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Your Privacy is Important to Us

Wine Sense is a retail operation. In this Privacy Statement the terms “we” and “our” refer to Swanston Management Inc. operating as Wine Sense, including all head office and locations. This Privacy Statement explains our practices regarding personal information of our customers, prospective customers and other visitors to this website (the “Website”), as well as those who have transactions with us through telephone, Internet, faxes and other means of communications.

Wine Sense’s Commitment to Privacy

At Wine Sense, we are committed to respecting the privacy of our customers and our Website visitors. For that reason we have taken, and will continue to take, measures to help protect the privacy of personal information held by us.

This Privacy Statement provides you with details regarding: (1) how and why we collect personal information; (2) what we do with that information; (3) the steps that we take to help ensure that access to that information is secure; (4) how you can access personal information pertaining to you; and (5) who you should contact if you have questions and concerns about our policies or practices.

By accessing or using the Website, you consent to the terms of this Privacy Statement. If you do not consent to the collection, use and disclosure of your personal information in accordance with this Privacy Statement, do not access the Website or provide us with any personal information.

1. When we collect personal information

(a) Automatic collection

We may receive certain information automatically when you interact with our Website, emails and/or online advertising. This may include information such as the type of Internet browser or computer operating system you are using, your IP address, and the domain name of the website you just left.

Depending on your browser settings, we may store some information on your computer in the form of a “cookie” or similar tracking technologies. Cookies are small pieces of data that are stored on your computer to allow us to recognize your computer when you return to the Website. We may also use cookies to deliver content, or to save information (like a password so you do not have to renter it). At your option, you may turn off our cookies using the applicable features contained in your Internet browser; however, doing so may prevent you from making full use of some or all of the features of the Website.

(b) Information you provide to us

When you interact with Wine Sense, you may provide us with personal information including the following: Contact information (e.g. name, address, email, telephone number) and information about yourself (e.g. your position or job title) that we may use to respond to your inquiry, and to manage your purchase or service request if applicable; and

Financial information (including credit card information) to process and manage your purchase.

We may also collect information from you when you apply for employment with Wine Sense. We will only ask for the information necessary to process your application (e.g. your contact information and resume) and retain your information in accordance with our employee policies.

(c) Social Media

We may offer you the opportunity to engage with us through third-party social networking websites, plug-ins and applications. Through these platforms, you may allow us to access information associated with your social media account. We may use this information to confirm your identity and to personalize your experience on our Website.

2. How we use personal information

As part of our business operations, we collect and use certain personal information about our customers and prospective customers, including contact information such as name, address, email address and telephone number, in order to process your requests, provide you with customer services and to understand your needs so that we can serve you better. We use credit card information to process purchases and other payments. We may use demographic and profile data, combined with other publicly available information, to tailor online content according to your preferences. In addition, we may use your personal information for the following purposes:

To manage your customer status;

Facilitate participation in certain promotions and programs;

Inform you about opportunities to participate in additional programs and services;

To respond to your inquiries and, if you ask us to, forward your inquiries to a third party when resolving a customer service assistance case;

Managing and responding to service requests;

To process payment for your purchase request;

To meet regulatory or contractual requirements relating to the services and products provided to you; and

To help identify you when you visit the Website, to gather demographic information about users of our Website, and to improve our online offerings and Website administration.

3. When we share personal information

At the request of a customer and with their consent we may connect customers with specific third party providers as part of customer service programs that we offer. In these circumstances, the personal information that the third party receives is limited to only the information held by us that they need in order to render their services to us and/or to facilitate your participation in the program.

In addition, will disclose personal information:

If a law, regulation, search warrant, subpoena or court order legally authorizes us or requires us to do so;

As necessary to our service providers that help us with our business operations;

If necessary to protect the safety or security of users of the Website, to detect and prevent fraud or abusive behaviour, or when otherwise required or permitted by law to protect our rights and those of our customers;

In the event that we sell, transfer or otherwise dispose of the business to an affiliate, successor, assign or other third party entity; or

With your consent (for example, we may seek your consent to allow us to share your contact information with a specific partner with offers we think would be of value to you, see above).

Except as set out above, we do not sell, rent, share or disclose the personal information we hold or make our customership list available to others without your consent. Our contractors and third party service providers are contractually obligated to maintain privacy policies and data security measures that are no less stringent than our own.

4. How long do we hold personal information?

Personal information is retained only for so long as is necessary for the purpose set out above. When no longer required, we will destroy, erase or de-personalize the information. Legal requirements may necessitate our retaining some or all of the personal information we hold for a period of time that is longer than we might otherwise hold it.

5. Accuracy

To ensure that the personal information you provided is accurate, complete and up to date, we urge you to provide us with updates regarding such information and to inform us of any errors affecting the personal information that we hold.

6. Security Measures

We maintain technological, organizational and physical safeguards in an effort to protect the personal information held by us from unauthorized use, access, disclosure, distribution, loss or alteration. Access to personal information will be restricted to our authorized personnel who require the information in order to perform their duties properly. In addition, access will be limited to only that information that is strictly necessary for the performance of those duties. The same limitations are imposed upon our third party service providers.

7. Accessing personal information

Our customers are entitled to access the personal information held by us concerning them. You can access your personal information by making a written request to us. We will generally respond to your request for information within thirty days, unless, for reasons beyond our control, a longer response time is necessary, in which case, you will be advised accordingly.

8. Inquiries or Complaints

If you wish to submit comments concerning this Privacy Statement or its application by us, we invite you to convey your concerns or suggestions to: Wine Sense, 2609 Portage Avenue, Winnipeg, Manitoba Canada R3J 0P6, Attention: Privacy Officer. We will reply as quickly as possible and inform you of the steps, if any, that have been or will be taken in order to address the concern or implement the suggestion. You may also file a complaint with a competent provincial Privacy Commissioner or the Office of the Privacy Commissioner of Canada at Toll-free: 1-800-282-1376.

9. Wine Sense emails

As a customer, with your consent, you will receive email communications from us to advise you of promotions, products, programs and services that we offer. If you wish to opt out of receiving future promotional emails from us, you may do so by contacting us directly at info@mywinesene.com or by clicking the unsubscribe mechanism attached to our emails. Please allow us up to ten business days for us to process your request. Note that if you unsubscribe from certain of our emails, we may still contact you by email about your customership, or as otherwise permitted by law.

With your consent, we may also provide your contact information to specific partners to contact you via email or telephone with offers that we think will be of value to you.

10. Third Party Links

Our Website may contain links to external websites. This Privacy Statement only applies to personal information that we collect and use on or through the Website. We are not responsible or liable for the content or activities of any linked websites, or for the privacy practices of third parties. We strongly recommend that you review a third party’s privacy policy before disclosing any personal information to the third party. Nonetheless, we seek to protect the integrity of our Website and welcome any feedback you may have about third party websites that are linked through our Website.

11. Modifications to this policy

We reserve the right to change this Privacy Statement at any time. We will alert you that changes have been made by indicating at the top of the Privacy Statement the date that it was last updated. We encourage you to review our Privacy Statement to make sure that you understand how information that you provide will be used. Any changes that are made to this Privacy Statement will apply to both any personal information that we hold prior to the effective date of the amended Privacy Statement and any personal information that we collect on or after such effective date.