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Privacy Policy
Effective Date: July 1, 2023
Retail Services & Systems, Inc. and affiliated companies doing business under Total Wine & More brands and associated brands (“Total Wine,” “we,” “our,” or “us”) know that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This Privacy Policy lets you know what information we collect, how we may share that information, and your choices regarding the sharing of your information. Please note, our privacy practices are subject to the applicable laws of the places in which we operate. You will see additional region-specific terms that only apply to customers located in those geographic regions, or as required by applicable laws.
You are subject to our Terms & Conditions, which govern your access to and use of the Total Wine & More Sites (defined below). Click Terms & Conditions for more information.
Privacy Policy table of contents
- Our privacy commitment
- What our Privacy Policy covers
- Acceptance of and changes to this Privacy Policy
- Personal information we collect and use
- How we collect personal information
- Notice of cookies & clickstream technology, including opting out
- How we use your Personal Information
- Security of your personal information
- How we disclose your personal information
- Your rights related to Personal Information held by us
- Additional notice to California residents
- Our response to requests
- Non-discrimination policy for exercising your privacy rights
- Notice of financial incentive
- Retention
- Updating your personal information
- E-mail & account registration
- Children’s and minor’s privacy
- Nevada privacy notice
- How to contact us
1. Our privacy commitment
We value the relationship we have with our customers and prospective customers, and we are committed to protecting the confidentiality, accuracy, and integrity of your Personal Information, meaning any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer or household. Personal Information does not include deidentified or aggregate information, or public information lawfully available from governmental records. We understand the importance of keeping your Personal Information secure.
2. What our Privacy Policy covers
This Privacy Policy covers our customer-facing operations and applies to Personal Information collected from and about prospective customers and customers of businesses that operate retail liquor stores under Total Wine & More brands and associated brands in various states, whether collected at a retail location (a “Store”) or from the Total Wine & More website, webpages, mobile site, and/or app (the “Sites”).
We may provide different or additional privacy notices in connection with certain activities, programs, and offerings. We may also provide additional “just-in-time” notices that may supplement or clarify our privacy practices or provide you with additional choices regarding your personal information. 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 the Job applicant terms & conditions page for more information.
Our Sites may include links to websites and/or applications operated and maintained by third parties. Please note that we have no control over the privacy practices of websites or applications that we do not own. We encourage you to review the privacy practices of those third parties.
3. Acceptance of and changes to this Privacy Policy
As Total Wine continues to improve the services, products, and features we provide, this Privacy Policy is subject to change. We reserve the right to amend this Privacy Policy at any time by posting the amended policy on the Sites and updating the Effective Date at the top of this page.
By using the Total Wine site and services, you signify your acceptance of this Privacy Policy. If you do not agree with any position or statement herein, your sole option is to discontinue use of the Store or Sites. Your continued use of any portion of the Stores or Sites following notification or posting of such changes constitutes your acceptance of those changes. If you have questions or concerns about our specific policies, please send an e-mail to privacy@totalwine.com
4. Personal Information we collect about you
Total Wine collects your Personal Information (including individuals associated with you, all of whom are referred to as “you” in this Privacy Policy) in its normal course of business and over the course of your relationship with us. We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:
- Identifiers, such as name, alias, delivery address, delivery signature, postal address, phone number, email address, date of birth, age or age range, IP address, unique personal identifier, online identifier, and other similar unique identifiers, certain of which are described in the “Cookie Policy” below
- Characteristics of protected classifications under California or federal law, such as age (over 40); gender identity or gender expression; marital status; military or veteran status; or disability information.
- Commercial information, such as transaction history, purchase history or tendencies, last 4 digits of credit cards, &MORE Rewards or awards purchases, points, and benefit utilization, returns data, product delivery data, product or service ratings, product or service reviews, and email or mail subscriber status.
- Internet or other similar network activity, such as search history and information about consumer’s interaction with an Internet website, application, or advertisement.
- Geolocation Information, such as presence at a retail location, billing information, product delivery information, or “Preferred Store” election on website or application.
