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Privacy Policy

Privacy Policy

LAST UPDATED: 11/06/2022


1. Purpose: This privacy policy (“Privacy Policy”) describes the collection, use, and disclosure of personal information by Ikenga Wines LLC (“we”, “us”, or “our”) from individuals who access or use our website located at www.ikengawines.com (the “Site”) and the products or services we may provide or offer through the Site or otherwise (collectively, the “Services”). 

By using our Services, you agree to the collection, use, and disclosure of Personal Information (as defined below) in accordance with this Privacy Policy. This Privacy Policy is incorporated by reference into our Terms of Service (the “Agreement”) and is subject to the provisions of the Agreement. All other terms not defined herein will have the meanings set forth in the Agreement.

2. Scope. This Privacy Policy applies to Personal Information that is Processed (as defined below) by us in the course of offering our Services to you. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. You should ensure you have read both our Agreement and Privacy Policy prior to using our Services.  

3. Transparency and Notice
3.1 Types of Personal Information We Collect. The types of Personal Information we may collect (directly from you or from third party sources) and our privacy practices depend on the nature of your relationship with us and the requirements of applicable law. We collect Personal Information regarding our users of the Services (collectively “Individuals”), which, for greater certainty, includes visitors to the Site and both Account holders and non-Account holders who purchase our products. 
3.1.1 Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an Account, requesting information about the Services, or contacting us directly, we may ask you to provide some or all of the following types of information:
• Payment Information.When you purchase our products through the Services, you will need to provide us certain information that can be used to identify you in order for us to deliver the products to you. Such information includes, without limitation, your email address, delivery details such as your first and last name, phone number, physical address, and payment details such as your credit card number and billing address (collectively, “Payment Information”). Other than the last four digits of the credit card you use to purchase our products, Payment Information will not be stored by us and will be accessed and processed by third-party payment processors as described in more detail in Section 5 below. 
• Account Information. You do not need to create an Account in order to use our Services or purchase our products. However, if you would like to receive a subscription to our products or, in some circumstances when you would like to become a wholesale customer of our products, you will need to create an Account. If you create an Account, in addition to some of the Payment Information described above, we may collect additional information from you. We may store such information that you provide us in relation to your Account on the Services.
• Communications with Us. We may collect and store Personal Information from you such as your first and last name, email address, and the content of any message you send us when you choose to request information about our Services, request to receive customer or technical support, provide feedback about our products or Services, or otherwise communicate with us. 
• Surveys. We may contact you to participate in surveys, including during business or marketing events. If you do volunteer to participate, you may be asked to provide certain information which may include Personal Information and should only contribute information in your participation in our surveys that you provide voluntarily. 
• Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with Accounts and other devices.
3.1.2 Information Collected from Other Sources. We may receive information about you from other sources, including through third party services and organizations to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services. 
3.2 How we Use Your Information. We Process Personal Information about Individuals for a variety of business purposes, including: 
• To Provide Products, Services, or Information Requested, including to:
• Generally manage Individual information and Accounts;
• Respond to questions, comments, and other requests;
• Provide access to certain areas, functionalities, and features of our Services (for instance, in order to process your orders and deliver our products to you); 
• Integrate the Services with other services; and 
• Contact you to answer requests for customer support or technical support.
• For Administrative Purposes including to:
• Measure interest and engagement in our Services;
• Conduct research and development;
• Improve our products and Services;
• Develop new products and services;
• Ensure internal quality control;
• Verify Individual identity;
• Communicate with you about your Individual Accounts, activities on our Services and changes to any of our policies;
• Process your financial information and other payment methods for products or Services purchased;
• Prevent potentially prohibited or illegal activities; and
• Enforce our Agreement. 

To Market Our Products and Services. We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest to you, including new content or services. We may provide you with these materials by email or other mechanisms as permitted by applicable law. Such uses include:
• To tailor content, advertisements, and offers;
• To notify you about offers, products, and services that may be of interest to you;
• To provide services to you and our sponsors;
• Other purposes you consent to or are disclosed to you when you provide Personal Information. 
• You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described below. 
• De-Identified and Aggregated Information Use. We may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. De-identified or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information with third parties for our or their purposes in an anonymized or aggregated form designed to prevent anyone from identifying you. 
• Other Uses. We may use Personal Information to pursue other interests to improve our services, such as direct marketing, research (including marketing research), network and information security, fraud prevention, or other purposes disclosed to you at the time you provide Personal Information or with your consent.

