Cult Wines Inc. (“Cult Wines,” “we,” “our,” and/or “us”) values the privacy of individuals who use our website at https://www.wineinvestment.com/us/ and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from or about Cult Wines users (“Users”) or their devices. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Use Policy.
Information We Collect
We may collect a variety of information from or about you or your devices from various sources, as described
below.
If you do not provide your information when requested, you may not be able to use our Services if that
information is necessary to provide you with our Services or if we are legally required to collect it.
Information you provide to us
Registration and Profile Information.
When you sign up for an account, register to use our Services, sign
up for notifications or updates, or participate in our surveys, we ask you for your full name, address, email
address, phone number, information about your investment style, risk appetite and investment length, payment
details, information about your financial background (i.e. your net worth, income, or job position), copies of
identification documents (i.e. passports), utility bills for verification checks purposes, and any other
information we collect. If you sign up using a social media account, we will also receive information from those
social media services such as your name, email address, gender, date of birth, profile photo, and friends.
Payment Information.
When you add a credit card or payment method to your account, a third party service
provider that handles payments for us will receive your payment card information.
Communications.
When you communicate with us, we may receive additional information about you. For
example, when you communicate with our Customer Support Team, we will receive your name, email address, phone
number, the contents of a message or attachments that you may send to us, and other information you choose to
provide. If you subscribe to our newsletter, then we will collect certain information from you, such as your
email address. When we send you emails, we may track whether you open them to learn how to deliver a better
customer experience and improve our Services.
Careers.
If you decide that you wish to apply for a job with us, you may submit your contact information
and your resume online. We will collect the information you choose to provide on your resume, such as your
education and employment experience. You may also apply through LinkedIn. If you do so, we will collect the
information you make available to us on LinkedIn.
Information We Collect When You Use Our Services.
Location Information.
We may infer your general location information (for example, your IP address may
indicate your general geographic region).
Device Information.
We receive information about the device and software you use to access our Services,
including internet protocol (IP) address, web browser type, operating system version, phone carrier and
manufacturer, application installations, device identifiers, mobile advertising identifiers, and push
notification tokens.
Usage Information.
To help us understand how you use our Services and to help us improve them, we
automatically receive information about your interactions with our Services, like the pages or other content you
view, the searches you conduct, purchases you make, and the dates and times of your visits.
Information from Cookies and Similar Technologies.
We and third party partners collect information using
cookies, pixel tags, or similar technologies. Our third party partners, such as analytics and advertising
partners, may use these technologies to collect information about your online activities over time and across
different services. Cookies are small text files containing a string of alphanumeric characters. We may use both
session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent
cookie remains after you close your browser and may be used by your browser on subsequent visits to our
Services.
Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note
that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features
of the Service to their fullest potential.
Information We Receive from Third Parties
Information from third party services.
If you choose to link our Services to a third party account, we
may receive information about you, including your profile information and your use of the third party account.
If you wish to limit the information available to us, you should visit the privacy settings of your third party
accounts to learn about your options.
How We Use the Information We Collect
We use the information we collect:
- To provide, maintain, improve, and enhance our Services;
- To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
- For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you;
- To personalize your experience on our Services such as presenting tailored content;
- To send you text messages and push notifications;
- To facilitate transactions and payments;
- To de-identify and aggregate information collected through the Services and use it for any lawful purpose.
- To find and prevent fraud, and respond to trust and safety issues that may arise;
- For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
- For other purposes for which we provide specific notice at the time the information is collected.
How We Share the Information We Collect
We share information with the following categories of third parties.
Affiliates.
We may share any information we receive with our corporate affiliates for any of the
purposes described in this Privacy Policy.
Vendors and Service Providers.
We may share any information we receive with vendors and service
providers retained in connection with the provision of our Services.
Third Party App Integrations.
If you connect a third party application to our Services, we may
share information name and location with that third party.
Marketing.
We do not rent, sell, or share information about you with nonaffiliated companies for
their direct marketing purposes, unless we have your permission.
Analytics Partners.
We use analytics services such as Google Analytics to collect and process
certain analytics data. These services may also collect information about your use of other websites, apps, and
online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/,
and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
Advertising Partners.
We work with third party advertising partners to show you ads that we
think may interest you. These advertising partners may set and access their own cookies, pixel tags and similar
technologies on our Services and they may otherwise collect or have access to information about you which they
may collect over time and across different online services. Some of our advertising partners are members of the
Network Advertising Initiative (http://optout.networkadvertising.org/?c=1#!/) or the
Digital Advertising Alliance (http://optout.aboutads.info/?c=2&lang=EN). If
you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out
of receiving web-based personalized ads from member companies. You can access any settings offered by your
mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about
how you may opt out of personalized ads in mobile apps.
As Required By Law and Similar Disclosures.
We may access, preserve, and disclose your
information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and
legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or
others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may
occur if you post any objectionable content on or through the Services.
Merger, Sale, or Other Asset Transfers.
We may disclose and transfer your information to service
providers, advisors, potential transactional partners, or other third parties in connection with the
consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with
another company or we sell, liquidate, or transfer all or a portion of our business or assets.
Consent.
We may also disclose information from or about you or your devices with your
permission.
Your Choices
Marketing Communications.
You can unsubscribe from our promotional emails via the link provided
in the emails. Even if you opt-out of receiving promotional messages from us, you will continue to receive
administrative messages from us.
Do Not Track.
There is no accepted standard on how to respond to Do Not Track signals, and we do
not respond to such signals.
Third Parties
Our Services may contain links to other websites, products, or services that we do not own or operate. We are not
responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not
apply to your activities on these third party services or any information you disclose to these third parties.
We encourage you to read their privacy policies before providing any information to them.
Security
We make reasonable efforts to protect your information by using physical and electronic safeguards designed to
improve the security of the information we maintain. However, as our Services are hosted electronically, we can
make no guarantees as to the security or privacy of your information.
International Visitors
Our Services are hosted in the United States and intended for visitors located within the United States. If you
choose to use the Services from the European Union or other regions of the world with laws governing data
collection and use that may differ from United States law, then please note that you are transferring your
personal information outside of those regions to the United States for storage and processing. Also, we may
transfer your data from the United States to other countries or regions in connection with storage and
processing of data, fulfilling your requests, and operating the Services. By providing any information,
including personal information, on or to the Services, you consent to such transfer, storage, and processing.
If you are looking for our affiliated European operations, please visit www.wineinvestment.com.
Update Your Information or Pose a Question
You can update your account and profile information or close your account through your profile settings. If you
have questions about your privacy on the Services or this privacy policy, please contact us at [email protected]
Changes to this Privacy Policy
We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when
it is posted. If we materially change the ways in which we use or share personal information previously
collected from you through the Services, we will notify you through the Services, by email, or other
communication.
Contact Information
If you have any questions, comments, or concerns about our processing activities, please email us at [email protected] or write to us at 200 Park Ave South, Suite 1116, New
York, NY, 10003.