Privacy Policy (Effective Date: May 25, 2018)
ConcealedWines AB. (“Concealed Wines”) values the privacy of visitors to our website and individuals whose personal information we receive through the use of form submissions and other related services.
This privacy policy explains how we collect personal information on our website, and how we use and disclose that personal information. This privacy policy also describes our collection and use of personal information on behalf of our customers (“Clients”) who subscribe to our Customer Identity Management Platform and related services.
By providing your personal information to our website, you consent to the information handling practices described in this privacy policy. We encourage you to read the section titled “Your Choices” below to understand the choices you have with regard to your personal information.
This Privacy Policy also applies to personal information that we collect by other means, which we combine with personal information collected on our Concealed Wines Websites or through the operation and delivery of our Services.
This Privacy Policy is incorporated into and is subject to the Concealed Wines Terms of Service. Any capitalized terms not defined herein have the meaning set forth in the Concealed Wines Terms of Service.
1. Websites Covered
This privacy policy covers the information practices of websites that link to this privacy policy, including, but not limited to, www.concealedwines.com and www.concealedwines.se.
Concealed Wines’s websites may contain links to websites operated by third parties. Concealed Wines is not responsible for the privacy practices or the content of such other websites. We encourage you to learn about such third parties’ privacy and security policies before providing them with personal information.
2. Information We Collect
We collect the following data about users: (1) information that you voluntarily submit to us (“User-Supplied Information”); (2) technical data automatically collected from all visitors to the Concealed Wines Website (described below under “Passive Data Collection”); (3) information we collect through our Services; and (4) information we collect from third party sources.
User-Supplied Information.
We may collect user-supplied information when you choose to provide us with your Personal information via the Concealed Wines Websites, including when you send us an email asking a question, register to attend an event, submit a form to receive marketing materials or email newsletters, or request any research or whitepapers.
Passive Data Collection.
Like most web-based services, we automatically receive and record information in on our server logs from your browser when you use the Concealed Wines Websites. We may use a variety of methods, including clear GIFs or Pixels (also known as “web beacons”) and “cookies”, to collect this information.
We use both session and persistent cookies. The information that we may collect with these automated methods may include, for example, your IP address, cookie information, a unique device or user ID, browser type, system type, the content and pages that you access on the Concealed Wines Websites, the frequency and duration of your visits to the Concealed Wines Websites, and the “referring URL” (i.e., the page from which you navigated to the Concealed Wines Websites).
We may also use cookies on the Concealed Wines Websites to store session validators on your hard drive. If we directly combine any information gathered through passive means with Personal information, we treat the combined information as Personal information under this Privacy Policy.
Otherwise, we use information collected by passive means in aggregated forms. For additional information about the technologies that we use and how they operate, please see our Cookie Policy.
3. Use of Collected Information
We use personal information to establish and enhance our relationship with you. We may use personal information to operate, provide, improve, and maintain the Concealed Wines Websites; to prevent abusive and fraudulent use of the Concealed Wines Websites; to personalize and display content on the Concealed Wines Websites; where permitted by applicable law, to send you information, including via email, about our products and Services in which we believe you may be interested; to respond to your inquiries and for other customer service purposes; and for other administrative and internal business purposes.
We may use your e-mail address, including any email address provided at concealedwines.com or through the Concealed Wines Websites as set forth in the “Communications and Unsolicited Marketing Communications” section.
On the Concealed Wines Websites, we may use passively collected data to: (a) remember your information so that you will not have to re-enter it during your visit or the next time you visit the Concealed Wines e Websites; and (b) monitor aggregate website usage metrics such as total number of visitors and pages viewed.
4. Disclosure of Collected Information
We do not sell or rent email addresses and other personal information that we collect directly through the Concealed Wines Websites. Please be aware, however, that any information that you voluntarily choose to display on any publicly available portion of the Concealed Wines Websites, or on any Service, becomes publicly available and may be collected and used by us or others without restriction.
