Last updated as of the 26th day of March, 2021

Although important, legal language can sometimes make your eyes cross. We recommend diving in after you pour yourself a glass of your favorite wine – it makes the reading process far more enjoyable.

Contents

Pix.wine Inc. (“Pix,” “we,” “us,” “our”) does not share the personal information of its website visitors (“you,” “your”) with any third parties except specifically in connection with performance of our or our successor’s services for you, as further detailed in Section 5 below. 

Pix respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website or use our platform or services (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are

1.1 Purpose of this privacy notice

This privacy notice aims to give you information on how Pix collects and processes your personal data through your use of this website, including any data you may provide through this website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

1.2 Controller

Pix is the controller and responsible for this website.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Pix.wine Inc.
Name of DPO: Michael McGregor
Email address: michael@pix.wine

Postal address: 1040 Main Street #300, Napa, CA 94559

You have the right to make a complaint at any time to your respective supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the relevant supervisory authority, so please contact us in the first instance.

1.3 Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

1.4 Third-party links

This website includes links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect from you

Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

2.1 Types of personal data we collect. We may collect, use, store and transfer different kinds of personal data about you that we have grouped together as follows:

  • Account Data includes your account identifier and account creation and modification dates, name, business name, e-mail address, website settings and other preferences you have indicated regarding your account. You and/or your employer are the primary source of the account data, although our website might generate some elements of the account data. If you log into our website using a social media account, then we will obtain elements of the account data from the relevant social media account provider.
  • Communication Data includes information contained in or relating to any communication that you send to us or that you receive from us, Pix Associates and/or other third parties as well as your communication preferences and any metadata associated with such communications. You and/or your employer are the primary source of this Communication Data.
  • Contact Data includes your name, e-mail address, telephone number, postal address and/or social media account identifiers. You and/or your employer are the primary source of the contact data. We will obtain elements of the contact data from the social media account providers in the event that you log into our website using a social media account.
  • Profile Data includes your username and password, your indicated interests, indicated preferences, feedback, information contained in or relating to any communication that you send to us or that we send to you. You and/or your employer are the primary source of this profile data.
  • Technical Data includes your internet protocol (IP) address, geographical location, browser type and version, operating system, time zone setting and location, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use of our website or services. Our analytics tracking system is the source of this technical data.  
  • Transaction Data includes your name, contact details, payment card (or other payment) details and your transaction details. You, the Pix Associates and/or our payment services provider are the primary sources of the transaction data.
  • Usage Data includes information about how you use our website, products and services. Our analytics tracking system is the source of this usage data.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data that will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2 If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

6. International transfers

We may share your personal data within our group of Internal Third Parties. To ensure that your personal data is protected when transferred to an Internal Third Party outside the EEA, a data transfer agreement has been put in place between Pix.wine Inc. and the Internal Third Party incorporating the EU’s standard contractual clauses. 

Furthermore, many of our External Third Parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data to External Third Parties based outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EEA. For further details, see European Commission: Model contracts for the transfer of personal data to third countries. 

Please contact us at privacy@pix.wine if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

3.1 Direct interactions. You may give us your identity and account data, contact data, communication data, profile data and transaction data by entering into an agreement, filling in forms or providing other information via our website. This includes personal data you provide when you:

  • enter into an online agreement;
  • request our services;
  • request marketing or other communications be sent to you; or
  • give us feedback.

3.2 Automated technologies or interactions. As you interact with our website, we may automatically collect technical data and usage data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Insofar as those cookies are not strictly necessary for the provision of our website or our services, we will ask you to consent to our use of cookies when you first visit our website. Please see our cookies policy  for further details.

3.3 Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in Section 4 above.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow External Third Parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. Data security

We have put in place appropriate security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at privacy@pix.wine.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. Changes to our privacy policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

11. Glossary

Comply with a legal or regulatory obligation means processing or using your personal data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.

Pix Associate means any individual, firm, company, corporation, government, state or agency of a state, or any association, trust, joint venture, consortium, partnership or other entity (whether or not having separate legal personality) that has an agreement with Pix to use or exchange data in connection with Pix’s platform and/or services. 

Pix Group means Pix.wine Inc. and those entities that control, are under common control with, or are controlled by Pix.wine Inc., as well as External Third Parties and those entities that perform services for Pix, such as hosting services, IT services, data analytics and related services.

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at privacy@pix.wine

Performance of contract means processing or using your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Third parties

Internal Third Parties means other companies in the Pix Group as well as Pix Associates acting as joint controllers or processors and who provide related services. 

External Third Parties means service providers acting as processors who provide hosting, IT and system administration services.