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PRIVACY POLICY

Effective December 23, 2019

Welcome to WineEnthusiast.com. The Wine Enthusiast, Inc. (“we”, “us” or the
“Company”) is committed to protecting your privacy! This Privacy Policy
describes how we collect, use, share and protect your personal information,
including information gathered through your use of WineEnthusiast.com, and
affiliated websites winemag.com, wineexpress.com and thirstynest.com
(“Websites”) that link to this Privacy Policy and any services we may provide
(collectively, “Services”). This Privacy Policy covers data, including personal
information, collected through our Services and all other means whether online
or offline. By using our Services, you accept the practices described in this
Privacy Policy. If you do not agree to this Privacy Policy, please do not use
our Services.

We encourage you to use this Privacy Policy to learn more about:

 * What information of yours is collected by us;
 * How we use the information we collect;
 * Your rights with respect to the information we collect;
 * How we protect children;
 * How you can opt-out of receiving communications from us;
 * The security of your information;
 * How to contact us with any comments or questions about this Privacy Policy;
 * California Privacy Rights;
 * Text Messaging Terms;
 * Cookie Policy; and
 * Third Party Pixels & Cookies.

This policy may be updated from time to time without prior notice, so please
check back periodically. If you continue to use our Services after such changes
have been made, you hereby provide your consent to the changes.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

 * You may provide your personal information to us when you contact us by phone,
   email, via our websites or any other way in order to use our Services to
   search within or place orders through our services, contact us with
   inquiries, respond to surveys, participate in one of our promotional
   sweepstakes or otherwise access our services. This information may include:
   * Identifying Information. For example, we may collect your first and last
     name, unique personal identifier, online identifier, mailing address, email
     address and telephone number, including your mobile phone number.
   * Payment Information. We may collect your credit card information, including
     billing address.
   * Event Information. For example, we may collect specific information such as
     name, date and mailing address associated with your event registry.
   * Information You Post. For example, we may collect information you post in a
     public space on our sites including our customer review and question and
     answer sections.
   * Social Media Information. We may collect information you post on our social
     media pages. We may also collect your social media profile information.
     Also, keep in mind that if you voluntarily disclose personal information
     online, for example, in a forum made available via social media, that
     information can be viewed and used by others.
   * Information You Submit. For example, we may collect information when you
     contact us through the “Live Chat” feature on our certain of our sites. You
     may also provide marketing and communications data, including your
     preferences for receiving mailings from us.
   * Device Information. We may collect the type of device you use to access our
     Websites. This may include your device identification number, IP address or
     mobile operating system.
   * Commercial Information. For example, we may collect information about the
     products or services you purchased, obtained or considered, as well as
     other purchasing or consuming histories or tendencies.
   * Internet or other Network Activity Information. We may collect information
     related to your browsing history and other information regarding your
     interactions with our Websites or advertisements.
   * Information We Collect Automatically and Use of Cookies. Certain
     non-personally identifiable information about our visitors is collected by
     the standard operation of our internet services and through the use of
     “cookies”. Click herefor more information on our cookies policy, the types
     of cookies we use and to manage your cookies preferences.

USE OF INFORMATION WE OBTAIN

We may use the information we obtain about you to:

 * Provide our Services, including but not limited to the fulfillment of orders;
 * Improve the content of our Services and enhance your experience;
 * Communicate with you about our Services, and respond to your inquiries;
 * Send correspondence (including, for example, email on behalf of ourselves
   and/or reputable organizations whose products or services are complementary
   to our Services);
 * Personalize your use and interaction with our Services;
 * Analyze trends and statistics;
 * Operate, evaluate, develop, manage and improve our business;
 * Maintain and enhance the safety and security of our Services and prevent
   misuse;
 * Comply with and enforce applicable legal requirements, relevant industry
   standards or policies; and
 * Otherwise manage and enhance our Services or as otherwise permitted by law or
   as we may notify you.

