Protecting your privacy is fundamental to the way Wine Country Table, owned and operated by JVW Corporation dba Jordan Vineyard & Winery and its partners and subsidiaries (collectively, “Company,” “we,” “us,” or “our”) conduct business. Although privacy regulations require companies to inform you of their practices regarding the collection and use of your personal information, keeping client information confidential has always been our policy. We have always known that privacy is important to you, and we are committed to safeguarding your personal information. This Privacy Statement explains how we may collect, use and disclose your personal information.

PERSONAL INFORMATION

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.

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.

DATA SECURITY

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.

Protecting your information is our top priority. We maintain a physically secure office and computer network. Our office is paperless, however at times paper files are required. In those instances, paper files are scanned into our secure network. If paper copies of information are required to be retained, all documents are kept in a secure, locked location.

To combat external risk and security of our network and all data, we have implemented a VERY strict and comprehensive set of protocols for all computer and network use. These protocols include but are not limited to:

• Secure user authentication protocols
• Secure access control measures
• Encryption on public and private networks
• Encrypted and monitored laptops, portable devices and wireless devices
• Regularly scheduled deployment of security updates and antivirus patches

THIRD-PARTY PROVIDERS

Some applications and services embedded within, or linked from, our website, such as maps and social media platforms, are controlled by third-party providers. These third-parties may use cookies, alone or in conjunction with other tracking technologies, to collect information about you when you use our website or navigate away from our website. These third parties may also have privacy policies that differ from ours. For example, they may collect personal information about your online activities over time and across different websites, and other online services, and may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third-parties or their privacy practices, and this Privacy Statement does not apply to any third-party website or service you may access through our website. If you have any questions about a third-party provider’s privacy policies or advertising, you should contact the responsible provider directly.

NON-PERSONAL INFORMATION

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.

CONTACT INFORMATION

Company appreciates your business. If you have questions or comments about this Privacy Statement, please call your Company contact or email us at privacy@jordanwinery.com.

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 www.wctdev.wpengine.com/privacy.

NO DATA COLLECTED FROM THOSE UNDER LEGAL DRINKING AGE

Our website is intended only for those of over the age of 21.

As such, we do not knowingly collect information from individuals under the legal drinking age, children, or minors.

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.

Finally, we also offer and deliver services, content or interactive features through and/or using third party application programming interfaces, gadgets, and/or extensions that are hosted on our website or through other third-party websites or social networking platforms. When you use these services, content, or interactive features, or otherwise connect with, or “accept” or “allow” third party applications, networks, platforms or services through our website, you are authorizing those third parties to receive your information and additionally to potentially share any or all of your information with us, based on your privacy or other settings on the particular third-party network or platform. Any information we receive by these means will be treated and/or processed according to this Privacy Policy.

CCPA PRIVACY NOTICE

This CCPA 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

Wine Country Table collects 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:

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.wctdev.wpengine.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 Optin Monster’s popup email signup.

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.
• 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:

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:

The verifiable consumer request must:

1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
2. 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.

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. We will deliver our written response electronically to the email address provided with the request.

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 (.tsv) 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.

NON-DISCRIMINATION

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.

CONTACT INFORMATION

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: