woodthorpewines.co.uk

Last updated: 03/09/2024

We are Woodthorpe Wines Ltd. This privacy policy outlines how we collect, use, and protect

your personal information when you use our services.

You can contact us at info@woodthorpewines.co.uk

Table of contents

 Introduction

 Contact information

 Types of data collected

 Mode and place of processing personal data

 Detailed information on the processing of personal data

 Further information

 Your rights based on the General Data Protection Regulation (GDPR)

 Further information if you reside in Switzerland

 Further information if you reside in Brazil

 Further information if you reside in California

 Further information if you reside in Virginia

 Further information if you reside in Colorado

 Further information if you reside in Connecticut

 Further information for Utah consumers

 Additional information about data collection and processing

 Definitions and legal references

Introduction

What is this policy about?

This document explains how this website collects, uses, and protects your personal data to

achieve the purposes outlined in this document.

What is personal data?

Personal data refers to information that can be used to identify you directly or indirectly. This

includes details such as first name, last name, email address, tracking technologies (like cookies

or tracking pixels), user activity, and device information. You can find detailed information on

each type of personal data collected in dedicated sections of this privacy policy or in text shown

before data is collected.

This document was generated with the use of the privacy policy template.

Contact Information

Woodthorpe Wines Ltd

Bicester/Nottingham

Email: info@woodthorpewines.nhs.uk

Phone: +44 7533 451682

Types of data collected

The types of personal data that this website collects, by itself or through third parties, may

include:

 first name;

 last name;

 email address;

 Trackers;

 Usage data

Complete details on each type of personal data collected are provided in the dedicated sections

of this privacy policy or by specific explanation texts displayed prior to the data

collection. personal data may be freely provided by you, or, in case of Usage data, collected

automatically when using this website. Unless specified otherwise, all data requested by this

website is mandatory and failure to provide this data may make it impossible for this website to

provide its services.

In cases where this website specifically states that some personal data is not mandatory, you

are free not to communicate this data without consequences to the availability or the

functioning of the service.

Any use of cookies – or of other tracking tools — by this website or by the owners of third-party

services used by this website serves the purpose of providing the service required by you, in

addition to any other purposes described in the present document.

You are responsible for any third-party personal data obtained, published or shared through

this website.

Mode and place of processing personal data

Methods of processing

We take appropriate security measures to prevent unauthorized access, disclosure,

modification, or unauthorized destruction of the data. The data processing is carried out using

computers and/or IT enabled tools, following organizational procedures and modes strictly

related to the purposes indicated.

In addition to ourselves, in some cases, the data may be accessible to certain types of persons

in charge, involved with the operation of this website (e.g. administration, sales

team, marketing team, legal team).

The data may also be accessible to external parties appointed, if necessary, as data processors

by us.

The updated list of these parties may be requested from us at any time by contacting us at the

contact details provided in this document.

Place

The data is processed at our operating offices and in any other places where the parties

involved in the processing are located. Depending on your location, data transfers may involve

transferring your data to a country other than your own. To find out more about the place of

processing of such transferred data, you can check the section containing details about the

processing of personal data.

Retention time

Unless specified otherwise in this document, personal data shall be processed and stored for as

long as required by the purpose they have been collected for and may be retained for longer

due to applicable legal obligation or based on your consent.

Detailed information on the processing of personal data

Your personal data is collected to allow us to provide our service, comply with our legal

obligations, respond to enforcement requests, protect our rights and interests (or yours or

those of third parties), detect any malicious or fraudulent activity, as well as the purposes set

out below:

Analytics

The services contained in this section enable us to monitor and analyze web traffic and can be

used to keep track of your behavior.

Google Analytics (Universal Analytics) (Google LLC)

Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC

(“Google”). Google utilizes the data collected to track and examine the use of this website, to

prepare reports on its activities and share them with other Google services. Google may use the

data collected to contextualize and personalize the ads of its own advertising network.

To understand Google's use of data, consult Google's partner policy and their Business data

page.