HOW WE SHARE YOUR INFORMATION

We will not disclose your personal information except as described. We may share
your information in the following ways:

 * Internally. We may share your information within The Wine Enthusiast family
   of companies.
 * On Our Websites. For example, we may display information you post in our
   customer review or question and answer sections of our websites.
 * With Our Service Providers. We may share your information with third parties
   who perform services on our behalf. For example, this may include third party
   merchandise vendors, providers of order fulfillment and package delivery
   services for our products or payment processors. It may also include
   companies that send emails on our behalf, process subscriptions to our
   magazine, provide marketing assistance, data analysis or search results. We
   do not authorize these service providers to use or disclose your personal
   information except as necessary to perform services on our behalf or comply
   with legal requirements.
 * For Marketing Purposes. This may include third parties whose products and
   services are complementary to ours and in which we believe you may be
   interested.
 * To Comply With The Law Or to Protect Ourselves. We also may disclose personal
   information about you (1) if we are required to do so by law or legal process
   (such as a court order or subpoena); (2) in response to requests by
   government agencies, such as law enforcement authorities; (3) to establish,
   exercise or defend our legal rights; (4) when we believe disclosure is
   necessary or appropriate to prevent physical harm or financial loss; (5) in
   connection with an investigation of suspected or actual illegal activity; or
   (6) otherwise with your consent.
 * With any Successors To All Or Part Of Our Business. We reserve the right to
   share or transfer any personal information we have about you in connection
   with a prospective or actual sale, merger, transfer or other reorganization
   of all or parts of our business (including in the event of a divestiture,
   restructuring, reorganization, dissolution or liquidation).

YOUR RIGHTS WITH RESPECT TO THE PERSONAL INFORMATION WE HAVE COLLECTED.

You have the right to:

 * Know what personal information we have about you and request a copy of the
   same;
 * Update or change any incorrect personal information;
 * Ask us to stop collecting, processing and using your personal information in
   certain ways;
 * Request the portability of your personal information; and
 * Raise concerns about automated decision making processes.

If you wish to do any of the above, please send an email request
to privacy@wineenthusiast.net. We may request you provide us with information to
verify your identity before responding to your request. We may refuse to comply
with a request if the request is manifestly unfounded or excessive or repetitive
in nature. We may also retain your personal information to comply with laws,
prevent fraud, resolve disputes, trouble-shoot problems, assist with
investigations or enforce our contracts.

If you are a California resident, please see our explanation of your right to
opt-out of the sale of your personal information in the “Your California Privacy
Rights” section below.

USE OF OUR SERVICES BY CHILDREN.

Our Services are not intended for children under the age of 16, and we do not
intend to collect personal information from or about children under the age of
16. If a child under the age of 16 has provided us with personal information,
that child’s parent or legal guardian should contact us
at privacy@wineenthusiast.netif they would like the information submitted by the
child deleted from our records or database. If you are age 21 or younger, you
are not authorized to submit any content or information to us without the
explicit consent of your parent or guardian. Also, our Websites wineexpress.com
and thirstynest.com are not intended for use by anyone under the age of 21. No
one under the age of 21 is allowed to use these sites, provide any personal
information or receive email distributions with respect to these Websites.

OPTING OUT OF FUTURE COMMUNICATIONS.

You may opt-out of receiving email marketing communications from us by using the
“unsubscribe” link in our emails, or by emailing us
at privacy@wineenthusiast.net. To opt-out of physical mailings and telephone
communications, or to add your name to our do-not-share list, you may email us
at the above address or call us at 800-648-6058. We will be sure your name is
removed from our list (and the list we may share with third parties) as soon as
possible after we receive your request. Please be aware, however, that even
after your request is processed, we may, for a time, retain residual information
about you in backup and/or archival copies of our database.