3.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
We, as well as third parties that provide content, advertising, or other functionalities on the Services, may use cookies, pixel tags, local storage, and other technologies (collectively, the “Technologies”) to automatically collect information through the Services. The Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our Services.
• Analytics Service Providers. We may use analytics service providers to collect information regarding Individual behavior, Individual demographics, and how Individuals engage with our Services. We use this information to help determine how to improve our Services, gauge user experience and respond to changes in our Services, to develop content, and for internal research purposes. The analytics service providers we use include: 
◦ Google Analytics. We may use Google Analytics, a service provided by Google Inc., to gather information about how users engage with our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
◦ Double Click. For more information about Double Click, please visit https://www.google.com/intl/en_us/doubleclick/platform/terms.html. For more information on turning off Google ad personalization, go to https://support.google.com/ads/answer/7395996.
◦ Facebook Connect and Facebook Custom Audience. For more information on Facebook Custom Audience, please visit https://www.facebook.com/help/405977429438260and https://www.facebook.com/business/help/341425252616329. Information about opting out of Facebook Custom Audience is provided at https://www.facebook.com/business/help/1415256572060999. To opt out from Facebook Connect, please visit http://www.aboutads.info/choicesand http://www.youronlinechoices.eu/.
◦ Our uses of such Technologies fall into the following general categories:
◦ Operationally Necessary. This includes Technologies that allow you access to our Services that are required to identify irregular Services behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions such as shopping-carts or similar functions;
◦ Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our Individuals use the Services;
◦ Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
◦ Advertising or Targeting Related. We may use Technologies, including third-party Technologies, to deliver content, including ads relevant to your interests, on our Services or on third party sites.

4. Third Party Websites, Social Media Platforms, and Software Development Kits
Our Services, including certain journals and newsletters published in our Services, may reference or link to other websites. In addition, other websites may reference or link to our Services. These other domains and websites are not controlled by us. By visiting such websites, you assume the risk that the Personal Information provided by you may be viewed and used by Third Parties for any number of purposes. In addition, our Services may also contain links to various social media platforms. If you already use these social media platforms, their cookies may be set on your computer or device when using the Services. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications.
We may use third party software development kits (“SDKs”) or application program interfaces (“APIs”) as part of the functionality of our Services. APIs and SDKs may allow third parties, including advertisers, to collect your Personal Information to provide content that is more relevant to you. We use the following SDKs [  ]. For more information about our use of SDKs and APIs, please contact us as set forth below.  

5. Onward Transfer – We May Disclose Your Information
Information We Share. We may share your information as described in this Privacy Policy (e.g., with our third-party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission. 
We Use Vendors and Service Providers. We may share information we receive from you with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Services.
Business Partners. We may share Personal Information with our business partners or affiliates with whom we jointly offer products or Services or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear along with ours. We require our affiliates and business partners to agree in writing to maintain the confidentiality of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which we provided them. 
Marketing – Interest-Based Advertising and Third-Party Marketing.  Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities (e.g., your IP address, page(s) visited, location, time of day). We may also combine and share such information as well as selected Personal Information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with third party advertising partners, please see Section 7.4 below on how you may opt out of such sharing at no cost by. 
Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures).We may access, preserve, and disclose your Personal Information, other Account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) enforce our policies or contracts; (v) collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we believe that disclosure of your Personal Information is otherwise necessary or advisable.
Merger Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. 

6. International Data Transfers. You agree that all Personal Information collected via or by us may be transferred, Processed, and stored anywhere in the world, including but not limited to the United States and the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers in order to provide the Services. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request.

7. Opt-Out (Right to Object to Processing)
7.1 General: You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to our Processing of your Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting us as described below. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Services and/or information from the advertisements on third party websites for other legal purposes as described above. 
7.2  Email and Telephone Communications: If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails.  We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding us and our Services and you will not be able to opt out of those communications (e.g., communications regarding the Services, including regarding your orders and subscriptions through the Services, or updates to the Agreement or this Privacy Policy).
7.3 “Do Not Track”: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
7.4 Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your browser by removing them or by adjusting your preferences as your browser permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. 
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes. 
Even if you opt out, we may still collect and use information regarding your activities in connection with your use of the Services (through the Site or otherwise) and/or information from the advertisements on third party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements. 
7.5 Rights of Access, Rectification, Erasure, and Restriction. If you are located in the European Economic Area, in accordance with applicable law, you may have the right to: (i) request confirmation of whether we are Processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly Processed Personal Information; and (vi) request erasure of Personal Information held about you by Ikenga Wines, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.  
We will Process such requests in accordance with applicable laws. To protect your privacy, Ikenga Wines will take steps to verify your identity before fulfilling your request.

8. Data Retention. We retain the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, to provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. 

9. Security of Your Information. We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.
By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services or sending an e-mail to you. You may have a legal right to receive this notice in writing.

10. Children’s Information. The Services are not available to persons under 21 (or, in some jurisdiction, such other age as required by local law), and we do not knowingly collect Personal Information from children. 

11. California Privacy Rights. California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Except as otherwise provided in this Privacy Policy, we do not share Personal Information with third parties for their own marketing purposes.

12. Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after we make the updated Privacy Policy available to you. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

13. Contact Us. If you would like to contact us about our privacy practices, or exercise any of your data subject rights, please send a written request to us at info@ikengawines.com

14. Definitions.
• “Personal Information” is any information relating to an identified or identifiable natural person.
• “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
• “Cookies” Cookies are small text files placed in Individual’s devices to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, some features of the Services may not work properly. 
• “Pixel Tags” or “Web Beacons” A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on the Site. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.