PRIVACY policy
Last modified: January, 2014

Introduction
This website, forefrontwines.com (our “Website”) is operated by a member of the Crimson Wine group of companies, the ultimate holding company of which is Crimson Wine Group, Ltd., a Delaware corporation. All references to “our”, “us”, “we” or “Company” within this Privacy Policy are deemed to refer to Crimson Wine Group, Ltd., its subsidiaries, affiliates and/or associates, as appropriate.

We endeavor to protect your personal privacy. We provide this Privacy Policy to help you to understand the types of information we may collect from you or that you may provide when you visit the Website and our practices for collecting, using, maintaining, protecting and disclosing that information. By providing your personal information to us, you signify your acceptance of this Privacy Policy and agree that we may collect, use and disclose your personal information as described herein. If you do not agree to this Privacy Policy, please do not provide your personal details to us. This Privacy Policy is incorporated into, and is part of, the Terms of Use, that govern your use of the Website in general. We will use your information only for the purposes set forth below.

We may need to update this Privacy Policy from time to time. We recommend that you check this page regularly to ensure that you have read the most recent version. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

Legal Purchase Age
You must not provide us with your personal information if you are not of legal age to purchase alcohol in the jurisdiction in which you reside and (if different) in the jurisdiction in which you are accessing the Website. We do not intend to collect personal information from any individuals under the legal purchase age, or to market alcoholic beverages to anyone under the legal purchase age. If you are under the legal purchase age, do not use or provide any information on this Website or on or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use.

If we receive notice or believe that someone under the legal purchase age has provided us with personal information we will make every reasonable effort to remove such personal information from our files, or to flag such personal information and (to the extent permitted by law) retain it for the sole purpose of ensuring that it is no longer used. If you believe we might have any information from or about an individual under the legal purchase age, please contact us by email.

Information We Collect About You and How We Collect It
We collect several types of information from, and about, users of our Website, including information:
  • By which you may be personally identified, such as name, postal address, e-mail address or telephone number (“personal information”).That is about you but individually does not identify you.
  • About your internet connection, the equipment you use to access our Website and usage details.

  • We collect this information:
  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses and information collected through cookies and other tracking technologies.
  • From third parties, for example, our business partners.

  • Information You Provide to Us
    The information we collect on or through our Website may include:
  • Information that you provide by filling in forms on our Website. This may include information provided at the time of registering to use our Website, subscribing to our wine groups or clubs, contacting us with an inquiry, making a purchase, posting material or requesting further services or information. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
  • Records and copies of your correspondence (including e-mail addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

  • You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties, including but not limited to chat rooms, bulletin boards, blogs, discussion groups, etc. (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your User Contributions and such User Contributions may result in unsolicited messages or other contact from others. Personal information posted in such User Contributions are not covered under this Privacy Policy. See the Terms of Use for additional information pertaining to User Contributions.

    Usage Details, IP Addresses, Cookies and Other Technologies
    As you navigate through and interact with our Website, we may automatically collect certain information about your equipment, browsing actions and patterns, including:
  • Details of your visits to our Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website.
  • Information about your computer and Internet connection, including your IP address, operating system and browser type.
  • The information we collect automatically is statistical data. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:
  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.
  • The technologies we use for this automatic data collection may include:
  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
  • Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

  • You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our Website if cookies are disabled. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

    There are a number of ways to manage cookies. Please refer to your browser instructions or help screen to learn more about these functions. For example, in Internet Explorer, you can go to the Tools/Internet options/Security and Privacy Tabs to adapt the browser to your expectations. If you use different computers in different locations you will need to ensure that each browser is adjusted to suit your cookie preferences.

    Some modern browsers have a feature that will analyze website privacy policies and allow a user to control their privacy needs. These are known as “P3P” features (Privacy Preferences Platform).

    You can easily delete any cookies that have been installed in the cookie folder of your browser. For example, if you are using Microsoft Windows Explorer:
    open “Windows Explorer”
    click on the “Search” button on the tool bar
    type “cookie” into the search box for “Folders and Files”
    select “My Computer” in the “Look In” box
    click “Search Now” Double click on the folders that are found
    “Select” any cookie file
    hit the “Delete” button on your keyboard

    If you are not using Microsoft Windows Explorer, then you should select “cookies” in the ‘Help’ function for information on where to find your cookie folder.

    How We Use Your Information
    We may use personal information collected from you to provide specific services that you request, as well as to provide additional services that may be of interest. For example, we may use your personal information in the following ways:
  • To present our Website and its contents to you.
  • To provide you with information, products or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account/subscription.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • To allow you to participate in interactive features on our Website.
  • For internal marketing analysis.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

  • We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please send an email stating such to our Website administrator here.

