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Our Policy
Welcome to the web site (the "Site") of TastePass, a service provided by inWine S.A.S ("inWine", "we", "us" and/or "our"). This Site is operated by inWine and has been created to provide information about our company and our platform and sharing services (together with the Site, the "Services") to our Service visitors ("you", "your"). This Privacy Policy sets forth an outline of the information that inWine gathers, in what ways that information is used, and the options that you have to access, correct, or delete such information.
Our Promise
You own your data. We exist to help you get the most out of it. We want to be transparent in this regard, and we strongly believe in keeping your personal information personal, private and secure. We will not sell, rent, or otherwise share your personal information to anyone except as required to provide our service or as otherwise outlined in this Policy without first notifying you and providing an opportunity to consent.
Who Does This Policy Apply to
- Customers: Any person that registers individually or on behalf of an entity or organization in order to use inWine Services.
- Website Visitors: Visitors to our Websites, as well as others that may opt in to receive commercial communications from inWine. Under this Policy, “Websites” shall refer to www.inwine.com and all affiliated websites owned or operated by inWine. “Websites” does not include any websites owned or operated by our Customers, nor any where we acted as Registrar for said Customer.
- Event Attendees: inWine hosts a series of annual conferences and is an active participant at many other conferences, summits, and additional events. Any individuals that provide their information to inWine or inWine representatives and affiliates when they attend or register to attend inWine-sponsored events or others where inWine participates.
- End Users: inWine may process End User data on behalf of its Customers. Subsequently, this Policy also applies to any End User that visits a Customer website and whose information we process in order to provide Services to our Customers.
Exclusions: This Privacy Policy shall not apply to any unsolicited information that you provide to inWine through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, "Unsolicited Information"). All Unsolicited Information shall be deemed to be non-confidential and inWine shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution. This Policy does not apply to Customers websites. Customers are responsible for posting their own terms, conditions, and privacy policies. Each Customer is responsible for ensuring their compliance with all applicable laws and regulations, inclusive of their use of our Services by End Users. inWine does not knowingly collect information from individuals under the age of 18. If you are under the age of 18, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Data to inWine through the Services, please contact privacy@inwine.com and we will endeavor to delete that information from our databases.
What Information Do We Collect
- Customer Account Information.When you register for a inWine account, we request your email address. This information is your "Account Information" for the purposes of this Privacy Policy. Account Information is required to identify you as a Customer and permit you to access your account(s). By voluntarily providing us with such Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.
- Customer Payment Information.You are not required to enter your credit card information unless and until you decide to continue with a paid subscription to our Services. When you sign up for one of our paid Services, you must provide billing information. The information you will need to submit depends on which billing method you choose. For example, if you pay with a credit card, we will collect your card information and billing address, although we do not store full credit card numbers or personal account numbers; rather, we work with our preferred payments partner, Stripe, to handle all transactions.
- Website Visitors: We will collect your name, email address, and other contact information. We ask for and—at your option—collect personal information from you when you submit opt-in forms on our Websites, including places where you can sign up for and agree to receive commercial communications from us. We also may ask you to submit personal information if you choose to use interactive features of the Websites, including participation in surveys, promotions, requesting customer support, or otherwise communicating with us. We will send such communications in accordance with applicable law.
- Website Log Files. When you visit and interact with most websites, as well as ours and including our Community board on inWine chat, we gather certain information and store it in log files. This information may include but is not limited to Internet Protocol (IP) addresses, system configuration information, URLs of referring pages, and location and language preferences. We rotate logs frequently and only store log files where absolutely necessary; e.g. to perform an abuse investigation, to analyze a distributed denial of service attack, etc. Website Cookies and Tracking. In operating the Services, we may use a technology called "cookies." A cookie is a piece of information that the computer hosting our Services gives to your browser when you access the Services. Our cookies help provide additional functionality to the Services and help us analyze Services usage more accurately. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a "help" section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features. Note that if you disable cookies entirely, inWine’s Websites may not function properly.
- Interactive Website Elements.The Websites may offer publicly accessible blogs, community forums (e.g. inWine chat), comments sections, discussion forums, or other interactive features ("Interactive Elements"). If you choose to participate in any of these Interactive Elements, please be aware that any information that you post may be read, collected, and used by others who access it. If you wish to remove your personal information from any of our Interactive Elements, please see the section below entitled, "What are your data rights".
- Event Attendee. We may collect personal information such as name, address, phone number and email address when participants register for or attend a sponsored event or other events at which inWine (and/or its affiliates or representatives) are present.
- End Users. It is our Customers and their users who are responsible for the content transmitted across our network (e.g., images, written content, graphics, etc.). We collect End Users information when they use our Customers’ websites, web applications, and APIs. This information may include but is not limited to IP addresses, system configuration information, and other information about traffic to and from Customers websites (collectively, the "Log Data"). We collect and use Log Data to operate, maintain, and improve our Services in performance of our obligations under our Customer agreements. For example, Log Data can help us to detect new threats, identify malicious third parties, and provide more robust security protection for our Customers. If you are an individual from the European Economic Area (EEA), please note that our legal basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it. We normally will collect personal information from you only where: (a) we have your consent to do so, (b) where we need your personal information to perform a contract with you (e.g. to deliver inWine Services you have requested), or (c) where the processing is in our legitimate interests. Please note that in most cases, if you do not provide the requested information, inWine will not be able to provide the requested service to you. In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person. Where we rely on your consent to process your personal data, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your personal data, you have the right to object. If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us at privacy@inwine.com.
