PRIVACY POLICY Strade Bianche Wines, LLC and our subsidiaries and affiliates ("Strade Bianche Wines" or "we") respect your preferences concerning the treatment of personal information that we may collect from your use of the Strade Bianche Wines Web sites and your interactions with Strade Bianche Wines off-line. This policy lets you know how we collect and use your personal information, and how you can control its use. This policy describes the broadest potential use of personal information throughout the Strade Bianche Wines Web sites and in off-line transactions; however, we may make far less use of your personal information. The Strade Bianche Wines Web sites provide links to non-Strade Bianche Wines sites we believe may be of interest to you. Those sites are beyond our control. You are advised to check the privacy policies and terms of use of any non-Strade Bianche Wines sites before providing your personal information to them. TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT Personal Information: This policy covers the following personal information that Strade Bianche Wines collects through your use of the Strade Bianche Wines Web sites and in connection with off-line communications. Specifically, Strade Bianche Wines may collect this information from offline and online registrations and forms, communications and interactions, and sales inquiries and transactions. Strade Bianche Wines also may use third party sources, such as opt-in lists, as specified in Section 4 below. Contact information, such as name, physical address, telephone number(s), email address, and company. The majority of the information collected under this category is business contact information and when this information is collected in forms on our web site, it is collected and/or transmitted using Secure Socket Layer (SSL) technology. Transactional information, including information about the products and services you purchase or download or about which you make an inquiry. User preferences, such as product requirements, areas of industry interest, newsletters, and other information you select in the customer profile when registering on Strade Bianche Wines or indicated by your use of the Strade Bianche Wines Web sites. Financial/credit card and payment information. Event and conference participation information, such as lectures, classes or booths attended or visited during an event or conference hosted or attended by Strade Bianche Wines. If we use electronic tracking technologies at an event, we will provide notice in the event registration materials and/or correspondence. We may supplement information you provide with information received from third parties. Electronic Communications Protocols and Cookies: In addition to the information specified above, Strade Bianche Wines may collect information about your use of the Strade Bianche Wines Web sites through electronic communications protocols and cookies. As is true when you visit most Web sites, Strade Bianche Wines may automatically receive information from you as part of the communication connection itself, which often consists of network routing information (where you came from), equipment information (browser type), your IP address, and date and time. Strade Bianche Wines also uses cookies, embedded URLs and embedded pixels to capture additional information. Cookies: Strade Bianche Wines server will query your browser to see if there are "cookies" previously set by the Strade Bianche Wines Web sites. A cookie is a small piece of information sent by a Web server to store on a Web browser so it can later be read back from that browser. Cookies on the Web sites may collect a unique identifier, user preferences and profile information and membership information. Strade Bianche Wines also uses cookies to collect general usage and volume statistical information that does not include personally identifiable information. Some cookies may remain on the user's computer after they leave the Web site, and the majority are set to expire within 30 – 365 days. While we do not offer an opt- out for cookies, browsers provide you information and control over cookies. You can set your browser to alert you when a cookie is being used, and accept or reject the cookie. You can also set your browser to refuse all cookies or accept only cookies returned to the originating servers. Users can generally disable the cookie feature on their browser without affecting their ability to use the site, except in some cases where cookies are used as an essential security feature necessary for transaction completion. Embedded URLs: Strade Bianche Wines also uses a tracking technique that employs embedded URLs to allow use of the site without cookies. Embedded URLs allow limited information to follow you as you navigate the site, but is not associated with personal information and is not used beyond the session. Embedded Pixels: On the Web site, Strade Bianche Wines may use embedded pixel technologies on selected pages for the purposes of identifying unique user visits to the Strade Bianche Wines Web sites as opposed to aggregate hits. In addition, embedded pixels or other technologies may be used in emails to provide information on when the email was opened to track marketing campaign responsiveness; information collected using these technologies may be associated with the recipient's email address. Third Party Cookies: Strade Bianche Wines may engage one or more third party service providers to track and analyze usage and volume statistical information from visitors to the Web site. The service provider(s) set cookies on behalf of Strade Bianche Wines. Strade Bianche Wines also uses other third party cookies to track the performance of Strade Bianche Wines advertisements on their Web sites. Strade Bianche Wines may re-associate the information provided by the technologies directly above with personal information. Widgets: Our Web site includes Widgets, which are interactive mini-programs that run on our site to provide specific services from another company (e.g., links to bookmarked sites). Personal information, such as your email address, may be collected through the Widget. Cookies may also be set by the Widget to enable it to function properly. Information collected by this Widget is governed by the privacy policy of the company that created it. USE AND SHARING OF PERSONAL INFORMATION Strade Bianche Wines uses (and, where specified, shares) your personal information for the following purposes: To engage in transactions. Strade Bianche Wines may use personal information such as name, physical address, telephone number, email address, and company to engage in transactions with you, including contacting you about your order. To process transactions. Strade Bianche Wines may use financial/credit card and payment information to process your order. Strade Bianche Wines may need to share some of this information with delivery