    We may use the information we have collected from you to enable us to display advertisements to the target audiences of our advertisers, if any. Even though we would not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

    Disclosure of Your Information
    We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

    We may disclose personal information that we collect or you provide as described in this Privacy Policy:
  • To our subsidiaries and affiliates.
  • To contractors, service providers and other third parties we use to support our business (such as warehousing and delivery; marketing and advertising; credit card and data processing; age verification; software development; website hosting and management; information technology and office services; legal, accounting, audit and other professional service providers; and other services related to our business), provided such service providers and subcontractors do not collect, use or disclose the personal information for any purpose other than to perform such functions on our behalf, to provide services to us, or as otherwise required by law.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To third parties who, in our reasonable judgment, are providing or seeking the information as your authorized or appointed legal agent.
  • To carefully selected third parties, including our affiliates, to send you third party marketing and promotional information that may be of interest. In such circumstances these organizations may be bound by confidentiality obligations and restrictions on the use of your personal information. We will obtain your express permission before we allow a third party that is not an affiliate to send you any such marketing and promotional information.
  • We may also disclose your personal information:
  • To comply with any court order, law or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others.

  • Unsubscribe, Access, Questions and Further Information
    At your request and where the law requires us to do so, if you contact us using the unsubscribe details provided below we will confirm what personal information we hold about you, update your information, remove your information, fulfill specific opt-out requests (including requests where you previously opted in with respect to the use of your personal information), and/or correct any inaccuracies in such personal information.

    If you would like to unsubscribe from the Company’s communications or from all communications about the Company’s brands, please contact: Crimson Wine Group, Ltd., Attention: ForeFront Website, 2700 Napa Valley Corporate Drive, Suite B, Napa, California 94558, call 707.260.0538 or email.

    California Privacy Rights
    California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email or write us at: Crimson Wine Group, Ltd., Attention: ForeFront Website, 2700 Napa Valley Corporate Drive, Suite B, Napa, California 94558.

    Portfolio Permissions
    If you have given permission to receive communications about the Company brands generally (for example, by opting to receive news and special offers by email about the Company’s other great wine labels and brands), you may from time to time receive communications about brands to which you have not opted in specifically. Information about many of the Company’s brands can be found on the Crimson Wine Group website.

    We occasionally may send you communications about brands not featured on the Website (e.g., new brands). We recommend that you refer to the Website from time to time as the list of featured brands will be updated periodically.

    Providing general permission for us to communicate with you about our brands does not mean that you will receive communications about all of the Company’s brands. We will only communicate with you about those brands that we think may be of particular interest to you. Any such communications will provide you with an opportunity to unsubscribe from the brand in question and/or from all communications about the Company brands.

    Interfaces with Third-Party Websites
    Our Website may contain links, references, and content from other websites outside of our control. Please be aware that we have limited or no control over these websites and our Privacy Policy does not apply to these sites. We encourage you to read the privacy policy and terms and conditions of any linked, referenced, or interfacing websites you enter.

    We may contract with third party marketing companies to serve advertisements on our behalf across the Internet. They may collect non-personal information about your visits to our website, and your interaction with our products and services. They may also use non-personal information about your visits to this and other websites to target advertisements for goods and services. These targeted advertisements may appear on other websites that you visit. The anonymous information is collected through the use of technology such as Cookies and Web Beacons, which are industry standard. No Personally Identifiable Information (“PII”) is collected in this process.

    You may opt-out of the use of your information for tailored advertising purposes. To learn more about the use of this information or to choose not to have this information used by our third-party advertising partner by opting out, please visit the Network Advertising Initiative by clicking here. If you delete your Cookies, use a different browser, or buy a new computer, you will need to renew your opt-out choice.

    Other
    Nothing in this Privacy Policy or otherwise will create, or add to, any right or claim (whether legal, equitable, or otherwise) that any individual or person may have at law or otherwise against the Company or any third party, or any of their respective directors, officers, employees, agents, or representatives (collectively the “Crimson Wine Family”), nor will the existence of this Privacy Policy or its application impose or add to any obligations upon or create any liability for the Crimson Wine Family that it does not already otherwise have under law.

    Changes to Our Privacy Policy
    It is our policy to post any changes we make to the Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account and/or through a notice on the Website home page. The date the Private 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 e-mail address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

    Contact Information
    To ask questions or comment about this Privacy Policy and our privacy practices, email or contact us at Crimson Wine Group, Ltd., Attention: ForeFront Website, 2700 Napa Valley Corporate Drive, Suite B, Napa, California 94558 or 707.260.0330