Privacy Policy

This Privacy Policy applies solely to information collected through the web site located at the URL: www.SantaMargheritaWinesUSA.com (the “Site”); whether accessed via computer, mobile device or other technology. The Site is offered by SM Wine Group, which is operated by Santa Margherita USA, Inc. (“Santa Margherita USA”, “we”, “us”, “our”).

This Privacy Policy explains what information may be collected through the Site, how such information may be used and/or shared with others, how we safeguard it and how you may access and control its use in connection with our marketing communications and activities. This Privacy Policy was last updated on June 17, 2016.

IF YOU ARE NOT OF LEGAL DRINKING AGE, YOU SHOULD NOT VISIT OR USE THIS SITE. OUR PRODUCTS, AND THE CONTENT OF THIS SITE, ARE INTENDED ONLY FOR INDIVIDUALS WHO ARE OF LEGAL DRINKING AGE.  ACCORDINGLY, OUR SITE DOES NOT REQUEST OR KNOWINGLY COLLECT PERSONAL DATA FROM INDIVIDUALS UNDER THE LEGAL DRINKING AGE. IF WE RECEIVE NOTICE, OR REASONABLY BELIEVE, THAT SOMEONE UNDER LEGAL PURCHASING AGE HAS PROVIDED US WITH PERSONAL INFORMATION, WE WILL MAKE REASONABLE EFFORTS TO REMOVE SUCH PERSONAL INFORMATION FROM OUR DATABASE.

1. INFORMATION COLLECTED ON OUR SITE

Information You Provide To Us

When you use the Site, for example, to participate in some social networking features, subscribe to newsletters, or post questions/comments to the Site or enter into promotions, we or our service providers may collect Personal Information (information that could reasonably be used to contact you or to identify you personally) such as your name, e-mail address, date of birth, geographic location or mailing address.

Information Collected Automatically

Usage Information. Whenever you visit or interact with the Site, Santa Margherita USA, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about how the Site is accessed and used (“Usage Information”). Usage Information may include, in part, browser type, operating system, the page served, product information viewed, the time, and the preceding page views. This statistical data provides us with information about the use of the Site, such as how many visitors visit a specific page on the Site, how long they stay on that page, and which hyperlinks, if any, they “click” on. This information helps us keep our Site fresh and interesting to our visitors and tailor content to a visitor’s interests.

Device Identifiers. Santa Margherita USA may also automatically collect your IP address or other unique identifier (“Device Identifier”) for the computer, mobile device, technology or other device (collectively, “Device”) you use to access the Site. A Device Identifier is a number that is automatically assigned to your Device when you access a web site or its servers, and our computers identify your Device by its Device Identifier. We may use a Device Identifier to, among other things, administer the Site, help diagnose problems with our servers, analyze trends, track users’ web page movements, help identify, and gather broad demographic information for aggregate use.

Cookies; Pixel Tags. The technologies used on the Site to collect Usage Information, including Device Identifiers, may include but are not limited to: cookies (data files placed on a Device when it is used to visit the Site), mobile analytics software and pixel tags (transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a web page or in an email, which indicates that a page or email has been viewed). Cookies may also be used to associate you with social networking sites and, if you so choose, enable interaction between your activities on the Site and your activities on such social networking sites (including but not limited to content posted in response to a contest or promotion or your use of social networking features integrated with the Site). We, or our vendors, may place cookies or similar files on your Device for security purposes, to facilitate site navigation and to personalize your experience while visiting our Site (such as allowing us to select which content, ads or offers are most likely to appeal to you, based on your interests, preferences, location, or demographic information). A pixel tag may tell your browser to get content from another server.

Similarly, we use Google Analytics to help us track and analyze usage of our Site, using cookies, pixels and other tracking technologies. We may share your Usage Information with Google Analytics or other associated ad-serving companies.

To learn how you may be able to reduce the number of cookies you receive from us, or delete cookies that have already been installed in your browser’s cookie folder, please refer to your browser’s help menu or other instructions related to your browser. If you do disable or opt out of receiving cookies, please be aware that some features and services on our Site may not work properly because we may not be able to recognize and associate you with your account(s). In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests. Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, so note that our systems are not configured to recognize Do Not Track headers or signals from some or all browsers.

You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser.

For more information on advertising using cookies and how to opt out of advertising cookies specifically, please see Targeted Advertising below.

2. HOW WE USE THE INFORMATION COLLECTED THROUGH OUR SITE

Any information you submit on the Site will be used for a variety of business purposes, including for example, to: respond to your questions and requests; provide you with access to certain areas and features of the Site; verify your identity; communicate with you about your activities on the Site; tailor content, advertisements, and offers we serve you; market research, Site analytics and operations; improve the Site and for internal purposes; contact you with regard to your use of the Site and interest in certain products, and, in our discretion, changes to any Santa Margherita USA policy; and for purposes disclosed at the time you provide your Personal Information or otherwise with your consent.