If you elect to receive marketing text messages from us, either via our website
or by sending a text message indicating your consent, you are providing your
prior express written consent to receive recurring marketing or promotional SMS
text messages from us (each, a “Text Message”) sent through an automatic
telephone dialing system. These may include cart abandon messages. Message
frequency varies. This service is optional and is not a condition for purchase.
You can opt out of receiving any further Text Messages from us at any time by
replying “STOP” to any Text Message you receive from us. For help, reply “HELP”
to any Text Message you receive from us or email textsupport@wunderkind.co.In
addition to any fee of which you are notified, your mobile provider’s message
and data rates may apply to our confirmation Text Message and all subsequent
Text Message correspondence according to your individual rate plan provided by
your wireless carrier. Please consult your mobile service carrier’s pricing plan
to determine the charges for browsing data and sending and receiving Text
Messages. Under no circumstances will we or our affiliates be responsible for
any SMS messaging or wireless charges incurred by you or by a person that has
access to your wireless device or telephone number. If your carrier does not
permit SMS messages, you may not receive the Text Messages. Neither we nor the
wireless carriers (such as T-Mobile) will be liable for any delays in the
receipt of, or failure to deliver, any Text Messages, as delivery is subject to
effective transmission from your network operator. Text Message services are
provided on an “AS IS” basis. Data obtained from you in connection with any Text
Message services may include your cell phone number, your provider’s name and
the date, time and content of your text messages. We may use this information in
accordance with our Privacy Policy to contact you and to provide the services
you request from us. If you change or deactivate the phone number you provided,
you have an affirmative obligation to update your account information and the
phone number(s) attached to your account to prevent us from inadvertently
communicating with anyone who acquires any phone number(s) previously attributed
to you, and any new phone number(s) you attach to your account may receive our
standard marketing Text Messages unless you also unsubscribe via the above
procedures.

DO NOT TRACK (“DNT”).

Our websites are not designed to respond to DNT signals received from browsers.

PROTECTION OF PERSONAL INFORMATION.

We are committed to using our best efforts to maintain the security of your
personal information. To prevent unauthorized access, maintain data accuracy and
ensure the appropriate use of information, we adhere to industry standard
practices and procedures to help safeguard and secure the information we
collect. Although we use our best efforts to protect the security of your
personal information and our systems, due to the inherent open nature of the
internet, no transmission via the internet can be guaranteed to be 100% secure.
As a result of this and other factors beyond our control, we cannot guarantee
the security of the information you transmit to or through our services.
Therefore, you assume that risk by using our services. Our Websites are secured
and verified by Trustwave and GoDaddy Secure Certificate Authority.

INFORMATION FROM USERS OUTSIDE OF THE USA AND CONSENT TO TRANSFER JURISDICTION.

Our Services are operated in the USA. If you are located in another
jurisdiction, please be aware that information you provide will be transferred
to, and stored and processed in the USA. By using our Services, you consent to
the transfer, processing and storage of your information in the USA, where
privacy laws may not be as comprehensive as those in your country of citizenship
or residence. We will take all steps reasonably necessary to ensure your data is
treated securely and in accordance with this Privacy Policy.

If you are a resident of the EEA or Switzerland, you are entitled to certain
rights under the “General Data Protection Regulation” or “GDPR” enacted in
April, 2016. These include, without limitation, the right to (1) Access your
personal data, (as that term is defined under the GDPR), (2) Request deletion of
your personal data, (3) Restrict processing of your personal data, and (4) to
receive your data in a portable manner. We will only process your personal data
as described in this Privacy Policy and only for the duration necessary. To
exercise any of these rights, please contact us as described in the “How to
Contact Us” section below. If applicable, you may make a complaint to the data
protection supervisory authority in the country where you are based.

SECURITY OF PERSONAL INFORMATION ON THIRD-PARTY WEBSITES.

Our Services may contain links to other websites that are not under our control
or supervision. Please be aware that we are not responsible for the privacy
practices of third-party websites. Third-part websites may have their own
privacy policies and consumer service policies, or no policies at all. We
encourage you to be aware when you access any such third-party links and to read
the privacy policies of the third-party websites to see how your personal
information will be handled before providing them with your personal
information.

RETENTION OF YOUR INFORMATION.

We store and maintain your information for the purposes for which it is
processed by us. The length of time for which we maintain information depends on
the purposes for which we collected and use it and/or required to comply with
applicable laws.

