Privacy Policy

Ehlers Estate (“Ehlers”) is committed to protecting your privacy. The information that you provide to Ehlers, 3222 Ehlers Lane, St. Helena, California 94574 (sometimes referred to as “we”, “us” or “our”) is utilized in order for us to (among other things) provide you with the highest level of customer service reflective of the quality of our brands.

This Privacy Policy (“Policy”) applies to our offline and online data collection practices, including when you visit our website at www.ehlersestate.com or the (collectively the “Site”), inquire about our products or services, make a purchase from us, visit our vineyards or tasting rooms, subscribe to our mailing lists or to our wine club programs or when you engage with us via email or on social media or through any other method.

We may update this Policy from time to time, as specified in the “Changes to This Privacy Policy” section below.

Specific State Privacy Policies

If you are a California resident, please also see our California Consumer Privacy Section in this Policy.
If you are a Texas or Nebraska resident, please also see our Multi-State Data Privacy Section in this Policy.

Your Consent

Please review this Policy periodically, and especially before you provide any Personal Information to us. You should read this entire Policy before submitting information, including personal information, to us in any form or using our Site. By accessing or using the Site or submitting information to us, you consent to the data practices described in this Policy.

All Personal Information may be used for the purposes stated in this Policy. We may make full use of all information that is de-identified, aggregated, or otherwise not in personally identifiable form. We may also make full use of all user-generated content you submit to us.

Collection of Personal Information

We collect Personal Information about you in the following ways: 1) from you when you choose to voluntarily provide it both offline at our physical property and online; 2) using automated technology, including when you visit our Site or interact with our electronic advertisements or communications; and 3) using third party sources including but not limited to service providers, entities providing data analysis and analytics, social media and social networking websites and other entities. Automated technology collects information from your computer or mobile device and includes cookies, web beacons, local shared objects, or other similar technology. More information is given in the “Cookies and Other Technology” section below.

All Personal Information may be used for the purposes stated in this Policy. We may combine data collected from third-party sources.

Categories of Personal Information Collected

Ehlers collects Personal Information, such as: your name; signature; mailing address; telephone number; email address; date of birth; credit card information; location; products or services purchased, obtained, considered, reviewed or other purchasing or consuming habits; and, if you visit our property, photographs, video, and face imaging for security purposes.

We collect information about you through your browser, computer hardware and software. This information can include your IP address, your device information, domain name, browsers you used to access our Site and services, web pages viewed, time spent on web pages, link clicks, transactions entered into and site-navigation pattern. This information is used by Ehlers for the improvement of our Site. This site is being monitored by one or more third-party monitoring software(s), including website analytics and chat functions, and may capture information about your visit that will help us improve the quality of our service.

How We Use Your Personal Information

We use Personal Information of customers for a wide range of purposes, including:

To respond to and fulfill your requests, purchase orders, and wine club orders, follow up with you after you have communicated with us or submitted information to us, and to provide products or services that you have ordered;
To process your order transactions, contact you regarding your order, and deliver products to you;
To improve our products, services, Site, and social media;
To provide you with a customized user experience;
To send promotional communications or offers regarding our products and services (unless you have requested that we not send such communications);
To authenticate your account credentials and identify you, as necessary to log you in and/or ensure the security of your account;
For marketing, research, legal, and other business purposes;
To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies;
To maintain and preserve the safety of our guests, premises, property, and products; and,
To improve our premises and your customer experience;
As otherwise specified at the point of collection.

Email/Text Marketing

If you no longer wish to receive email marketing communications from us, you may unsubscribe from receiving marketing-related emails by using the unsubscribe method provided in our communications (e.g., by clicking on the “unsubscribe” link in the email to unsubscribe). Please note that unsubscribing from our promotional material will not prevent us from contacting you for other reasons, such as order confirmations, responses to customer service inquiries, or information about an event for which you have registered.

Alternatively, to the extent that applicable law requires your prior opt-in consent to receive marketing and promotional emails, we will ask for your consent and you can choose not to opt-in.

You may also choose to participate in certain text or SMS/MMS marketing. If you opt in to such marketing, we may collect and use certain personal information, including phone number, email, product browsing behavior, purchase behavior, device type, cellular carrier, and location to contact you and provide you marketing communications or promotions.

