Effective date: March 2023

About this Privacy Policy

This brand website is owned by E. & J. Gallo Winery, Inc. ("we", "our", "us" or “Gallo”).

We created this Privacy Policy to inform you about how we collect, use and disclose personal data of residents of the United Kingdom (“UK”) and the European Economic Area (“EEA”) via this website in accordance with the United Kingdom’s General Data Protection Regulation (“UK GDPR”) and the European Union’s General Data Protection Regulation (“GDPR”). Although this website may include links or references to non-Gallo websites, pages, materials or entities, this Privacy Policy does not apply to those sites, materials or entities unless otherwise indicated.

You should read this entire Privacy Policy together with our Cookie Policy before submitting information to us through, or otherwise using, our website.

You must be over 18 to use ouR website

Given the nature of our business, our website is intended only for individuals who are of legal drinking age. As a result, our website does not request or knowingly collect personal data from individuals under the age of 18. If you are not of legal drinking age, you should not visit or use our website.

WHO IS THE DATA CONTROLLER AND HOW TO CONTACT US

E. & J. Gallo Winery, Inc. located at 600 Yosemite Boulevard, Modesto, CA 95354, United States, is the controller of any personal data collected or otherwise processed on or through this site. Our authorized representative in the UK is E. & J. Gallo Winery Europe Ltd., Harman House, 1 George Street, Uxbridge, Middlesex UB8 1QQ. Our authorized representative in the EU is E. & J. Gallo Winery (Deutschland) GmbH, Louisenstrasse 65, 61348 Bad Homburg, Germany.

If you have any questions about this Privacy Policy, or about the personal data we hold about you, you may contact us by writing to us or our authorized representative at either address above or by calling us in California on (country code 1) 800-750-8828, Monday through Friday from 8-5 Pacific Standard Time and Saturday from 9-3 Pacific Standard Time, or by emailing us at: DataPrivacy@ejgallo.com.

WHAT ARE THE PURPOSES AND LEGAL BASES FOR PROCESSING OF PERSONAL DATA COLLECTED THROUGH THIS WEBSITE?

We process your personal data in the following ways:

• to handle and respond to queries, questions, comments, or complaints you submit via the website;
• to contact you about other products or services which we think you may be interested in;
• to let you know about offers, discounts, coupons, promotions, competitions, prize draws, activities, events, or clubs that you have expressed an interest in;
• to respond to you when you choose to participate in our promotions, competitions, prize draws, activities, or events;
• to send you communications you have consented to receiving;
• for business purposes such as carrying out market research and analyzing how our customers use our websites in order to improve our websites, products and services;
• to update you when there are changes to this Privacy Policy;
• to comply with the law, protect our legal rights, or to comply with any regulatory authority requests;
• to keep track of your interactions with our websites and provide you with a more customized experience;
• for the purposes of fulfilling the legitimate interests listed below.

We rely on the following legal bases for processing your personal data:

• Necessity to enter into or perform a contract with you: where we need to process your personal data to enter into an agreement with you or a legal entity you represent, such as your registration for a prize draw, sweepstakes, competition or contest, to perform contractual obligations, to respond to questions or requests from you, or to provide customer support.
• Legitimate interests: where we process personal data from you:

• for the security and safety of the website, our IT connected to the website and the users of the website;
• to detect and prevent fraud;
• to protect and defend the rights or property of others, or our own rights and interests;
• to respond to your inquiry, including the information you provide to us;
• to keep track of your activities on the website, to tailor content and offers for you, and to improve our products and services, provided you have given consent for such activities. Please see our Cookie Policy for detailed information on our use of cookies on this site.

• Compliance with legal obligations: we may need to process your personal data to comply with relevant laws, regulatory requirements and to respond to lawful requests, court orders, and legal process.
• Your consent: in some cases we may need consent to process your personal data (i.e., to publish your photo or entry in regard to a contest) – in such cases, we will ask you to voluntarily provide consent before we process your personal information.

WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?

1. Personal data you submit to us via Contact Us or other forms on our website

On our website, you have the option to contact us to ask a question or provide feedback. You may also be able to register to receive information on our products or services, or enter into competitions, prize draws or other promotions that we offer from time to time. As part of an online fill-in form or registration process, we ask you to provide us with certain information (usually name, contact email address and phone number if you elect to be contacted by phone/text, address or postcode).  Providing such data is voluntary, but it may be necessary to fulfill the activity you requested on our site.

At the time of collection of such information, we indicate what is mandatory (usually at least your name and email address) and what is optional. Where required by law to confirm your eligibility to participate, interact with us, or purchase or use our alcoholic products, we will ask you to confirm your age or date or birth. Such data collection happens in the following circumstances:

• when you access our website, if we are required by law to confirm your age before granting such access;
• when you enter your location or when using our "where to buy" search function;
• when you register to receive communications from us;
• when you register to attend one of our events;
• when you indicate you would like us to send information about products you may be interested in;
• when you enter competitions, prize draws or other promotions;
• information you provide to us when you participate in surveys or market research;
• when you contact us with a query or complaint.

We will log and store the date/time of your submission.

1. Personal data we collect automatically

When you use our website, we receive and record certain technical information by using cookies or similar technologies such as tags or pixels. We use these technologies for the following purposes:

• To improve the performance of our websites by understanding which parts work well, and which don't.
• To enable us to collect information about how you and other people use our websites.
• To improve your experience on our websites and to personalise your experience.
• To measure how effective our online advertising and marketing communications are.
• To deliver relevant online advertising to you both on our websites and elsewhere.

