Terms and Conditions


Effective as of January 2018

This Privacy Policy (the “Privacy Policy”) describes the types of information CRM For Wineries (“CRM” or “we”), collects from you (“you” or “your”) via CRM’s website and contents (the “Website”).  It also describes how we use and disclose such information, as well as your rights with respect to CRM’s collection, use, and disclosure of such information. 

We understand the importance of your privacy and we treat all information we receive in a responsible manner.  By accessing or using the Website, you agree that we may collect, use, and disclose Personal Data, Aggregate Information, and Cookies pursuant to this Privacy Policy. 

We may change or update this Privacy Policy from time to time by posting the revised version on the Website.  Therefore, you should periodically verify the date of this Privacy Policy to ensure that you are familiar with the most up-to-date version, as the most up-to-date version will govern with respect to your use of the Website. 

Information We Collect

When you use the Website, CRM may collect three types of information:

(1) Personal Data

Personal Data is any information directly or indirectly relating to an identified or identifiable individual, such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual (“Personal Data”).

(2) Aggregate Information

Aggregate Information is information about your activities on or in connection with the Website that typically cannot be used to identify, locate, or contact you (“Aggregate Information”).  For example, Aggregate Information includes information regarding the frequency of use of the Website and browser types used to access the Website.

(3) Cookies, etc.

Cookies, beacons, device identifiers, or similar technologies (referred to for convenience as “Cookies”) are small pieces of data placed on your device that your web browser or device uses to access the Website and that permit CRM to track your activity on the Website.  We obtain information from Cookies when you visit the Website.  You may turn off cookies in your browser or device settings, but this may limit functionality of the Website.  Cookies help analyze usage and provide certain functionality.  Cookies don’t contain Personal Data and for that reason, we treat Cookies in the same manner as we treat Aggregate Information.  If Cookies do contain Personal Data, such Personal Data will only be used or disclosed in the same manner as other Personal Data pursuant to this Privacy Policy.  Cookies cannot be used as a malicious tool.


Collecting Personal Data

CRM collects Personal Data when:

(1) you use certain features of the Website that require the collection of Personal Data in order for those features to function;

(2) you voluntarily enter or upload Personal Data to or through the Website; and

(3) you communicate with CRM, whether through the Website or through another form of communication, such as e-mail or telephone.


Collecting Aggregate Information

CRM collects Aggregate information resulting from your use of the Website. 

Using and Sharing Personal Data

CRM uses Personal Data we collect:

(1) to provide services through the Website, such as downloading information or registration for various events;

(2) to improve the features and functionality of the Website;

(3) to communicate with you in response to any of your questions and requests; and

(4) to provide relevant marketing and other information to you, but only if, and to the extent that, you have consented to us providing such marketing and other information to you in accordance with applicable laws.  In such a case, we will provide an easy link to permit you to “opt-out” of receiving future marketing communications. 

In rare cases, CRM may be required, or may, acting in good faith, believe it is required, to share certain information with legal authorities.  In such a case, CRM will provide only the minimum amount of information required and, unless prohibited by law, CRM will notify you of the Personal Data it has provided.  Such cases include:

(1) if required by law;

(2) to protect or defend itself, you, or others against legal liability or immediate danger; and

(3) to investigate a possible crime, such as fraud or identity theft.

CRM may share Personal Data with third party service providers as CRM deems necessary for such third party service providers to perform their duties required for the Website to function.  For example, the Website may utilize hosting providers.  Such third party service providers are not authorized to retain, share, store or use Personal Data for any purposes other than to provide the services for which they have been retained to provide.

CRM does not sell or otherwise share Personal Data with unrelated third parties.

Personal Data may be transferred to CRM’s affiliates or as part of a sale of substantially all of the assets of CRM.  In such a case, each such party will be required to hold Personal Data and not disclose Personal Data except in accordance with terms at least as restrictive as those contained in this Privacy Policy.

Using and Sharing Aggregate Information

CRM uses Aggregate Information:

(1) to provide the services offer through the Website, such as downloading information or registration for various events;

(2) to improve the features and functionality of the Website;

(3) to monitor and analyze usage of the Website;

(4) to research, compile, and report on usage trends, user demographics, and user behaviors; and

(5) for other legitimate business purposes.

CRM may share Aggregate Information with its affiliates and certain third parties, such as investors, potential investors, and third party service providers we use to provide and facilitate the Website. 

Aggregate Information is anonymized and does not have the capacity to be used to identify an individual.  In other words, CRM may share this information but no Personal Data will be disclosed to third parties.

Location Information

CRM may use the Website to collect and use location information to provide certain functionality, such as identifying the geographic area of a user.  All such information will be governed by this Privacy Policy.

External Links

The Website may contain links to third party websites operated by other people or companies. CRM is not responsible for those websites, and links to such websites are included solely for your convenience. Please review the privacy policies of such third party websites.

Security and Data Protection

CRM takes appropriate security measures to protect Personal Data against unauthorized access, alteration, disclosure or destruction.

Such measures include internal reviews of CRM’s data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where Personal Data is stored. 

CRM restricts access to Personal Data to its employees, service providers, and agents who need to know such information in order to operate, develop or improve the Website. These individuals are bound by confidentiality obligations and are required to treat such Personal Data confidentially and in accordance with this Privacy Policy. 

Data Processing and GDPR

CRM is both the data processor and the data controller for your Personal Data.  This means that CRM performs operations on Personal Data and controls your Personal Data.  In the case where CRM uses third party service providers with respect to your Personal Data, CRM is the data controller and such third party is the data processor.

CRM controls and processes Personal Data only for the purposes for which it was collected and in accordance with this Privacy Policy.  CRM takes reasonable steps to ensure that Personal Data we control or process is accurate, complete, and current.

To the extent applicable, CRM will adhere to the requirements as outlined in Regulation (EU) 2016/679 (General Data Protection Regulation, commonly referred to as GDPR). 

CRM may transfer your Personal Data to countries other than the one in which you live. 

Financial Information

In the event that CRM may require certain financial information, such as credit card information to register for an event, on the Website, we will not share this financial information, other than the financial institutions involved in processing your payment.  At all times, CRM will comply in all respects with applicable consumer protection laws.

Corrections and Removals

You may have the right to access your Personal Data and require CRM to update, delete, or correct this information.  If any part of your Personal Data, such as your name, e-mail address, mailing address, telephone number or other personal information is incorrect or has changed, you may update, correct or remove the relevant information by contacting CRM. We will take reasonable steps to update or correct Personal Data in CRM’s possession or control.

Contact CRM

We have a designated privacy team available to you if you have any questions or concerns about this Privacy Policy.  If you would like to contact us about this Privacy Policy, please do so as follows:


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