Privacy Policy Banner
Last modified: April 2023

Summary

Betty David Infinity LLC d/b/a Walter on Wine (hereinafter “Walter on Wine”) is committed to protecting your personal information and being clear and transparent about what information we collect and how we will use it. This policy explains how any personal information we collect when you use our website or digital services, or that you provide to us, will be processed by us.
Please read the following policy carefully to understand our views and practices regarding your personal information and how we will treat it.

  1. Who we are and how we can be contacted
  2. Our websites covered by this privacy policy
  3. About our Privacy Department
  4. Other policies you should read
  5. Information we may collect from you
  6. Marketing Communication
  7. Information we collect about you from other places
  8. Sharing your personal information
  9. How long will personal information be kept by us
  10. Your rights under data protection legislation
  11. What you can do if you’re not happy with how we use your information
  12. About Data Security
  13. Changes to our Privacy Policy and Terms of Use

1. Who we are and how we can be contacted

Our full company name is Betty David Infinity LLC d/b/a Walter on Wine (hereinafter “Walter on Wine”), a Pennsylvania limited liability company. When you use our website and our services directly we act as a Data Controller.
If you need to contact us you have a number of options, you can:

  • email us at privacy@walteronwine.com
  • You can send us a letter addressed to the Privacy Department at 1151 E. Hector St., Unit #408, Conshohocken, PA  19428
  • You can also contact us using our contact form on our website here
  • You can also contact us by telephone on +215-221-2889

2. Our websites covered by this privacy policy

The information set out in this policy is applicable to the following websites:

  • walteronwine.com
    • Website available here and through the local extensions accessible from the home page
    • Mobile application available on market mobile applications stores

3. About our Privacy Department

We are committed to protecting and respecting your privacy. You can contact our Privacy Department by sending an email to privacy@walteronwine.com.

4. Other policies and information we encourage you to read

While this Privacy Policy contains all the information you need on how we collect and use your personal information on our websites, there is information in some other places which we encourage you to read.

  • Additional privacy policies

This is our main privacy policy for your use of website and digital services and products offered by Walter on Wine. However, there may be additional information in privacy policy for specific digital products and services. Please read these policies when you register or subscribe to these products and services.

  • Our Cookie Policy

When you use our website and other digital products and services provided by us, information can be collected through cookies to distinguish you from other users of our website and other digital products and services. We have a separate Cookie Policy which explains our use of cookies and the purposes for which we use them. We encourage you to read our Cookie Policy.

  • Linked platforms and linking to our site

Our site may contain links to and from our websites and digital platforms of our partner networks, advertisers, affiliates and social media pages. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.These third-party sites are not under our control, and you acknowledge that (whether or not such sites are affiliated in any way with Walter on Wine) Walter on Wine is not responsible for the accuracy, copyright compliance, legality, decency or any other aspect of the content of such sites.  The inclusion of such a link does not imply endorsement of any site by Walter on Wine or any association with its operators. 
You may link to any page of our site, but no framing is permitted.  Any link to our site must be immediately followed by notice to Walter on Wine. In the event we deem your linking practices in relation to our site to be inappropriate, we may provide you with notice concerning removal or modification of the inappropriate link, and you agree to comply with any and all requirements of Walter on Wine relating thereto.

5. Information we may collect from you

This section sets out:

  • How we collect your personal information;
  • The categories of data that we collect;
  • A description of how we plan to use the information we collect;
  • The legal basis that we will rely on to process information collected;
  • How long we will hold the information collected; and
  • Specific types of data

We may collect and hold the following information about you:

Marketing Data

If you request further information from us or our partners by signing up to receive any newsletters or marketing communications ("Marketing Data")

  • Purpose/Activity: Marketing Data is processed for the purposes of sending you the relevant notifications and/or newsletters and/or any marketing communication.
  • Type of Data: We will ask you for your name and email address so we can send you these information.
  • Lawful basis for processing: The legal basis for this processing is your consent.

Review Data

Information you provide to us when you complete a survey or respond to a questionnaire or submit a review or feedback of a product featured on our website ("Review Data").

  • Purpose/Activity: To collect information about a specific matter, for example, our services to you or reviews of a product you have tried. In many cases surveys, and questionnaires are anonymous and we only collect personal information for statistical data. If this is not the case, we will let you know at the time of collecting the information.
  • Type of Data: Information may include your full name, your email address and other personal data requested.
  • Lawful basis for processing: We will use our legitimate interests in the monitoring and improvement of our products and services to our customers and users as the legal basis for processing Review Data.

Communication Data

Information you provide us when you communicate with us, e.g. by email or contact us form via our website ("Communication Data").

  • Purpose/Activity: This information is used to enable us to respond to or following up on your comments, queries or questions.
  • Type of Data: Information may include your full name, your email address and other personal data you provide us to enable us to deal with your communication.
  • Lawful basis for processing: We will use our legitimate interests in the assisting you and answering your communications as the legal basis for processing Communication Data.

