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SEVEN APART PRIVACY POLICY

1. Acceptance of Privacy Policy

Welcome to Seven Apart (“Seven Apart,” “we,” “our,” or “us”) and our Privacy Policy (“Privacy Policy”). This Privacy Policy is important and affects your legal rights, so please read carefully.

At Seven Apart we recognize that protecting the privacy and security of the personal information we collect about you in the course of using our website, https://sevenapart.com/ (“Website”), an important responsibility. This Privacy Policy governs Seven Apart’s Website, its subdomains, any websites of our brands (including, Seven Apart), and all portals, applications, products, services, events, and any interactive features, applications, or other services (collectively, “Services”). This Privacy Policy does not apply to other websites or platforms that have a different privacy policy.

As a general principle, information you provide to us will only be used or shared by Seven Apart as outlined in this Privacy Policy. By visiting or using the Services, you agree to the practices and policies set forth in this Privacy Policy. If you do not agree to the terms of this Privacy Policy, you may not use the Services.

2. KINDS OF INFORMATION COLLECTED BY US AND HOW WE COLLECT YOUR INFORMATION

We collect two basic types of information from you in conjunction with your use of the Services – Personal Information and Automatically Collected Information (collectively, “Information”).

Personal information” is any information that can individually identify you and includes, as an illustrative example and without limitation, name, address, email address, phone number, username, password, date of birth, and credit card information. We collect no Personal Information about you unless you specifically and knowingly provide it. “Automatically Collected Information” includes information that does not personally identify you, but may include, as an illustrative example and without limitation, tracking and usage information about your location, use of the Websites, Application, and the Internet, etc.

Personal Information

There are a number of circumstances in which you voluntarily supply us with your Personal Information. The following lists the most common ways in which we collect your Personal Information:

• When you send us a request for more information about the products, services, and information listed on the Seven Apart Website using the “Inquiries” link;

• When you join our mailing lists or newsletters;

• When you sign up to join our Allocation List;

• When you sign up for a Member Account with us;

• When you purchase a product from, or place an order with us and in order for us to ship you our products;

• When you sign up for our promotions and giveaways;

• When you register for one our programs or events;

• When you request a tasting or contact us for other similar business purposes;

• When you sign up to be a part of our Influencer Program;

• When you sign up to be a Banks’ Insider;

• When you send an email to our webmaster, so that we may respond to your message;

• When you register for an account on one of our Websites;

• When you submit employment-related information provided on job applications submitted through the Website or electronically, including for example, job preferences, work history, and other Personal Information;

• When you participate on social media accounts involving Seven Apart;

• When you submit questions, comments, or feedback through the Website, or otherwise; or

• When you submit or knowingly volunteer Personal Information on any other place while using the Services.

Automatically Collected Information

Some information is automatically received and sometimes collected from you when you visit or use the Websites or Services. The following lists the most common information that is automatically received or collected:

• The name of the domain and host from which you access the Internet, including the Internet Protocol (IP) address of the device you are using and/or the IP address of your Internet Service Provider (ISP);

• The type and version of Internet browser software you use and your operating system;

• Websites visited before or after you visit our Website;

• The date and time you access the Website, the length of your stay, the specific pages that you access and number of “clicks” while visiting the Websites; and

• Information concerning the country of origin of your device and the language(s) used by it.

We use this information to monitor the usage of our Website and Services, assess performance, ensure technological compatibility with your device, understand the relative importance of the information provided on the Website and Services, and to improve your customer experience. We may also use this data to conduct statistical analyses on visitors’ usage patterns and other aggregated data and gather demographic information We may collect this information in an anonymous and aggregated format, meaning, it is not linked to any Personal Information. We may also choose to share this aggregate information about consume behavior to third parties, but as stated, it is not linked to any Personal Information.

Cookies

As part of our ongoing efforts to ensure the best possible experience for all users of our Website, we may use “cookies” to collect anonymous, non-personally identifiable information about your visit, including your IP address, browser type, operating system, access dates and times, referring website address, and browsing activity. We use “cookies” to identify repeat visitors to our Website. “Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. Cookies enable us to provide special features such as storing items in your shopping cart between visits or tailoring products or services offered to you based on past preferences or geographic location. Even without cookies, you can still use most of the features of our Site, including placing items in your shopping cart and purchasing them.

Most Web browsers automatically accept cookies, but allow you to turn off cookies as part of the browser options. Please consult the “Help” section of your browser for more information. Please note that by blocking any or all cookies, you may not have access personalization available through the Website.

Analytics and Advertising

We, as well as third-party vendors acting on our behalf (such as Google and Hotjar), may use first-party cookies (such as the Google Analytics cookies) and third-party cookies or other third-party identifiers to gather anonymous analytics and statistics about our Website and how it is are being used by our visitors so we can improve our Website. Our web server storage logs may collect the domain names, internet protocol addresses, the types of web browsers, and certain data of visitors to the website.