Website Chat Function

Our website chat function and subsequently text exchanges therein are operated by RedChirp. When you use our website chat function, your personal information, including identifiers and contact information, as well as the content of your chat communications will be recorded by Ehlers and/or our service providers (i.e., RedChirp) on behalf of Ehlers. We will use the information collected to provide you with services requested and communicate with you on related topics. For more information, please visit the Terms and RedChirp’s Privacy Policy. This information is also directly provided in the website chat function box and disclosed immediately prior to any engagement with the Website Chat Function.

Others With Whom We May Disclose Your Personal Information

Service Providers and Contractors

We disclose Personal Information you provide to consultants, service providers, and contractors that we use to support our business and operations who have agreed to keep the information confidential and use it only to provide the applicable service(s) such as vendors that help us communicate with you, vendors that host our website and data, security and fraud detection vendors.

Third Parties and Vendors

We disclose Personal Information to third parties we work with who help us gather information from you and communicate with you which may include payment processors, entities that provide sweepstakes/contests sponsorship, social media companies, companies providing data analytics, targeted advertising, or online behavioral marketing services.

Administrative or Legal Obligations

We may disclose Personal Information to third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our (or others’) rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations.

Sale or Corporate Restructuring

We may disclose Personal Information to third parties in connection with the sale, assignment or other transfer of the business of our website or the sale, assignment, merger, reorganization or other transfer of our brand or company.

How We Use “Cookies and Other Technology”

An IP address is the unique number that is automatically assigned to your computer when you log onto the Internet. As you enter the Site, our server records and monitors your IP address and uses it to develop statistical analysis. These analyses assist us in refining and adapting the content and design of our site. The use of IP addresses also enables us to prevent malicious Internet users from masquerading as other users. Automated technology collects information from your computer or mobile device and includes cookies, web beacons, local shared objects, or other similar technology. A cookie is a small piece of information sent by a website that is saved on your hard drive by your computer’s browser. A “web beacon” is a small object or image that is embedded into a web page, application, or email and is used to track activity. They are also sometimes referred to as pixels and tags.

As you access or use our Site, we and/or third parties may collect information using cookies, web beacons, pixels, and navigational and location data collection (clickstream, log files, server logs) for the purposes described in this Policy. Such automated technologies further help us to keep track of your interactions with our website and provide you with a more customized experience.

To find more information about cookies please visit www.allaboutcookies.org. Most browsers are initially set to allow cookies, but also offer the option to restrict cookies or warn you of their use. By disabling cookies, you won’t be able to enjoy the convenience provided by our customization.

Third Party Advertising and Analytics Disclaimers

We and/or third parties including service providers on our behalf, may use cookies, web beacons and other similar technology, to collect information from you such as your activities on the Website for the purposes described in this Policy including advertising, analytics, online behavioral marketing, monitoring performance, and improvement of our online services (traffic, errors, page load time, popular pages, etc.)

Examples of our third-party service providers to help deliver our services or to connect to our services include:

Google Analytics and Google AdSense: We use Google AdSense to display advertisements on our Site and Google Analytics to understand how our website, services, advertisements, and products perform and how you use them. Google AdSense may use cookies, web beacons, and similar technologies to collect information about your activities on our Site and other websites in order to provide you with interest-based advertising. Google Analytics collects information such as IP address, device information, browsing behavior, and interactions with our Site to help us analyze usage and improve performance. If you would like to opt out of Google Analytics and Google AdSense, you can opt out of Google Analytics by installing Google’s Opt Out browser add on: https://tools.google.com/dlpage/gaoptout and opt out of interest-based Google ads using https://adssettings.google.com/u/0/authenticated. To learn more about how Google processes your data, please visit https://www.google.com/policies/privacy/.
Meta Ads and Pixel: We use Meta technologies, including the Meta Pixel and related advertising tools, to advertise and market our services to you and to measure the effectiveness of our advertisements. Meta may collect information such as identifiers and internet or other electronic network activity information when you interact with our Site or advertisements. To learn more about how Facebook uses your data please visit https://www.facebook.com/privacy/explanation or log on to your Facebook account and access your settings. To understand more about Facebook advertising and manage your preferences, please visit https://www.facebook.com/about/ads.
Sprout Social: We use Sprout Social to manage and analyze our social media presence, engagement, and communications. Sprout Social may collect and process certain personal information, including identifiers and internet or other electronic network activity information, in connection with your interactions with our social media accounts and related communications. For more information about how Sprout Social processes personal information, please visit https://sproutsocial.com/privacy/.
Klaviyo: We use Klaviyo to manage our email marketing campaigns and retargeting efforts. Klaviyo may collect and process personal information such as identifiers, commercial information, browsing behavior, purchase history, and interactions with our emails and Site in order to send personalized marketing communications and advertisements. You may opt out of receiving marketing emails by using the unsubscribe link in any marketing email. For more information about Klaviyo’s privacy practices, please visit https://www.klaviyo.com/legal/privacy.