3. SHARING OF INFORMATION

Except as provided in this Privacy Policy, we will not provide any of your Personal Information to any third parties without your consent. We may share non-Personal Information, such as aggregate user statistics, demographic information, and Usage Information with third parties. We may also share your information as disclosed at the time you provide your information, as set forth in this Privacy Policy and in the following circumstances:

Third Parties. In order to carry out your requests, to make various features, services and materials available to you through the Site, and to respond to your inquiries, we may share your Personal Information with third parties that perform functions on our behalf, such as companies or individuals that: host or operate our Site; host or operate email functionality or email campaigns; analyze data; provide customer service; advertisers; sponsors or other third parties that participate in or administer our promotions. Your Personal Information may also be used by us or shared with our affiliates, sponsors, partners, advertisers or other third parties, including lead generation companies to provide you with product information and promotional and other offers. If you enter any contest, sweepstakes or other promotion that we make available through the Site, we may share the information you submit to us with the co-sponsors of the contest, sweepstakes, or promotion. We will identify any co-sponsor(s) in the official rules for the promotion.

Your Agreement To Have Your Personal Information Shared. While on our Site, you may have the opportunity to opt in to receive information and/or marketing offers via email from someone else or to otherwise consent to the sharing of your information with a third party. If you use the social sharing features of the Site, your information may be shared with certain of your friends or groups. If you agree to have your Personal Information shared, your Personal Information will be disclosed to the third party and the Personal Information you disclose will be subject to the privacy policy and business practices of that third party.

Business Transfers. Your Personal Information may also be used by us or shared with our subsidiaries and affiliates for internal reasons, primarily for business and operational purposes. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all or substantially all of our assets, or assets related to the Site, Personal Information, Usage Information, and any other information that we have collected about the users of the Site may be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

Legal Disclosure. Santa Margherita USA may transfer and disclose information, including your Personal Information, Usage Information and Device Identifier, (including IP address), to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Use or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our Site or the public.

4. TARGETED ADVERTISING

We may use third party ad network providers to help present ads on the Site, as well as other service providers to evaluate and provide us with information about the use of the Site and viewing of our content. Such providers may place and access cookies, pixel tags, or similar technologies on your Device to serve you ads or other content personalized to your interests which they infer from your browsing on the Site and other sites you have visited. In doing so, the provider collects or has access to non-Personal Information such as your Usage Information. The use of cookies, pixel tags, or similar technologies by these providers is subject to their own privacy policies, not ours.

If you do not want to receive the benefits of targeted advertising, you may opt out of some network advertising programs that use your information by visiting the NAI Opt-Out Page at http://www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance consumer choice page at www.aboutads.info/choices. Please note that even if you choose to remove your information (opt out), you will still see advertisements while you’re browsing online. However the advertisements you see may be less relevant to you and your interests. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page and the DAA consumer choice page provide mechanisms to opt out of receiving cookies from those companies. Please note that if you opt out of targeted advertising, we may still track your visits to the Site for our own analytics, operations and security purposes. .

5. YOUR CHOICE AND ACCESS

You may always direct us not to share your Personal Information with third parties, not to use your Personal Information to provide you with information or offers, or not to send you newsletters, e-mails or other communications by: (i) sending us an e-mail at info@santamargheritausa.com; (ii) contacting us by mail at 1900 Sunset Harbour Drive, Annex-3, Miami Beach, FL 33139, or (iii) following the removal instructions in the communication that you receive. Your opt-out request will be processed within 30 days of the date on which we receive it.

If you wish to verify, correct, or update any of your Personal Information collected through the Site, you may contact us at the above address or e-mail. In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted through the Site. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. In addition, you should be aware that it is not possible to remove or delete an account from our databases.

6. PERSONS UNDER 21.

The Site is not directed to persons under 21. We do not knowingly collect Personal Information from anyone under 21 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information.

7. SECURITY OF YOUR INFORMATION

We use certain reasonable security measures to help protect your Personal Information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Site and provide us with your information at your own risk.

8. OTHER SITES.

The Site may contain links to other sites that we do not own or operate. This includes links from service providers, advertisers, sponsors and partners that may use our logo(s) as part of a co-branding agreement. We do not control, recommend or endorse and are not responsible for these sites or their content, products, services or privacy policies or practices. These other web sites may send their own cookies to your Device, they may independently collect data or solicit Personal Information and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site which appears or claims that it is one of our Sites (including those linked to through an email or social networking page).

9. CONSENT TO PROCESSING

The Site is governed by and operated in, and in accordance with the laws of the United States. We make no representation that the Site is governed by or operated in accordance with the laws of any other nation. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect may be transferred to and processed in the United States. By using the Site, or providing us with any information, you (a) acknowledge that the Site is subject to the laws of the United States, (b) consent to the collection, processing, maintenance and transfer of such information in and to the United States and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen, and (c) waive any claims that may arise under those laws.

10. CHANGES

Please note, we may change information on the Site and/or this Privacy Policy, at any time without prior notice to you, and any changes will be effective immediately upon the posting of the revised Privacy Policy on the Site. However, Santa Margherita USA will use your Personal Information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless you consent to the new or revised policy. By continuing to use this Site after we change any information on the Site and/or this Privacy Policy, you accept this Privacy Policy, as modified.

11. YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you may have certain additional rights. If you would like to prevent disclosure of your Personal Information for use in direct marketing by a third party, do not opt in to participate in these activities. If you are a California resident, and you have opted in to one of these activities, but you later decide that you would like to prevent our disclosure of your Personal Information to third parties for their direct marketing purposes, please contact us at info@santamargheritausa.com.

12. CONTACT US

If you have any questions or concerns regarding this Privacy Policy, please contact us at:

Attn:   SANTA MARGHERITA USA, INC.
1900 Sunset Harbour Drive, Annex-3,
Miami Beach, FL 33139
Re: Santa Margherita USA Privacy Policy
E-Mail: info@santamargheritausa.com