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Effective Date: January 1, 2023

This Notice supplements Total Wine’s Privacy Policy. Please read this Notice in conjunction with Total Wine’s Privacy Policy.

This Notice applies to the collection and use of California residents’ Personal Information by California Fine Wine & Spirits, LLC d/b/a Total Wine & More, Virginia residents’ Personal Information by all legal entities operating Virginia retail stores under the Total Wine & More brand, and affiliates of any such businesses who operate under the Total Wine & More brands in providing products and services to California or Virginia residents (altogether referred to in this Notice as "Total Wine", "we," or "us," or "our,"), where such use or collection may be governed by the California Consumer Privacy Act ("CCPA"), California’s "Shine the Light" Law, California Online Privacy Protection Act (CalOPPA), Virginia’s Consumer Data Protection Act (“VCDPA”), or other applicable California or Virginia privacy regulations. This Privacy Notice describes the types of Personal Information we collect about California and Virginia residents who use any Total Wine Site or otherwise interact with us, as required by California and Virginia law.

Please read this Notice carefully because it provides important information and explains your rights. Please visit this web page from time to time, as we may update our notice for changes in the law or our data practices. If you have any questions or concerns, or wish to exercise your privacy rights, we invite you to contact us by any of the methods listed at the bottom of this Notice.

Also, California residents who are job applicants for work in any of our businesses operating in the United States are subject to a different privacy policy regarding the information collected during the application process and any employment. See California Resident Job Applicant Disclosure Notice for more information.

YOUR RIGHTS RELATED TO PERSONAL INFORMATION HELD BY US

You have the right to:

  • request that we disclose what categories of your Personal Information we collect, use, disclose or sell;
  • request the specific pieces of personal information that we have collected about you;
  • opt out of the “sale” of their personal information; and
  • ask us to delete Personal Information we have collected about you.

You can exercise your rights using our Privacy Portal.

You may only make a verifiable consumer request for disclosure or deletion twice within a 12-month period.

Also, under California’s “Shine The Light” law (California Civil Code Section 1798.83), California residents may annually request, free of charge, information about the Personal Information (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year. However, no information is shared with third parties for their own marketing purposes except where expressly authorized by you.

OUR RESPONSE TO REQUESTS

We will acknowledge receipt of your Request within 10 days of receipt of your request. We provide a substantive response to your Request as soon as possible, generally within 45 days from when we receive your Request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your Request is going to take us longer than normal to fulfill, we will notify you.

We usually act on Requests and provide information free of charge, but we reserve our right to charge a reasonable fee to cover our administrative costs of providing the information in certain situations.

In some cases, the law may allow us to refuse to act on certain requests. When this occurs, we will explain why.

NON-DISCRIMINATION POLICY FOR EXERCISING YOUR PRIVACY RIGHTS

We will not discriminate against you for exercising any of your privacy rights. In particular, we will not:

  • Deny you goods or services
  • Charge you different prices for goods or services, whether through denying benefits or imposing penalties
  • Provide you with a different level or quality of goods or services
  • Threaten you with any of the above

However, under the CCPA and VCDPA, we may offer certain incentives that result in different prices, offers, benefits, or services to customers who choose to join our &MORE Rewards Program that may not be available to customers who are not &MORE Rewards Program members or who choose to terminate their &MORE Rewards Program membership. For more information about our &MORE Rewards Program, the different product offerings and services available under that program, how to opt-in to the program, and the value of &MORE Rewards Program member data, see the &MORE Rewards Program Terms & Conditions.

NOTICE OF FINANCIAL INCENTIVE

We make various offers and financial incentives to our customers. The terms of any such offer or financial incentive will be presented to you at the time you receive our offer. The nature and value of any such offer or financial incentive may differ depending on what information we collect and use about you and whether you choose to enroll in our &MORE Rewards Program. For details about the benefits of enrolment in our &MORE Rewards Program, please see the &MORE Reward Program Terms & Conditions.

Whether you choose to enroll in our &MORE Rewards Program and whether you choose to allow us to collect and use other types of Personal Information about you affects how we communicate with you and the types and frequency of offers that you may receive. For example, if we collect no information from you, we will be unable to make any offers to you other than through general advertising or when you visit our stores. Conversely, when you enroll in our &MORE Rewards Program or otherwise allow us to continue to collect and use Personal Information about you, we are able to provide you different, more tailored or customized, and generally more valuable offers and financial incentives than the ones we may choose to make through our general advertising, which only reaches a small percentage of our customers.

The value of your Personal Information that allows us to make these offers and financial incentives is the value of the offer itself. We calculate the value of our offers and financial incentives by using the expense related to the offer.

Whether or not you are a member of our &MORE Rewards Program, you may withdraw from receiving any of our offers or financial incentives by contacting us at privacy@totalwine.com or 1-855-330-6673 or by unsubscribing to our email marketing by clicking "Unsubscribe" link in any e-mail from us.

INFORMATION SECURITY

We aim to protect Personal Information by implementing and maintaining reasonable security, such as by using reasonable organizational, technological and physical safeguards appropriate to the sensitivity of the Personal Information we hold. We take commercially reasonable measures to safeguard your Personal Information, but we cannot guarantee its absolute security.