PRIVACY

Effective Date April 1, 2022

We respect your concerns about privacy and value the relationship we have with you. This Privacy Policy describes the types of personal information we collect on this website. Our Privacy Policy also describes how we may use the information that we collect, to whom and under what circumstances we may disclose it, and the measures we take to protect the security of the information. We also tell you how you can contact us to address questions you may have.

NOTICE TO CALIFORNIA RESIDENTS - YOUR CALIFORNIA PRIVACY RIGHTS

This California Consumer Privacy Policy supplements the privacy notice on the 26 Generazioni website and mobile applications (“CA Supplement”), if applicable, and applies solely to adult consumers of 26 Generazioni who are California residents.
This California Consumer Privacy Policy uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018.

1.   Notice of Collection and Use of Personal Information
We may collect the following categories of personal information about you:
•   Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, and similar technology; telephone number and other forms of persistent or probabilistic identifiers), online identifiers, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
•   Secondary Identifiers: signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, other financial information, medical information, and health insurance information
•   Protected Classifications: race, age, and gender
•   Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
•   Online Activity: internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
•   Geolocation: geolocation data
•   Sensory Information: audio, electronic, visual, and similar information
•   Employment Information: professional or employment-related information
•   Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, and attitudes.
We may use the categories of personal information listed above for certain business or commercial purposes, as described in this table:

Purpose	Categories of Personal Information
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders, transactions, refunds, returns, or exchanges, verifying customer information, processing payments, managing accounting, billing, and record keeping, advertising and marketing our products and services, administering contests, surveys, sweepstakes, and promotions, advertising or marketing third-party products or services, performing market and statistical research, developing new products or services, enhancing or improving 26 Generazioni content, products, and services, resolving problems and complaints, complying with company policies, complying with legal requirements and government requests, providing analytics services, or providing similar services	Identifiers, Secondary Identifiers, Protected Classifications, Commercial Information, Online Activity, Geolocation, Sensory Information, Employment Information, and Inferences
Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance	Identifiers, Secondary Identifiers, Protected Classifications, and Commercial Information
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction	Identifiers, Secondary Identifiers, Protected Classifications, Commercial Information, and Geolocation
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity	Identifiers, Commercial Information, Online Activity, and Sensory Information
Debugging to identify and repair errors that impair existing intended functionality	Identifiers, Commercial Information, and Online Activity
Undertaking internal research for technological development and demonstration	Identifiers, Online Activity, Geolocation, and Inferences
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us	Identifiers, Protected Classifications, Commercial Information, Online Activity, Geolocation, and Inferences

2. Our Prior Collection, Use and Disclosure of Personal Information
We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Policy. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose.
a. Sources of Personal Information
We may have obtained personal information about you from various sources, as described below.

Category of Source of Data Collection	Categories of Personal Information
From you and your device, for example, through your use of our websites, your use of our application(s), when you send us an email, use our services, or otherwise visit, contact or communicate with us	Identifiers, Secondary Identifiers, Protected Classifications, Commercial Information, Online Activity, Geolocation, Sensory Information, and Employment Information
Our data collection devices (e.g., iPad, paper signup form, etc.)	Identifiers, Secondary Identifiers, Protected Classifications, Commercial Information, Online Activity, Geolocation, and Employment Information
Our parent company	Identifiers, Secondary Identifiers, Commercial Information, and Geolocation
Our affiliates	Identifiers
Our vendors and other business partners	Identifiers
From other individuals, such as when they refer you as a friend	Identifiers
Advertising networks	Identifiers

b. Sharing of Personal Information
We may have shared your personal information with certain categories of third parties, as described below.

