RED THUMB NATURAL WINES
Updated: October 27, 2020
Red Thumb Natural Wines (“Red Thumb”) and its affiliates, operate this website (the “Site”) and the services related to or offered on the Site (hereinafter, the “Services”). Red Thumb’s Services may include, without limitation, offering and selling goods, products, tools, applications, email services, bulletin and message boards, chat areas, news groups, forums, communities, calendars, merchandise, products and downloadable mobile applications related to the Site or provided through the Site.
The use of the phrase “Personal Information” in this Policy means information that identifies a specific person that may include as a person’s full name, address, e-mail address. The phrase “Anonymous Information” in this Policy means non-personal information that cannot reasonably be used to identify individual persons (e.g., interests, demographics, geographical location and anonymous usage data).
Unless you opt out in accordance with this policy, by visiting this Site or using the Services, you are accepting the policies and practices described in this Policy. Each time you visit the Site or use the Services, you agree and expressly consent to Red Thumb’s collection, use and disclosure of the information that you provide as described in this Policy.
Your Personal Information will be processed by Red Thumb in the United States.
In addition to this general Policy, each Service may have additional privacy provisions that are specific to the particular Service. These supplemental disclosures are made adjacent to the particular Service at the time Red Thumb collects the information. These supplemental disclosures also govern the use of your information.
In general you can use the Site and/or Service without telling Red Thumb who you are or revealing any Personal Information about yourself. However, if you do not provide Red Thumb with certain requested information, we may not be able to provide you with certain Services and features that may be contained on the Site and/or Service, including without limitation, selling the products on the Site to you.
- INFORMATION GATHERED BY RED THUMB
Red Thumb collects information about you in the following ways:
A. Information you voluntarily provide Red Thumb.
Red Thumb collects and maintains information that you voluntarily submit to Red Thumb during your use of the Site and Services and when purchasing goods, products and/or services. For example:
- When you register for the Site, certain provided information to Red Thumb will be required such as your name and email address;
- As applicable, when you post comments and/or content on the Site and/or Service information about you that accompanies those posts or content, which may include a name, user name, likes, status, profile information and/or picture. This information is always public, which means it is available to everyone and may be displayed in search results on external search engines.
- As applicable, if you sign up to enter a giveaway, contest or sweepstakes or receive a newsletter, if any, you may provide Red Thumb contact information (e.g., email or physical address);
- If you access or log-in to the Site and/or Services through a social media or other service or connect the Site and/or Services to a social media or other service, the information Red Thumb collects may also include your user ID and/or user name associated with that social media service, any information or content you have permitted the social media service to share with Red Thumb, such as your profile picture, email address or friends lists, and any information you have made public in connection with that social media service. When you access the Site and/or Services through social media services or when you connect the Site and/or Service to social media services, you are authorizing Red Thumb to collect, store, and use such information and in accordance with this Policy;
- If you purchase a good, product or service, you will be required to provide Red Thumb your credit card information and other Personal Information; and
- You may provide Red Thumb with Personal Information in the course of email, customer support interactions and surveys.
B. Information Red Thumb collects through your use of the Site.
As you use the Site and Services, certain information may also be passively collected. Through cookies, pixels and beacons for the purposes of targeted and retargeted advertising, log files and other technologies, Red Thumb may collect information about how you use the Site and the Services. For example, Red Thumb may determine through an IP address that a particular computer or device is located in Los Angeles and Red Thumb may use this information to deliver advertisements promoting Los Angeles-based businesses. This information allows Red Thumb to deliver more helpful information, programs, tools and advertisements.
Red Thumb may also combine online and/or offline information received from third parties (“Third Parties”) with the information Red Thumb has already collected from you via Red Thumb’s Site and/or Services. The third party information is used for a variety of purposes including verifying other information about you and to enhance the content and advertising Red Thumb provides to you.
Red Thumb and Third Parties may customize the advertisements that you see based upon: (i) the information that you provide Red Thumb; (ii) data Red Thumb receives from Third Parties; or (iii) your visits on the Site or use of Services and other websites or services (commonly referred to as “Behavioral Advertising”). Please see the “Cookies and Targeted Advertising” section below for more information on the use of tracking technologies and the information collected for Behavioral Advertising, and how you can delete cookies.
2. HOW RED THUMB USES YOUR INFORMATION
Red Thumb may use the foregoing information gathered in the ways described below or described at the time that the information is collected.
In general, Red Thumb and Third Parties use the foregoing information gathered as necessary or appropriate for purposes including, but not limited, to:
- administer your account;
- register you and provide you access to the Site and/or Services;
- respond to inquiries or requests in connection with the Site;
- fulfill your requests and/or orders for products or services;
- send communications and administrative emails about the Site and/or Services;
- personalize and better tailor the features, performance and support of the Site and Services for your use;
- send you Site and/or Service-related communications, including any notices required by law, in lieu of communication by postal mail. You may not opt out of Service-related e-mails.
