Wine Authentication Services LLC ("Company," "we," "us") is concerned about online privacy issues and wants you to be familiar with how we collect, use and disclose your Personally Identifiable Information (as defined below). This Privacy Policy (the "Policy") describes our practices in connection with Personally Identifiable Information that we collect through our web sites located at www.wineauthentication.com and www.fakewine.com (collectively, the "Site"). This Policy does not govern our collection of information through any other means, other than through the Site; nor does this Policy govern the collection of information by any third parties.

By using the Site, you agree to the terms and conditions of this Policy. If you do not agree to the terms and conditions of this Policy, please do not use the Site. We reserve the right to change this Policy without prior notice. You can determine when this Policy was last revised by referring to the "LAST UPDATED" legend at the top of this page. Any changes to our Policy will become effective upon our posting of the revised Policy on the Site. Use of the Site following such changes constitutes your acceptance of the revised Policy then in effect.

The Site is controlled and operated by Company from the United States, and is not intended to subject Company to the laws or jurisdiction of any state, country or territory other than that of the United States. Company does not represent or warrant that the Site or any part thereof is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Site's availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. By using this Site and submitting any PII, visitors from outside of the United States acknowledge this Site is subject to United States law, consent to the transfer of PII to the United States, and waive any claims that may arise under their own national laws.

Note Regarding Age: The Site is not directed to individuals under the age of twenty-one (21), and we request that such individuals do not provide Personally Identifiable Information through the Site.

• 1. What Types of Information Does Company Collect From Me?

  Company gathers two basic types of information through the Site: "Personally Identifiable Information" (or "PII") and "Non-Personally Identifiable Information" (or "Non-PII"). Personally Identifiable Information is information that identifies you as an individual; that is, your name, postal address, telephone number, fax number, e-mail address and credit card number. Non-Personally Identifiable Information is aggregated information, demographic information, IP addresses and any other information that does not reveal your specific identity.

• a. Personally Identifiable Information.

  You do not have to provide PII to use the Site. However, in order for you to take advantage of particular opportunities provided through the Site (for example, to sign up to use the forums or message boards provided on the Site), we may require that you furnish PII. We collect PII from you through the Site only when you voluntarily provide it to us.

• b. Non-Personally Identifiable Information.

When you visit and interact with the Site, Company and third parties with whom Company has contracted to provide services to Company may collect Non-PII (for example, a catalog of the Site pages you visit). Non-PII is generally collected through the Site from five different sources: server log files, environmental variables, cookies, Pixel Tags and information that you voluntarily provide.

• i. Server Log Files.

  Your Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use your IP address, and the IP addresses of all users, for purposes such as calculating Site usage levels, helping diagnose problems with the Site's servers, and administering the Site. Collecting IP addresses is standard practice on the Internet and is done automatically by many web sites.

• ii. Environmental Variables.

  We and our service providers may also collect certain environmental variables, such as your MAC address, computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version. These environmental variables are collected by most browsers, and can be used to optimize your experience on the Site.

• iii. Cookies.

  We and our service providers may use "cookies" on the Site. Cookies are data that a web server transfers to an individual's computer for recordkeeping purposes. Cookies are an industry standard used by most web sites, and can facilitate users' ongoing access to and use of a particular web site; cookies do not cause damage to your computer systems or files. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular web site, to your computer.

• iv. Pixel Tags.

  We and our service providers may also use so-called "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some Site pages and HTML-formatted e-mail messages to, among other things, compile aggregate statistics about Site usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to Site visitors and may be associated with Cookies on the visitors' hard drives. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted e-mail messages, Pixel Tags can tell the sender whether and when the e-mail has been opened.

• v. Information That You Voluntarily Provide.

  We also collect Non-PII (e.g., your interests, your geographic location, etc.) when you voluntarily provide such information to us. When such information is not combined with any PII, such information is considered to be Non-PII, as it does not personally identify you or any other user. Additionally, we may aggregate PII in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using PII to calculate the percentage of our users who have a particular telephone area code. Such aggregate information is considered Non-PII for purposes of this Policy.

• 2. How Does Company Use Information Collected on the Site?
  • a. Personally Identifiable Information.

    We may use your PII in the following ways:

    • i. Fulfillment of Requests.

      Company may use your PII to fulfill the purpose for which such PII was provided (e.g., to confirm your registration or fulfill your purchase, if applicable).

    • ii. Administrative Communications.

      From time to time, in our sole discretion, we may use your PII to send to you important information regarding the Site. Because this information may be important to your use of the Site, you may not opt-out of receiving such communications.

    • iii. Marketing Communications.

      We may use your PII to inform you of products, programs, services and promotions that we believe may be of interest to you. If you would prefer not to receive such marketing communications from us, please see the "Opt-Out" section below.

    • iv. Purchases.

      We may offer you the opportunity to purchase goods and/or services through the Site. If you make a purchase through the Site, we may collect your credit card number, billing address and other information related to such purchase (collectively, "Payment Information") from you, and may use such Payment Information in order to fulfill your purchase.

    • v. Identity Verification.