Voluntary Information

When you provide us information (for example, the information set out in the scenarios above), in some cases we may ask you for additional, voluntary information. This information will be identified as optional and is used to help us better understand our customers and tailor our services to them.

Statistical Information

We also collect and use aggregated data such as statistical or demographic data ("Aggregated Data"). Aggregated Data may be derived from your personal information but does not reveal your identity in any way. For example, we may aggregate your Usage and Device Data to calculate the percentage of our website users accessing a specific feature of our website. Aggregated Data is used for our own business purposes only.

Sensitive Personal Information

While we do not request sensitive personal data, we do have sections on our websites where you can submit additional information, for example, when you submit a review. If you submit information on these free text section, only submit information you are comfortable providing and always bear in mind that it may be sensitive information. If you submit reviews or feedback for our website, please remember that this information will be visible to others users of our website.

Children and Personal Information

This website is not intended for use by children and we do not knowingly collect data relating to children. If we become aware that we are holding any information about children under the age of 18, we will take any actions necessary to comply with data protection legislation, including if appropriate, deleting the information. If you become aware that your child (under 18) has provided their personal information to us, without your consent, please let us know as soon as possible by emailing privacy@walteronwine.com    so that we can take appropriate action.

6. Marketing Communications

You may receive marketing communications or newsletters from us only (i) if you wish it, (ii) if you are one of our customers, provided that this communication will concern similar products or services.
In this context, we will use the information you provide us, usually just your name and email address.
In any case, you can unsubscribe or make stop direct marketing from us at any time either

  1. by clicking on the unsubscribe option at the bottom of each marketing communication we send to you; and
  2. by contacting us by email or letter using any of the contact details set out in this notice.

We will generally send you marketing communications until you choose to unsubscribe from receiving them. If you do so, there’s nothing stopping you for subscribing again at any time.

7. Information we collect about you from other places

To enable us to provide you with our services, we may receive information from other sources including:

Location Data

We may collect your location data ("Location Data").

  • Purpose/Activity: This data is used by us to provide our location-based services (research of nearby restaurant).
  • Type of Data: IP Address Information from the GPS functionality of your mobile device.
  • Lawful basis for processing: The legal basis for this processing is your consent.

Usage and Device Data

We may collect information from our web servers’ logs ("Usage and Device Data").

  • Purpose/Activity: This information is used by us for system administration and to analyze how people are using our websites and digital platforms. It also helps us to provide the best online infrastructure for your online activities.
    From time to time we may also use your Usage and Device Data to make online suggestions and recommendations to you about goods or services that may be of interest to you.
  • Type of Data: Information may include your connexion log, IP address, operating system and browser type, language preferences.
    We may also collect information on the searches you carry out on our website and your interaction with communications we send you, for example, when you open email communications.
  • Lawful basis for processing: The legal basis for this processing is our legitimate interests, namely monitoring, improving our website, products and services and growing our business.
  • Retention Period: 1 year.

Behavioral Data

We and our business partners collect information using cookies or other similar technologies stored on your device ("Behavioral Data")

  • Purpose/Activity: This information is used to analyze how you use our website, digital products and services. They help us to improve our websites, deliver a better and more personalized service to you, display relevant advertising.
    We may match your Behavioral Data with your Marketing Data to send you personalized notifications and/or newsletters.
  • Type of Data: Cookies contain information that is transferred to your computer's hard drive. Information may include your display and search preferences, your search history, your location, the way you are surfing on /using our websites, products or newsletters such as mouse move, display duration and clicks) and your interests.
  • Lawful basis for processing: The legal basis for this processing is your consent or, where relevant, our legitimate interests, namely monitoring and improving our website, products and services.

8. Sharing your personal information

We only share your personal data with people who have a need to know such information to perform their responsibilities. We may share your personal information with the following:

  • Service Providers –Walter on Wine may share your personal data with its contractors to process your request or provide the services. These contractors act as data processors on our behalf and provide IT and system administration services, such as hosting and email and SMS services.For example, we must release your credit card information to the card-issuing bank to confirm payment for products and services purchased on this site; release your address information to the delivery service to deliver products that you ordered; and provide order information to third parties that help us provide customer service.

These service providers are legally obligated to keep the personal information they may have received confidential and secure and to use your personal information the basis of our instructions only.We will encourage our service partners to adopt and post privacy policies. However, the use of your personal data by our service partners is governed by the privacy policies of those service partners, and is not subject to our control.

We may also share your personal information with third parties:

  1. For legal reasons

Occasionally we may be required by law enforcement or judicial authorities to provide personal data to the appropriate governmental authorities. We will disclose Personally Identifiable Information upon receipt of a court order, subpoena, or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements; or to protect the rights, property, or safety of Walter on Wine, our customers, or others. In this context, we may disclose your personal information to our professional advisors who are under a duty of confidentiality.

