In the course of offering and providing our products and services, it is common for us to receive sensitive information from and about our clients, including financial and business information, some of which constitutes personal information. Generally speaking, personal information is any information that can be used, directly or indirectly, to identify, locate or contact someone. Types of personal information include names, physical addresses, mailing addresses, social security numbers, email addresses, phone numbers, bank account numbers and driver’s license numbers. Under certain circumstances, personal information may also include other information that can reasonably link to a particular person, such as internet protocol (IP) addresses, unique device identification numbers, employment information, medical information and internet activity.
How We Collect Personal Information
Typically, we receive personal information directly from our clients or their agents in the course of performing our services. For example, customers may provide their personal information to us in order for us to process wine and other merchandise orders, process event ticket purchases or make reservations for tours, tastings or other accommodations.
We also collect personal information through our website (jordanwinery.com). For example, if you setup an account for client portal access, Jordan Estate Rewards requests, and trade visit requests on our website, we will collect information such as your name, email address, username and password, and we will receive any documents you submit through the client portal. Our web servers may also collect information from visitors such as IP address, browser type and version, time zone setting, operating system and platform. Some web browsers allow the user to send “do-not-track” signals to websites, but our website does not respond to those signals.
Our website, like most websites, employs “cookies” and similar technologies. Cookies are small files that are stored on your computer or mobile device when you visit our website and allow us to recognize your browser and obtain information about your use of our website.
Moreover, we use Google Analytics (“GA”) for aggregated, anonymized website traffic analysis. In order to track your session usage, Google drops a cookie with a randomly-generated ClientID in your browser. This ID is anonymized and contains no identifiable information like name, address, email address, telephone number, etc. We also send Google your IP Address. We use GA to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness. If you would like to access what browsing information we have—or ask us to delete any GA data—please delete your cookies, reach out to us via the contact information provided on this webpage, and/or install the Google Analytics Opt-Out Browser Add-On.
How We Use Personal Information
We use the personal information we collect from you to fulfill the purpose for which you provide it. We may also use your personal information: (1) to provide you with information, products or services that you request from us; (2) to provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you; (3) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections; (4) to improve our website and present its contents to you; (5) for testing, research, analysis and product development; and (6) for any other purpose with your consent.
Disclosure of Personal Information
We may disclose personal information we collect from you: (1) to our subsidiaries and affiliates; (2) to contractors, service providers, and other third parties we use to support our business; (3) to fulfill the purpose for which you provide it; (4) to a buyer or other successor in the event of a sale or transfer of some or all of our business or assets; (5) for any other purpose disclosed by us when you provide the information; (6) to comply with any court order, law or legal process, including responding to any government or regulatory request; (7) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections; (8) if we believe disclosure is necessary or appropriate to protect the rights, property or safety of us, our clients or others; or (9) with your consent.
We do not sell or otherwise share personal information with third parties for direct marketing purposes.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access and disclosure. The use of, and access to, your personal information by us is restricted to employees and contractors who need to know that information to provide services to you. We maintain physical, electronic and procedural safeguards to limit access to your nonpublic personal information.
Unfortunately, transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our website or other electronic means. Any electronic transmission of personal information is at your own risk.
This Privacy Statement does not restrict our collection, use or disclosure of any aggregated information or information that does not identify, or cannot be reasonably linked to, any individual.
Changes to Our Privacy Statement
We will post any changes we make to this Privacy Statement on our website. If we make material changes to how we treat personal information we collect from you, we will notify you by email or through a notice on our website homepage. The date this Privacy Statement was last revised is identified above. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Privacy Statement on our website to check for any changes.
Company appreciates your business. If you have questions or comments about this Privacy Statement, please call your Company contact or email us at firstname.lastname@example.org.
Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit the CCPA Privacy Notice.
No Data Collected from those under Legal Drinking Age
Our website is intended only for those of Legal Drinking Age—with a date of birth of 10/21/2000 or before. It is not intended to be used by individuals with a date of birth after that date.
As such, we do not knowingly collect information from individuals under the legal drinking age, children, or minors.
JVW recognizes that often times accounts will have more than one individual on file, with accompanying purchase history, accrued loyalty points, etc. that have been awarded to that account and not to a particular individual. We define these as “Household Accounts”, and they include any account that has multiple members on file or personal information recorded that pertains to more than one individual.
If there is an item of value associated with a household (e.g. reward points, etc.) account, requests to “break-up” the item of value of a household and assign to individual accounts can only be honored by the entire household verifying their identity and joining the request. In doing so, we cannot confirm or provide any personal information of other members on the account. We will work with our members on a case-by-case basis in these situations to determine the appropriate course of action and how best to facilitate these requests.
Website Data Collection Technologies
When you use our website, we along with our affiliates, subsidiaries and third-party service providers may use “cookies” and similar technologies (e.g., beacons, log files, pixels and Flash LSOs) (collectively, “technology”). This technology involves placing small files/code on your device or browser that serve a number of purposes, such as remembering your preferences (e.g., language) and generally improving your experience on our website. Specifically, we may use such technology for purposes such as to:
- Provide us with general analytics about our website, including demographic information in a non-identifiable form, in order to improve its performance and customize your experience;
- Support security measures, such as requiring re-login into your account;
- Allow you to engage in our social media offerings on our Website (e.g., Facebook “Like” button); and
- More effectively market our website and advertise other websites that may be of interest to you.