We may enter into relationships with third-party advertising companies to drive traffic to and serve ads on our Website. These third-party companies may also collect Automatically Collected 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.

We and these third-party vendors, including Google, may use third-party technologies (such as a Facebook Custom Audience Pixel) together with our own first party technologies in order to analyze ad impressions, your use of ad services, and interactions with these ad impressions and ad services. The information collected may also include information about your visits to our Website, include the pages you have viewed and what content you have seen. These third-party tracking technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the effectiveness of the advertisements that have been delivered to you.

You can opt out of certain advertising by visiting the Network Advertising Initiative consumer opt out page at http://optout.networkadvertising.org/, by using the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout, or by visiting the Digital Advertising Alliance’s opt-out page at https://www.aboutads.info/choices. Please note, at this time we do not respond to browser-based “do not track” signals.

Social Media Sites

When you interact with Seven Apart on or through a social media platform, such as Facebook, or Instagram, we collect the Personal Information that you make available to us on that page or account, including your user ID and/or username, and any information you have made public in connection with that social media service. Please note, however, that we will comply with the privacy policies of the corresponding social media platform and we will only collect and store such Personal Information that we are permitted to collect by these social media platforms.

Our Website includes social media widgets, such as Facebook and Instagram widgets. These features collect Automatically Collected Information about your IP address and which page you’re visiting on our Websites, and they set a cookie to make sure their features function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Websites. Your interactions with those features are governed by the privacy policies of the companies that provide them.

3. HOW WE USE YOUR INFORMATION

We use the Information we collect from you and about you to help us personalize and continually improve your experience with our Services. You have no obligation to provide us with any of your Information, but you may not be able to use or access certain portions of the Website or the Services if you do not provide us with your Personal Information (and you cannot use our Website or Services without agreeing to the terms of this Privacy Policy).

As non-limiting examples, we use the Information we collect from and about you in the following ways:

• To provide the features, products, and services you request;

• To facilitate your registration for an account with us;

• To notify you about promotions, giveaways, new wines, released, special offers, and events we think you will find valuable or of interest;

• To notify you of changes to our Website;

• To communicate with you and provide you with information:

• To provide customer support;

• To ship products to you;

• To perform our obligations under a contract with you:

• To deliver to you relevant advertising:

• To provide you with other offers:

• To improve our Websites, features, products and services;

• To facilitate your application for job opportunities with us;

• To monitor the usage of our Service,

• To detect, assess, prevent and address technical and performance issues,

• To assist, when necessary, in protecting our rights or property, enforcing the provisions of our Privacy Policy, or preventing harm to you or others,

• To conduct statistical analyses on visitors’ usage patterns and other aggregated data;

• To deliver to you relevant advertising from use of demographic and preference information such that advertising related to our Services is targeted to the users for whom they are most pertinent, and

• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information.

We may contact you by email or other means at an email address that you have provided to us. For example, we may send you account information or promotional offers. 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 wine@beauvigne.com from the email address you would like removed and include the word “Unsubscribe” in the subject line. Or you may send a postcard to Seven Apart Wines.

We will store your Information only for as long as we need to use your information for the above purposes.

4. HOW WE DISCLOSE YOUR INFORMATION

We will only share Information as provided in this Privacy Policy, and within our company and corporate affiliates. We do not and will not sell or trade your Personal Information to any third party outside of Seven Apart.

Third-Party Marketing Disclosure

We do not sell, trade, or otherwise transfer to outside parties your Personal Information, unless we provide you with advance notice, or in the circumstances provided below. However, Automatically Collected Information may be provided to other parties for marketing, advertising, or other uses. For example, in addition to informing you about our own products and services, from time to time, we may also share your personally identifiable information with select marketing partners who offer products or services that we believe will be of interest to you. Our marketing partners may use this information to contact you directly regarding their own offers of interest. You may choose to opt-out of having your personal information shared with these third-party companies by sending an e-mail to wine@beauvigne.com with the phrase “Do Not Share” in the subject line. You may also send a postcard to Seven Apart.

Service Providers

We may make your Information available to certain third-party service providers, such as contractors or vendors, who help us manage or provide services offered on our Websites or Services, such as hosting, analytics, customer service, processing, storing, tracking, and organizing information on our behalf, etc. We may need to share your Information with them but we require that all of our service providers keep Information confidential and not disclose it to third parties and not use it for any other purpose, including direct or indirect marketing purposes.

Mailchimp

Seven Apart uses Mailchimp, on online marketing platform, to send and manage email campaigns across channels. Mailchimp processes the Personal Information you provide to us, including your name and email address, we upload our distribution list to the Mailchimp platform. For more information about Mailchimp’s privacy practices, please review the Mailchimp Privacy Policy.

