PRIVATE POLICY | Oba Wine

OBA Wine Privacy Statement

At OBA Wine, we approach data and privacy as we approach everything we do: we put people first.

As part of our effort to protect your privacy and to comply with applicable privacy and data protection laws, we strive to consider all of our data governance practices through the lens of the recognized principles of data minimization, limited collection, and limited use, among other key areas addressed below. We do so to respect and maintain your trust. In other words, we believe that taking care of you includes taking care of your data and privacy. Grab a glass of wine and read to learn more.

Last Revised: October 20, 2021

1. Applicability and Scope

This Privacy Statement ("Statement") applies to the website located at obawineus.com, and any other operating by OBA Wine brands or products that direct the viewer or user to this Statement.

In this Statement, the terms "Oba Wine" "we," and "us" refer to OBA Wine Corporation and its respective subsidiaries and affiliated companies. Note that websites that are owned and operated by OBA Wine may contain links to digital properties that are owned and operated by other companies. This Statement does not apply to websites and services that are owned and operated by unaffiliated third parties.

2. User-generated content

When relevant, users are solely liable for any content they may post or upload onto the Site and the consequences of disclosing, forwarding, making available, or broadcasting such content. OBA Wine does not adhere to or approve any content, opinion, suggestion, or notice generated by users and OBA WIne declines all responsibility and liability in respect of any such content to the fullest extent permitted by applicable law.

However, OBA WIne reserves the right, but not the obligation, to monitor the use of the Site and to remove any content which, in its sole discretion, would breach these Terms & Conditions, may be offensive, illegal, or otherwise objectionable in any way.
User accepts that OBA Wine may freely and peacefully use, at no cost and without any restriction and time limit, any content posted onto the Site. This includes the communication of any such content onto the Site as well as its communication and reproduction on any other mediums of whatever nature for the promotion and advertising of OBA Wine, its products, and services.

3. Updates to this Privacy Statment

This Statement went into effect on the “Last Revised” date noted near the top of this page. We may update this Statement from time to time. We will notify you of any modifications to this Statement that might materially affect your rights or the way that we use or disclose your personal information prior to the change becoming effective by means of a message on this website. We encourage you to look for updates and changes to this Statement by checking the “Last Revised” date when you access our websites and mobile applications.

4. Information We Collect

As you use our websites and mobile applications or visit one of our stores, we collect information about you and the services you use. The information we collect falls into three main categories: (1) information you voluntarily provide us; (2) information we collect from you automatically; and (3) information we collect from other sources.

Some examples of when we collect this information include when you browse or make a purchase on one of our websites or mobile applications; create an OBA Wine account; use our website or participate in a survey or promotion.

(a) Information You Voluntarily Provide Us

Some information we collect is provided when you use our services, such as when you create an account and join the OBA Wine Rewards loyalty program; pay for products; book a wine tasting, or submit online forms through our websites or mobile applications.

This may include your first and last name, username, password, email address, postal address, phone number, financial account information such as a credit card number, the day and month of your birthday, demographic information (such as your gender), and any other information you give us, such as to participate in a promotion or to contact OBA Wine customer service.

You may also in some instances provide us information about other people, such as name, phone number, and email address, including when you direct us to send someone a gift card.

(b) Information We Collect Automatically

Purchasing Information – We may collect information about your transactions in our stores, on our websites including what products you purchase, how frequently you purchase them, any Rewards or promotions associated with a purchase, and the products you have placed on your “Wishlist" or “My Bag" for future purchase.

Location Information – We may collect information about the location of your devices, such as information that identifies your device’s precise location (for example, GPS latitude and longitude level) or its approximate location (e.g., less precise location estimated based on a browser or device’s IP address).

We collect this location information or derive it from your GPS, WiFi, Bluetooth, or other device settings for purposes of enhancing or facilitating our services, such as to enable the functionality of our websites or mobile applications that provide you with information about stores near you, to enable you to remotely order and pay for our products and services, or so that you may have certain OBA Wine products delivered to you by a third-party vendor.

Some information we collect is from unaffiliated sources, including in some cases information that is publicly available, provided by or purchased from marketing business partners, or present on social media platforms.