  1. On the basis of your consent

Third parties can collect information about you on our website, products or services via cookies or similar technologies, in order for example to provide personalized ads or to make profiling. These cookies will be accepted by you in accordance with our Cookie Policy. You can read it here.

If you consented to receive offers from our partners, we can also transfer your Marketing Data to third parties, in order to send you newsletters and marketing communications as mentioned above (section 7).

Finally. you should also be aware that when Personally Identifiable Information is voluntarily disclosed (i.e. your name, email address, etc.) in the discussion forums or other public areas on this site, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this Policy does not apply to such information. Any submissions to chat rooms or other public areas on this site are accepted with the understanding that they are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information. Please be careful and responsible whenever you're online.

9. How long will personal information be kept by us?

As a rule, we will not hold your personal information for any purpose or purposes for longer than is necessary to fulfil the purposes we collect 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.

In some circumstances you can ask us to delete your data: see your right to be deleted 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. Your rights under data protection legislation

Data protection legislation provides you with certain rights when it comes to the processing of your information. These are the right to:

The right to be informed

You have the right to be informed about how we collect and process your personal information, including who we are, how we use your personal information and your rights in relation to your personal information. We have gathered all the information you need in this Privacy Policy, in our Cookie Policy and in our Subscription Agreement.

The right of access your information

You have the right to access the personal information we have on you. We can confirm whether or not your information is being processed and provide you with access to your personal information.

The right to correct your information

If your personal information is inaccurate or incomplete, you are entitled to have that information corrected and updated. If we have disclosed your information to any third parties, where possible, we will inform them of any updates you provide to us. You can update the personal information we hold about you by contacting us using any of the contact methods details in this Privacy Policy.

The right to delete your information

You have the right to request the deletion or removal of your personal information where there is no reason for us to continue to process it. The circumstances in which you can request the right to be forgotten includes, where the information is no longer necessary in relation to the purpose for which it was originally collected or processed and where you have withdrawn your consent to processing.

There are some limited circumstance where the right to be forgotten does not apply – if you want to know, just ask.

Please note that we may not be able to delete information associated with past transactions on the site. In addition, it may be impossible to completely delete your information without some residual information because of backups.

The right to restrict processing

You also have the right to ‘block’ or suppress the processing of your personal information. If you request us to suppress your personal information, we will stop any further processing of it.

The right to data portability (transfer your information)

If you want to move or transfer your personal information to a different service provider or copy your information for your own purposes, you have the right to have your information transferred to another person.

The right to object

You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your information.

You can also exercise the right at any time by contacting us at privacy@walteronwine.com

11. What can you do if you’re not happy

We are committed to protecting and respecting your privacy. However, if you’re not happy with how we collect or process your information or just want some further information on your rights, you can contact us in the following ways:

  • Email us at privacy@walteronwine.com
  • You can send us a letter addressed to the Privacy Department at 1151 Hector St., Unit #408, Conshohocken, PA  19428

You can also contact us using our contact form on our website here. We will work with you to resolve any issues you may have and aim to answer any question raised by you as soon as possible.

12. About Data Security

Wehave implemented industry standard measures to protect the privacy, security and integrity of your personal data. Access to personal data is restricted to those employees and service providers who need to know this information and who have been trained to comply with rules on confidentiality.

On Walter on Wine’s commercial sites, if any, subscribers' banking information will be collected by an authorized payment service providers and distribution institutions.for the purposes of effective, legal secure payment processes. These measures may consist of SSL encryption (intended to make the data unreadable to others) during the collection or transfer of confidential data. Said information will be used only for purposes of online payment and will not be retained.

Walter on Wine makes commercial reasonable efforts to ensure that your personal data are not altered, damaged or accessed by unauthorized third parties.

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through this site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.

13. Changes to our Privacy Policy and Terms of Use

We may change our policy from time to time. Any changes we make to this policy in the future will be posted on this page. If you have an online account with us, we may notify you of any changes by email.

This Privacy Policy, our Cookie Policy, and Subscription Agreement referenced herein constitute the complete agreement between you and Walter on Wine with respect to their subject matter and supersede any prior agreement or communications. Your continued use of this site subsequent to our posting of these terms shall constitute your acceptance of the modified terms.  If any term or provision of these terms shall be found to be invalid, illegal or otherwise unenforceable, such finding shall not affect the other terms or provisions of these terms or the whole of these terms, but such term or provision shall be deemed modified to the extent necessary to render such term or provision enforceable, and the rights and obligations of you and Walter on Wine shall be construed and enforced accordingly, preserving to the fullest permissible extent the intent and agreements set forth in these terms.  Your obligations pursuant to these terms shall survive termination of this site, any use by you of this site, any user content on this site or these site terms.

Please enjoy responsibly.

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