We share your information, including personal information, as follows:
Concealed Wines Service Providers
We may provide personal information to third parties for their use in performing internal business functions (e.g., maintenance, security, data analysis, email transmission, CRM, database management services, email marketing, surveys, or data hosting) on our behalf. We require such third parties to agree to only use your personal information in accordance with this Privacy Policy and for no other purpose than to provide us with necessary services.
Legal Requirements
We may disclose personal information if we have a good-faith belief that doing so is required by a subpoena or other judicial or administrative order or otherwise required by law.
Additionally, we may disclose personal information where we, in good faith, deem it appropriate or necessary to prevent violation of the Concealed Wines Terms of Service, or our other agreements; take precautions against liability; protect the rights, property, or safety of Concealed Wines, any individual, or the general public; maintain and protect the security and integrity of our Services or infrastructure; protect ourselves and our Services from fraudulent, abusive, or unlawful uses; investigate and defend ourselves against third-party claims or allegations; or assist government enforcement agencies.
Aggregate Information and Non-Identifying Information
We may share aggregated information with Clients, prospective Clients, partners or the press in order to demonstrate usage of the Service, identify industry and advertising trends, and to generate publicity for the Comapny Names Services.
5. Your Choices
On the Concealed Wines Websites
You may, as a visitor to our website, choose not to provide us with personal information. You may also, at any time, access your personal information to update, correct, or delete certain personal information about you by contacting us at info@concealedwines.com or at the address set forth below in the “Contact Us” section.
You also have the right to obtain from Concealed Wines the erasure of personal data about you in accordance with applicable data privacy laws. You may exercise your rights with the following requests concerning your rights on your personal data:
Right to be removed (right to be forgotten):
You are entitled to request deletion of your personal data, like e-mail address. Concealed Wines deletes your personal information at your request, provided we do not have an obligation to store personal data in accordance with the EU Data Protection Ordinance (GDPR) or other legislation.
Right to Access to your data:
You have the right to confirm whether your data is processed and access your information about how your data is processed. For example, the purposes of the treatment and the categories of information to which the treatment applies.
Submit a complaint:
You are entitled to lodge a complaint with a competent regulatory authority (without prejudice to any other administrative or judicial remedy). Such a complaint is given to the competent supervisory authority that is the Data Inspection that you access.
Request rectification:
You also have the right to edit or modify any incorrect data, like e-mail address / phone number without unnecessary delay, as well as providing additional information supplementing incomplete personal data.
Right to data portability
You are entitled to obtain the personal data relating to you that you have submitted to us in a structured, widely used and machine-readable format and may transfer them to another personally responsible person (data portability) when:
(a) The treatment is based on your consent or on an agreement; (b) The treatment is automated.
You are entitled to transfer personal data directly from us to another personally responsible person when this is technically possible.
In addition you may decide to use your Right to object to treatment and not to opt–in, either when you first provide Concealed Wines with any personal information, to receive marketing information from Concealed Wines about products and Services (including our products and Services and those of third parties).
See also Section 6, “Communications and Unsolicited Marketing Communications”, for additional information regarding changing your preferences or opting out of receiving marketing information.
Please be aware that even if you update or remove personal information that you have provided to us, your personal information may be retained in our backup files and archives for a reasonable period of time for legal purposes.
6. Communications and Unsolicited Marketing Communications
If you opted in to receive communications from us, including through info@concealedwines.com, we may send you administrative messages and updates regarding your account, updates regarding the Concealed Wines Websites, and, where permitted by applicable law, information regarding our offer, products and Services, including, without, limitation, through social media updates, by email and postal mail.
If you no longer want to receive commercial email messages, you may indicate your preferences regarding commercial email messages by taking the steps described in such messages. Also, you may indicate your preferences regarding commercial email messages and postal mail messages by contacting us using the information in the “Contact Us” section below.
7. Client Data
We collect, use, and retain certain information at the direction and on behalf of our Clients/Partners from individuals (“End Users”) who use the Client/partner website (Client Data) and our Concealed Wines website (e.g. Youtube, Facebook, Twitter and similar).