Personal data processed: Trackers; Usage data

Place of processing: United States

Opt-out link: https://tools.google.com/dlpage/gaoptout

Category of personal information collected according to the CCPA: internet or other electronic

network activity information. This processing constitutes a sale according to the CCPA, VCDPA,

CPA, CTDPA and UCPA

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the

pages of this website and interact with them. Such services are often referred to as widgets,

which are small elements placed on a website or app. They provide specific information or

perform a particular function and often allow for user interaction.This type of service might still

collect web traffic data for the pages where the service is installed, even when you do not use

it.

Google Fonts (Google LLC)

Google Fonts is a typeface visualization service provided by Google LLC that allows this website

to incorporate content of this kind on its pages.

To understand Google's use of data, consult Google's partner policy and their Business data

page.

Personal data processed: Trackers; Usage data

Place of processing: United States

Opt-out link: https://tools.google.com/dlpage/gaoptout

Category of Personal Information collected according to the CCPA: internet or other electronic

network activity information.

Contacting you

Contact form (this website)

By filling in the contact form with your data, you authorize this website to use these details to

reply to your requests for information, quotes or any other kind of request as indicated by the

form’s header.

Personal data processed: email address; first name; last name

Category of personal information collected according to the CCPA: identifiers. This processing

constitutes: a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA

Further information

Legal basis of processing

We may process personal data relating to you if you have given your consent for one or more

specific purposes:

 provision of data is necessary for the performance of an agreement with you and/or for

any pre-contractual obligations thereof;

 processing is necessary for compliance with a legal obligation to which we are subject;

 processing is related to a task that is carried out in the public interest or in the exercise

of official authority vested in us;

 processing is necessary for the purposes of the legitimate interests pursued by us or by

a third party.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing,

and whether the provision of personal data is a statutory or contractual requirement, or a

requirement necessary to enter into a contract.

Understanding how long we keep your information

When we collect your personal information, we keep it for as long as required for the purposes

we collected for. Sometimes, we might need to keep your personal information longer due to a

legal obligation or based on your consent.

Here’s what that means in more detail. We will keep your personal information based on the

purposes and reasons set out below:

 for contractual purposes: If we have concluded a contract with you, then we'll keep

your information until the contract has been performed in full.

 for our legitimate interests: If we're using your personal information for purposes that

are necessary and relevant to our business operations, we'll keep it as long as we need it

for those purposes. You can learn more about these purposes within the relevant

sections of this document or by contacting us.

 with your consent: We may be allowed to retain personal data for a longer period

whenever you have given consent to such processing, unless you withdraw your

consent.

 legal obligations: we may be obliged to retain personal data for a longer period

whenever required to fulfill a legal obligation or upon order of an authority.

Once the retention period expires, your personal data will be deleted. Therefore, the right of

access, the right to erasure, the right to rectification and the right to data portability cannot be

enforced after expiration of the retention period.

Your rights based on the General Data Protection Regulation (GDPR)

You may exercise certain rights regarding your data processed by us. In particular, you have the

right to do the following, to the extent permitted by law:

 Withdraw your consent at any time. You have the right to withdraw consent where

they have previously given your consent to the processing of your personal data.

 Object to processing of your data. You have the right to object to the processing of your

data if the processing is carried out on a legal basis other than consent.

o If your personal data is processed for public interest, by an official authority, or

for our legitimate business interests, you can object by providing a reason

related to your particular situation.

o However, if your personal data is being processed for direct marketing purposes,

you can object at any time, free of charge, and without any reason. If you do, we

will stop using your personal data for marketing. To find out if we are using your

data for direct marketing, please refer to the relevant sections of this document.

 Access your data. You have the right to learn if data is being processed by us, obtain

disclosure regarding certain aspects of the processing and obtain a copy of the data

undergoing processing.

 Verify and seek rectification. You have the right to verify the accuracy of your data and

ask for it to be updated or corrected.

 Restrict the processing of your data. You have the right to restrict the processing of

your data. In this case, we will not process your data for any purpose other than storing

it.

 Have your personal data deleted or otherwise removed. You have the right to obtain

the erasure of your data from us.

 Receive your data and have it transferred to another controller. You have the right to

receive your data in a structured, commonly used and machine-readable format and, if

technically feasible, to have it transmitted to another controller without any hindrance.

 Lodge a complaint. You have the right to bring a claim before your competent data

protection authority.

 Learn about the reason for data transfers. You are also entitled to learn about the legal

basis for data transfers abroad, including to any international organization governed by

public international law or set up by two or more countries, such as the UN.