services, credit card clearing houses and other third parties to complete the transaction. To provide support or other services. Strade Bianche Wines may use your personal information to provide you support or other services you have ordered, as well as product updates, product patches and fixes and other similar communications. To tailor marketing to your needs and respond to your requests. Strade Bianche Wines may use your personal information to notify you about new product releases and service developments. Strade Bianche Wines also may use your personal information to respond directly to your requests for information, including registrations for newsletters or other specific requests, or pass your contact information to the appropriate Strade Bianche Wines distributor or reseller for further follow-up related to your interests. In addition, if you consent, Strade Bianche Wines may share your contact information with other selected partners that offer complementary products or services. Please review the specific partner's privacy policy regarding any further interactions with them. To provide online forums and social networks. Some services available on the Web sites permit you to participate in interactive discussions, post comments, opportunities or other content to a bulletin board or exchange, or otherwise engage in networking activities. Some of these services are moderated; all may be accessed for technical reasons. Strade Bianche Wines does not control the content that users post to these forums or social networks. You should carefully consider whether you wish to submit personal information to these forums or social networks and should tailor any content you submit appropriately and in accordance with the relevant terms of use. In addition, you should review any additional terms and conditions that may govern your use of these services, including terms related to use, sharing your personal information and receiving communications; any such terms will be clearly identified on the relevant site. Social Media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing it. To post Testimonials. We post testimonials on our web site, which may contain personal information. Prior to posting the testimonial, we obtain the customer's consent to post their name along with their testimonial. To administer product downloads. Strade Bianche Wines may contact you if you download products to confirm certain information about your order (for example, that you did not experience problems in the download process), discuss the downloaded products or provide marketing or sales information about related products and services. Strade Bianche Wines also may use this information to confirm compliance with licensing and other terms of use and may share it with your company. To select content, improve quality and facilitate use of the Web Sites. Strade Bianche Wines may use your personal information, including the information gathered as a result of site navigation and electronic protocols and cookies (including third party cookies), to help create and personalize Web site content, facilitate your use of the Web sites (for example, to facilitate navigation and the login process, avoid duplicate data entry, enhance security, keep track of shopping cart additions and preserve order information between sessions), improve Web site quality, track marketing campaign responsiveness, and evaluate page response rates. To power joint sales or product promotions. Strade Bianche Wines and its partners may engage in joint sales or product promotions. Such promotions will always reference the partners involved. Both Strade Bianche Wines and the partner(s) will have access to that information, and either Gravel Road Wine sor our partners may provide you the sales or product promotion information. We recommend you review the privacy policies of these partners to address your particular needs and concerns. To contact a referral/"tell a friend". If you elect to use our referral service to inform a friend about our site, we will ask you for the friend's name and email address. Strade Bianche Wines will automatically send the friend a one-time email inviting them to visit the site. Strade Bianche Wines uses this personal information for the sole purpose of sending this one-time email and tracking the success of our referral program. The friend may contact Strade Bianche Wines at to be removed from the referral program. To communicate with you about a conference or event. We or our partners may communicate with you about a conference or event hosted or co-sponsored by Strade Bianche Wines or one of our partners. This may include information about the event's content, event logistics, payment, updates, and any additional meetings, special demonstrations or other customer facilitation that we may provide related to an event for which you have registered. Strade Bianche Wines may contact you after the event about the event and related products and services and may share information about your attendance with your company. Strade Bianche Wines also will permit designated partners or conference sponsors to send you up to two communications through the services of a third-party bonded warehouse. Please note that our partners or conference sponsors may directly request your personal information at their conference booths or presentations; providing your information is optional, and you should review their privacy policies to address your particular needs and concerns. To comply with legal requirements. Strade Bianche Wines may be required to disclose your personal information in order to comply with legally mandated reporting, disclosure or other legal process requirements. Strade Bianche Wines will use reasonable efforts to limit the personal information it provides for these purposes. Please note that your personal information may be transferred, accessed and stored globally as necessary for the uses stated above in accordance with this policy. While Strade Bianche Wines may share your personal information with agents and contractors in order to perform the functions listed above, including credit card clearing services, order fulfillment, and event, campaign and web site management, we require that they treat your personal information, and limit its use, in accordance with the standards specified in this policy. REGISTRATION, CUSTOMIZATION, PREFERENCES AND OPT-OUT Opting Out. Strade Bianche Wines enables you to opt out of marketing communications. You may opt out of email marketing by modifying your online profile as described above or by using our general unsubscribe automated link that is included in Strade Bianche Wines marketing emails. You can request to unsubscribe from email communications, as well as opt-out from phone and postal marketing by emailing indicate "opt-out" in the subject line, and specify what problem you have encountered in the body of the message. Some non-marketing