PAUL HOBBS SELECTIONS
PRIVACY STATEMENT
Last Modified: January 2020
At Paul Hobbs Imports, LLC (“PH”, “we”, “us”), we are committed to protecting your privacy. This Privacy Policy describes the Personal Data we collect from or about you, as well as how we use and to whom we disclose that information. Unless, related to an individual who seeks to be, is or was employed by Company, this Privacy Policy applies when you visit our website, www.paulhobbsselections.com (the “Site”), and when you use the “contact us” portion of the Site, correspond with a representative of PH via e-mail using the hyperlinks created for that purpose, respond to email campaigns by using the hyperlinks created for that purpose, make a purchase from us, subscribe to any of our mailing lists, newsletters, or wine-allocation programs, request a tasting, signing up for any of our events, or otherwise submit information to the Site. We refer to these activities, products and services collectively as the “Services.”
As used with this Privacy Policy, “Personal Data” means information that identifies a particular individual, such as name, physical address, email address, social security number or phone number.
Not Directed To Individuals Under The Legal Drinking Age
Our Site is not intended for people under the legal drinking age of 21. We do not seek or knowingly collect any Personal Data from or about individuals under the age of 21. If we become aware that we have unknowingly collected Personal Data from an individual under the legal drinking age, we will make commercially reasonable efforts to delete such information from our database.
Security
PH uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. PH cannot, however, ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once PH receives your transmission of information, we make commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
If PH learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. PH may post a notice on the Site if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach (or to withdraw your consent from receiving electronic notice) you should notify us. You may submit any questions you may have about our security procedures by emailing us at info@paulhobbsselections.com.
Information We Collect
1. Information You Provide Us
When you use our Services, you may provide us with information about you, including your Personal Data, and commercial information such as credit card information and your purchasing or consuming histories. We use this information to process your requests and to communicate with you about your orders. Additionally, we may also use your name and contact information to notify you of changes to our Site, new wines and releases, special offers, and events we think you will find valuable or of interest. If you do not wish to receive this information via email, you may opt out by clicking the “Unsubscribe” link at the bottom of the email. Alternatively, you may send an email to info@paulhobbsselections.com from the email address you would like removed and include the word “Unsubscribe” in the subject line. We may, however, use your email address without further consent for non-marketing or administrative purposes (such as notifying you of major changes to the Site or for customer service purposes). We assume that, unless you advise us otherwise, that you have consented to the collection, use and disclosure of your personally identifiable information as explained in this Privacy Policy.
You can ask to see your Personal Data. If you want to review, verify or correct your Personal Data, please contact the Company by emailing us at info@paulhobbsselections.com.
When requesting access to your Personal Data, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the Personal Data that we hold about you. We may charge you a fee to access your Personal Data; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact the Company.
Your right to access the Personal Data that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the Personal Data that we hold about you. In addition, the Personal Data may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
2. Information We Collect Through Automated Means
When you use our Services, we collect certain internet or other electronic network activity information automatically that may constitute Personal Data, as described in this section. As discussed further below, we and our service providers (which are third party companies that work on our behalf), may use a variety of technologies, including cookies and similar tools, to assist in collecting this information. We collect information on your use of the Services, such as pages visited, links clicked, non-sensitive text entered, and mouse movements, as well as information such as the referring URL, browser, browser language, operating system, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and Internet Protocol (“IP”) address. We use publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address. We use the term “Usage Data” to refer to this information about your use of any Site that we collect. Our purpose in collecting Usage Data is to better understand how our visitors use the Site and may utilize it to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Site; (b); (c) monitor the effectiveness of marketing campaigns; (d) monitor aggregate metrics such as total number of visitors, pages viewed, etc.; and (e) track your activity on the Site.
3. Information We Collect From Our Partners
We perform ongoing demographic data gathering and analysis to complete data profiles and better understand our customers. Our purpose in collecting demographic data and completing customer profiles is to better understand our customers and provide the best experiences, services and products in our offerings. We collect information that may constitute Personal Data, such as names, email addresses, phone numbers and addresses.
4. Business Purposes
We collect this Personal Data to fulfill contracts, comply with laws and for our legitimate business interests. Our purposes for collecting and using this information include:
· Performing a contract with you or to take steps at your request before entering into a contract
· Complying with legal or regulatory obligations or in response to law enforcement request
· Other legitimate interests and business purposes, such as:
o To process your transactions, maintain or service your account(s), communicate with you, schedule tastings, offer you discounts through our wine clubs, manage records, respond to court orders and legal investigations, and administer and provide services to you;
o To offer our services to you, to improve and customize our services for you and to understand how our services are used; and
o To operate, maintain and improve the Site, for example by conducting analytics
In some cases, we rely on your consent for processing your Personal Data, but only in those cases where we specifically ask for your consent.
Disclosure of Your Information to Third Parties
In addition to informing you about our own products and services, from time to time, we may also share your Personal Data and non-personally-identifiable information to our subsidiaries, affiliated companies, or other businesses or persons for the purpose of processing purchases from us and organizing such information on our behalf. PH does share non-personally-identifiable information (such as anonymous user usage data, referring / exit pages and URLs, platform types, number of clicks, etc.) with interested third-parties to assist them in understanding the usage patterns for certain content, services, advertisements, promotions, and/or functionality on the Site. PH requires that these parties agree to process such information in compliance with its privacy policy, and we use reasonable efforts to limit their use of such information and to use other appropriate confidentiality and security measures.