 Know about security measures: You have the right to know about the security

measures we take to safeguard your data.

How to exercise these rights

Any requests to exercise your rights can be directed to us. Our full contact details can be found

at the start of this document.

Such requests are free of charge and will be answered by us as early as possible, providing you

with the information required by law.

Any rectification or erasure of personal data or restriction of processing will be communicated

by us to each recipient, if any, to whom the personal data has been disclosed unless this proves

impossible or involves disproportionate effort. At your request, we will inform you about those

recipients.

Further information if you reside in Switzerland

This section applies to you if you reside in Switzerland, and supersedes any other possibly

divergent or conflicting information contained in the privacy policy.

Further details regarding the categories of data processed, the purposes of processing, the

categories of recipients of the personal data, if any, the retention period and further

information about personal data can be found in the section titled “Detailed information on the

processing of personal data” within this document.

Your rights according to the Swiss Federal Act on Data Protection

You may exercise certain rights regarding your data within the limits of law, including the

following:

 right of access to personal data;

 right to object to the processing of your personal data (which also allows you to demand

that processing of personal data be restricted, personal data be deleted or destroyed,

specific disclosures of personal data to third parties be prohibited);

 right to receive your personal data and have it transferred to another controller (data

portability);

 right to ask for incorrect personal data to be corrected.

How to exercise these rights

Any requests to exercise your rights can be directed to us through the contact details provided

at the start of this document. Such requests are free of charge and will be answered by us as

early as possible, providing you with the information required by law.

Further information if you reside in Brazil

This section of the document integrates with and supplements the information contained in the

rest of the privacy policy and is provided by the entity running this website and, if the case may

be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively

as “we”, “us”, “our”).

This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”,

“yours”), according to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it

supersedes any other possibly divergent or conflicting information contained in the privacy

policy. This part of the document uses the term “personal information” as it is defined in the

LGPD.

The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing.

Legal bases are as follows:

 your consent to the relevant processing activities;

 compliance with a legal or regulatory obligation that lies with us;

 the carrying out of public policies provided in laws or regulations or based on contracts,

agreements and similar legal instruments;

 studies conducted by research entities, preferably carried out on anonymized personal

information;

 the carrying out of a contract and its preliminary procedures, in cases where you are a

party to said contract;

 the exercising of our rights in judicial, administrative or arbitration procedures;

 protection or physical safety of yourself or a third party;

 the protection of health – in procedures carried out by health entities or professionals;

 our legitimate interests, provided that your fundamental rights and liberties do not

prevail over such interests; and

 credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details

provided at the start of this document.

Categories of personal information processed

To find out what categories of your personal information are processed, you can read the

section titled “Detailed information on the processing of personal data” within this document.

Why we process your personal information

To find out why we process your personal information, you can read the sections titled

“Detailed information on the processing of personal data” and “The purposes of processing”

within this document.

Your Brazilian privacy rights

You have the right to:

 obtain confirmation of the existence of processing activities on your personal

information;

 access to your personal information;

 have incomplete, inaccurate or outdated personal information rectified;

 obtain the anonymization, blocking or elimination of your unnecessary or excessive

personal information, or of information that is not being processed in compliance with

the LGPD;

 obtain information on the possibility to provide or deny your consent and the

consequences thereof;

 obtain information about the third parties with whom we share your personal

information;

 obtain, upon your express request, the portability of your personal information (except

for anonymized information) to another service or product provider, provided that our

commercial and industrial secrets are safeguarded;

 obtain the deletion of your personal information being processed if the processing was

based upon your consent, unless one or more exceptions provided for in art. 16 of the

LGPD apply;

 revoke your consent at any time;

 lodge a complaint related to your personal information with the ANPD (the National

data Protection Authority) or with consumer protection bodies;

 oppose a processing activity in cases where the processing is not carried out in

compliance with the provisions of the law;

 request clear and adequate information regarding the criteria and procedures used for

an automated decision; and

 request the review of decisions made solely on the basis of the automated processing of

your personal information, which affect your interests. These include decisions to define

your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you

exercise your rights.

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by

using the contact details provided at the start of this document, or via your legal

representative.