communications are not subject to general opt-out, such as communications related to product download, sales transactions, software updates and other support related information, patches and fixes, quality assurance surveys, conferences or events for which you have registered, and disclosures to comply with legal requirements, as well as communications with partners, including product alerts, updates, marketing and sales materials and other notices related to partner status. Information-Sharing Choices. Strade Bianche Wines only shares personal information with selected companies after providing users the ability to either opt out of or opt into the sharing. There are limitations to opting out of such sharing in the case of (1) joint sale or joint events where the data goes to both Strade Bianche Wines and the other party at the same time; (2) where the customer has requested follow-up which involves Strade Bianche Wines partners; and (3) where third parties are required to accomplish the transaction or perform the service. Third Party Permission-Based Lists. On occasion, Strade Bianche Wines may use third-party lists to send communications about Strade Bianche Wines products and services. These lists, which may be maintained by third parties, include users eligible under applicable law to receive emails from other companies such as Strade Bianche Wines. When we use such lists, the communications will include mechanisms to opt out of Strade Bianche Wines marketing communications and the third party lists. If you have trouble opting out, or if you wish to make us aware of any issues related to a third-party mailing, you may contact us directly at bbarnett@gravelroadwines.com. WRITING REVIEWS AND COMMUNITY If you choose to Write a Review or post a profile on this Web site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums. To request removal of your personally identifiable information from our blog or community forum, contact us at bbarnett@gravelroadwines.com. In some cases, we may not be able to remove your personally identifiable information, in which case we will let you know if we are unable to do so and why. Members may create a Community profile which allows you to create, publish and share your wine reviews in a social setting. Here, members may be able to post their photo and bios along with their reviews. Members may access their Community account to update or delete their personally identifiable information and to change their privacy settings. To do this, simply log into the Community section and edit your profile. LINKS This web site contains links to other sites. Please be aware that Strade Bianche Wines is not responsible for the privacy practices of other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each site that collects personally identifiable information. This privacy statement applies solely to information collected by this Web site. EMAILS If a user wishes to subscribe to our emails we ask for contact information such as name and email address. We may use your personally identifiable for purposes other than sending you promotional materials. For example, we may use your information to complete transactions requested by you, or to send you administrative communications about any account you may have with us or about future changes to this Privacy Policy. You may also unsubscribe from promotional Emails by emailing us at ADVERTISING Strade Bianche Wines may use third parties to administer a limited set of Strade Bianche Wines advertisements on its Web sites. No personal information is provided to the advertisers as part of this process, but aggregate profile information may be used in the selection of advertising to make sure that it has relevance to the user. On some banner ads, an embedded pixel may be present, and while it does not associate with a cookie or other personal profile information, it may return session connection information that allows advertisers to better determine how many individual users have clicked on the ad banner. SURVEYS AND CONTESTS Our site requests information from users via surveys and contests. Participation in surveys and contests is voluntary and the user can choose to disclose information or not. Information requested may include contact information (such as name and shipping address), and demographic information (such as zip code and age level). Contact information will be used to notify the winners and award prizes. This information may be used for marketing opportunities by Strade Bianche Wines if authorized by the registrant, and will also be used for purposes of monitoring or improving the use and satisfaction of this site. SECURITY The security of your personal information is very important to Strade Bianche Wines. We have in place physical, administrative and technical safeguards designed to protect your personal information from unauthorized access. In addition, Strade Bianche Wines uses standard security protocols and mechanisms to exchange the transmission of sensitive data such as credit card details. When you enter sensitive information such as your credit card number on our site, we encrypt it using secure socket layer (SSL) technology. In the event that your personal information is acquired, or is reasonably believed to have been acquired, by an unauthorized person and applicable law requires notification, Strade Bianche Wines will notify you of the breach by email, fax, or U.S. mail. Strade Bianche Wines will give you notice promptly, consistent with the reasonable needs of law enforcement and/or Strade Bianche Wines to determine the scope of the breach and to investigate and restore the integrity of the data system. COMPLIANCE ISSUES If you believe your personal information has been used in a way that is not consistent with this policy or your specified preferences, or if you have further questions related to this policy, please contact us by email at bbarnett@gravelroadwines.com. SALE OF COMPANY In the event that another company acquires us or a significant portion of our assets is sold to another company, all customer data, including financial records and consumer information collected on gravelroadwines.com, may be transferred to the new company. You will be notified of any such change in ownership or control of your personally identifiable information via a posting of such acquisition on gravelroadwines.com or via email. POLICY UPDATES We may update this policy from time to time, so please review it frequently. We will post a prominent notice in this section of this policy notifying users when it is updated. If we are going to use your personal information in a manner different from that stated at the time of collection, we will notify you via email, and you will have a choice as to whether or not we use your personal information in this different manner. We appreciate your comments on Strade Bianche Wines privacy practices: Last Updated: July 17, 2019.