      For your protection, and the protection of our community, we may use your PII to verify your identity (for example, we may contact you to verify the information provided to us), and we may provide such PII to third parties as necessary to verify your identity (for example, we may verify your credit card information with a third party processor.)

    • vi. Internal Business Purposes.

      We may also use your PII for our internal business purposes, such as data analysis, audits, identification of inappropriate use of the Site and so forth.

  • b. Non-Personally Identifiable Information.

    Because Non-PII does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to share such Non PII, which does not personally identify you, with third parties, for any purpose. In some instances, we may combine Non-PII with PII (such as embedding e-mail addresses in cookies). If we do combine any Non-PII with PII, the combined information will be treated as PII as long as it is so combined (see 2.a above).

• 3. How Is Personally Identifiable Information Collected on the Site Disclosed?
  • i. Third Party Service Providers.

    We may work with third parties who provide services including but not limited to database management, website hosting and other services of an administrative nature. We reserve the right to share your PII with such third parties for the purpose of enabling these third parties to provide such services.

  • ii. Purchases.

    We may provide your Payment Information, or other PII provided by you, to third parties as necessary to complete your purchase (for example, to process your credit card). To the extent that Payment Information includes Non-PII, use of such Non-PII is governed by Section 2.b above.

  • iii. Consulting Requests.

    If you specifically request that we provide your PII to a third party (for example, if you specifically request that we provide your PII to a particular expert so that such expert may contact you), we will fulfill your request by providing such PII to such third party. PLEASE NOTE THAT WE ARE NOT RESPONSIBLE FOR ANY THIRD PARTY'S USE OF YOUR PII.

  • iv. Forums.

    We and/or our third-party service provider(s) make available through the Site interactive services (including, as examples only, and without limitation, message boards and forums) to which you are able to post information and materials (each, a "Forum"). Please note that any information you disclose through a Forum becomes public information, and may be available to other visitors to the Site and to the general public. In addition, when you choose to make a posting or other submission on or through a Forum, certain information (such as your user name) may be available for other users to view. We urge you to exercise discretion and caution when deciding to disclose your PII, or any other information, on the Site. WE ARE NOT RESPONSIBLE FOR THE USE OF ANY PII YOU VOLUNTARILY DISCLOSE THROUGH ANY FORUM OR OTHERWISE THROUGH THE SITE. WE URGE YOU TO BE EXTREMELY CAREFUL WITH YOUR PII WHEN USING THE SITE.

  • v. Assignment.

    We reserve the right to transfer any and all information that we collect from users of the Site to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Company's business, assets or stock.

  • vi. Law Enforcement; Emergencies; Compliance.

    Finally, notwithstanding any other provision of this Policy to the contrary, we reserve the right to disclose your PII to others as we believe to be appropriate (a) under applicable law; (b) to comply with legal process; (c) to respond to governmental requests; (d) to enforce our Terms of Service agreements; (e) to protect our operations; (f) to protect the rights, privacy, safety or property of Company, you or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain.

• 4. Other Important Notices Regarding Our Privacy Practices.
  • a. Third Party Sites.

    The Site may contain links to third party web sites. These linked sites are not under Company's control and we are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site. We provide such links only as a convenience, and the inclusion of a link on the Site does not imply endorsement of the linked site by Company. If you provide any PII through any such third party web site, your transaction will occur on such third party's web site (not the Site) and the PII you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.

  • b. Third Party Advertisers.

    We may use third party advertisers ("Third Party Advertisers") to serve advertisements on the Site. Please note that Third Party Advertisers may use cookies and other technologies to, among other things, enable such Third Party Advertisers to record which ads your browser has seen and which Site pages you may have been viewing when the ads were delivered. For more information about these cookies and other technologies, and how to "opt-out" of information collection by Third Party Advertisers, you may visit https://networkadvertising.org/optout_nonppii.asp

  • c. Security.

    We seek to have security measures and tools in place to help protect against the loss, misuse and alteration of the information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. As a result, although we strive to protect your PII, we cannot ensure or warrant the security of any information you transmit to us through or in connection with the Site or that is stored by us. You acknowledge and agree that any information you transmit through the Site is so transmitted at your own risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with "Contacting Us," below (note that physical mail notification will delay the time it takes for us to respond to the problem).

  • d. Opt-Out.

    We may use your PII to send messages to you regarding products, programs, services and promotions that we believe would be of interest to you. If you do not wish to receive marketing communications from us, you may opt-out of such marketing communications by sending us a message via the Contact Us option on the home page. You must use OPT-OUT as your subject. We will endeavor to comply with your request as soon as reasonably practicable.

  • e. Changing or Removing Your PII.

    If you would like to review, correct, update or remove PII that you have previously provided to us through the Site, you may do so by logging in to your account and making changes to the PII that you have provided to us. Please note that we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed therefrom. We also reserve the right, from time to time, to re-contact former users of the Site. Finally, we are not responsible for removing information from the databases of third parties with whom we have already shared your PII.

  • f. Contacting Us.

    If you have any questions regarding this Policy, please contact us by sending us a message via the Contact Us option on the home page. Please note that these communications will not necessarily be secure; accordingly you should not include credit card information or other sensitive information in your correspondence with us.