You can control cookies being used on your device by using the One Trust Cookie Preference Center that is active on this site or by activating the setting on your browser that allows you to block the deployment of all or some Cookies. For more information about how we use cookies, please see our Cookie Policy which is available from the Cookie Preference Center or from the link on the bottom of this webpage.

1. Personal data which we collect from third parties

We may collect personal data about you from third parties, including websites operated by third parties which are affiliated with us (for example, microsites which promote our products or promotions and are linked to our website).

WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

We may share your personal data as follows:

• with third party processors we have engaged to carry out certain activities on our behalf. This includes companies we have engaged to help us with prize draws, promotions, advertising and marketing services, or vendors who help us process customer complaints or queries; and
• with government authorities, courts and others if the law requires us to, or if we think it is necessary to comply with the law or in order to protect or defend our legal rights, or those of others.

We may also anonymise your personal data, so that is no longer possible to identify you from it. If we do this, we may share it with third parties in anonymised form.

TRANSFERS OF YOUR PERSONAL DATA TO THE UNITED STATES

When you use our site, your personal data may be sent to and stored in the United States.

We may also send personal data to countries towards which an adequacy decision has been granted. Where this is not the case, and where required, we enter into data processing and data transfer agreements that incorporate the UK International Data Transfer Agreement (“IDTA”) and associated addendum and Standard Contractual Clauses (SCCs) approved by the EU Commission to ensure an adequate level of protection of your personal data. These IDTAs and SCCs include certain provisions which protect your personal information.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We retain your personal data for as long as we need to address your query, provide the services requested by you or otherwise facilitated by your use of our website, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. After this time, we can keep your data due to our legal obligations (e.g., a period of 6 years thereafter is required for archival, audit and legal purposes) and for the purposes of our legitimate interests, unless a longer retention period is required or permitted by law. Personal data of participants of prize draws, contests, competitions, sweepstakes, etc., is kept for as long as necessary to conduct the promotion and will be deleted after the deadline for complaints related to participation, extended by the reasonable time required for their delivery. In the case of winners or those who have submitted complaints, personal data will be retained until the expiry of statutory retention periods and statutes of limitation, such as applicable tax laws, for which data is retained for 6 years.

HOW DO WE PROTECT YOUR PERSONAL data?

We take appropriate steps to protect personal data from loss, misuse and unauthorized access, disclosure, alteration or destruction, whether in transmission or storage. Please keep in mind, however, that there is no such thing as perfect security, and no Internet transmission is ever completely secure or error-free.

It’s Your Choice: Contact Preferences

When submitting data on our website, you may need to explicitly declare your consent to our processing of your personal data for the stated purposes (e.g., receipt of marketing communications from us, etc.). You are under no obligation to provide such consent and, if you choose to give your consent, you may withdraw your consent at any time with future effect. We want to keep in touch with you in ways that you find to be beneficial. If, after giving your consent, you change your mind and you don’t want us to send you promotional communications anymore, you can let us know by following the instructions we provide to you at the time we send you the relevant communication or by sending us an email at DataPrivacy@ejgallo.com.

Keep in mind that these preferences regarding promotional contacts do not mean that we might not contact you for other reasons, such as those related to an inquiry you made, an event for which you registered, a legally required notice and so on.

WHAT RIGHTS DO YOU HAVE IN RELATION TO YOUR PERSONAL DATA?

You have the right to request that we:

• confirm whether or not personal data about you is being processed;
• provide you with further details about how we process your personal data;
• provide you with a copy of any data which we hold about you;
• treat your consent as withdrawn (where we rely on your consent as a legal basis for processing your personal information) at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
• consider any valid objection to the processing of your personal information (including the right to object to processing on grounds related to your particular situation where we are relying on our legitimate interests as a legal basis for processing);
• delete your personal data;
• update or delete inaccurate, incomplete or out of date personal data which we hold about you;
• restrict the way that we process your personal data; and
• consider any valid request to transfer your personal data to a third party provider of services (data portability).

If you wish to exercise any of these rights or have questions about them, please get in touch with us by emailing us at DataPrivacy@ejgallo.com, or by contacting us using the details set out above.

Please note, however, that we may be unable to comply with requests to exercise the above rights if certain exemptions apply. For example, if we need to keep processing your personal information for our legitimate interests or to comply with a legal obligation. We may also ask to you provide us with information necessary to confirm your identity.

COMPLAINTS OR QUERIES

If you have any complaints, queries or questions about how we use your personal data, you may contact us at DataPrivacy@ejgallo.com.  We will then get in touch with you to see how we can help.

If you have a complaint about how we use your personal data, we prefer you to contact us first. However, you also have the right to lodge a complaint with the competent local data protection authority if you are in the EU or with the Information Commissioner’s Office (ICO) if you are in the UK. The ICO’s helpline can be reached at 0303 123 1113 or you may visit their website at https://www.ico.org.uk. 

Changes to This Privacy Policy

We may amend this Privacy Policy from time to time. Please review this Privacy Policy periodically to be informed of how we use and protect your information. If we have your email address, we may also email you with information about these changes. If you do not accept a new revision of this Privacy Policy, you should discontinue to use this site. Any changes will be effective 14 days from posting on our website.