PH does not share your Personal Data with other, third-party companies for their commercial or marketing use without your consent or except as part of a specific program or feature for which you will have the ability to opt-in or opt-out. You may choose to opt-out of such programs or features by replying directly to the third-party company in accordance with their procedures. PH is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. If you experience issues with these third-party companies, please call them directly. We may enter into relationships with third-party advertising companies to drive traffic to and serve ads on our Site. These third-party companies may also collect information through the use of their own cookies and other technology (including JavaScript and web beacons) to measure the effectiveness of their ads and to personalize advertising content. We do not have access to or control over cookies or other features used by these advertisers, and their information practices are not covered by this Privacy Policy. Please contact them directly for more information about their privacy practices.
PH may release personally identifiable information and/or non-personally-identifiable information if required to do so by law, or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. Copyright Law), respond to a court order, subpoena, or search warrant, or have a good faith belief that access, preservation, or disclosure of such information is reasonably necessary to protect the rights, property, or safety of our Company, its customers, or the public, or that it is appropriate or necessary to take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Site, and to protect the rights, property, or personal safety of PH, our users or others.
Aggregate Information
We may track visits to the pages and links on our Site so we can make decisions about its design and usage. We may choose to share this aggregate and de-identified information on consumer behavior to third parties.
Cookies And Related Technologies
As part of our ongoing efforts to ensure the best possible experience for all users of our Site, we may use “cookies” and related technologies, such as tags, SDKs, tracking pixels, and other similar technologies to collect the information described in “Information We Collect Through Automated Means.” “Cookies” are small pieces of information (a small text file containing a string of alphanumeric characters) that are sent to your computer that uniquely identifies your browser. PH may use both session cookies and persistent cookies. A persistent cookie remains after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the Site. Persistent cookies can be removed by following your web browser help file directions. A session cookie is temporary and disappears after you close your browser. Cookies enable us to provide special features such as storing items in your shopping cart between visits, tailoring products or services offered to you based on past preferences or geographic location. Most Web browsers automatically accept cookies but allow you to turn off cookies as part of the browser options. Even without cookies, you can still use most of the features of our Site, but you will be unable to place items in your shopping cart or make purchases.
Notice Concerning Do Not Track
Do Not Track is a privacy preference that users can set in certain web browsers. We do not currently track you over time and across third party websites to provide targeted advertising and therefore the Site do not respond to Do Not Track signals.
Links to Other Websites
Occasionally, we provide links to other websites for your convenience and information. These websites operate independently from our Site and are not under our control. These websites may have their own privacy notices or terms of use, which you should review if you visit any website linked through our Site. We are not responsible for the content or use of these unrelated websites.
Other California Privacy Rights
In addition to the rights already described, California law permits customers in California to request certain details about how their information is shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business must either provide this information or permit California customers to opt in to, or opt out of, this type of sharing.
If you are a California resident, you may opt out of such future sharing of your personal information (as defined by the California Shine the Light Act) by contacting us at info@paulhobbsselections.com with the phrase “Do Not Share” in the subject line.
Individuals With Disabilities
If you have a disability and would like to access this privacy policy in a different format, you may contact us at info@paulhobbsselections.com with the phrase “Alternative Format Privacy Policy” in the subject line.
Special Note to International Users
The Site are hosted in the United States and is intended for and directed to users in the United States. If you are a user accessing the Site from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure, that differ from United States laws, please be advised that through your continued use of the Site, which are governed by U.S. law and this Privacy Policy, you are transferring your personally identifiable information to the United States and you consent to that transfer.
Updates to This Policy
The terms of this Privacy Policy may change from time to time. We will notify you of any material changes to this Privacy Policy by changing the “Last Modified” date at the top of this Privacy Policy. We encourage you to check this page periodically for any changes. Your continued use of the Site following the posting of changes to this Privacy Policy will mean you accept those changes. For revisions to this Privacy Policy that may be materially less restrictive on our use or disclosure of the personally identifiable information you have already provided, PH will attempt to obtain your consent before implementing such revisions with respect to such information.
In the Event of Merger, Sale, or Bankruptcy
In the event that PH is acquired by or merged with a third party entity, it reserves the right, in any of these circumstances, to transfer or assign the information (including personally identifiable information) it has collected from its users as part of such merger, acquisition, sale, or other change of control. In the unlikely event of PH's bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, PH may not be able to control how your personally identifiable information is treated, transferred, or used.
Governing Law
This Privacy Policy and our privacy practices will be subject exclusively to the laws of the State of California within the United States of America. We make no representation that this Privacy Policy and such practices comply with the laws of any other country. Visitors who use the Site and reside outside the United States do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. If you reside outside of the United States, by using our Site, you consent to the transfer and use of your information outside your country.
Contact Us
Any questions you may have regarding our Privacy Policy or any information about our marketing partners should be directed via email to info@paulhobbsselections.com.