Privacy Policy

Effective Date: December 1, 2021

Protecting your privacy is fundamental to the way Saba Wine Holdings, Inc., Saba Winery, its partners and subsidiaries (collectively, “Company,” “we,” “us,” or “our”) conduct business. Although privacy regulations require companies to inform you of their practices regarding the collection and use of your personal information, keeping client information confidential has always been and will alwayd be our policy. We know that privacy is important to you, and we are committed to safeguarding your personal information. This Privacy Statement explains how we may collect, use and disclose your personal information.

PERSONAL INFORMATION

In the course of offering and providing our products and services, it is common for us to receive sensitive information from and about our clients, including financial and business information, some of which constitutes personal information. Generally speaking, personal information is any information that can be used, directly or indirectly, to identify, locate or contact someone. Types of personal information include names, physical addresses, mailing addresses, social security numbers, email addresses, phone numbers, bank account numbers and driver’s license numbers. Under certain circumstances, personal information may also include other information that can reasonably link to a particular person, such as internet protocol (IP) addresses, unique device identification numbers, employment information, medical information and internet activity.

HOW WE COLLECT PERSONAL INFORMATION

Typically, we receive personal information directly from our clients or their agents in the course of performing our services. For example, customers may provide their personal information to us in order for us to process wine and other merchandise orders, process event ticket purchases or make reservations for tours, tastings or other accommodations.

We also collect personal information through our website (jordanwinery.com). For example, if you setup an account for client portal access, Saba Wine Club requests, and trade visit requests on our website, we will collect information such as your name, email address, username and password, and we will receive any documents you submit through the client portal. Our web servers may also collect information from visitors such as IP address, browser type and version, time zone setting, operating system and platform. Some web browsers allow the user to send “do-not-track” signals to websites, but our website does not respond to those signals.

Our website, like most websites, employs “cookies” and similar technologies. Cookies are small files that are stored on your computer or mobile device when you visit our website and allow us to recognize your browser and obtain information about your use of our website.

Moreover, we use Google Analytics (“GA”) for aggregated, anonymized website traffic analysis. In order to track your session usage, Google drops a cookie with a randomly-generated ClientID in your browser. This ID is anonymized and contains no identifiable information like name, address, email address, telephone number, etc. We also send Google your IP Address. We use GA to track aggregated website behavior, such as what pages you looked at, for how long, and so on. This information is important to us for improving the user experience and determining site effectiveness. If you would like to access what browsing information we have—or ask us to delete any GA data—please delete your cookies, reach out to us via the contact information provided on this webpage, and/or install the Google Analytics Opt-Out Browser Add-On.

HOW WE USE PERSONAL INFORMATION

We use the personal information we collect from you to fulfill the purpose for which you provide it. We may also use your personal information: (1) to provide you with information, products or services that you request from us; (2) to provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you; (3) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections; (4) to improve our website and present its contents to you; (5) for testing, research, analysis and product development; and (6) for any other purpose with your consent.

DISCLOSURE OF PERSONAL INFORMATION

We may disclose personal information we collect from you: (1) to our subsidiaries and affiliates; (2) to contractors, service providers, and other third parties we use to support our business; (3) to fulfill the purpose for which you provide it; (4) to a buyer or other successor in the event of a sale or transfer of some or all of our business or assets; (5) for any other purpose disclosed by us when you provide the information; (6) to comply with any court order, law or legal process, including responding to any government or regulatory request; (7) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections; (8) if we believe disclosure is necessary or appropriate to protect the rights, property or safety of us, our clients or others; or (9) with your consent.

We do not sell or otherwise share personal information with third parties for direct marketing purposes.

DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access and disclosure. The use of, and access to, your personal information by us is restricted to employees and contractors who need to know that information to provide services to you. We maintain physical, electronic and procedural safeguards to limit access to your nonpublic personal information.

Unfortunately, transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to us through our website or other electronic means. Any electronic transmission of personal information is at your own risk.

THIRD-PARTY PROVIDERS

Some applications and services embedded within, or linked from, our website, such as maps and social media platforms, are controlled by third-party providers. These third-parties may use cookies, alone or in conjunction with other tracking technologies, to collect information about you when you use our website or navigate away from our website. These third parties may also have privacy policies that differ from ours. For example, they may collect personal information about your online activities over time and across different websites, and other online services, and may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third-parties or their privacy practices, and this Privacy Statement does not apply to any third-party website or service you may access through our website. If you have any questions about a third-party provider’s privacy policies or advertising, you should contact the responsible provider directly.

NON-PERSONAL INFORMATION

This Privacy Statement does not restrict our collection, use or disclosure of any aggregated information or information that does not identify, or cannot be reasonably linked to, any individual.

CHANGES TO OUR PRIVACY STATEMENT

We will post any changes we make to this Privacy Statement on our website. If we make material changes to how we treat personal information we collect from you, we will notify you by email or through a notice on our website homepage. The date this Privacy Statement was last revised is identified above. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Privacy Statement on our website to check for any changes.

CONTACT INFORMATION

Company appreciates your business. If you have questions or comments about this Privacy Statement, please call us or email us at privacy@sabawine.com.