CAVALLI DATA & PRIVACY POLICY

Welcome to Cavalli’s data and privacy policy.

Cavalli (Pty) Ltd (hereinafter “Cavalli”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit or use our website or applications (including but not limited to www.cavalliestate.com) as well as any of our social media pages, including but not limited to Facebook, Twitter, and Instagram (collectively referred to as the Platforms), regardless of where you visit them from, and to inform you about your privacy rights and how the law protects you.

At Cavalli Estate, we recognize and respect your privacy. The information you provide us is used to let you know about our wines, events we hold or participate in, other winery news you might find interesting, and to fulfill your wine orders.

We understand the sensitivity of giving out personal information, and we do not share this information with any third party marketing or sales organizations of any kind, except in the performance of services on behalf of Cavalli Estate, and with their authorized use limited to this purpose.

We may periodically use information you have provided to us to enhance our services and products. For example, we may engage a professional survey company to use your email address to request your participation in a Cavalli Estate online customer survey about your experiences with Cavalli Estate, in an effort to improve our service to you; such surveys are voluntary and tabulated anonymously. When you order products from us, we collect information about each transaction, including the transaction amount, a description of the goods or services being purchased, the names of the buyer, and the type of payment used. When you send email or other communication to us, we may retain those communications in order to process your inquiries, respond to your requests and improve our services. All information collected is kept in the strictest confidence.

When you join our mailing list, we will send you an e-mail confirming you have been added to our list. If at any time you wish to be removed from our mailing list, simply follow the “unsubscribe” instructions at the bottom of any Cavalli Estate email you have received and you will be removed as quickly as possible and receive no further communications from Cavalli Estate electronically.

If you supply us with your postal address online you may receive periodic mailings from us with information on our latest releases, order forms, and news about Cavalli Estate. To be removed from our postal mailing list, please contact Cavalli Estate by phone or email (PH: 021 855 3218 or orders@cavalliestate.com).

If you supply us with your telephone number, you may receive follow-up telephone contact from us regarding orders placed online.

Please be aware as part of our promotional efforts, your Cavalli Estate Winery account username and password may be periodically sent to you in an email or mailed to you via the postal service to make it more convenient for you to access your online account. Please keep your log-in credentials confidential. For your security, we recommend you DO NOT keep your credit card information on file with our online storefront; instead, enter your payment information anew each time you place an order using your Cavalli Estate online account.

If you supply us with credit card and other payment information as part of your transaction, we will only share specific information (for example, your name and credit card number) with banks and other third parties in the financial system as necessary to process your transaction and maintain your account, and protect against fraud or other misconduct. For example, we may use card authorization and fraud screening services to verify that your credit or debit card information and address match the information that you provided to us.

In addition to the above, we use the information we collect to:

• Provide our products and services to you;
• Perform auditing, research and analysis in order to maintain, protect and improve our products and services; and
• Ensure the technical functioning of our network and order processing system.

We take appropriate security measures to protect against the unauthorized access or use, alteration or loss of data, including without limitation, information that we have collected from you on our site. The security of your account also depends on keeping your account password confidential, and you should not share your account name or password with anyone. If you do share your account information with a third party, they will have access to your account and your personal information.

Please note that this Privacy and Security Policy may change from time to time. We will not reduce your rights under this Privacy and Security Policy without your explicit consent, and we expect most such changes will be minor. Regardless, we will post any Privacy and Security Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy and Security Policy changes).

OUR PROMISE

• We will comply with applicable privacy and data protection laws and regulatory frameworks.
• We will only process your personal information to supply, improve and manage our services. Any additional or unusual uses of your information will be explained at the point of collection.
• We will only send you marketing emails if you have permitted us to (and you will be given the opportunity to unsubscribe in each of our emails).
• We will enable you to opt-out of usage tracking where possible; we track your use of our services to help us to tailor our content and advertising and to improve our services. We will not use information that identifies you personally but if you prefer, you may opt-out here.
• We will not share personally identifiable information with unrelated third parties for their own use without your consent. We may however share your information so that we can provide you with the best customer experience across our brands.
• We will take appropriate steps to safeguard your information in accordance with industry standards but please keep in mind that no system can be guaranteed as 100% secure.
• We will only keep your information for as long as we need it: (i) to provide you with a product/service; (ii) to improve our services; and (iii) for legal and audit purposes.
• We will not actively collect personal information from under 13s and kindly ask that if you are under 13 you do not give us information about yourself or others.
• We will give you control over the information we hold about you by enabling you to access, update and delete your information in-line with your legal rights.
• We will take steps to ensure that our suppliers and licensees look after your information as we do, including where they are processing your information in countries that do not provide the same legal protection to your information.