Remarketing and Advertising Opt-out: We use remarketing services to inform, optimize, and serve ads on third-party websites to you based on your use of our Site and social media. For more information regarding targeted advertising and to opt out of sharing your information with third-party companies engaged in targeted advertising, including social networking sites visit the AdChoices website powered by the Digital Advertising Alliance (DAA) at http://optout.aboutads.info/?c=2&lang=EN. If you choose to opt out, you will continue to receive advertisements but they will not be tailored to your interests.

This Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third parties to learn about their privacy practices.

Digital Advertising Alliance

You can also opt out from companies like Google, Instagram, Pinterest, Facebook and other participating companies through the Digital Advertising Alliance in the USA: http://www.aboutads.info/choices/. You can also opt out of participating companies from the Digital Advertising Alliance of Canada in Canada: http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe: http://www.youronlinechoices.eu/, or opt out using your mobile device settings.

Retention of Personal Information

We will retain your personal information (collected through offline and online methods) only for as long as it is necessary for the purposes described in this Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. For more information regarding retention of personal information see Annex 1.

Intended Audience of Websites; COPPA Compliance

Children’s Online Privacy Protection Act (“COPPA”) does not apply to Ehlers. Our Site and social media accounts are not intended for people under the legal drinking age and as a result, we will not knowingly collect information from minors in the United States or elsewhere with or without the consent of their parents or guardians. If you are not 21 or older, you should not visit or use our Site or social media accounts.

Security

We take appropriate steps to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration or destruction, whether in transmission or storage. Please keep in mind, however, that there is no such thing as perfect security, and no Internet transmission is ever completely secure or error-free. Moreover, you are responsible for maintaining the confidentiality of any user name and password you use.

External Links

We may make available third party applications through our Site and social media applications for your use. Links to such applications, any other websites included in this Site or links on our social media accounts operate with privacy policies beyond our control. Unless otherwise indicated, once you have left our Site or our social media account, all use of information you provide is governed by the privacy policy of the other website’s or social media account’s operators. We are not responsible for any transactions that occur between you and a third-party website or social media account.

Governing Law

This Policy and our privacy practices will be subject exclusively to the laws of the State of California, United States of America. We make no representation that this Policy and its practices comply with the laws of any other jurisdiction.

Contact Us

If you have any questions or concerns about this Policy, please contact us at info@ehlersestate.com.

CALIFORNIA CONSUMERS ONLY: Your California Privacy Rights

This Privacy Rights Act Notice (“Notice”) provides additional information to California residents whose Personal Information is collected by Ehlers pursuant to California law, including the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”). If you are not a California resident, this Notice does not apply to you. Please visit our Privacy PolicyPrivacy Policy (“Policy”) [Insert link to main Privacy Policy] for more information. Any capitalized terms undefined in this Notice have the same definition as the Policy.

RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, DISCLOSED, OR SOLD AND SHARED

Information Collected

Within the past 12 months, we have collected the categories of Personal Information about California consumers as described in Annex 1 to this Notice. To review these categories click here.

Business-to-Business (“B2B”) Information

If you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship, we collect the contact information you provide to us, including name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating that business relationship. We use that information for internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship. We do not disclose that information outside our business relationship without your consent. See Annex 1 for more details.

Information Sold or Shared, or Disclosed

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect. We will share your Personal Information with third parties only in the ways that are described in this Privacy Policy.

As explained in Annex 1 of this Policy, we share your data with third party partners such as social networking sites and advertising companies in order to serve you with ads tailored to your preferences across various platforms. This type of sharing may be considered “selling” or “sharing” under the CPRA. You can control the information shared about you and request an opt-out as explained below.