How Do We Use Information We Collect
inWine only processes personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorised. As a general rule, all data we collect (including personal information, where applicable) may be used to: Provide, operate, maintain, improve, and promote the Website and Services; Enable you to access and use the Website and Services; Process and complete transactions, and send you related information, including purchase confirmations and invoices; Send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; Send commercial communications, in line with your communication preferences, such as providing you with information about products and services, features, newsletters, offers, promotions, and events about us and our partners; and send other news or information about us and our partners. Monitor and analyze trends, usage, and activities in connection with the Websites and Services and for marketing or advertising purposes; Comply with legal obligations as well as to investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities; Personalize the Websites and Services, including providing features or content that match your interests and preferences. Information from Third Party Services. From time to time, we may combine information we collect as described above with personal information we obtain from third parties. For example, we may combine information entered through a inWine sales submission with information we receive from a third-party sales intelligence platform to enhance our ability to market our Services to Customers or potential Customers.
When We Share Information
We retain the services of other companies that help us to run our business (“Service Providers”). These companies provide services to help us deliver customer support, process credit card payments, manage and contact existing Customers as well as sales leads, provide marketing support, and otherwise operate and improve our Services. These Service Providers may only process personal information pursuant to our instructions and in compliance both with this Privacy Policy and other applicable confidentiality and security measures and regulations, including our obligations under the EU-US and Swiss-US Privacy Shield frameworks described in Section 6, below. We do not permit our Service Providers to use any personal information we share with them for their own marketing purposes or for any other purpose than in connection with the services they provide to us. In addition to sharing with Service Providers as described above, we may also share your information with others in the following circumstances: With our resellers and other sales partners who may help us distribute the Services to Customers; In the event of a merger, sale, change in control, or reorganization of all our part of our business; When we are required to disclose personal information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims; Where we have a good-faith belief sharing is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required to comply with our legal obligations; or as you may otherwise consent from to time to time. When We Link to Other Websites This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by inWine (the "Third Party Sites"). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that inWine endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.
When We Aggregate Data
When you interact with inWine through our Services, we receive and store certain non-identifiable information from Customers and their End Users. This information, such as Logs, which are collected passively cannot be used to specifically identify you. inWine may store such information itself or such information may be included in databases owned and maintained by inWine affiliates, agents or service providers. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors Internet service providers. It is important to note that no Personal Data is available or used in this process.
When We Transfer Data Internationally
inWine is a French corporation with primarily storage of your information in the European Economic Area (the “EEA”). To facilitate our global operations, we may transfer and access such information from around the world, including from other countries in which inWine has operations to provide the Services. Whenever inWine shares personal information originating in the EEA or Switzerland with a inWine entity outside the EEA or Switzerland, it will do so under the EU standard contractual clauses or the Privacy Shield Frameworks detailed in this section. If you are accessing or using our Websites or Services or otherwise providing information to us, you are agreeing to the transfer of your personal information to the EEA and other jurisdictions in which we operate. inWine is certified under both the EEA Privacy Shield Frameworks as set forth by the EEA regarding the collection, use, and retention of personal information transferred from the US and Switzerland to the EEA, respectively. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. For more information on the EEA Privacy Shield or Swiss-U.S. Privacy Shield, please visit the U.S. Department of Commerce’s Privacy Shield website at: https://www.privacyshield.gov/welcome.
What Are Your Data Rights
- Customer, Website Visitors, and Attendees. You have the right to access, correct, make updates to, export, or delete your personal information. You may also email us at privacy@inwine.com with any subsequent subject access requests (use the term “SAR” as your email subject line), and we will respond within thirty (30) days. Customers also can access, correct, export, or update their Account Information by editing their profile or organization record at https://inwine.com.
- End Users: inWine has no direct relationship with End Users. We rely on our Customers to comply with the underlying legal requirements for subject access requests. If an End User requests that we access, correct, update, or delete their information, or no longer wishes to be contacted by one of our Customers that use our Services, we will direct that End User to contact the Customer website(s) with which they interacted directly. Our Customers are solely responsible for ensuring compliance with all applicable laws and regulations with respect to their website users.
- Subject Access Requests. We consider it important to verify that a requestor is inquiring about their own information before we can assist with any request. Where a SAR implicates the personal data of another individual, we balance the request against the risk of violating another person’s rights. We will comply with subject access requests to the extent required by applicable law or the US-EU or US-Swiss Privacy Shield.
How to Change Your Communication Preferences
To keep your information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update any information in our possession that you have previously submitted via the Services. Note that you may also manage your communications preferences and the receipt of any commercial communication by clicking the “unsubscribe” link included at the bottom of all emails from inWine. You may also adjust your preferences through your account settings if you have a inWine account, or else send an email to privacy@inwine.com.
How We Handle Data Security, Integrity, and Access
inWine takes all reasonable steps to protect the data that we receive from loss, misuse, and unauthorised access, disclosure, alteration, or destruction. We utilise appropriate physical, digital, and administrative protocols to keep your information secure, including the use of encryption services. Notwithstanding, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, take special care in deciding what information you send to us via email. For any questions about the security of your information, please contact privacy@inwine.com.
How We Will Notify You about Changes
The Services and our business may change from time to time. As a result, at times it may be necessary for inWine to make changes to this Privacy Policy. inWine reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. However, if we make changes that we believe will materially impact this Privacy Policy, we will promptly notify you of those changes and obtain consent (where applicable or required). Please review this Privacy Policy from time to time. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.
How We Will Handle a Business Transfer
As we develop our business, we may sell or buy businesses or assets. In the event of a corporate sale, merger, reorganisation, dissolution or similar event, we may assign or transfer this Policy, as well as all information covered thereunder.
How You Can Contact Us
inWine S.A.S
1 place Frédéric Ozanam
33200 Bordeaux
Franceprivacy@inwine.com