- send you newsletters and other messages, including changes to features of the Site and/or Service and special offers that you may opt out of by clicking “unsubscribe” in the email. Opting out may prevent you from receiving email messages regarding updates, improvements, or offers.
- send you promotional/marketing information, offers or other information regarding opportunities and functionality that Red Thumb thinks would be of particular interest to you;
- improve the quality of the Site and the Services; analyze, benchmark and conduct research on user data and user interactions with the Site and Services.
- We may use and share information with those persons and third-party entities specifically involved in providing you with services from Red Thumb and/or services related to Red Thumb. In addition, we may use and share aggregated information that does not uniquely identify you when it enables us to improve and enrich our services and Site content. Red Thumb reserves the right to use and share your information in the event Red Thumb believes doing so is necessary to operate the Site or where such disclosure may be required by law, or to protect Red Thumb’s right or the rights of others.
3. COOKIES AND TARGETED ADVERTISING
A. Tracking Technologies (e.g., Cookies)
Cookies can be removed by following your Internet browser’s directions within the help tab. In order to use certain Services offered through the Site, your web browser must accept cookies. If you choose to disable cookies, some aspects of the Site or Service may not work properly, and you may not be able to access the Site and/or Services.
An “Internet protocol address” or “IP Address” is a number that is automatically assigned to your computer when you use the Internet. Red Thumb, its partners or their respective service providers, may use your IP Address when you access the Site or Services or use other means to assist with delivering geographically targeted advertisements.
B. Targeted Advertising
Red Thumb adheres to the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance (for more information click here at http://www.aboutads.info/consumers).
4. HOW RED THUMB DISCLOSES INFORMATION TO THIRD PARTIES
Red Thumb may share your information with its parent companies, affiliates, and/or subsidiaries and with Third Parties under the circumstances described below. If you do not want Red Thumb to use or disclose information collected about you in the ways identified in this Policy, you should not use the Site or Services.
We may share non-personally identifiable information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested Third Parties to help them understand the usage patterns for certain Services.
A. Government Agencies
Red Thumb may disclose and release your Personal Information to government representatives: (a) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (b) in special cases, such as a physical threat to you or others, a threat to homeland security, a threat to Red Thumb’s system or network, or in any cases in which Red Thumb believes it is reasonably necessary to investigate or prevent harm, fraud, abuse, illegal conduct or a violation or alleged violation of this Policy or other agreement Red Thumb may have with you.
B. Service Providers
Red Thumb may provide your Personal Information to service providers who work on its behalf or help Red Thumb to operate Red Thumb’s business, the Site and the Services. Examples of such service providers include vendors and suppliers that provide Red Thumb with technology, services, and/or content for sending email, analyzing data, research, providing advertising and marketing assistance, processing payments (including credit card payments), and providing customer service. Access to your Personal Information by these service providers is limited to the information reasonably necessary to perform its limited function.
C. Third Parties
Red Thumb may share aggregated Anonymous Information about you with the Third Parties. Aggregated information is your Anonymous Information that is combined with the Anonymous Information of other users.
We may store personal information in locations outside the direct control of Red Thumb (for instance, on servers or databases co-located with hosting providers). As we develop our business, we may buy or sell assets or business offerings. Customer, email, and visitor information is generally one of the transferred business assets in these types of transactions. We may also transfer or assign such information in the course of corporate divestitures, mergers, or dissolution.
Any Personal Information or other content that you voluntarily disclose becomes available to the public, as controlled by any applicable privacy or website customization settings. To change your privacy settings on the Site, you may visit your online account with Red Thumb. If you remove information that you posted to the Site, copies may remain viewable in cached and archived pages of the Site, or if other users have copied or saved that information.
D. Promotional Partners
E. Affiliated Companies
Red Thumb may share your Personal Information and/or any other information collected hereunder with its subsidiaries and affiliated companies. Additionally, in the event Red Thumb goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Policy.
Red Thumb may make message boards, chat rooms, blogs, product review forums and other interactive forums available as part of the Services. You should be aware that any information which you post to these interactive forums or otherwise choose to make publicly available, including your Personal Information, may be disclosed and available to all users who have access to that portion of the Site or Services. By using these interactive Services, you agree that Red Thumb is not responsible for any information that you disclose or communicate in such forums, and any disclosures you make are at your own risk.
5. ACCESS AND CONTROL
At this time Red Thumb does not respond to browser ‘Do Not Track’ signals, as Red Thumb awaits the work of interested stakeholders and others to develop standards for how such signals should be interpreted.
The Site and Services are not directed or intended for children under 21 years of age. Red Thumb does not knowingly collect Personal Information from individuals under 21 years of age. If you are under 21 years of age, you should not register or provide Personal Information on the Site or through the Services. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to Red Thumb, please contact Red Thumb at firstname.lastname@example.org so that Red Thumb may delete and remove such child’s information from Red Thumb’s systems.