HOW TO CONTACT US.

If you wish to contact us to update your information, or if you have any
questions, comments or concerns regarding this Privacy Policy and/or the
practices described herein, please feel free to email us
at privacy@wineenthusiast.netor contact us by telephone at 800-648-6058.

You may also write to us at the following address:
The Wine Enthusiast Companies
Attention: Privacy Compliance
200 Summit Lake Drive, 4th Floor
Valhalla, N.Y. 10595

EFFECTIVE DATE AND MODIFICATIONS.

This Privacy Policy is effective December 23, 2019. Please note that we may
modify this Privacy Policy at any time, at our sole discretion, by posting the
modified Privacy Policy on our Services. The modifications will be effective
upon posting, unless some other date is specified. You should review this
Privacy Policy periodically so that you are aware of any modifications. If we
make a material change to the Privacy Policy, you will be provided with
appropriate notice in accordance with legal requirements. Your use of any of our
Services constitutes your full acceptance of the Privacy Policy in its
then-current form.

YOUR CALIFORNIA PRIVACY RIGHTS

If you reside in California, you also have the right to ask us once a year if we
have shared personal information with third parties for their direct marketing
purposes. To make a request, please refer to the instructions below regarding
how to make a request.

California Consumer Privacy Act of 2018. (“CCPA”)

If you reside in California, then you have the following rights:

You have the right to opt-out of the use of your personal information for
targeted or behavioral advertising which may be deemed a sale of information
under the CCPA. Please note that advertising, including targeted advertising,
enables us to provide you certain content for free and allows us to provide you
offers relevant to you. If you would like to opt-out of our use of information
for such purposes that may be considered a “sale” under California, you may do
so by emailing us at privacy@wineenthusiast.netor calling us at 800-648-6058.

You have the right to request deletion of your personal information.

You have the right to request us to disclose to you the following, no more than
twice in a 12-month period, and, in all cases, for the preceding 12 months:

 * Categories of personal information we collected about you.
 * Categories of sources from which we collected the personal information.
 * Business or commercial purpose for collecting your personal information.
 * Categories of third parties with whom we shared the personal information.
 * Specific pieces of personal information we collected about you.
 * Categories of personal information we disclosed for a business purpose.
 * Categories of personal information we have used for targeted or behavioral
   advertising and categories of third parties to whom such information was
   provided.

We will not discriminate against you because you exercised your rights under
this section of the Privacy Policy.

For purposes of exercising your rights above, please note the following
regarding how we collect and use your personal information as described in this
policy.

 * We collect the following categories of personal information and disclose the
   same categories of personal information for a business purpose: Identifying
   information; Payment information; Event information; Information you post or
   submit; Social media information; Internet or other electronic network
   activity; Commercial information.
 * We use the following categories of personal information in connection with
   targeted or behavioral advertising: Identifying information, Information you
   post or submit, Social media information, Internet or other electronic
   network activity.

Please note that certain information may be exempt from such requests under
California law. For example, we need certain information in order to provide the
Services to you. We also will take reasonable steps to verify your identity
before responding to a request. You are also permitted to designate an
authorized agent to submit requests on your behalf. In order for an authorized
agent to be verified, you must provide the authorized agent with signed, written
permission to make such requests or a power of attorney. We may also follow up
with you to verify your identity before processing the authorized agent’s
request.

How to Make Requests for Deletion of Personal Information and Requests for
Personal Information We Collect, Disclose or Sell

If you wish to submit a request under the California Consumer Privacy Act of
2018, please feel free to submit a verified request by one of the following
means.

 * You may call our toll-free number 1 (888) 914-9661, PIN# 144522.
 * You may fill out the following form.
 * You may also contact us by email or mail at the following:
   The Wine Enthusiast Companies
   Attention: Privacy Compliance
   200 Summit Lake Drive, 4th Floor
   Valhalla, N.Y. 10595
   privacy@wineenthusiast.net

TEXT MESSAGING TERMS

By signing up for text messages, you certify that you are over 21 years of age
and agree to receive automated recurring marketing messages (including cart
reminders) from Wine Enthusiast and its affiliated companies and marketing
partners. You also accept the Terms. Consent is not a condition of purchase. Msg
frequency varies. Msg & data rates may apply. Text STOP to unsubscribe.