PRIVACY POLICY

In the course of providing you with our services and through your interactions with us, Cavalli may collect information about you and about your use of our services. We are committed to being transparent in our handling of personal information and we endeavour to comply with applicable privacy and data protection laws in the territories within which we operate. This policy describes the types of information we might collect, how we may use it and the circumstances in which we might disclose or transfer it.

If you have any questions or comments about this policy or our approach to privacy please contact us at info@cavalliestate.com. We aim to reply to any queries within three working days.

SCOPE OF THIS POLICY AND YOUR CONSENT

This policy governs our processing of your information in relation to the products and services we supply to you.

Please be aware that we also license our brands and content to other companies who may produce their own websites, events and digital content. We take reasonable steps to ensure that these companies clearly identify themselves and handle your information appropriately. However, when you use any service which is operated by a third party, the use of your information will be subject to their privacy policy and not ours. If you have any concerns, please contact us at info@cavalliestate.com

Your use of our services constitutes your consent to the processing of your information described herein.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. Cavalli may update this policy at any time, so please check this page regularly to ensure you are kept up–to–date. We will notify you in advance of any significant changes in these terms and conditions which affect our ongoing relationship with you in a material way.

THIRD-PARTY LINKS

The Platforms may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the privacy notice of every website you visit.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Platforms.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and any third parties (if applicable) and your communication preference.
• Information collected via social media and other third parties,whichcan consist of information such as your name, profile picture, gender, e-mail address and date of birth. Please keep in mind that any information provided to us via a third party may also be subject to that third party’s privacy policy.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Profile and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• purchase our products or services;
• create an account on and/or access our Platforms;
• sign up for an account, subscribe to our services or publications;
• request marketing or newsletters to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.

For purchases on our online stores, we use third party websites to facilitate such purchases. Your interactions with third party platforms, will be governed by the privacy terms of that third party, and we are not responsible for such interactions or for additional personal information you may decide to provide to such third parties. You are strongly advised to read any relevant third party’s privacy policies prior to any such interaction.

HOW WE USE YOUR INFORMATION AND LEGAL BASIS FOR PROCESSING

We will use your information: (i) to deliver, improve and personalise our services to you in accordance with your preferences: and (ii) for our own legitimate business purposes and needs. Specifically, we may use your information to:

• fulfil your product orders or to provide the service or information you have requested;
• administer your account(s);
• send you service related communications;
• manage our competitions (including publishing the names of winners where required);
• respond to your requests and feedback;
• analyse and/or improve our services;
• personalise the way Cavalli content is presented to you online;
• deliver interest-based advertising based upon your browsing of our websites and others;
• prevent fraud or other potentially illegal activities (including copyright infringement);
• block disruptive users and protect the safety of users of our services;
• enforce our terms of service;
• send you newsletters, offers and promotions relating to our brands and services and special promotions from our trusted partners in accordance with your email preferences; and
• manage our email suppression list.

Where Cavalli proposes using your personal information for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for your use other than as listed above.

Purposes for which we will use your personal data:

Under the new data protection legislation we are required to advise you of the legal basis for processing your personal data.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer/client	(a) Identity (b) Contact	Performance of a contract with you.
To process and deliver your order including: (a)Manage payments, fees and charges (b)Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e)Marketing             and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/ services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

SHARING & DISCLOSING YOUR INFORMATION

Information shared by Cavalli:

To improve your experience of our services and brands, information about your use of our services may be shared by Cavalli for the purposes of research, analysis, marketing and ad-serving.

Information shared with our suppliers:

We use a number of third parties to perform business functions on our behalf, such as sending our newsletters, hosting our online services, providing our customer services and fulfilling product orders and processing payments. We only disclose the information necessary to enable these third parties to perform their services. Our suppliers are contracted to comply with our instructions and we require that they do not use your personal information for their own business purposes.

Information shared with other parties:

Generally, we will only disclose your data to other parties with your consent, for example if you choose to share content via social media functionality. We may also disclose your personal information to law enforcement agencies, government/regulatory bodies, internet service providers and content protection organizations as required or allowed by law. For example, if you post inappropriate or objectionable content on our services or where we reasonably believe you may be in breach of the law, we may report your content and behaviour to relevant parties.