How and when we will respond to your request

Prompt responses

We will strive to promptly respond to your requests. In any case, should it be impossible for us

to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us

from immediately, or otherwise ever, complying with your requests. In cases where we are not

processing your personal information, we will indicate to you the physical or legal person to

whom you should address your requests, if we are in the position to do so.

Access or processing confirmation requests

If you file an access or personal information processing confirmation request, please make sure

that you specify whether you’d like your personal information to be delivered in electronic or

printed form. You will also need to let us know whether you want us to answer your request

immediately, in which case we will answer in a simplified fashion, or if you need a complete

disclosure instead. In the latter case, we’ll respond within 15 days from the time of your

request, providing you with all the information on the origin of your personal information,

confirmation on whether records exist, any criteria used for the processing and the purposes of

the processing, while safeguarding our commercial and industrial secrets.

Rectification, deletion, anonymization or personal information blocking requests

If you file a rectification, deletion, anonymization or personal information blocking request, we

will make sure to immediately communicate your request to other parties with whom we have

shared your personal information in order to enable such third parties to also comply with your

request — except in cases where such communication is proven impossible or involves

disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the

following cases:

 when the transfer is necessary for international legal cooperation between public

intelligence, investigation and prosecution bodies, according to the legal means

provided by the international law;

 when the transfer is necessary to protect your life or physical security or those of a third

party;

 when the transfer is authorized by the ANPD;

 when the transfer results from a commitment undertaken in an international

cooperation agreement;

 when the transfer is necessary for the execution of a public policy or legal attribution of

public service;

 when the transfer is necessary for compliance with a legal or regulatory obligation, the

carrying out of a contract or preliminary procedures related to a contract, or the regular

exercise of rights in judicial, administrative or arbitration procedures.

Further information if you reside in California

About this section

This section of the document integrates with and supplements the information contained in the

rest of the privacy policy and is provided by the business running this Website and, if the case

may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to

collectively as “we”, “us”, “our”).

Applicability

This section applies to all users (users are referred to below, simply as “you”, “your”, “yours”),

who are consumers residing in the state of California, United States of America, according to

the "California Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California

Privacy Rights Act" (the "CPRA") and subsequent regulations. For such consumers, this section

supersedes any other possibly divergent or conflicting information contained in the privacy

policy.

Definition

This part of the document uses the term “personal information“ as defined in the California

Consumer Privacy Act(CCPA/CPRA).

Categories of personal information that we collect

 We have collected the following categories of personal information about you:

o identifiers, and

o internet or other electronic network activity information

 We do not collect sensitive personal information.

 We will not collect additional categories of personal information without notifying you.

What are the purposes for which we use your personal information?

Business Purposes

We may use your personal information to allow the operational functioning of this website and

features thereof. In such cases, your personal information will be processed in a fashion

necessary and proportionate to the business purpose for which it was collected, and strictly

within the limits of compatible operational purposes.

Commercial Purposes

We may also use your personal information for other reasons such as for commercial purposes,

as well as for complying with the law and defending our rights before the competent

authorities where our rights and interests are threatened, or we suffer an actual damage.

No unexpected or incompatible purposes

We won’t process your information for unexpected purposes, or for purposes incompatible

with the purposes originally disclosed, without your consent.

How long do we keep your personal information?

Unless stated otherwise inside the “Detailed information on the processing of personal data”

section, we will not retain your personal information for longer than is reasonably necessary for

the purpose(s) they have been collected for.

What are the sources of the personal information we collect?

We collect the above-mentioned categories of personal information, either directly or

indirectly, from you when you use this website.

Direct Collection: For example, you directly provide your personal information when you

submit requests via any forms on this website.

Indirect Collection: You also provide personal information indirectly when you navigate this

website, as personal information about you is automatically observed and collected.

Third Parties: Finally, we may collect your personal information from third parties that work

with us in connection with the service or with the functioning of this Application and features

thereof.

How we use the information we collect

Disclosing of your personal information with third parties for a business purpose

For our purposes, the word “third party” means a person who is not any of the following: a

service provider or a contractor, as defined by the CCPA.

We disclose your personal information with the third parties listed in detail in the section titled

“Detailed information on the processing of personal data” within this document. These third

parties are grouped and categorized in accordance with the different purposes of processing.