COOKIE POLICY

Cookies are small amounts of data that are sent to your browser from a web
server and stored on your computer’s hard drive or other devices for the purpose
of facilitating and enhancing your communication and interaction with our
Services and to assist with marketing efforts. To support our Services, we or
our service providers may use one or more of the following browser cookies for
the purposes set below. You have the option of disabling cookies by accessing
the tools provided to you in your Internet options. However, please note that
you may not have full access to our Services if you change your cookies settings
to disable them.

 * Analytics and Performance Cookies:These cookies are used to collect
   information about traffic to our Services and how users use our Services. The
   information gathered includes the number of visitors to our Services, the
   websites that referred them to our services, the pages that they visited on
   our Services, the time of day they visited our Services, whether they have
   visited our Services before, and other similar information. This information
   is aggregated, and does not identify individual users. We use this
   information to help us improve how our services work and to gather
   demographic information. We use Google Analytics for this purpose. Google
   Analytics uses its own cookies. You can find out more about Google Analytics
   cookies here. You can find out more about how Google protects your data here.
   You can prevent the use of Google Analytics relating to our Services by
   downloading and installing the browser plugin available through this link.
 * Essential Cookies: These cookies are essential to provide you with services
   available through our Services and to enable you to use some of the features.
   For example, they allow you to log in to secure areas of our Services and
   help the content you request to load quickly. Without these cookies, the
   functionality that you requested cannot be provided, and we only use these
   cookies to provide you with this functionality.
 * Functionality Cookies:These cookies allow our Services to remember the
   choices you make when using our Services, such as remembering your login
   details. These cookies are used to provide you with a more personal
   experience and to avoid you having to re-enter your preferences upon each
   visit to our Services.
 * Social Media Cookies:These cookies are used when you share information using
   a social media sharing button on our Services, and when you engage with our
   content through a social media networking website such as Facebook, Twitter
   or Instagram.
 * Targeting Cookies:These cookies are used to deliver relevant ads, track email
   marketing or ad campaign performance and efficiency. For example, we and our
   ad partners may rely on information gleaned through these cookies to serve
   you ads that may be interesting to you on other websites or to otherwise
   assist with our marketing or behavioral advertising efforts. Our ad partners
   may also place cookies or other tracking technologies on your electronic
   device to collect information about you. We may also allow other third
   parties such as ad networks and ad servers to serve tailored ads to you on
   our services. We sometimes provide our user information, such as email
   addresses to service providers who may “match” this information in
   de-identified form to cookies (or mobile ad identifiers) in order to provide
   you with more relevant ads when you visit other websites and mobile
   applications.

We neither have access to, nor does this privacy policy govern, the use of
cookies or other tracking devices you use to access our services by these
non-affiliated third parties. If you are interested in more information about
targeted browser advertising and how you can generally control cookies from
being put on your electronic device, you may visit the Network Advertising
Initiatives Consumer Opt-Out link or the “Digital Advertising Alliance’s
Consumer Opt-Out” link. The Digital Advertising Alliance also offers a tool for
opting out of the collection of cross-app data on a mobile device for
interest-based advertising. To exercise choices for the companies participating
in this tool, download the AppChoices App here. We do not control these opt-out
links or whether any particular company chooses to participate in these opt-out
programs. We are not responsible for any choices you make regarding these
mechanisms or the continued availability or accuracy of these mechanisms.

THIRD PARTY PIXELS & COOKIES

When you visit our website, log in, register or open an email, cookies, ad
beacons, and similar technologies may be used by our online data partners or
vendors to associate these activities with information they or others have about
you, including your email address. We (or service providers on our behalf) may
then send communications and marketing to these email addresses. You may opt out
of receiving this advertising by visiting https://app.retention.com/optout.



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