This document constitutes a binding agreement (the “Privacy Policy” ) between Club dVIN Limited (“us”, “we”, “our” or “Club dVIN”) and all visitors, users, and others who reside in the United States (“consumers” or “you”) regarding the collection and processing of personal information in the course of our in-person interactions with you and by means of the website accessible via the domain clubdvin.com and our mobile application (collectively, the “Digital Platforms”), and in connection with the provision of Products and Services (as those terms are defined in the Terms of Use).
We consider the privacy of your data and information, whether corporate or personal, to be of paramount importance. Information we gather from you as a consumer not only enables the transactions and interactions between us, but also helps us continually improve your experience with us and keep you informed of exciting new products, upcoming events and other services that might interest you.
In the course of our in-person interactions with you, and via our Digital Platforms, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). Personal Information does not include publicly available information from government records or de-identified or aggregated consumer information. Club dVIN obtains Personal Information either directly from you, or indirectly from you.
The Personal Information we collect includes:
We offer sign-on services that allow you to use third party login credentials to access our Digital Platforms. You may choose to provide us with access to certain personal information stored by such third-party websites. The personal information we have access to varies by website and is controlled by your privacy settings on that website and your consent. By associating an account managed by a third party with your Club dVIN account and authorizing us to have access to this information, you agree that we may collect, use, and store information from these websites in accordance with this Privacy Policy.
From time to time, Club dVIN will issue non-fungible tokens (NFTs) in connection with special events or Products sold by our service partners (“Tasting Tokens”). One feature of such Tasting Tokens is that they include geolocation data connected to tasting event or wine product. When participating in our events and acquiring Tasting Tokens, such geolocation information will be entered onto the blockchain.
When you visit our Digital Platforms, the following information about your visit is automatically collected by us, as it is sent by your browser or the mobile application:
The aim of this automatic collection and processing is to obtain visit statistics to improve our Digital Platforms and your experience as a customer. In particular, we use IP addresses to analyze trends, administer the Digital Platforms and gather broad demographic information for aggregate use.
We also collect and use cookies when you use our website. A cookie is a piece of data stored on your hard drive containing information related to your visit to various websites. We use cookies on certain of our pages to help analyze our web page flow, customize our Products and Services, content and advertising, measure promotional effectiveness and promote trust and safety. Cookies track your movement on our website, including what you view and your transactions and purchases. They help us improve and personalize your experience.
A few important things you should know about our use of these technologies are that:
We use a tool called “Google Analytics”, and tools within it such as Google Tag Manager and Google Firebase Analytics, to collect information about the use of our Digital Platforms. Google Analytics collects use information regarding how often users visit the Digital Platforms, what device they are using and what pages they visit when they do so, and what other sites they visited prior to coming to our website. We use the information we get from Google Analytics to improve our Digital Platforms. Google Analytics collects only the IP address assigned to you on the date you visit our Digital Platforms, rather than your name. Google’s ability to use and share information collected by Google Analytics about your visits to the Digital Platforms is restricted by the Google Analytics Terms of Use and the Google Privacy Policy, found here.
We also use a tool called “Hotjar” to collect information about the us of our Digital Platforms. Hotjar collects information about how users interact with our website, including by hovering over or clicking on links. Hotjar collects only the IP address assigned to you on the date you visit our Digital Platforms, rather than your name. Hotjar’s ability to use and share information collected by Hotjar about your visits to the Digital Platforms is restricted by the Hotjar Terms of Use and Hotjar Privacy Policy, found here.
You may disable cookies that are not strictly necessary, including Google Analytics and Hotjar for the Digital Platforms by selecting “configure cookies” on the cookie banner when you access the Digital Platforms. By visiting the Digital Platforms without disabling this function, you accept the use of these cookies.
We may use, sell, or disclose the personal information we collect for one or more of the following purposes, including to third parties as described below:
Club dVIN will not collect additional categories of Personal Information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you with prior notice.
We may share your information with third parties (i) in order to connect you with additional products or services that may interest you, (ii) in connection with hosting our live events, and (iii) to improve the manner in which we promote our Digital Platforms, Products and Services. We also share aggregated information with analytics services to market our Products and Services more effectively.
We outsource certain activities such as order shipments, marketing assistance, postal and email delivery, customer service, and data analysis, and we use a credit card processing company to bill users for goods and services. These companies do not retain, share, store or use Personal Information for any secondary purposes and are not allowed to use Personal Information except for the purpose of providing these services. Our agreements with these third parties contain data protection clauses that guarantee appropriate customer safeguards.
We share your Personal Information with the following categories of third parties:
In order to use certain features of our Digital Platforms and to participate in certain other in-person events, you must register for a user profile and be granted a username and password.
If your password has been compromised for any reason, you should immediately notify Club dVIN and change your password. We will never request your password or other highly sensitive information via e-mail. If you receive an e-mail or other correspondence requesting that you provide any sensitive information (including your account password, credit card information, or private key) via e-mail or to a website that seems suspicious, please do not provide such information and report the request to us.
We have implemented appropriate security measures to protect your personal information, both online and off-line. These include firewalls, IP blacklisting, protections from brute force attacks, and other general security practices such as disabling ping-backs and track-backs. We also utilize sophisticated third-party providers for secure server infrastructure, as well as other generally accepted physical safeguards.
We will not knowingly collect personal information from any person that is actually known to us to be a child under the age of 16. IF YOU ARE UNDER 16 YEARS OF AGE, PLEASE DO NOT USE OR ACCESS THE DIGITAL PLATFORMS AT ANY TIME OR IN ANY MANNER.
We reserve the right to amend this Privacy Statement at our discretion and at any time. When we make changes to this Privacy Statement, we will notify you through a notice on the Digital Platforms homepage.
If you have any questions or comments about this Privacy Statement, the ways in which we collect and use your personal information, or your choices and rights regarding such use, please do not hesitate to contact us at info@clubdvin.com.
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