- Audio or video footage collected using CCTV cameras, (only if you visit one of our premises that uses this technology) or Customer Service phone call recording.
- Job applicant information, such as education, employment, or other professional information. See the Job applicant terms & conditions page for more information.
- Inferences drawn from Personal Information for purposes of creating a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, and attitudes.
- Sensitive Personal Information. We may collect minimal sensitive personal information, as defined in the applicable state privacy laws, but only with your consent. Such minimal sensitive personal information consists of account passwords used to access the Sites, which are encrypted and inaccessible to the Total Wine in the ordinary course of business. We do not use sensitive personal information for inferring characteristics about you.
5. How we collect your Personal Information
We collect personal information about you from various sources. For example, we collect and obtain information:
- Directly from you, such as when you visit our Sites, manually enter Personal Information into our Sites’ forms to place a delivery order or join the &MORE Rewards program, or when you post on-line to a social media account.
- Indirectly from you. For example, from observing your actions on our Sites.
- Affiliated Companies and Service Providers that process information for us, such as third-party social networking providers, tech or customer support, operations, web or data hosting, billing, credit card processing, accounting, security, marketing, or data management, validation, enhancement, or hygiene. For example, we get updated addresses from the National Change of Address (“NCOA”) service to ensure we have the correct contact information for our customers.
- Consumer data resellers and renters, such as entities that compile Personal Information about prospective or current Total Wine customers for purposes of updating, verifying or deduplicating Personal Information, or prospecting new potential customers.
- From publicly available sources. For example, online database searches.
6. Notice of cookies & clickstream technology, including opting out
As you navigate the Sites, we may also collect information about you using common information-gathering tools, such as cookies and web beacons (collectively “Website Navigational Information”). Website Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Sites (such as the web pages viewed and the links clicked).
Cookies
Like many companies, we use cookies on our Sites. Cookies are pieces of information shared between your web browser and a website. Use of cookies enables a faster and easier experience for the user.
There are different kinds of cookies with different functions:
- Session cookies: These are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.
- Persistent cookies: A persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
- First-party cookies: The function of this type of cookie is to retain your preferences for a particular website for the entity that owns that website. They are stored and sent between Total Wine’s servers and your computer’s operating system. They are not used for anything other than for personalization as set by you. These cookies may be either Session or Persistent cookies.
- Third-party cookies: The function of this type of cookie is to retain your interaction with a particular website for an entity that does not own that website. They are stored and sent between the Third-party’s server and your computer’s or device’s hard drive. These cookies are usually Persistent cookies.
We do use third-party cookies on our Sites, as well as third party provided web beacons (please see the section on Web Beacons below). These cookies are used by us and our marketing partners to better understand your preferences and to tailor and improve your experience on the site based on our impressions of your interests.
More specifically, our Sites use Google Analytics and Adobe Site Catalyst, which are web analytic tools provided by Google, Inc. and Adobe Inc., respectively. These services use cookies to help our Sites analyze how users use the Sites. The information generated by the cookies about your use of the Sites (including your IP address) will be transmitted to and stored by these vendors on servers in the United States. These vendors will use this information for the purpose of evaluating your use of the Sites, compiling reports on Site activity, and providing other services relating to Site activity and internet usage for Total Wine. These vendors may also transfer this information to third parties where required to do so by law, or where such third parties process the information for the vendors for purposes of providing those services. These vendors will not associate your IP address with any other data held by them. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, if you do block the use of cookies, you will not be able to use the full functionality of the Sites. By using the Sites, you consent to the processing of data about you by Google and Adobe in the manner and for the purposes set out above.
Along with the above noted uses, we use cookies for the following purposes:
- Strictly necessary cookies: These cookies are essential to enable you to move around the Sites and use its features, such as accessing secure areas of the Sites. Without these cookies, services you have asked for, such as logging into your account and using a shopping cart, cannot be provided. You can set your browser to block or alert you about these cookies, but then some parts of the Sites will not work. These cookies do not store any personally identifiable information.