Concealed Wines has no relationship with such End Users whose Client Data we process on behalf of our Clients. We also do not decide how the Clients use such Client Data. Concealed Wines does not access and use the Client Data, except at directed by our Clients or required by law.
Information Collected Directly Through Use of the Services about End Users:
We collect two types of data about End Users: (1) information that is passed through the Service as a result of use of the Website and (2) technical data automatically collected from all visitors to pages of your website that load the Services.
The information that we collect on your behalf depends on the particular Services to which you subscribe and your preferences. Social network and/or identity providers are hosted by a third party and on our Client’s service. The Client’s and the End User’s interaction with these features are governed by the privacy statement of the company providing it.
End User Information:
We maintain no rights to use any End User Personal Information transmitted to us on your behalf through the Concealed Wines Website or received from the social networks, except to make the Services available to you and/or End User.
We use the information that we collect automatically about the use of our Website to facilitate delivery of the Service and, in some cases, for internal reports.
Additionally, some of the information collected is used in the Client Reports. The Client Reports may contain both passively-collected information and End User Personal Information.
If you are a customer of one of our Service Partners, and you want to edit or delete any information captured about you on that Partner website, you should contact the Partner directly.
8. International Users
The Concealed Wines Websites are hosted in the European Union, and we may use service providers in the United States and elsewhere to process personal information on our behalf.
If you use the Concealed Wines Websites outside the European Union, please note that your personal data may be transferred outside of your home jurisdiction to the United States and to other jurisdictions where our affiliates and service providers are located.
Some of these jurisdictions, including the United States, do not have equivalent data protection laws as the European Union and other jurisdictions. By using our Websites, you are agreeing that your personal data may be transferred to the United States and other jurisdictions, as explained in this Section.
For EU residents, see Section 9, “EU and the Privacy Shield” below, for information regarding (i) Concealed Wines participation in the EU-US Privacy Shield Program through its Solution Partnership with Gigya and (ii) Concealed Wines’s handling of Personal information received from the European Union as a Subprocessor of Clients for its cloud Services.
9. EU, Switzerland and the Data Privacy Shield Framework
Concealed Wines complies with the E.U.- U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information obtained from European Union member countries and Switzerland in conjunction with its contractual relationship with Gigya.
Concealed Wines is a sub-processor for Clients websites that utilize our Services and certifies its processing of personal information from E.U. member countries and Switzerland is in accordance with the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability (the “Principles”).
You may view the certification for which Concealed Wines adheres to through its Solution Partnership with Gigya here https://www.privacyshield.gov/list.
Gigya and its subsidiaries are subject to the investigatory and enforcement authority of the Federal Trade Commission.
Information We Process.
We collect, in accordance with the Privacy Shield principles, the categories of information described in sections 2 and 7 above. We process personal information about website users for the purposes described in section 3 above.
Please note: additional information about Concealed Wines participation in the Privacy Shield program, with regard to data collected in a capacity as a processor to our Clients, is available by contacting info@concealedwines.com.
Accessing Personal information.
The Privacy Shield Principles provide individuals located in the E.U. and Switzerland whose personal information we process with the right to access their personal information in order to review, correct, amend or delete information processed under the Principles. E.U. and Swiss individuals who use our Site and would like to access their personal information may contact Concealed Wines at info@concealedwines.com or at the address set forth in the “Contact Us” section.
Additionally, anyone with a registered account on the Concealed Wines Websites may, at any time, review, update or correct the Personal information in their registration profile by using the tools provided within this privacy policy to make a request.
E.U. and Swiss End Users whose personal information we process on behalf of a Concealed Wines Client/partner (as a data processor) should first contact the Concealed Wines Client/partner, who is the controller of your personal information, to access their personal information; Concealed Wines will work with its Clients to provide End Users the necessary access about what personal information is processed.
Transfers to Third Parties.
As described in the “Disclosure of Collected Information” section above, we may transfer personal information from the E.U. and Switzerland to third parties. We contractually require third parties to whom we transfer personal information to provide the same level of protections as these Principles.
Concealed Wines remains responsible for the personal information we receive and transfer under Privacy Shield as it relates to our Services.