We have sold or shared the following categories of Personal Information in the preceding 12 months.

Personal Identifiers
Commercial Information
Internet/Network Activity

We have disclosed the following categories of personal information for a business or commercial purpose in the preceding 12 months:

Personal Identifiers
Commercial Information
Internet Activity

We do not knowingly sell or share the Personal Information of individuals under 16 years of age without affirmative authorization.

For details regarding the categories of third parties with whom we have shared, sold, or disclosed Personal Information, please see Annex 1.

CPRA Rights and Requests

Under the CPRA, you are entitled to certain rights, where you can make certain requests with regard to those rights as follows:

Right to Know about the Categories and Specific Pieces of Personal Information Collected (“Right to Know”)
Right to Request Deletion of Personal Information (“Right to Delete”)
Right to Correct or Rectify Inaccurate Information about you (“Right to Correct”)

How to Make Your Requests to Know, Delete, or Correct.

You have the right to make requests for the aforementioned rights (Request to Know; Request to Delete; or a Request to Correct (a “Request”)).

To make a Request for any of the information set forth above, please submit a verifiable consumer request pursuant to the instructions below. The Request must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected, sold, shared, or disclosed and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request. We will acknowledge your Request within 10 business days and will attempt to respond substantively within 45-90 days.

You may make a Request in the following ways:

You may make a request here: info@ehlersestate.com
You may make a request by calling [insert toll free phone number]

Once we receive your Request, we will begin the process to verify that you are the person that is the subject of the request (the “Verification Process”). The Verification Process consists of matching identifying information provided by you with the information we have about you in our records. You will be asked to provide us with two or three pieces of information that will help us to verify your identification.

We will review all information provided by you to us, to determine whether we can respond to your Request We will inform you of our decision to deny or grant your Request.

For any Requests to Know, you may make such Requests twice within a 12-month period.

For Requests to Correct, you will need to provide evidence supporting the inaccuracy of the current information, and we reserve the right to delete the information instead of correcting if such deletion does not impact you or you consent to the deletion.

We will retain correspondence, documents and information related to any Request for 24 months as required by law.

Additional CPRA Rights

The following are additional rights afforded to you under the CPRA.

Right to Know Sensitive Personal Information Collected

We collect and use Sensitive Personal Information as set forth in Annex 1.

We do not collect or process sensitive personal information for the purpose of inferring characteristics or for any purposes other than those set forth in Regulations Section 7027(m).

Right to Non-Discrimination for Exercising Privacy Rights

You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the California Consumer Privacy Act, including by exercising the rights specified herein.

Right to Know About and Access Information Regarding Automated Decision Making Technology

We do not use your Personal Information to engage in automated decision making about you.

Right to Opt-Out of Sale or Sharing of Personal Information

You have the right to opt-out of the sale or sharing of your Personal Information (“Request to Opt-Out”). We and our third-party partners, such as social networking sites and advertising companies, share your data in order to serve you with ads tailored to your preferences across various platforms. This type of sharing may be considered a “sale” or “share” under the CPRA. You can control the information shared about you and request an opt-out. We will process your Request to Opt-Out of sale within 15 days.

You can make a Request to Opt-Out in the following ways:

You may make a request here: [link to Cookie pop-up]
You may make a request by calling [insert toll free phone number]

Opt-out Preference Signals

We honor opt-out preference signals that you enable, including a Global Privacy Control. Opt-out preference signals are plug-ins available in certain browsers that signal to websites you visit of your preferences to opt out of the sale and sharing of certain personal information. If you have enabled an opt-out preference signal device from your browser, we will not sell or share your personal information without first seeking your explicit consent.

This Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third-parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third-parties to learn about their privacy practices.

Cookies

Cookies are small bits of code that are stored by your computer’s web browser and that may automatically identify your browser to the Services whenever your computer is used to visit the Services. Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.

To find our more information about cookies, please visit www.allaboutcookies.org.

Additional Ooptions to Opt-Out of Sale or Sharing

In addition to the above options to opt out of the sale or sharing of your information under the CPRA and CCPA as described above, you have controls and choices with respect to collection and use of your information by third parties. These are summarized for you below. We do not control or maintain opt-out mechanisms for third party companies and are not responsible for their operation.

