Effective Date: February 13, 2019

Winery Exchange, Inc. dba Bread & Butter Wines (“Bread & Butter”) understands that you care about how we collect, use, and share information when you interact with our websites, social media sites and handles, email, and online services (our “Services”), and we value the trust you place in us. This Privacy Policy explains:

-the types of information we collect through our Services
-how we use and protect that information
-the types of information we may share with others and under what circumstances
-the choices you have regarding our collection, use, and sharing practices
-details regarding our use of third party cookies and other tracking technologies

We also include specific disclosures for residents of the European Economic Area and Switzerland.

This Policy applies to our websites, social media sites and handles, email, and online services, emails we send, as well as the information we collect when you interact with us through other online services or offline. It also applies anywhere it is linked. It does not apply to third-party websites and mobile applications that may link to the Services or be linked to or from the Services; please review the privacy policies on those websites and applications directly to understand their privacy practices.

For questions about our privacy practices, contact us at:
500 Redwood Blvd #200, Novato, CA 94947
(415) 382-6900
Email: customerservice@wxbrands.com.com

Information We Collect

Information you give us: Some of the Services may include features or services that permit you to enter contact information and other information about you. We collect and store any information you enter on our Services. This includes:

-Contact and demographic information when registering to use our Services.
-Payment information and associated contact information when engaging in a transaction on our site.
-Appointment bookings you carry out through our site.
-Email address information when subscribing to our email bulletins.
-Information you provide when you complete a survey administered by us or a service provider acting on our behalf.
-Information you provide when you participate in a contest or sweepstakes that we offer.
-If you contact us, we may keep a record of that correspondence and any contact information provided.

We may from time to time offer you opportunities that are sponsored or co-branded with third parties. Such content may include contests, sweepstakes or promotions. In connection with such opportunities, the relevant third parties may obtain personal information that you voluntarily submit to participate in such opportunities. We do not control these third parties’ use of such information.

Information We Collect Automatically: When you interact with the Services, certain information about your use of our Services is automatically collected. Much of this information is collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device.  This includes:

-Details of your visits to our site and information generated in the course of the use our site (including the timing, frequency and pattern of service use) including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, and how you reached our site.
-Details regarding the device you use to access our Services, including, but not limited to, your IP address, operating system and browser type.
-Information about how you interact with our ads and newsletters, including whether you open or click links in any correspondence.

Any or all of activities with regard to collecting usage information may be performed by us or on our behalf by third-parties. Specifically, we use Google Analytics to help analyze how users interact with and use our website, compile reports on website activity, and provide other services related to our website activity and usage. The technologies used by Google may collect information such as your location, time of visit, whether you are a return visitor, and any referring website. We also use Google’s DoubleClick cookie to deliver tailored advertising based on your preferences or interests across services and devices and measuring the effectiveness of ads. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here.

Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Services may not be available, work, or work as designed. You may also be able to opt out of or block tracking by interacting directly with the third-parties who conduct tracking through our Services.

You can learn more about ad serving companies and the options available to limit their collection and use of your information by visiting the websites for the Network Advertising Initiative, the Digital Advertising Alliance, and the European Interactive Digital Advertising Initiative. Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device.

Please note that opting-out of advertising networks services does not mean that you will not receive advertising while using our Services or on other websites, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms.  If you delete your cookies, you may also delete your opt-out preferences.

Your browser or device may include “Do Not Track” functionality. At this time, WX does not respond to browser “Do Not Track” signals.

How We Use and Protect Your Information

We may use the information we collect from you for the following purposes:

-To market our products and Services to you.
-To provide you with our products, including to take steps to enter into a contract for sale, process payments, fulfill orders, and send service communications.
-To enable additional features on our Services and to provide you with a personalized service.
-Create custom audiences on social media sites
-To provide you with the best service and improve and grow our business, including understanding our customer base and purchasing trends, and understanding the effectiveness of our marketing.
-To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, and to comply with legal requirements regarding the provision of products and services.

How We Secure the Information We Collect From or About You

We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services.  While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

Our Sharing of Your Information

Bread & Butter is a brand operated by Winery Exchange, Inc. As such, any personal information we collect on the Services is processed, stored, and used by Winery Exchange. Other brands owned by Winery Exchange, Inc. similarly have access to the personal information we collect. Additionally, we share information externally as follows:

Service Providers: We engage third party service providers to perform functions on our behalf such as: website, software, and data storage, content management, database management, technical integration, marketing automation, analytics, site optimization, conducting customer surveys, and payment processing.
Social Media Platforms: Where you choose to interact with us through social media, your interaction with these programs typically allows the third party to collect some information about you through digital cookies they place on your device and other tracking mechanisms. In some cases, the third party may recognize you through its digital cookies even when you do not interact with their application. Please visit the third parties’ respective privacy policies to better understand their data collection practices and controls they make available to you.
Third parties involved in advertising: We partner with third parties who assist us in serving advertising regarding the Services to others who may be interested in the Services. These third parties may use tracking technologies on our website to collect or receive information from the Services and elsewhere on the internet and use that information to provide measurement services and target ads. While we will not share information that identifies you by name with unaffiliated third parties for their own uses, such third parties may, with sufficient data from other sources, be able to personally identify you.
Third parties who offer services you may be interested in: From time to time, Winery Exchange and select companies with which we have a relationship may use your personal information to notify you of new wines and releases, special offers, and events we think you will find valuable or of interest. We may share your personal information (other than credit card information) with third parties who we believe have products and services that may be of interest to you.

Additional Information About our Data Collection and Sharing Practices

Sharing of Aggregated Data: We may analyze aggregated, de-identified data and share these analyses at our discretion, including with marketing agencies, media agencies and analytics providers. These third parties will not be able to relate this data to identifiable individuals.

Change of Ownership or Corporate Organization:We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.

Cross-border Transfer of Data: If you use our Services outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries.  The laws in the U.S. regarding personal information may be different from the laws of your state or country.  Any such transfers will comply with safeguards as required by relevant law.  By using the Services, you consent to the collection, international transfer, storage, and processing of your data.

Your Options and Privacy Rights

Please visit the “[Account Login]” page to update your contact information and payment method.

If at any time you would like to unsubscribe from receiving future emails, you can click the unsubscribe link at the bottom of any email bulletin or email us at customerservice@wxbrands.com. we will promptly remove you from all correspondence.

Your California Privacy Rights

Residents of the State of California have the right to request information from regarding third parties to whom the company has disclosed certain categories of personal information during the preceding year for the third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please email customerservice@wxbrands.com or write to us at 500 Redwood Blvd., Suite 200, Novato, CA 94947.

Information for Individuals Located in the EEA and Switzerland

We process personal data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services; and (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedom related to data privacy. Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities, as described above.

Users that reside in the EEA or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.

If you are a resident of the EEA or Switzerland, you are entitled to certain rights. Please note: In order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you. These rights include the ability:

-to request from us access to personal information held about you;
-to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
-to ask for data to be erased if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing; and
-to request that we restrict our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.

To submit a request to exercise your rights, please contact us at customerservice@wxbrands.com. We may have a reason under the law why we do not have to respond to your request, or respond to it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Changes to This Policy

We may make changes to this Policy from time to time. We will post any changes, and such changes will become effective when they are posted. Your continued use of our Services following the posting of any changes will mean you accept those changes.

NOT DIRECTED TO PERSONS UNDER THE LEGAL DRINKING AGE

Our websites and Services are not intended for or directed to persons under the age of 21, and we do not knowingly collect information from persons under the age of 21. If we become aware that a person under the age of 21 has provided us with personal information, we will delete such information from our database.