Where required by law, we collect your consent for the use of such technologies.
A cookie is a small text file saved on your device or browser. Some of these cookies are necessary for the functioning of our Websites (known as “Strictly Necessary” cookies), while others are not (known as “Non-Essential” cookies). Some cookies (known as “persistent cookies”) will remain on your device until you delete them, while others (known as “session cookies”) are automatically erased when you exit your Internet browser. You can set your device or browser to accept or reject most cookies, or to notify you in most situations that a cookie is offered so that you can decide whether to accept it. However, if you block cookies, certain features on our website may not function. Additionally, even if you block or delete cookies, not all tracking will necessarily stop.
We may place or recognize technology on your browser or device when you visit our website for purposes of serving you targeted advertising (also referred to as “online behavioral advertising”). We also work with third party advertising companies who place their own cookies or similar technology on your browser or device when you visit our website and other websites to serve customized advertisements to you as you browse the Internet. As noted above, you can set your device or browser to accept or reject most cookies, or at least notify you in most situations that the technology is offered.
We automatically gather log files, such as your IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data when you use our website. We may combine information in log files with your information.
Clear Gifs, web beacons, web bugs, and embedded pixels are embedded on our website and are about the size of the period at the end of this sentence. The information collected by these technologies is associated with other technology and information, but only for internal tracking purposes only.
Flash Local Storage Objects (“Flash LSOs”/”Flash Cookies”) display content based upon your preferences for how you like to view our website. Flash LSOs are different from browser cookies because of the amount of, type of, and how information is stored. Cookie management tools provided by your browser will not remove Flash LSOs. To learn how to manage privacy and storage settings for Flash LSOs, click here.
CCPA Privacy Notice
This CCP PRIVACY NOTICE supplements the information contained in the Privacy Statement of JVW Corporation d/b/a Jordan Vineyard & Winery and its subsidiaries (collectively, “Company,” “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”).
Company adopts this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this CCPA PRIVACY NOTICE.
Information We Collected
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 device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A||Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B||Personal||Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). This includes a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C||Protected||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D||Commercial||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E||Biometric||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F||Internet Activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G||Geolocation||Physical location or movements.||NO|
|H||Sensory||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I||Profession or Employment||Current or past job history or performance evaluations.||NO|
|J||Non-Public Education||Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). This includes education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K||Inferences||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||NO|
What is Not Personal Information
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
How We Obtain Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our customers, clients, or their agents. For example, from our newsletter signup form at a tasting or event.
- Indirectly from our customers, clients, or their agents. For example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly from activity on our website (www.jordanwinery.com). For example, from submissions through our website portal or website usage details collected automatically.
- From third-parties that interact with us in connection with the services we perform. For example, from ShipCompliant to determine wine shipment compliance by state.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to process wine and other merchandise orders, we will use that information to complete your order.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our customers or clients, or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
We 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 notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. At this time, all contracts are under review and will be amended. For all future contracts, when we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
|Identifiers||Name, account number, customer number, email address.|
|Personal||Name, address, telephone number, date of birth, life events, spouse, education, employment, food allergies, physical ailments.|
|Protected||Date of birth.|
|Commercial||Records of products purchased, tastings booked, Jordan Estate Rewards requests, Jordan Estate Rewards level, loyalty points accrued.|
|Internet Activity||Facebook ID, email opt out, email bounced, IP address, language, geolocation, email client, preferred email format.|
We disclose personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
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, 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.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we 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 providers 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 or services 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 seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with any other legal obligation or court-order.
- 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.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
|COMPLETE AN INTAKE FORM AT:||https://preferences.jordanwinery.com/privacy|
|EMAIL US AT:||email@example.com|
Whether submitting a request through our intake form or to our firstname.lastname@example.org address, you will be prompted to verify your identity via a link sent in an email to the address used to submit the request.
The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period.
JVW does not currently have the ability to verify identities via the use of password-protected accounts. As such, if your information is stored as that of a household with multiple members, requests to know and requests to delete information regarding the household cannot be processed unless the entire household has submitted separate verifiable requests and confirms it is still within the household. After submitting the individual requests, each member must email email@example.com and request that their Access or Deletion requests be combined with the other members of the household and instruct that their request be treated as a singular household request.
Response Timing and Format
We try to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
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.
Changes to Our Privacy Notice
We reserve the right to amend this CCPA PRIVACY NOTICE at our discretion and at any time. When we make changes to it, we will notify you through a notice on our website homepage.
If you have any questions or comments about this CCPA PRIVACY NOTICE, our PRIVACY STATEMENT, the ways we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
|CONTACT NAME||Jared Kampel|
|STREET ADDRESS||PO Box 878|
|STREET ADDRESS (cont.)||1474 Alexander Valley Road|