Advertising Opt-Out

You can opt out of sharing your information with third party companies engaged in targeted advertising including social networking sites such as Google and Facebook using the following tools: For websites: http://optout.aboutads.info/?c=2&lang=EN. For mobile apps: http://www.aboutads.info/appchoices

Google Opt-Out

If you would like to opt out of Google Analytics and Ads, you can. If you are on the web, you can opt out of Google Analytics by installing Google’s Opt Out browser add on: https://tools.google.com/dlpage/gaoptout, and you can opt out of interest-based Google ads using https://adssettings.google.com/u/0/authenticated.

Facebook Ad Preferences

To understand more about Facebook advertising and manage your preferences, please visit https://www.facebook.com/about/ads. Login to Facebook and go to Settings > Ads > Ad Settings (web) or Ad Preferences > Ad Settings (app) for more information.

Opt-out Preference Signals

Retention of Personal Information

We will retain your Personal Information (collected through offline and online methods) for as long as it is necessary for the purposes set out in Annex 1 and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Authorized Agent Information

You may designate an authorized agent to make a request on your behalf under the California Consumer Privacy Act.

In order to allow an authorized agent to make a request on your behalf, please email us at info@ehlersestate.com to provide your written request and consent to an authorized agent.

When your authorized agent makes a request related to your personal information, we will require the agent to provide the above written permission. We may also require that you verify your own identity directly with us at the time such a request is made.

Other California Disclosure Information

California Do Not Track Notice

Because there are not yet common, industry accepted “do not track” standards and systems, our website does not currently respond to Do Not Track signals. In addition, we may allow third parties to collect Personal Information from your activity on our website, as described in the “Information Collection and Use” section above.

California Shine the Light Disclosure Information

Although we do not disclose to any third parties for their marketing purposes any personal information, California residents are entitled to receive the following disclosure information under California law:

Under California Law, California residents have the right to request in writing from businesses with which they have an established business relationship, (1) a list of the categories of personal information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. We will respond to such written requests within 30 days following receipt at the e-mail or mailing address stated above. If we receive your request at a different e-mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are required to respond to each customer only once per calendar year.

Changes to this Privacy Policy

This Policy may be revised from time to time for any reason. If this Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page. Be sure to check the Policy whenever you submit personal information to us.

Contact for More Iinformation

For information and questions about the use of your personal information or this California Consumer Privacy Section or your rights under California law, you may contact us at info@ehlersestate.com.

Multi-State Consumer Data Protection Act Notice

Texas and Nebraska

This Notice (“Notice”) provides additional information to residents of Texas and Nebraska whose Personal Information is collected by us pursuant to Texas and Nebraska law, including the Texas Data Privacy and Security Act (“TDPSA”) and the Nebraska Data Privacy Act (“NDPA”). If you are not a Texas or Nebraska resident, this Notice does not apply to you. Please visit our Privacy PolicyPrivacy Policy (“Policy”) [Insert link to Privacy Policy] for more information. Any capitalized terms undefined in this Notice have the same definition as the Policy.

Privacy Rights

Right To Know/Confirm

You have the right to know whether we are processing information about you.

Right To Correct

You have the right to request that we rectify inaccurate information about you.

Right To Request Deletion Of Personal Data

You have the right to request the deletion of your personal data provided by or obtained about you (“Request to Delete”), subject to certain exceptions permitted by law

Right To Opt-Out Of Sale And Use of Personal Information For Targeted Advertising and Profiling

You have the right to opt-out of the sale of your Personal Information, the processing of your personal information for targeted advertising, and the use of your information for automated decision making.

As explained in our Privacy Policy, we share your information with certain third parties, including social media companies, advertising platforms, advertising and email marketing agencies, and companies providing data analytics, including for the purpose of targeted advertising to you based on your preferences across platforms. To opt out of targeted advertising please click the “Your Privacy Choices” link [insert link] or see information regarding “How To Make A Rights Request” below.

We do not engage in automated processing.

We do not share your information for the purpose of targeted advertising.

Right To Non-Discrimination For Exercising Consumer Privacy Rights

You have the right not to receive discriminatory treatment for exercising your privacy rights conferred by the TDPSA. As the Right to Non-Discrimination is effective across the board, there is no specific “request” that you need to make in order to exercise this right.