In accordance with our legal obligations, we may also transfer, subject to a lawful request, personal information to public authorities for law enforcement or national security purposes.
Contacting Us, Complaints and Dispute Resolution.
E.U. and Swiss individuals who have questions or complaints about how we process their personal information may contact us at info@concealedwines.com. We will work to resolve your issue and respond no later than 45 days of receipt.
10. Security
The security of your information is important to us, including, but not limited to, the personal information collected via the Concealed Wines Websites and Services. We use reasonable security measures to protect against the loss, misuse, and alteration of Personal information under our control, both during the transmission and once we receive it.
This includes, but is not limited to, the use of firewalls and encryption. Although we make good faith efforts to maintain the security of such personal information, no method of transmission over the Internet or method of electronic storage, is 100% secure and we cannot guarantee that it will remain free from unauthorized access, use, disclosure, or alteration.
Further, while we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining this information.
If we learn of a security breach involving your personal information, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Concealed Wines Websites or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Concealed Wines Websites.
If a security systems breach occurs, we may post a notice on our homepage (www.companywebsite.xyz) or elsewhere on the Concealed Wines Websites and may send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach, involving your personal information, in writing.
This notice paragraph applies to users of the Concealed Wines Websites and our Clients who utilize our Services on their third party websites only. Should there be a breach that affects End Users of Clients, the Client will be responsible for disseminating notice of such a breach to those End Users.
11. Children
The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. Concealed Wines Websites are not directed toward individuals under the age of thirteen (13), and we request that such individuals do not provide personally identifying information through our websites.
Additionally, we do not knowingly collect or maintain personal information from anyone under the age of 13, unless or except as permitted by law. If we learn that personal information has been collected from a user under 13 years of age on or through the Concealed Wines Websites, then we will take the appropriate steps to cause this information to be deleted.
If you are the parent or legal guardian of a child under 13 who has registered on the Concealed Wines Websites or you believe has otherwise provided personal information to Concealed Wines, please contact Concealed Wines at info@concealedwines.com to have that child’s account terminated and information deleted.
12. Analytics In addition
we use Google Analytics to analyze our users’ use of the Concealed Wines Websites. Google Analytics is currently on company website links list. Google Analytics provides us with aggregated data in order to help us make informed business decisions. Ultimately, Google, as a third party, controls information collected through Google Analytics and you should check and be comfortable with its privacy practices prior to using the Concealed Wines Websites. You may review information about Google’s privacy practices with respect to Google Analytics at http://www.google.com/analytics/learn/privacy.html.
13. Third-Party Ad Networks
We use third parties such as network advertisers to assist us in displaying advertisements on third party websites, and to evaluate the success of our advertising campaigns. Network advertisers are third parties that display advertisements based on your visits to our Website as well as other websites. This enables us, and these third parties, to target advertisements by displaying ads for products and services in which you might be interested. Third party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information about your usage of our Websites, as well as aggregate information about visitors to our Website.
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI) and www.aboutads.info/choices (DAA).
Opting out of one or more NAI member or DAA member networks (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads on our Site or other websites.
You may continue to receive advertisements, for example, based on the particular website that you are viewing. Also, if your browsers are configured to reject cookies when you visit this opt-out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt-out may no longer be effective. Additional information is available on NAI’s and DAA’s websites accessible by the above links.
14. Updates to This Privacy Policy
We may occasionally update this privacy policy. If we do, we will change the “effective date” at the top of the privacy policy. Before making any update that would make this privacy policy materially less restrictive in our use or disclosure of personal information collected prior to the update, we will provide prior notice of the update by posting notice on our website at the top or bottom of the then-current privacy policy. We encourage you to periodically review this privacy policy to stay informed about our collection, use, and disclosure of personal information. Your continued use of our websites constitutes your agreement to our then-current privacy policy.
15. Contact Us
If you have questions about this privacy policy, you may contact us at info@concealedwines.com.
You may also write to us at:
Concealed Wines AB _- Attn: Privacy
at
Bo Bergmans gata 14, 115 50
Stockholm, Sweden