Sale or sharing of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing,

disseminating, making available, transferring or otherwise communicating orally, in writing, or

by electronic means, a consumer's personal information by the business to a third party, for

monetary or other valuable consideration”, as defined by the CCPA.

This means that, for example, a sale can happen whenever an application runs ads, or makes

statistical analyses on the traffic or views, or simply because it uses tools such as social network

plugins and the like.

For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing,

disseminating, making available, transferring, or otherwise communicating orally, in writing, or

by electronic or other means, a consumer's personal information by the business to a third

party for cross-context behavioral advertising, whether or not for monetary or other valuable

consideration, including transactions between a business and a third party for cross-context

behavioral advertising for the benefit of a business in which no money is exchanged”, as

defined by the CCPA. Please note that the exchange of personal information with a service

provider pursuant to a written contract that meets the requirements set by the CCPA, does not

constitute a sale or sharing of your personal information.

Opt-Out Rights

We sell or share your personal information with the third parties listed in detail in the section

titled “Detailed information on the processing of personal data” within this document. These

third parties are grouped and categorized in accordance with the different purposes of

processing.

You have the right to opt out of the sale or sharing of your personal information. This means

that whenever you request us to stop selling or sharing your personal information, we will

abide by your request. Such requests can be made freely, at any time, without submitting any

verifiable request. To fully exercise your right to opt out, you can contact us at any time using

the contact details provided at the start of this document. For a simplified opt-out method you

can also use the privacy choices link provided on this website.

If you want to submit requests to opt out of the sale or sharing of personal information via a

user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do

so and we will abide by such request in a frictionless manner (as defined in the CPRA

regulations). The GPC consists of a setting or extension in the browser or mobile device and

acts as a mechanism that websites can use to indicate they support the GPC signal. If you want

to use GPC, you can download and enable it via a participating browser or browser extension.

More information about downloading GPC is available here.

We use any personal information collected from you in connection with the submission of your

opt-out request solely for the purposes of complying with the opt-out request. Once you have

opted out, we are required to wait at least 12 months before asking whether you have changed

your mind.

Your privacy rights under the California Consumer Privacy Act and how to

exercise them

The right to access personal information: the right to know and to portability

You have the right to request that we disclose to you:

 the categories of personal information that we collect about you;

 the sources from which the personal information is collected;

 the purposes for which we use your information;

 to whom we disclose such information;

 the specific pieces of personal information we have collected about you.

You also have the right to know what personal information is sold or shared and to whom. In

particular, you have the right to request two separate lists from us where we disclose:

 the categories of personal information that we sold or shared about you and the

categories of third parties to whom the personal information was sold or shared;

 the categories of personal information that we disclosed about you for a business

purpose and the categories of persons to whom it was disclosed for a business purpose.

The disclosure described above will be limited to the personal information collected or used

over the past 12 months.

If we deliver our response electronically, the information enclosed will be "portable", i.e.

delivered in an easily usable format to enable you to transmit the information to another entity

without hindrance — provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to

exceptions set forth by the law (such as, including but not limited to, where the information is

used to identify and repair errors on this website, to detect security incidents and protect

against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal

information and notify any of our service providers and all third parties to whom we have sold

or shared the personal information to do so — provided that this is technically feasible and

doesn’t involve disproportionate effort.

The right to correct inaccurate personal information

You have the right to request that we correct any inaccurate personal information we maintain

about you, considering the nature of the personal information and the purposes of the

processing of the personal information.

The right to opt out of sale or sharing of personal information and to limit the use of your

sensitive personal information

You have the right to opt out of the sale or sharing of your personal information. You also have

the right to request that we limit our use or disclosure of your sensitive personal information.

The right of no retaliation following opt-out or exercise of other rights (the right to non-

discrimination)

We will not discriminate against you for exercising your rights under the CCPA. This means that

we will not discriminate against you, including, but not limited to, by denying goods or services,

charging you a different price, or providing a different level or quality of goods or services just

because you exercised your consumer privacy rights.

However, if you refuse to provide your personal information to us or ask us to delete or stop

selling your personal information, and that personal information or sale is necessary for us to

provide you with goods or services, we may not be able to complete that transaction.