Right To Data Portability

You can request a copy of your Personal Information in an easily accessible format and information explaining how that information is used.

How to Make a Rights Request

You can make a Rights Request in the following ways:

You may make a request here: info@ehlersestate.com
You may make a request by calling [insert toll free phone number]

We will acknowledge your Request within 10 days and will attempt to respond substantively within 45-90 days.

You must provide sufficient information to allow us to verify that you are the person about whom the personal information was collected and must contain sufficient detail to allow us to properly understand, evaluate and respond to your request. If we cannot verify your identity, we will not be able to respond to your request.

Right to Appeal

You have the right to appeal our decision to deny any of your privacy rights requests above. Within 45 days of receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

You can make an appeal in the following ways:

You may make a request here: info@ehlersestate.com
You may make a request by calling [insert toll free phone number]

We reserve the right to deny appeals in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.

If your appeal is denied, you may submit a complaint to the applicable Attorney General at https://www.texasattorneygeneral.gov/consumer-protection.

Opt-Out Preference Signals

Cookies

As explained in our “How we use cookies and other technology” section (add link to the Cookies section in the main Privacy Policy), you can opt out of cookies using your browser. You may also exercise your right to opt-out of cookies using our Cookie Preference Center (Link to Cookie Banner).

Please Note:

Opt-outs are device and browser based. You must opt out on each device and each browser where you want your choice to apply.
Opt-outs maybe stored via cookies. If you clear cookies, your opt-out may no longer be valid and you must opt out again where you want your choices to apply.
We may still share your Personal Information with our service providers that help us perform functions that are necessary for our business such as vendors that host our Site, analytics processors, etc. These entities are contractually obligated to keep this information confidential and not use it for any purpose other than for the services they provide to our business.

You may still receive ads from us that are not tailored to your interests.

Retention of Personal Information

We will retain your Personal Information for as long as it is necessary for the purposes set out in the Privacy Policy [LINK] and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Authorized Agent Information

In order to allow an authorized agent to make a request on your behalf, please email us at: info@ehlersestate.com to provide your written request and consent to an authorized agent. When your authorized agent makes a request related to your personal information, we will require the agent to provide the above written permission. We may also require that you verify your own identity directly with us at the time such a request is made.

We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.

Contact For More Information

For information and questions about the use of your personal information or this Notice or your rights under Texas law, you may contact us at info@ehlersestate.com.