Category of Third Party	Categories of Personal Information
Our parent company	Identifiers; Secondary Identifiers, Protected Classifications, Commercial Information; Online Activity, Geolocation, and Employment Information
Our affiliates	Identifiers; Commercial Information; Online Activity, and Employment Information
Vendors, consultants and advisors who provide services on our behalf	Identifiers; Secondary Identifiers, Protected Classifications, Commercial Information; Online Activity, and Geolocation
Data analytics providers	Identifiers, Commercial Information, Online Activity, and Geolocation
Social networks	Identifiers, Commercial Information, and Online Activity
Advertising networks	Identifiers, Commercial Information, Online Activity, and Geolocation
Government entities, including regulatory agencies and law enforcement	Identifiers, Protected Classifications, and Geolocation

c.   Sale of Personal Information
During the 12-month period prior to the effective date of this California Consumer Privacy Policy, we may have sold the following categories of personal information to social networks and our online advertising providers (to enhance the ability to serve you content and advertisements that may be of interest to you):
•   Identifiers, Commercial Information, Online Activity, and Geolocation
We do not collect and do not sell the personal information of minors under 21 years of age.
d.   Disclosure of Personal Information for a Business Purpose
We may have disclosed to third parties the following categories of personal information for a business purpose:
•   All the categories of personal information about you described in Section 1 above except for Inferences.

3. California Consumer Privacy Rights
You have certain choices regarding our use and disclosure of your personal information, as described below.

Rights Under the California Consumer Privacy Act of 2018
You may have the right to request, twice in a 12-month period:
•   Access: You may have the right to request that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
•   Deletion: You have the right to request that we delete certain personal information we have collected from you.
•   Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
How to Submit a Request: To submit an Access, Deletion, or Opt-Out of Sale request, please send us an email at Compliance@smwe.com with your full name and your e-mail address, call 1-800-267-6793, or visit Do Not Sell My Personal Information. Indicate that you are a California resident making a “California Consumer Privacy Act” inquiry and list which of the above rights you would like to exercise.
Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you request to access or delete your personal information, we may require you to provide information such as: physical address, date of birth, and phone number. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion, or opt-out of sale request on your behalf, we may require you to provide the authorized agent written permission to do so, and, for access and deletion requests, we may also require you to verify your own identity directly with us (as described above). Additional Information: If you choose to exercise any of your rights under the California Consumer Privacy Act, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

Rights Under California’s “Shine the Light” Law
If you reside in California, you have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties. To make such a request, please send us an email at Compliance@smwe.com or call 1-800-267-6793. Indicate that you are a California resident making a “Shine the Light” inquiry.

Privacy Notice to All Consumers:

PERSONAL INFORMATION WE COLLECT ABOUT YOU

You may choose to provide personal information (such as your name, address, telephone number, and e-mail address) through our website. Below are the ways in which you may provide the information, the types of information you may submit, and the ways we may use that information. In addition to the uses described below, we may also use the information you submit for internal purposes. We may also receive personally identifiable information from our business partners.

CONTACT US

If you communicate with us through the Contact Us link on our website (if applicable), we may ask you for information such as your name, email address, and telephone number so we can respond to your questions and comments. We may also use the information you provide to evaluate the quality of our products and to communicate with you about our products and services. If you decide to opt-out of any of the various ways we communicate with you, keep in mind that these preferences regarding promotional contacts do not mean that we might not contact you for other reasons, such as those related to an order you placed, an inquiry you made, a message that a friend or acquaintance requested be delivered (such as through our Forward to a Friend program), a newsletter to which you have subscribed, a membership you undertook, an event for which you registered, or a legally required notice.

JOIN OUR MAILING LIST

On our website, if applicable, you may sign up to receive newsletters, exclusive offers and promotions, notice of special events, and product news. To sign up, we require your name, e-mail address, and zip code. We use your contact details to send you the information you request and communicate with you about our products and services. You may stop the delivery of future e-mail from us by clicking on the unsubscribe link provided, but note, it may take up to 10 business days to honor your request. By providing your personal information you consent to our transferring and processing it in the United States.

OTHER WEBSITE FEATURES

We offer visitors to our website various features for their information and enjoyment, which we may change from time to time. Your use of our website is subject to our Terms of Use.

