. Because there currently is not a universally accepted technological or legal standard for recognizing or honoring DNT signals as reflections of user choice, we do not respond to them at this time. Once such technology is created and has received applicable regulatory approval, we will consider (a) whether it is possible; and (b) if so how it can be incorporated within our environment in the future.
5. Additional Notice for Nevada Residents
7. Your Responsibilities
We urge you to keep any password that you establish with us in a safe place and not to divulge it to anyone. Also remember to log out of your Account and close your browser window when you have finished your visit. This is to ensure that others cannot access your Account, especially if you are sharing a computer with someone else or are using a computer in a public place.
8. Protecting Underage Persons
Wilson’s Spirits! takes special care to protect the safety and privacy of persons under the age of 21. We do not permit anyone under the age of 21 to register with us. We also do not send email or text messaging correspondence to anyone who tells us that they are under the age of 21.
9. Links to Third Party Websites
10. Your Choices
Account Information: You may update and correct certain memberships. Account information you provide to us at any time [by logging into your account, contacting us at Contact Us, or calling (619) 474-4868. If you wish to [delete or deactivate] your account, Contact Us, or calling (619) 474-4868., but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
Location Information: When you first launch the Application that collects precise location information, you will be asked to consent to the Application’s collection of this information. If you initially consent to our collection of this location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. If you do so, our Application, or certain features thereof, may no longer function properly. You may also stop our collection of this location information by following the standard uninstall process to remove all of our Applications from your device.
Cookies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
Communications with Wilson’s Spirits: We want to communicate with you only if you want to hear from us. If you would like to update or correct your email address, mailing address home/work/mobile phone number or other contact information with us please contact our Customer Service team at (619) 474-4868.
You may also click the designated unsubscribe link at the bottom of all email advertisements to be removed from future email updates.If you previously opted-in to receiving text messages and wish to opt out of receiving text messages, please reply “STOP” to any text message from us. Once you opt-out via text message you will receive confirmation, via text message, that you will no longer receive text message communication from Wilson’s Spirits. Please note that any requests to remove or update your contact information may take up to ten to fifteen business days.
Mobile Push Notifications/Alerts: With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
11. Your Feedback