- Functional cookies: These cookies allow our Sites to remember choices you make (such as your username, language, or the region you are in) and provide enhanced, more personal or customized features. For instance, the Sites need to remember your login details, so that you do not have to repeatedly sign into your account when using a particular device to access our Sites. The information these cookies collect is usually anonymized. They may be set by us or by third-party providers whose services we have added to our pages. They do not gather any information about you that could be used for advertising or remember where you have been on the Internet.
- Performance & analytics cookies: These cookies collect information about how visitors use a Sites, such as which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to the Sites, all of which enables us to see how visitors use the Sites in order to improve the way that our Sites works. These cookies do not collect information that identifies a person, as all information these cookies collect is aggregated and anonymous.
- Marketing & advertising cookies: Total Wine does not "sell" your personal information as the word "sell" is commonly understood. In other words, we are do not give your personal information to third parties in exchange for money. However, our Sites do use cookies that may be used by third parties to build a profile of your interests and show you relevant advertisements on other sites. These cookies may also be used to enable you to share pages and content that you find interesting on our Sites through third-party social networking and other websites. The cookies do not store directly personal information, but are based on uniquely identifying your browser and Internet device. If you do not allow these cookies, you will experience less targeted advertising and may not be able to share pages or content you find interesting through third-party social networking sites.
- Please note: We embed videos or insert links to videos from YouTube on our Sites. As a result, when you visit a page with content embedded from or linked to YouTube, you may be presented with cookies from YouTube. If you opt out of advertising and marketing cookies here, YouTube may still utilize cookies for those embedded videos and links. You can control YouTube cookies by visiting https://policies.google.com/technologies/cookies
For information on all these categories of cookies, and for more information generally on cookies please refer to aboutcookies.org or https://consumer.ftc.gov/articles/how-protect-your-privacy-online
Opting out of cookies
There are various ways for you to manage cookies and other technologies.
Browser settings
Through your browser settings, you can disable all the above-listed cookies (and other tracking tools) or request to be prompted before accepting cookies from the Sites and other websites you visit. These browser settings may also permit you to delete cookies you already have. Please consult your web browser’s ‘Help’ documentation or visit aboutcookies.org or https://consumer.ftc.gov/articles/how-protect-your-privacy-online for more information about how to turn cookies on and off for your browser. If you use different browsers and computers, you will need to adjust the appropriate cookie settings for each browser and computer. Certain parts of the Sites may function differently, and you may not be able to use some portions of our Sites if you choose to disable cookies entirely.
You may also opt out by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (“GPC”) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal, click here https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.
Cookie Banner
When you first accessed the Sites, a cookie banner at the bottom of the screen allowed you to access user-enabled privacy controls through a OneTrust preference center. Such controls allowed you to opt-out of marketing & advertising cookies, as described above.
Third-party extensions
There are several browser extensions that allow you to manage cookies and personalize your browsing experience. Since these extensions are made by third party providers, Total Wine does not control these features and cannot provide technical support for these products.
Targeted advertising cookies
You may opt-out of advertising cookies from companies who are members of the Network Advertising Initiative (“NAI”) or who subscribe to the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Please visit the Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page to opt out directly from providers who participate in those programs.
Web beacons
The Sites may also use web beacons (including web beacons supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of the Sites and interaction with e-mails from Total Wine. Web beacons are transparent electronic images that can recognize certain types of information on your computer, such as cookies, when you view a particular Site tied to the web beacon, and a description of a Site tied to the web beacon. We use web beacons to operate and improve the Sites and e-mail communications. We may use information from web beacons in combination with other data we have about our customers to provide you with information about Total Wine and our services. We will conduct this review on an anonymous basis.
IP addresses
When you visit our Sites, Total Wine collects your Internet Protocol (“IP”) addresses to track and aggregate non-Personal Information. For example, Total Wine uses IP addresses to monitor the regions from which users navigate the Sites. IP addresses will be stored in such a way so that you cannot be identified from the IP address. In addition, Total Wine uses your IP address to get an approximate location so we can find a store closest to you. We do this for both your convenience, as well as for legal compliance reasons.
7. How we use your personal information
We collect and use your Personal Information for various purposes, including:
- Consumer Transactions, such as processing a purchase or fulfilling an order, as well as creating, maintaining, customizing, and securing your account with us.