For example, we may collect the information you submit to a blog, a chat room, or a social network like Facebook or Twitter. We may also collect or license information about you from other companies and organizations, such as information aggregators or event or promotion co-sponsors, including to supplement the information that we receive from you. We may also in some cases receive information about you from OBA Wine-affiliated entities, which we handle in accordance with this Privacy Statement. By gathering additional information about you, we can correct inaccurate information, enhance the security of your transactions and help prevent fraud, and give you product recommendations and special offers that are more likely to interest you.

4. How We Use Your Information

We use your information for business and commercial purposes, including to provide the products and services you request, to perform customer service functions, for security and fraud prevention, for marketing and promotional purposes, and to perform website analytics.

We may use the information we collect about you in a variety of ways, including to:

(a) To Provide Our Services. We process certain personal information when you access or use our services, including to:

process your purchases of, or requests for, products and services;
register and verify user accounts;
support and improve our loyalty programs, such as OBA Wine® Rewards
facilitate the functionality of our website, including payment-related functionality

(b) To Communicate With You. We process certain information in order to communicate with you in relation to your accounts, our services, our marketing, and your requests, including to:

communicate with you about orders, purchases, returns, services, accounts, programs, contests, and sweepstakes;
respond to your customer service inquiries and requests for information;
post your comments or statements on our websites;
send you personalized promotions, content, and special offers;
communicate with you about our brands, products, events, or other promotional purposes;
implement your communications preferences, such as sharing information with OBA Wine business partners so that they may email you about their promotions, products and initiatives; and
provide important product safety information and notice of product recalls.

(c) For Research, Development, and Improvement of Our Services. We want to ensure that our website, mobile applications, and services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process certain personal information, including to:

maintain, improve, and analyze our websites, ads, and the products and services we offer; and
detect, prevent, or investigate suspicious activity or fraud.

(d) To Enforce our Terms, Agreements, or Policies. To maintain a safe, secure, and trusted environment for you when you use our websites, mobile applications, and other services, we use your personal information to ensure our terms, policies, and agreements with you and any third parties are enforced.

(e) To Comply with Applicable Laws. We may be required to process certain personal information under certain laws and regulations, such as tax laws, as well as to:

maintain appropriate records for internal administrative purposes; and
comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.

(f) With Your Consent. We may process certain personal information in order to fulfill any other business or commercial purposes at your direction or with your consent.

5. Cookies, Web Beacons, and Similar Technologies

We and others may use a variety of technologies to collect information about your device and use of our websites and mobile applications. These technologies include first- and third-party cookies, web beacons, JavaScript, entity tags, and HTML local storage. Most web browsers can be programmed to accept or reject the use of some or all of these technologies, although you must take additional steps to disable or control other technologies. For more information on exercising your preferences in relation to cookies and similar technologies, please see the section of this Statement titled Your Choices.

Cookies – Cookies are small data files that are sent from a website’s server and are stored on your device’s hard drive either for only the duration of your visit ("session cookies") or for a fixed period ("persistent cookies"). Cookies contain information that can later be read by a web server. For more information about the cookies used on our website.

Web Beacons – Web beacons are small, transparent images that are embedded in web pages, applications, and emails that are sometimes called “clear gifs," “single pixel gifs", "page tags" or “web bugs." We use web beacons to track the web pages you visit, to test the effectiveness of our marketing, and to find out if an email has been opened and acted on.

JavaScript – JavaScript are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components.

Entity Tags -- Entity Tags are HTTP code mechanisms that allow portions of websites to be stored or “cached" within your browser and validates these caches when the website is opened, accelerating website performance since the web server does not need to send a full response if the content has not changed.

HTML5 Local Storage – HTML5 local storage allows data from websites to be stored or “cached" within your browser to store and retrieve data in HTML5 pages when the website is revisited.

These and similar technologies are used for the following purposes:

Services and Functionality – Some of these technologies are required to allow you to access and use our websites or mobile applications and the various services and functionality we offer. Without these technologies, some of the services and functionality on our websites and mobile applications would not work properly.

Performance Monitoring – Some of these technologies help us analyze and estimate traffic and assess the volume of use of services and functionality on websites and mobile applications. They show us how visitors and customers interact with our digital properties, whether there are any errors, the degree to which certain web pages, applications, services or functionality are accessed and used and how they are performing or operating. When these technologies are used for performance monitoring, no directly identifiable information (e.g., your name, email address or phone number) is collected.