Changes to This Privacy Policy

ANNEX 1

Notice of Collection, Use, and Disclosure

Category	Examples	Collected From	Purposes	Disclosed to	Sold or Shared	Retention Period
Personal Identifiers Commercial Information	Name, signature, mailing address, telephone number, email address, date of birth, credit card information, and location. Products or services purchased, obtained, considered, reviewed or other purchasing or consuming habits.	You when you visit our Site (including your online activities on our Site), purchase a product (through our Site, in person, or on the phone), register for an account on our Site, join our wine club programs, enter a promotion or competition conducted by us, engage with us on social media, or otherwise interact with us through posting content on our Site, or communicating with us via phone or email, or our website chat function. We may also collect information from third party sources, such as third party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals.	To respond to and fulfill your requests, purchase orders, and wine club orders, follow up with you after you have communicated with us or submitted information to us, and to provide products or services that you have ordered; To process your order transactions, contact you regarding your order, and deliver products to you; To improve our products, services, Site, and social media; To provide you with a customized user experience; To send promotional communications or offers regarding our products and services (unless you have requested that we not send such communications); To authenticate your account credentials and identify you, as necessary to log you in and/or ensure the security of your account; For marketing, research, legal, and other business purposes; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.	Consultants, service providers, and contractors that we use to support our business and operations (e.g. hosting or operating our Site, data collection, reporting, ad response measurement, Site metrics and analytics, data analysis, delivering marketing messages and advertisements, processing credit card payments, and providing fraud detection services) who have agreed to keep the information confidential and use it only to provide the applicable services; Third party payment processors, including in connection with transactions where we require credit or debit card account information such as credit or payment card account information (including card number, expiration date, and security code); Third party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics, targeted advertising, or behavior remarketing, as explained further below; Third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; An acquirer or successor-in-interest in the event of a reorganization, merger, sale, change of control, consolidation, joint venture, assignment, transfer or other disposition of all or any part of Ehlers Estates or its affiliates including any negotiation thereof; and Third party sponsors of contests, sweepstakes, discounts, and promotions that you enter into.	Yes. We share personal identifiers with third parties we work with who help us gather information from you and communicate with you, including social media companies, and companies providing data analytics, targeted advertising, or online behavioral marketing services. For more information on how to opt out, please click here [link to cookies pop-up]	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
Internet/Network Activity	IP address, your device information, domain name, browsers you used to access our Site and services, webpages viewed, time spent on webpages, links clicks, transactions entered into and site-navigation patterns.	Your computer or mobile device, through your online activities and interactions with us, including, without limitation, your use of our services, your online activity on our Site, including our website chat function, and on our social media channels or through our third party sources. Third party sources include third party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals.	Analyze and track usage of our services and products including our Site and social media accounts; Determine the popularity of our products, Site, and services; Better understand how you use our Site and services; Improve our Site, services, and products; Provide you with a customized user experience; To send promotional communications or offers including invitations to events, taking surveys, and participating in promotions (unless you have requested that we not send such communications); For other marketing, research, legal, and other business purposes; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.	Consultants, service providers, and contractors that we use to support our business and operations; Third party companies we work with who help to gather information from you or help us to communicate with you, including for purposes of data analytics, targeted advertising or behavior remarketing, as explained further below; and Third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; and An acquirer or successor-in-interest in the event of a reorganization, merger, sale, change of control, consolidation, joint venture, assignment, transfer or other disposition of all or any part of Ehlers Estate or its affiliates including any negotiation thereof.	Yes, we share internet/network activity information with third parties we work with who help us gather information from you and communicate with you, including social media companies, and companies providing data analytics, targeted advertising, or online behavioral marketing services. For more information on how to opt out, please click here [link to cookies pop-up]	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
Biometric Information	photographs, video, and face.	Your in-person visit to our vineyards including but not limited to vineyard, winery, tasting room, winery events, and wine club pickups.	To maintain and preserve the safety of our guests, premises, property, and products; Improve our premises and your customer experience; For marketing and promotional purposes on our Site and social media; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies.	Third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests.	No	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
Sensitive Personal Information	personal identification numbers, including driver’s license, passport, or state ID card numbers; account or debit or credit card numbers; or consumer’s geolocation.	You when you visit our Site (including your online activities on our Site), purchase a product (through our Site, in person, or on the phone), register for an account on our Site, join our wine club programs, enter a promotion or competition conducted by us, engage with us on social media, or otherwise interact with us through posting content on our Site, or communicating with us via phone or email, including our website chat function. We may also collect information from third party sources, such as third party service providers, opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals. To prevent, detect, and investigate any security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted sensitive personal information. For purposes that do not infer characteristics about the consumer.	To respond to and fulfill your requests, purchase orders, and wine club orders, follow up with you after you have communicated with us or submitted information to us, and to provide products or services that you have ordered; To process your order transactions, contact you regarding your order, and deliver products to you; To improve our products, services, Site, and social media; To provide you with a customized user experience; To send promotional communications or offers regarding our products and services (unless you have requested that we not send such communications); To authenticate your account credentials and identify you, as necessary to log you in and/or ensure the security of your account; For marketing, research, legal, and other business purposes; and To comply with our policies, procedures, and legal obligations, including complying with law enforcement or governmental authority requests, investigating fraudulent activity, resolving disputes, and enforcing our legal agreements and policies		No	We will retain your Personal Information for as long as it is necessary and to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.
Business-to-Business (“B2B”) Information	Name, phone number, address, email address and other contact and relationship information consistent with your role in facilitating the business relationship.	You, if you are a contact person for any of our business partners, vendors, distributors, suppliers, service providers, contractors, or other entities with which we have a business relationship or potential business relationship.	For internal purposes, including to contact you, send and receive information, and otherwise facilitate the business relationship.	We do not disclose B2B Information outside our business relationship without your consent.	No	We will retain your B2B Information for as long as it is necessary to fulfill the purposes outlined in this Policy and as otherwise needed to comply with applicable law and internal company policies.