- Customer Service and Relationship Management, such as addressing a customer complaint, applying &MORE Rewards points to a transaction.
- Customer Experience, such as improving website offerings and interface, identifying and repairing errors in our Sites’ functionality, testing, research, analysis, and product development, including to develop and improve our Sites, products, and Services.
- Marketing and Advertising, such as providing promotions that are interesting to you based on your purchasing and viewing history, ad customization that does not involve or contribute to profiling, and managing promotions and contests.
- Merchandising, such as determining and improving product assortment based on your purchasing history.
- Analytics, such as information about Site performance relative to your computer or device, hosting our Sites, and managing databases.
- Security and Compliance, such maintaining the safety, security, and integrity of our Sites, products and Services, databases and other technology assets and our business, including preventing fraud, detecting security breaches, and prosecuting violators, and responding to law enforcement requests and meeting requirements of applicable law, court order, or governmental regulations.
8. Security of your personal information
Whether you are shopping on our Sites or in our Stores, we use reasonable security measures to protect the confidentiality of personal information under our control and appropriately limit access to it. The Total Wine Sites use Transport Layer Security (“TLS”) or equivalent encryption technologies to protect your personal information during data transport, including your name, address, and credit card number. However, no security controls are failproof, and Total Wine cannot completely ensure or warrant the security of your personal information. We therefore urge you to always use caution when transmitting information over the Internet.
When you create an account on TotalWine.com you are required to establish a password that must be at least 8 characters, contain one letter, one number, and one special character. Your password may not contain your first name or last name. You are solely responsible for maintaining the secrecy of your password and account information. We strongly recommend that you do not share this information with others. You have the ability to purchase on our Sites without creating an account; however, you will need to reenter your personal information each time you use our Sites to make a purchase.
9. How we disclose your personal information
We do not disclose any Personal Information about you to others except as stated in this Privacy Policy, as otherwise permitted by law, or authorized by you. This Privacy Policy does not apply to privacy practices of third parties that we do not own or control, including but not limited to any third-party websites, services, applications, or online resources to which the Sites may link, embed, reference, or otherwise provide access. We are not responsible for the privacy practices or the content of such third-party sites. Please contact these third parties directly for information regarding their privacy practices. However, we only allow our service providers to handle your personal information if we are satisfied with the appropriate measures taken to protect your personal information. We also impose contractual obligations on service providers, contractors, and third parties to ensure they can only use your personal information to provide services to us and to you.
We may disclose your Personal Information to the following categories of other parties for a business purpose or commercial purpose, as those terms are defined in state privacy laws:
- Our affiliates, employees, and authorized agents;
- Service providers for our businesses, as described further below;
- Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you, as described further below;
- Government regulators or law enforcement, where required;
- Our legal advisors and other parties when required by law or pursuant to legal process; and
- To any entity involved in the purchase or sale of our businesses, as described further below.
Service providers
We use third-party service providers to enhance your consumer experience. This may include, for instance, providers who assist us with tech or customer support, operations, web or data hosting, billing, credit card processing, accounting, security, marketing, data management, validation, enhancement or hygiene, or otherwise help us to provide, develop, maintain and improve our services. These companies may use information about your visits to our Sites to help process delivery orders and/or provide personalized recommendations and advertisements about our goods and services on our Sites or other websites. Because service providers we use may be located in the United States, your Personal Information may be processed and stored inside the United States; and the U.S. government, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Information under U.S. laws.
Third parties
Some areas in our Sites may be offered to you in association with affiliated or non-affiliated third parties, such as co-promotional partners, dedicated producers of drinks, or co-sponsors of events you may want to attend. Such co-branded areas may require you to disclose Personal Information to the third party. The co-branded areas will identify the third party; however, the third party’s privacy policy will apply to how they treat your Personal Information. We recommend you review the privacy policy of these third parties. If you elect to register for events or products with these third parties you will be providing your Personal Information to both us and the third party.