User Convenience – Some of these technologies enhance the ease of use of our websites and mobile applications and the services and functionality they make available by accelerating load and refresh times and remembering information that you have provided on prior visits to our websites or when you last used a website or mobile application service or functionality.

Marketing – Some of these technologies are used to tailor your experience on our website, within our mobile applications, or across your applications or devices by controlling the promotions, advertisements and other marketing messages that may appear when you access or use these or other digital properties.

Taken together, these technologies help us learn which services and functionality you are using and how you are accessing information about us. We may use this information to personalize your visit to a website or use of a mobile application or to send you relevant promotions and advertisements.

6. Your Choices

You have control over your promotional communications preferences, mobile application functionality, cookie settings, interest-based advertising preferences, Flash cookies, and more.

Promotional Communication Choices

You can opt out of receiving promotional emails and mailings by informing us of your preference at the time you sign up for an OBA Wine account, by modifying your promotional preferences online in your account’s profile management section, or by following the “unsubscribe” instructions in the promotional emails we send you. Similarly, you may opt in to receive text messages, telephone calls and mailings. Please note that if you opt out of receiving promotional communications from us, we may still send you transactional communications, including emails about your OBA Wine accounts or purchases.

Cookies, Web Beacons and Similar Technologies – You may be able to reject cookies, web beacons, entity tags and HTML5 local storage by adjusting the appropriate settings in your browser. Each browser is different, but many browsers have preferences or options that may be adjusted to allow you to either accept or reject cookies and certain other technologies before they are set or installed, or allow you to remove or reject the use or installation of certain technologies altogether. If you want to learn the correct way to modify your browser settings, please use the Help menu in your browser or review the instructions provided by the following browsers: Internet Explorer, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile; and Android browser.

For more information on how to opt-out of tracking technology from Google Analytics, click here.

Interest-Based Ads – Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance (DAA) or the Network Advertising Initiative (NAI), both of which maintain websites where people can opt out of interest-based advertising from their members. To opt-out of website interest-based advertising provided by each organization’s respective participating companies, visit the DAA’s opt-out portal available at http://optout.aboutads.info/, the DAA of Canada’s opt-out portal available at https://youradchoices.ca/en/tools, or visit the NAI’s opt-out portal available at http://optout.networkadvertising.org/?c=1.

Residents of the European Union may opt-out of online behavioral advertising served by the European Interactive Digital Advertising Alliance’s participating member organizations by visiting https://www.youronlinechoices.eu/.

To opt-out of data collection for interest-based advertising across mobile applications by participating companies, download the DAA’s AppChoices mobile application opt-out offering here: https://youradchoices.com/appchoices.

Adobe Flash Player Technology – We allow Adobe to set and enable special cookies that are necessary to deliver video content for Adobe Flash Player. You cannot remove Flash cookies simply by changing your browser settings. If you would like to limit the websites that can store information in Flash cookies on your device, you must visit the Adobe website: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

"Do Not Track" Technology – Some newer web browsers have a "Do Not Track" preference that transmits a "Do Not Track" header to the websites you visit with information indicating that you do not want your activity to be tracked. We currently do not respond to browser "Do Not Track" signals, as there is no standard for how online services should respond to such signals. As standards develop, we may develop policies for responding to do-not-track signals that we will describe in this Privacy Statement.

7. Additional Disclosures for California Residents

In the preceding twelve months we may have disclosed these categories of personal information for a business purpose:

Identifiers
- Sources of Information – We collect identifiers from the information you voluntarily provide to us; from the information we automatically collect; and from other sources, as outlined in Section 3(a)-(c) above.
- Purpose of Information Collected – We collect identifiers to provide our services; to communicate with you; for research and development and services improvement; and to comply with applicable laws, and as otherwise outlined in Section 4 above.
- How we share it – We share identifiers with our service providers; to protect lawful interests; and for any other purpose with your consent, as otherwise outlined in Section 5 above.

Personal information under California Civil Code section 1798.80
- Sources of Information – We collect Section 1798.80 information from the information you voluntarily provide to us; from the information we automatically collect; and from other sources, as outlined in Section 3(a)-(c) above.
- Purpose of Information Collected – We collect Section 1798.80 information for the purposes outlined in Section 4(a)-(f) above.
- How we share it – We share identifiers with our service providers; to protect lawful interests; and for any other purpose with your consent, as otherwise outlined in Section 5 above.