You may, of course, decline to submit Personal Information through the Site and/or Service, in which case the Site and/or Service may not be able to provide certain services to you. You may decline to share information, update or correct your account information and email preferences at any time by logging into your account, or by otherwise following the prompts on the Site.
Red Thumb offers you choices regarding the collection, use, and sharing of your Personal Information. When you receive promotional communications from Red Thumb, you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the promotional e-mail you receive.
If you would like assistance disabling your account please contact customer service at email@example.com.
Keep in mind, however, that even if you delete information from your account and/or profile, Red Thumb may retain your Personal Information in conformance with its data retention policy and Personal Information may remain within Red Thumb’s databases, access logs, and other records. In addition, Red Thumb is not responsible for updating or removing your Personal Information contained in the lists or databases of Third Parties who have been provided information as permitted by this Policy.
6. CALIFORNIA PRIVACY RIGHTS
If you are a California resident, you have the right to request the following information regarding Red Thumb’s use of your Personal Information. Red Thumb will fulfill each of these requests to the extent required by law, within 45 days of receipt of a verifiable request:
A. The Personal Information Red Thumb Collects About You. You have the right to request the Personal Information Red Thumb collects about you. If you make this request, Red Thumb will provide you with the following (to the extent required by law): (i) the categories of Personal Information Red Thumb collects about you; (ii) the categories of sources from which your Personal Information was collected; (iii) how your Personal Information is processed and the categories of how it was used; (iv) the categories of Third Parties with whom your Personal Information was shared; (v) categories of Personal Information Red Thumb has sold to Third Parties and the categories of such Third Parties. If Red Thumb has not sold your Personal Information, Red Thumb will make that clear in its response.
Red Thumb’s response will be limited to Personal Information collected about you within the last twelve (12) months.
B. Deletion of Your Personal Information. You have the right to request that Red Thumb delete Personal Information collected by Red Thumb. Upon receipt of such request, Red Thumb will delete your Personal Information collected as of the date of such request, except when necessary to: (i) complete the transaction for which the Personal Information was provided or perform a contract with the you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity and prosecute those responsible; (iii) debug to identify and repair errors that impair existing intended functionality; (iv) exercise free speech (of business or another consumer) or other rights; (v) comply with the California Electronic Communications Privacy Act; (vi) engage in public or peer reviewed research in the public interest; (vii) enable internal uses reasonably aligned with the expectations of the consumer based on their relationship with the business; and (viii) comply with a legal obligation; (ix) use your Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information
Please note that if Red Thumb deletes your Personal Information, you may not be able to use certain Site functions that require your Personal Information.
C. Selling Your Personal Information. Red Thumb does not sell your Personal Information. However, as a California resident, you have the right to opt-out of any transfer or sale of your Personal Information Red Thumb collects about you. If you choose to opt out, please click the “Do Not Sell My Personal Information” button located on the home page of the Site.
If you are a California resident interested in exercising your privacy choices please send us a request to firstname.lastname@example.org or click “Request My Personal Information” on the Site home page. For all requests, please include your name, street address, city, state and zip code. We are not to be responsible for notices that are not labeled, are sent improperly or do not have complete information.
7. YOUR RIGHTS
If you are a European resident, you have the right to access personal information Red Thumb holds about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact Red Thumb through email@example.com.
Additionally, if you are a European resident Red Thumb hereby notes that it is processing your information in order to fulfill contracts Red Thumb might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
8. OTHER IMPORTANT INFORMATION
The Sites may link to websites operated by Third Parties that Red Thumb does not control. Red Thumb does not monitor, control, or endorse the information collection or privacy practices of any Third Parties. Red Thumb encourages you to become familiar with the privacy practices of every website you visit and to contact them if you have any questions about their respective privacy policies and practices. This Policy applies solely to information collected by Red Thumb through the Site or Services and does not apply to these third party websites. The ability to access information of Third Parties from the Site or Services, or links to other websites or locations, is for your convenience only and does not signify Red Thumb’s endorsement of such Third Parties, their products, services, websites, locations or their content.
Red Thumb places a priority on the security of Personal Information, and Red Thumb undertakes reasonable security measures to help protect the data that resides on its servers. Red Thumb also uses secure server software (SSL) to process all financial transactions that occur on the Site. SSL technology can encrypt Personal Information transmitted over the Internet. However, no security system is impenetrable. Red Thumb does not warrant the security of its servers, nor does Red Thumb warrant that your information, including Personal Information, will be completely secure or not be intercepted while being transmitted over the Internet.
In addition, Red Thumb is not responsible for the privacy or data security practices of other organizations, such as Facebook, Tumblr, Twitter, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including in connection with any information you disclose to other organizations through or in connection with the Services.
If you have any questions regarding privacy or this Policy, you may contact Red Thumb as follows: Email firstname.lastname@example.org.
Red Thumb reserves the right to change, modify, add or remove portions of this Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless Red Thumb advises you otherwise. Your continued use of the Site or Services after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Policy, as amended. Red Thumb encourages you to bookmark this Web page and review this Policy regularly.