Parts of the Sites use YouTube API Services to provide access to Total Wine’s YouTube channel. You acknowledge and agree to be bound by the YouTube Terms of Service (https://www.youtube.com/t/terms) and Google’s Privacy Policy (https://policies.google.com/privacy) when engaging YouTube content and services through the Sites. You may manage your YouTube API data by visiting Google’s security settings page at: .
To provide advertisements and content that are more relevant to you, we and our advertising and content providers may collect Personal Information when you use our Sites (such as the IP address of your device, the identifier on your mobile device, or cookies stored on your device), and may share the information we collect with third parties. Please see our Cookie Policy for more information.
Social media, reviews, and user generated content
Any personally identifiable information you submit on a social media website, such as Facebook or Twitter, bulletin board, blog, chat room, or any other public forum on our Sites can be read, collected, or used by other users of these forums, who could be used to send you unsolicited messages. We recommend that you do not provide your name, e-mail address, or any other personal information in public forums on this Sites. Please note that if you choose to do so, it is at your own risk and you accept full responsibility for those posts and any consequences that may arise.
Sale of assets
As we continue to develop our businesses, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. Also, if either Total Wine itself or substantially all of Total Wine assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third-party purchaser in these circumstances, which could include a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets.
Other legally required disclosures
Total Wine preserves the right to disclose without your prior permission any Personal Information about you or your use of this Sites if Total Wine has a good faith belief that such action is necessary to: (a) protect and defend the rights, property, or safety of Total Wine, employees, other users of this Sites, or the public; (b) enforce the terms and conditions that apply to use of this Sites; (c) respond to a legally valid request from a competent governmental authority; or (d) respond to claims that any content violates the rights of third parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process, or governmental request.
10. Your rights related to Personal Information held by us
Please note that your rights listed below may vary depending on your state of residence. If you are a resident of California, Colorado, Connecticut, or Virginia, the following rights apply to you unless a specific state is mentioned. You may exercise your rights through Total Wine’s Privacy Portal.
| Right to Know Collected Personal Information |
You have the right to know, and request disclosure of:
Please note that we are not required to:
|
|---|---|
| Right to Know Disclosed, Sold, or Shared Personal Information | In connection with any Personal Information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:
|
| Right to Opt-Out of Sale or Sharing | You have the right to opt-out of the sale of your Personal Information or sharing of your Personal Information. If you exercise your right to opt-out of the sale or sharing of your Personal Information, we will refrain from selling or sharing your Personal Information, unless you subsequently provide express authorization for the sale or sharing of your Personal Information. |
| Right to Limit Use of Sensitive Personal Information |
In California, you have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:
In Colorado, Connecticut, or Virginia, you have the right to opt-in to the use of sensitive personal information, which Total Wine will provide before or at the time of collection of such information. |
| Right to Deletion |
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
Please note that we may not delete your personal information if it is reasonably necessary to:
|
| Right to Correction | If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information. |
| Right to Appeal | If you are a Colorado, Connecticut, or Virginia resident, you may appeal our decision to your request regarding your personal information. We respond to all appeal requests as soon as we reasonably can, and no later than legally required. |
11. Additional notice to California Residents
California law requires us to disclose the following additional information with respect to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of the Privacy Policy.
Shine the Light
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.
Categories of Personal Information disclosed for business or commercial purposes over the last 12 months
You can find a list of categories of Personal Information that we collect in the “Personal Information we collect about you” section above. For details regarding the sources from which we obtain Personal Information, please see the “How we collect your Personal Information” section above. We collect and use personal information for the business or commercial purposes described in the “How we use your Personal Information” section above. Below is a non-exhaustive list of examples of such “business purposes” or “commercial purposes” as defined under California law.
- Consumer Transactions, such as processing a purchase or fulfilling an order, as well as creating, maintaining, customizing, and securing your account with us.
- Customer Service and Relationship Management, such as addressing a customer complaint, applying &MORE Rewards points to a transaction.
- Customer Experience, such as improving website offerings and interface, identifying and repairing errors in our Sites’ functionality, testing, research, analysis, and product development, including to develop and improve our Sites, products, and Services.