Sale or transfer of all or part of our business or assets

We reserve the right to transfer your personal information in the event we sell or transfer all or a part of our business or assets so that the buyer can continue to offer you the online services. We will make reasonable efforts to provide you with advance notification of the transfer of your information in such circumstances.

INTERNATIONAL TRANSFERS

As described in the previous section, we may share your information with contracted third party service providers. These companies may be located in, or use IT equipment located in, countries different to that in which your information is collected. Where this is the case, we will take steps to ensure that your information receives an equivalent level of protection.

Whenever we transfer your personal data out of the European Economic Area (EEA), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

HOW LONG WE WILL KEEP YOUR INFORMATION

We will only retain your personal information on our systems for as long as is necessary for the relevant service or as long as is set out in any relevant contract you hold with us.  After this time, your personal information will either be securely deleted or anonymised so that it can be used for research or statistical purposes.

HOW WE SECURE YOUR INFORMATION

We maintain appropriate organisational and technological safeguards to help protect against loss, misuse or unauthorised access, disclosure, alteration or destruction of the information we hold about you. We also seek to ensure our service providers do the same. Unfortunately, no system can be guaranteed as completely secure and there is an inherent risk in transmitting information over the internet. It may be possible for an unrelated party to intercept or access such transmissions unlawfully.

If you believe that your personal information under our control has been compromised, including access to any accounts you hold with our services, please contact us immediately using the details below.

YOUR LEGAL RIGHTS

You have the following rights:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.  If you would like to know what information we hold about you, you may submit a request to us by using the contact details below.

We will require you to prove your identity before granting access to your personal information. You will not have to pay a fee to access your personal data (or to exercise any of the other rights detailed below). However, we may be entitled to charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We will process your request within the timeframe required.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure (deletion) of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

If you would like us to delete your information from our records then please contact us using the details below and we will respond within a reasonable time but within no more than 3 working days. Please note that we may be required to retain certain information by law and/or for own legitimate business purposes.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw.

Communication Preferences and Opt-outs

If you wish to stop receiving marketing communications from us then please click on the “unsubscribe” link at the bottom of the relevant newsletter and/or contact us directly in requesting us to do so. Please note that this will not unsubscribe you from all communications, only the newsletter in the question and as such you will need to perform this action for each of the newsletters you are subscribed to. If you wish to opt-out completely then please contact us at using the details provided below. Please note that you cannot unsubscribe from some service related messages.

In accordance with industry standards, we reserve the right to retain a minimal amount of data necessary to ensure we do not contact you in the future.

COOKIES

Our Site also uses “cookie” technology to make your visits more convenient. These “cookies” are set so we may better customize your visit experience in the future. You are free to reject or “Not Accept” all cookies, but we will not be able to auto-enter your email address or customize your future visits.

We may use Google Analytics to analyze traffic to this web site. Google Analytics does not create individual profiles for visitors. Unlike some tracking services Google Analytics does not have a database of individual profiles for each visitor. Google Analytics only collects aggregate data. For more information about Google Analytics privacy policy, please click here.

EMAIL COMMUNICATIONS

We may use your email address to contact you to respond to your inquiries or to provide information on products or services to you. To help us determine whether you have received an email from us, and to help us make emails more useful and interesting, we may receive a confirmation that you have opened an email from us. We will not share your email with others outside companies.

CHILD PRIVACY

Because of the nature of our business, our products and services are not designed to appeal to minors, and therefore we do not knowingly attempt to solicit or receive any information from children. Our terms and conditions of use require that access to the Site is limited to persons of legal age to purchase alcohol in their country of residence and in the country from which they are accessing the Site. If we have reason to believe that information is being provided by a person under the legal drinking age, we will not collect the information.

INAPPLICABILITY OF PRIVACY POLICIES OF ANY LINKED SITES OR OTHER PARTIES

This Site may contain links to other sites such as our distributors and third parties. This Privacy Policy only addresses our use and disclosure of your personal information collected on our Site, if any. While we try to link only to sites that share our standards and respect for privacy, we are not responsible for the privacy practices of any third parties or the content of linked sites, although we do encourage you to read the applicable privacy policies and terms and conditions of such parties or web sites.

If you feel Cavalli Estate Website is not following its stated Privacy and Security policy, or you have any further questions about our Privacy and Security policy, please let us know at the address or phone number below.

CONTACT US

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

If you have any questions or comments about this policy or our approach to privacy please contact us at:

Data Protection Officer

Cavalli, R44 Highway, Somerset West, Cape Town, South Africa

Email: info@cavalliestate.com