To the extent permitted by the law, we may offer you promotions, discounts, and other deals in

exchange for collecting, keeping, or selling your personal information, provided that the

financial incentive offered is reasonably related to the value of your personal information.

How to exercise your rights

 To exercise the rights described above, you need to submit your verifiable request to us

by contacting us via the details provided at the start of this document.

 For us to respond to your request, it’s necessary that we know who you are. Therefore,

you can only exercise the above rights by making a verifiable request which must:

o provide sufficient information that allows us to reasonably verify you are the

person about whom we collected personal information or an authorized

representative;

o describe your request with sufficient detail that allows us to properly

understand, evaluate, and respond to it.

 We will not respond to any request if we are unable to verify your identity and therefore

confirm the personal information in our possession actually relates to you.

 Making a verifiable consumer request does not require you to create an account with

us. We will use any personal information collected from you in connection with the

verification of your request solely for the purposes of verification and shall not further

disclose the personal information, retain it longer than necessary for purposes of

verification, or use it for unrelated purposes.

 If you cannot personally submit a verifiable request, you can authorize a person

registered with the California Secretary of State to act on your behalf.

 If you are an adult, you can make a verifiable request on behalf of a child under your

parental authority.

 You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

 We will confirm receipt of your verifiable request within 10 days and provide

information about how we will process your request.

 We will respond to your request within 45 days of its receipt. Should we need more

time, we will explain to you the reasons why, and how much more time we need. In this

regard, please note that we may take up to 90 days to fulfill your request.

 Our disclosure(s) will cover the preceding 12-month period. Only with regard to

personal information collected on or after January 1, 2022, you have the right to request

that we disclose information beyond the 12-month period, and we will provide them to

you unless doing so proves impossible or would involve a disproportionate effort.

 Should we deny your request, we will explain you the reasons behind our denial.

 We do not charge a fee to process or respond to your verifiable request unless such

request is manifestly unfounded or excessive. In such cases, we may charge a

reasonable fee, or refuse to act on the request. In either case, we will communicate our

choices and explain the reasons behind it.

Further information if you reside in Virginia

This section of the document integrates with and supplements the information contained in the

rest of the privacy policy and is provided by the controller running this Application and, if the

case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to

collectively as “we”, “us”, “our”).

This section applies to you if you reside in the Commonwealth of Virginia, according to the

“Virginia Consumer data Protection Act" (the "VCDPA"), and, it supersedes any other possibly

divergent or conflicting information contained in the privacy policy. This part of the document

uses the term “personal data” as defined in the VCDPA.

Categories of personal data processed

You can read about these activities in detail in the section titled “Detailed information on the

processing of personal data” within this document.

Types of personal data we collect

 We have collected the following categories of personal data: identifiers and internet

information

 We do not collect sensitive data.

 We will not collect additional categories of personal data without notifying you.

Why we process your personal data

To find out why we process your personal data, you can read the sections titled “Detailed

information on the processing of personal data” and “The purposes of processing” within this

document.

We won’t process your information for unexpected purposes, or for purposes incompatible

with the purposes originally disclosed, without your consent. You can freely give, deny, or

withdraw such consent at any time using the contact details provided at the start of this

document.

How we use the data we collect: sharing of your personal data with third parties

We share your personal data with the third parties listed in detail in the section titled “Detailed

information on the processing of personal data” within this document. These third parties are

grouped and categorized in accordance with the different purposes of processing. For our

purposes, the word "third party" means "a natural or legal person, public authority, agency, or

body other than the consumer, controller, processor, or an affiliate of the processor or the

controller" as defined by the VCDPA.

Sale of your personal data

For our purposes, the word “sale” means any “exchange of personal data for monetary

consideration by us to a third party” as defined by the VCDPA. Please note that according to the

VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of

a controller does not constitute a sale. In addition, other specific exceptions set forth in the

VCDPA may apply, such as, but not limited to, the disclosure of personal data to a third party

for the provision of a product or service requested by you. As specified in the “Detailed

information on the processing of personal data” section of this document, our use of your

personal information may be considered a sale under VCDPA.

Your right to opt out of the sale of your personal data and how you can exercise it

You have the right to opt out of the sale of your personal data. This means that whenever you

request us to stop selling your data, we will abide by your request. To fully exercise your right

to opt out you can contact us at any time using the contact details provided at the start of this

document.