When you interact with an email campaign that you receive from us, Mailchimp may collect Automatically Collected Information about your device and interaction with an email, including usage data. Mailchimp uses cookies and other tracking technologies to collect some of this information. Mailchimp’s use of cookies and other tracking technologies is discussed in more detail in its Cookie Statement.

Emergency Situations

We may also use or disclose your Information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us, the Website or Services; (b) respond to requests from public and government authorities; (c) protect and defend our rights or property, the Website, Services, or our users; or (d) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, the users of the Websites or Services or the public.

Merger, Sale, Or Bankruptcy

If we sell all or part of our business, or make a sale or transfer of our assets, or are otherwise involved in a merger or transfer of all or a material part of our business, or are involved in a bankruptcy, Seven Apart may transfer your Information to the party or parties involved as part of that transaction.

California Disclosures

If you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of Personal Information we have shared with third parties, if any, for the third parties’ direct marketing purposes, during the preceding calendar year. To request a notice, please submit your request to the contact information provided below. California law also permits residents of California to opt-out of Seven Apart’s disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes at any time by submitting a request in writing to the contact information provided below. Please note that this opt-out does not prohibit disclosure made for non-marketing purposes.

5. HOW WE STORE AND PROCESS YOUR INFORMATION

Personal information collected on our Website or through our Services are stored and processed in the United States.

The servers and databases in which information is stored may be located outside the country from which you accessed the Website or Services and in a country that does not have the same privacy laws as your country of residence. The Personal Information you provide us may be transmitted abroad for the purpose described in this Privacy Statement, but we will collect, process and use Personal Information only in accordance with this Privacy Policy.

Employment-related information and queries may be transferred internally at Seven Apart. By visiting this Website and our Services and submitting information, you consent to such collection, processing, transfer and/or storage of your Personal Information.

6. HOW WE SECURE YOUR INFORMATION

We employ reasonable security measures to protect the Information we receive from you. While we strive to create a secure and reliable site for our users, the confidentiality of any communication or material transmitted over the Internet cannot be 100% guaranteed. Users should keep in mind that any information submitted through an Internet transaction is potentially accessible to the public, and consequently, can be collected and used by others without their consent. Seven Apart is not responsible or liable for illegal interception of personal data via any Internet transaction. No transmission of information is guaranteed to be completely secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise data security. You acknowledge and agree to assume this risk when communicating with us.

7. PAYMENTS AND CREDIT CARD SECURITY

We may provide paid products and/or services within the Services. In that case, we may use third-party services for payment processing (e.g., payment processors), such as Wine Direct. We will not store or collect your complete payment card or banking details. Information may be provided directly to our third-party payment processors whose use of your personal information is governed by their respective Privacy Policies.

When we collect and transmit sensitive data such as your credit card number, we encrypt it using secure socket layer technology (SSL) and the https security protocol to communicate with your browser software. This method is the industry standard security protocol, which makes it extremely difficult for anyone else to intercept the credit card information you send to us. Seven Apart collects credit card information solely to complete a single transaction. Seven Apart does not store complete credit card information.

8. Links on Our Websites

We do not include or offer third-party products or services on our Websites or Application. The Website may contain links to other sites, such as to Facebook or Instagram. We are not responsible for the privacy practices of those sites. Links to other sites do not imply an endorsement of the materials or policies on those websites. You should read the privacy policies of each site you visit to determine what information that site may be collecting about you.

9. NOT DIRECTED TO INDIVIDUALS UNDER THE LEGAL DRINKING AGE

Our Website is not intended for people under the legal drinking age of 21. We do not seek or knowingly collect any personal information from or about individuals under the age of 21. If we become aware that we have unknowingly collected personal information from an individual under the legal drinking age, we will make commercially reasonable efforts to delete such information from our database.

Accordingly, Seven Apart respects the privacy of children and we are committed to complying with the Children’s Online Privacy Protection Act (COPPA). We also do not intentionally collect Personal Information from children. If you are under the age of thirteen (13), you may not register for an account on the Website. Similarly, if we learn that a child under 13 has provided Personal Information to us without verification of parental consent, we will take commercially reasonable steps to delete that information.

10. REVIEWING AND CHANGING YOUR INFORMATION

You may view, update or change information related to your account. Visit the My Account page on the Website and enter your account using your email address and password.

11. 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 this Website following the posting of changes to this Privacy Policy will mean you accept those changes.

12. 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 this Website 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 Website, you consent to the transfer and use of your information outside your country.

13. CONTACT US

Any questions you may have regarding our Privacy Policy or any information about our marketing partners should be directed via email to wine@sevenapart.com. You can also write us at:

Customer Service

4057 Silverado Trail

Napa CA 94558-1113