Commercial information
- Sources of Information – We collect commercial information from the information you voluntarily provide to us; from the information we automatically collect; and from other sources, as outlined in Section 3(a)-(c) above.
- Purpose of Information Collected – We collect commercial information to provide our services; to communicate with you; for research and development and services improvement; and to comply with applicable laws, and as otherwise outlined in Section 4 above.
- How we share it – We share commercial information with our service providers and OBA Wine affiliates, as outlined in Section 5(a), (b) and (e) above.

Electronic network activity information
- Sources of Information – We collect network information through the information you voluntarily provide to us; from the information we automatically collect; and from other sources, as outlined in Section 3(a)-(c) above.
- Purpose of Information Collected – We collect network information to provide our services; to communicate with you; for research and development and services improvement; and to comply with applicable laws, and as otherwise outlined in Section 4 above.
- How we share it – We share network information with our service providers; to protect lawful interests; and for any other purpose with your consent, as outlined in Section 5 above.

Geolocation data
- Sources of Information – We collect geolocation data through the information you voluntarily provide to us; from the information we automatically collect; and from other sources, as outlined in Section 3(a)-(c) above.
- Purpose of Information Collected – We collect geolocation data to provide our services; to communicate with you; for research and development and services improvement; and to comply with applicable laws, and as otherwise outlined in Section 4 above.
- How we share it – We share geolocation data with our service providers; to protect lawful interests; and for any other purpose with your consent, as outlined in Section 5 above.

Inferences
- Sources of Information – We develop inference data through the information you voluntarily provide to us; from the information we automatically collect; and from other sources, as outlined in Section 3(a)-(c) above.
- Purpose of Information Collected – We develop inference data to provide our services; to communicate with you, and for research, development, and services improvement, as outlined in Section 4(a)-(c) above.
- How we share it – We share inference data with our service providers and to protect lawful interests, as outlined in Section 5 above.

How We Sell Your Information – In the preceding twelve months we have not sold personal information. We do not sell personal information, but we recognize that the CCPA defines “personal information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.”

In addition to the Your Choices section above’s description for submitting your cookie preferences via the “Cookie Preferences” link in our website footer, or for opting out of interest-based advertising and controlling browser settings, California consumers may also use the Digital Advertising Alliance’s tool to send requests under the CCPA for a web browser to opt out of the sale of personal information by some or all of that framework’s participating companies by accessing the DAA’s tool here: https://www.privacyrights.info/, or by downloading the DAA’s AppChoices mobile application opt-out here: https://www.privacyrights.info/appchoices.

Your Rights

Access to Specific Information and Data Portability Rights – Subject to certain exceptions, if you are a California resident you have the right to request a copy of the personal information that we collected about you during the 12 months before your request. Once we receive your request and verify your identity, we will disclose to you:

The categories of personal information we have collected about you;
The categories of sources for the personal information we have collected about you;
Our business or commercial purpose for the information collection;
The categories of third parties with whom we share that personal information;
The specific pieces of personal information we collected about you;

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.

Opting Out – As described in “How We Sell Your Information” above, California residents have the right to opt-out of having their personal information sold.

Non-Discrimination – California residents may not receive discriminatory treatment by the business for exercising your CCPA rights.

Exercising Access, Data Portability, and Deletion Rights – To exercise the access, data portability, and deletion rights described above as a California resident, please submit a verifiable consumer request to us by either:

Use of an Authorized Agent to Submit a Request – Only you or a person you formally authorize to act on your behalf, may make a verifiable consumer request related to your personal information as a California consumer. If you use an authorized agent to submit such a request, we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right.

Direct Marketing – If you are a California resident, you can request a notice disclosing the categories of personal information we have shared with third parties for the third parties’ direct marketing purposes.

Privacy Rights Metrics (January 2020 – December 2020) – Includes requests from the United States and Canada:

Right to Know

Requests Received – 498
Requests Complete – 336
Requests unable to be completed* – 162
Average completion time – 9 days

Right to Delete

Requests Received – 2,659
Requests Complete – 1,266
Requests unable to be completed* – 1,393
Average completion time – 13 days

*Requests may be unable to be completed due to factors such as inability to verify the customer, duplicate requests, or no information is found.