We use any personal data collected from you in connection with the submission of your opt-out

request solely for the purpose of complying with the request.

Processing of your personal data for targeted advertising

We do not process your personal data for targeted advertising. If we decide to do so, we will

inform you beforehand and will grant your right to opt out of the processing of your

personal data for targeted advertising.

Your privacy rights under the Virginia Consumer data Protection Act and how to

exercise them

You may exercise certain rights regarding your data processed by us. You have the right to do

the following:

 access personal data: the right to know. You have the right to request that we confirm

whether we are processing your personal data. You also have the right to access such

personal data.

 correct inaccurate personal data. You have the right to request that we correct any

inaccurate personal data we maintain about you, considering the nature of the

personal data and the purposes of the processing of the personal data.

 request the deletion of your personal data. You have the right to request that we

delete any of your personal data.

 obtain a copy of your personal data. We will provide your personal data in a portable

and usable format that allows you to transfer data easily to another entity — if this is

technically feasible.

 opt out of the processing of your personal data for the purposes of targeted

advertising, the sale of personal data, or profiling in furtherance of decisions that

produce legal or similarly significant effects concerning you.

 non-discrimination. We will not discriminate against you for exercising your rights

under the VCDPA. This means that we will not, among other things, deny goods or

services, charge you a different price, or provide a different level or quality of goods or

services just because you exercised your consumer privacy rights. However, if you refuse

to provide your personal data to us or ask us to delete or stop selling your

personal data, and that personal data or sale is necessary for us to provide you with

goods or services, we may not be able to complete that transaction. To the extent

permitted by the law, we may offer a different price, rate, level, quality, or selection of

goods or services to you, including offering goods or services for no fee, if you have

exercised your right to opt out, or our offer is related to your voluntary participation in a

bona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise your rights

 To exercise the rights described above, you need to submit your request to us by

contacting us via the contact details provided at the start of this document.

 For us to respond to your request, we need to know who you are.

 We will not respond to any request if we are unable to verify your identity using

commercially reasonable efforts and therefore confirm that the personal data in our

possession relates to you. In such cases, we may request that you provide additional

information which is reasonably necessary to authenticate you and your request.

 Making a consumer request does not require you to create an account with us.

However, we may require you to use your existing account. We will use any

personal data collected from you in connection with your request solely for the

purposes of authentication, without further disclosing the personal data, retaining it

longer than necessary for purposes of authentication, or using it for unrelated purposes.

 If you are an adult, you can make a request on behalf of a child under your parental

authority.

How and when we are expected to handle your request

 We will respond to your request without undue delay, but in all cases and at the latest

within 45 days of its receipt. Should we need more time, we will explain to you the

reasons why, and how much more time we need. In this regard, please note that we

may take up to 90 days to fulfill your request.

 Should we deny your request, we will explain to you the reasons behind our denial

without undue delay, but in all cases and at the latest within 45 days of receipt of the

request. It is your right to appeal such decision by submitting a request to us via the

details provided in this document. Within 60 days of receipt of the appeal, we will

inform you in writing of any action taken or not taken in response to the appeal,

including a written explanation of the reasons for the decisions. If the appeal is denied

you may contact the Attorney General to submit a complaint.

 We do not charge a fee to respond to your request, for up to two requests per year. If

your request is manifestly unfounded, excessive or repetitive, we may charge a

reasonable fee or refuse to act on the request. In either case, we will communicate our

choices and explain the reasons behind them.

Further information if you reside in Colorado

This section of the document integrates with and supplements the information contained in the

rest of the privacy policy and is provided by the controller running this website and, if the case

may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to

collectively as “we”, “us”, “our”).

This section applies to you if you reside in the State of Colorado, according to the “Colorado

Privacy Act" (the "CPA"), and, supersedes any other possibly divergent or conflicting

information contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the CPA.

Categories of personal data processed

In this section, we summarize the categories of personal data that we've processed and the

purposes thereof. You can read about these activities in detail in the section titled “Detailed

information on the processing of personal data” within this document.

Categories of personal data we collect

 We have collected the following categories of personal data: identifiers and internet

information

 We do not collect sensitive data.

 We will not collect additional categories of personal data without notifying you.