- Marketing and Advertising, such as providing promotions that are interesting to you based on your purchasing and viewing history, ad customization that does not involve or contribute to profiling, and managing promotions and contests.
- Merchandising, such as determining and improving product assortment based on your purchasing history.
- Analytics, such as information about Site performance relative to your computer or device, hosting our Sites, and managing databases.
- Security and Compliance, such maintaining the safety, security, and integrity of our Sites, products and Services, databases and other technology assets and our business, including preventing fraud, detecting security breaches, and prosecuting violators, and responding to law enforcement requests and meeting requirements of applicable law, court order, or governmental regulations.
Categories of Personal Information sold or shared over the last 12 months
We do not “sell” your Personal Information in exchange for money. However, certain state law views the “sale” of Personal Information more broadly, to include any transfer to another business or third party for valuable consideration. Under this broad definition, we have shared during the 12-month period prior to the effective date of this Privacy Policy the Identifiers (as defined above) with entities that compile Personal Information about prospective or current Total Wine customers for purposes of updating, verifying or deduplicating Personal Information, prospecting new potential customers, and improving the types of services and products we offer to you. For more information about how your information is disclosed and the entities to whom it is disclosed, see the “How we disclose your Personal Information” section above. The categories of information disclosed about you include identifiers, commercial information, internet, or other similar network activity as defined in the "Personal Information we collect about you" section above. In addition, the collection of Internet or electronic network activity information (as defined above) through cookies on our Sites for a variety of purposes, including personalized advertising and facilitating your activity on social media, may constitute a “sale” under state privacy laws and occurred during the 12-month period prior to the effective date of this Privacy Policy. Please refer to our Cookie Policy to better understand your privacy options.
12. 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.
13. 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 certain state privacy law, 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.
14. 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.
15. Retention
We retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Please note that in many situations we must retain all, or a portion, of your personal information to comply with our legal obligations; resolve disputes; enforce our agreements; protect against fraudulent, deceptive, or illegal activity; or for another one of our business purposes. We dispose of the information we collect in accordance with our retention policies and procedures.
16. Updating your personal information
Total Wine wants your personal information to be accurate and complete. We provide several different methods for you to update your personal information. To update your name, address, phone number and/or e-mail information:
| Online: | Login to My Account on TotalWine.com to update your personal account information (if you've created an account on TotalWine.com) |
| Phone: | 1-855-330-6673 |
| Email: | privacy@totalwine.com |
| Mail: |
Total Wine & More, Store Support Center |
If you send an e-mail or letter request, please be sure to include your current information and the requested changes.
17. E-mail & account registration
During registration on the Sites, we collect an e-mail address to communicate with you about your transaction. We use this e-mail address to contact you if there are any issues and to notify you about the status of your order. If you do not want this retained for future promotional e-mail inclusion, we provide you the ability to opt-out.
If a user wishes to subscribe to our e-mails, we ask for contact information such as name, preferred store, and e-mail address. We may use your personal information for purposes other than sending you promotional materials. For example, we may use your information to send you administrative communications about any account you may have with us or about future changes to this Privacy Policy. If at any time you should wish to unsubscribe, please click on the "unsubscribe" link in any e-mail from us or send an e-mail to privacy@totalwine.com.
When you register as a member of the Sites or sign-up to receive our e-mail offers, we collect information that helps us identify you. The more information you provide, the better we can customize our services and your experience to suit your needs and preferences.
18. Children's and minor's privacy
Total Wine Stores and Sites are intended for adults 21 years of age and older. We do not knowingly collect personal information from minors under the age of 21. If you have reason to believe that a person under the age of 21 has provided Personal Information to us, please contact us as provided in the “How to contact us” section below with sufficient detail to enable us to delete that information from our databases.
For more information about Parental Control options, see our Terms & Conditions.
19. Nevada privacy notice
Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. Total Wine does not sell your personal information to third parties as defined in Nevada law and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. See above for more information about how you can protect your information, and what we do to protect your information.
20. How to contact us
| Phone: | 1-855-330-6673 |
| Email: | privacy@totalwine.com |
| Mail: |
Total Wine & More, Store Support Center |