Last modified: June 1, 2018
Fullerton Wines ("FW") may collect some personal information at registration (“Registration Data”), such as name, postal address (including postcode/zip code), email address, payment details, member type, company name and website (if applicable), gender and age, in addition to information, namely:
I. Site activity information. We keep track of purchase history and member information updates.
II. Access Device and Browser Information. When you access the website from a computer, mobile phone, or other device, we may collect information from that device about your browser type, location, and IP address, as well as the pages you visit.
III. Restrictions on Use. We will not disclose your personal information to any third party provided, however, our obligations under this Subsection 11(4) shall not apply to information that is in the public domain through no fault of ours or the disclosure of which is required by law.
IV. Links to Third Parties. There may be links within our website to various third party websites. If you click on such a link and are redirected to a third party website, please note that any information you share will be governed by their privacy policies.
V. FW does not track or collect any sensitive information about you. This includes race, religion, ethnicity or political opinion.
FW primarily uses your information for the purpose of delivering the products and services that you have chosen and to personalize FW’s interactions with you. The use of your information is to enable FW to provide products and services to you, including:
- To fulfill your orders and agreements with us we use your personal and payment details through Vinsuite, a secure third party provider.
- To manage your access to our online content and apps, and to send you content via electronic newsletters.
- To send you service notifications related to your product or service such as subscription renewal notifications, password resets and order confirmations.
- To manage customer service queries.
- To manage your privacy preferences and to ensure you only receive communications that you have requested, which may include using your details to suppress you from communications.
- To send you administrative emails about your account, reminders for upcoming events, service changes, or new policies. These updates, changes and notifications are essential for the services that you have selected.
- To provide general location-based services (e.g. the region or country you are in) or search results for our content.
- To detect and reduce fraud including fraudulent orders.
- To run competitions, prize draws and promotions or if you attend one of our events subject to separately agreed terms, you may choose to grant a global right to FW to use your name, picture, likeness, voice, biographical information and statements, for content or other purposes on FW.
Other than where we have asked for your consent, FW mainly relies on two other separate bases to lawfully use your information. First, FW needs to use your information in certain ways to provide FW's products or services to you, in accordance with FW's agreements with you. In this case, it is necessary for FW to use your information so that FW can deliver the products or services you have chosen. Second, in certain cases, FW may use your information where necessary to further our legitimate interests, where those legitimate interests are not overridden by your rights or interests. Specifically:
- To measure customer and user response and engagement with FW's products and services such as online content, email newsletters and subscription offers. This may include the secure sharing of your information with third parties who help us to analyze and measure these things.
- To ensure our products (including websites and apps) are compatible with the browsers and operating systems used by most of FW's visitors.
- To create audience profiles specific outreach efforts. For example, certain audiences may receive notifications if the contents of the notification is considered to be of particular use or relevance to that audience.
- To detect and reduce fraudulent activity and for other security related purposes such as to help FW protect against harassment, IP infringement, crime or other security issues.
- For any purpose required by law or regulation and to verify information that we provide to third parties for compliance and audit purposes.
You have the right to object to any of the above uses of your information, please contact us if you wish to do so. We will consider all objections reasonably, but there may be legal reasons where we deem that the use of your information is still appropriate. We will explain our decision to you in a timely manner.
Data Retention: FW securely stores your information, and hold it for as long as FW needs to in order provide our services and products to you in accordance with (i) applicable law, or (ii) as long as is set out in any relevant agreement you have with us.
If you request for FW to no longer contact you, we will retain the minimum amount of information about you so that we can ensure we remove you from any future communications. Please note that if you ask us to completely remove all information about you, and you subsequently use our products and services at a later date, we will no longer be able to recognize your previous request to not be contacted, which is why we would keep it and suppress it in line with industry standards.
As the internet is a global environment and we work with third parties across the globe, collecting and using your personal information may involve the transfer of this information internationally, including outside of the European Union. By using our products and services you acknowledge and agree to your personal information being transferred in this way, including to jurisdictions outside the EEA, as applicable.
We take information security seriously and have policies and procedures in place to ensure the information we hold on you remains safe. We limit who has access to your information and ensure that those who do are bound by contracts to keep your information availability restricted and safe.