INFORMATION WE COLLECT BY AUTOMATED MEANS

We collect certain information by automated means when you visit our website, such as how many users visited our website and the pages accessed. By collecting this information, we learn how to best tailor our website to our visitors. We collect this information through various means such as "cookies," "web beacons," and IP addresses as explained below.

We collect internet-related information from visitors to our website, including the referring URL, your IP address, which browser you used to come to the website, and the pages of our website that you viewed during your visit, for the purposes of system administration, to gather broad demographic information, and to monitor the level of activity on our website. We also utilize certain graphics in our email messages to determine things like which email messages were opened and how many times they were opened.

We have also implemented Google Demographics and Interest Reporting which, in the aggregate, groups our users into certain categories including: age ranges, gender, affinity categories, and in market segments.

COOKIES

Like many companies, we use "cookies" on our website. Cookies are bits of text that are placed on your computer's hard drive when you visit certain websites. We use cookies to tell us, for example, whether you have visited us before or if you are a new visitor and to help us identify website features in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a particular website.

Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all our website features.

WEB BEACONS

Certain pages on our website may contain "web beacons" (also known as internet tags, pixel tags, and clear GIFs). Web beacons allow third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the third party.

IP ADDRESSES

An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the internet. When you visit our website, we may view the IP address of the device you use to connect to the internet. We use this information to determine the general physical location of the device and understand from what regions of the world our website visitors come. We may also use this information to enhance your experience on our website.

MINORS

Our website is not directed at children, and as a result we will not knowingly collect information from anyone under the age of 21. We will not knowingly market alcoholic beverages to anyone under the legal purchase age. If we receive notice or believe that someone under the legal purchase age has provided us with personal information, we will make every reasonable effort to remove such personal information from our files or flag such personal information and retain it for the sole purpose of ensuring that it is not used any further.

INFORMATION WE SHARE

We do not sell, license, or otherwise disclose information about our consumers and customers, except as described herein. We may share the information you provide with our affiliated companies so they can communicate with you about products we think might interest you. We may share the information with service providers we have retained to perform services on our behalf. We have not authorized these service providers to use or disclose your information, except as necessary to perform services on our behalf or comply with legal requirements. We will share your information with Marchesi Antinori S.p.A., Antica Napa Valley, and Ste. Michelle Wine Estates to use for their own purposes. In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, (iii) to bring legal action against someone who may be violating our Terms of Use or any other terms applicable to any activity or feature of our website, or (iv) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.

We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use information you have provided through our websites in a manner that is consistent with this Privacy Policy.

LINKS TO THIRD-PARTY WEBSITES

From time to time, we may provide links to third-party websites. These websites may operate independently from us and may have their own privacy policies in place, which we strongly suggest you review if you visit any linked website. To the extent any linked website you visit is owned or operated by someone other than us, we are not responsible for its content or any use of the website.

HOW WE PROTECT PERSONAL INFORMATION

We maintain administrative, technical, and physical safeguards on this website to help protect against unauthorized disclosure, use, alteration, or destruction of the personal information you provide. We use secure socket layer (SSL) technology to help protect your credit card information as it is transmitted to us. You are responsible for maintaining the confidentiality of any user name and password you use.

STORAGE

Your personal information will be kept on servers in a physically and technologically secure environment located in the United States accessed only by authorized personnel or contractors who are bound to keep your information confidential. Any transmission of your credit card information will be encrypted. If you contact us regarding identity theft or some other form of unauthorized use of your data, we may disclose pertinent information to law enforcement agencies and other third parties with responsibility and authority to investigate such a claim.

UPDATES TO OUR PRIVACY POLICY

This Privacy Policy may be updated, without prior notice to you, to reflect changes in our information practices. If there are material changes to our Privacy Policy, we will indicate at the top of the Privacy Policy when it was most recently updated and provide other appropriate notice to you.

HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy, or if you would like us to update information we have about you, please contact us by emailing us at info@26generazioni.us or by writing to us at:

26 Generazioni
14111 NE 145th Street
Woodinville, WA 98072

-or-

Marchesi Antinori S.p.A.
Piazza Antinori, 3
50123 Firenze, Italy