Why we process your personal data

To find out why we process your personal data, you can read the sections titled “Detailed

information on the processing of personal data” and “The purposes of processing” within this

document.

We won’t process your information for unexpected purposes, or for purposes incompatible

with the purposes originally disclosed, without your consent. You can freely give, deny, or

withdraw such consent at any time using the contact details provided at the start of this

document.

How we use the data we collect: sharing of your personal data with third parties

We share your personal data with the third parties listed in detail in the section titled “Detailed

information on the processing of personal data” within this document. These third parties are

grouped and categorized in accordance with the different purposes of processing.

For our purposes, the word "third party" means "a person, public authority, agency, or body

other than a consumer, controller, processor, or affiliate of the processor or the controller." as

defined by the CPA.

Sale of your personal data

As specified in the “Detailed information on the processing of personal data” section of this

document, our use of your personal data may be considered a sale under the CPA.

For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for

monetary or other valuable consideration by a controller to a third party" as defined by the

CPA.

Please note that according to the CPA, the disclosure of personal data to a processor that

processes personal data on behalf of a controller does not constitute a sale. In addition, other

specific exceptions set forth in the CPA may apply, such as, but not limited to, the disclosure of

personal data to a third party for the provision of a product or service requested by you.

Your right to opt out of the sale of your personal data and how you can exercise it

You have the right to opt out of the sale of your personal data. This means that whenever you

request us to stop selling your data, we will abide by your request.

To fully exercise your right to opt out you can contact us at any time, using the contact details

provided at the start of this document.

For a simplified opt-out method you can also use the privacy choices link provided on this

website.

We use any personal data collected from you in connection with the submission of your opt-out

request solely for the purpose of complying with the request.

Processing of your personal data for targeted advertising

We do not process your personal data for targeted advertising. If we decide to do so, we will

inform you beforehand and will grant your right to opt out of the processing of your

personal data for targeted advertising.

For our purposes, the word "targeted advertising" means "displaying to a consumer an

advertisement that is selected based on personal data obtained or inferred over time from the

consumer's activities across non-affiliated websites, applications, or online services to predict

consumer preferences or interests" as defined by CPA. Please note that according to the CPA,

targeted advertising does not include: “advertisements directed to a consumer in response to

the consumer's request for information or feedback; advertisements based on activities within

a controller's own websites or online applications or any affiliated website or online

application; advertisements based on the context of a consumer's current search query, visit to

an internet web site or online application; or processing personal data solely to measure or

report advertising frequency, performance or reach”.

Universal opt-out mechanism: Global privacy control

If you want to submit requests to opt-out of the targeted advertising via a user-enabled global

privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide

by such request. The GPC consists of a setting or extension in the browser or mobile device and

acts as a mechanism that websites can use to indicate they support the GPC signal. If you want

to use GPC, you can download and enable it via a participating browser or browser extension.

More information about downloading GPC is available here.

Your privacy rights under the Colorado Privacy Act and how to exercise them

You may exercise certain rights regarding your data processed by us. In particular, you have the

right to do the following:

 opt out of the processing of your personal data for the purposes of targeted advertising,

the sale of personal data, or profiling in furtherance of decisions that produce legal or

similarly significant effects concerning you.

 access personal data. You have the right to request that we confirm whether or not we

are processing your personal data. You also have the right to access such personal data.

 correct inaccurate personal data. You have the right to request that we correct any

inaccurate personal data we maintain about you, taking into account the nature of the

personal data and the purposes of the processing of the personal data.

 request the deletion of your personal data. You have the right to request that we delete

any of your personal data.

 obtain a copy of your personal data. We will provide your personal data in a portable

and usable format that allows you to transfer data easily to another entity – provided

that this is technically feasible.

In any case, we will not increase the cost of, or decrease the availability of, a product or service,

based solely on the exercise of any of your rights and unrelated to the feasibility or the value of

a service. However, to the extent permitted by the law, we may offer a different price, rate,

level, quality, or selection of goods or services to you, including offering goods or services for

no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards,

premium features, discounts, or club card program.

How to exercise your rights

 To exercise the rights described above, you need to submit your request to us by

contacting us via the contact details provided at the start of this document.

 For us to respond to your request, we need to know who you are and which right you

wish to exercise.