E. & J. Gallo Winery (hereinafter "Winery") and its brands, affiliates, subsidiaries, companies and/or their related brands (collectively referred to here as "we," "our,") created this Privacy Policy to inform our website users, club members, event registrants/participants, newsletter/information recipients, promotion, contest, sweepstakes or campaign participants, online community participants, those who correspond with us via SMS (text message), those who purchase or inquire about our products and services and others (collectively referred to as "customers") about our practices regarding collection, use and disclosure of personally identifiable information ("personal data") that we collect from them. All references to our "website" in this Privacy Policy includes any of our affiliated microsites linked to our website as well as any of our affiliated mobile applications.

This Privacy Policy does not apply, however, to Winery employees, employment applicants, suppliers, distributors or trade contacts except when they are acting in a "customer" capacity; in all other circumstances, other policies apply. This Privacy Policy also does not apply to any of our other websites that contain a separate privacy policy.

While our website or other materials may include links or references to non-Winery websites, materials or entities, this Privacy Policy does not apply to any data that may be collected through those non-Winery sites, materials or entities, unless otherwise indicated. This includes any websites of affiliated entities.

This Privacy Policy is subject to our Terms of Use. We may update this Privacy Policy from time to time, as specified in the "Changes to This Privacy Policy" section below.

Your Consent

You should read this entire Privacy Policy before submitting information to us or using our website. Whenever you submit information via our website or otherwise to us, whether online or offline, you consent to the collection, use and disclosure of that information in accordance with this Privacy Policy.

Intended Audience of Websites

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 legal drinking age. If you are not of legal drinking age, you should not visit or use our website.

Information Collection and Use

We may collect personal data (including, without limitation, age, birthdate, address, email address, phone number, Facebook account information, and geographic location) from customers both online and offline. Online, we may collect information through our website, an affiliated site (such as a promotional microsite linked to our site), a brand page on a community website (such as Facebook or the like) or through similar online avenues, and via mobile phone applications or SMS (text message) correspondence. In many cases, such information will be collected directly from you, such as through a transaction or inquiry (including via a telephone call or SMS correspondence) or your submission of a form, registration or communication to us. Information may also be gathered from our affiliates, companies and their related brands and from third-party sources (including without limitation, our third-party service providers (such as marketing and fulfillment companies), opt-in lists, publicly available data, consumer reporting agencies, other companies and referrals) and through your activities and interactions with us, including, without limitation, your online activity on our website. We may combine data collected from these disparate sources unless we tell you otherwise. Any of your personal data or other information gathered by one of our brands may be shared with and used by any of our other brands in accordance with this Privacy Policy.

We collect personal data about our customers in a number of ways. In this section, we describe what types of personal data we collect, the ways we collect it and how we use it. While we have tried to be complete, this list is not necessarily exhaustive, given that these activities can vary from time to time. When we collect information, we will tell you at the point of collection what information is required and what information is optional.

The types of personal data typically collected by us may include the following, depending on your activities:

• Contact information and Geographic Location, including name, title, street address (home, work, billing, shipping), postal code, country, telephone numbers (home, work, cell, etc.), email address (home, work), company name and other similar information, and your geographic location.


• Personal/demographic information, including birthday/age/age group, gender, birth date, salary range, occupation, level of education, contest- or promotion-specific information (e.g., for wedding promotions, we ask for your wedding date, location, etc.) and the like.


• Authentication information, including user IDs, log-in names, passwords, password reminders, etc. (in addition to other personal data such as contact information, birth date and the like).


• Transactional and financial information, including products or services you purchase, inquire about or request, payment information, debit/credit card information and so on.


• Preferences, views and comments, including beverage preferences and consumption frequency, subscriptions/communications preferences, feedback in response to surveys, etc.


• Participation information, including event attendance, sweepstakes/contest entries (including all information submitted on an entry), information provided when requesting or receiving discounts/coupons/rebates, registrations, information relating to use of online communities and all other user submissions and content you provide.

As you use our website, some information can be "passively" collected using various technologies, such as cookies, web beacons and navigational and location data collection (clickstream, log files, server logs). Your Internet browser automatically transmits some of this information, such as the URL of the website you just visited and the Internet Protocol (IP) address and browser version currently being used by your computer. Such technologies help us to keep track of your interactions with our website and provide you with a more customized experience.

As is the case with many websites, our website may use cookies and other automated information collection means. Cookies are information about you from our website that is stored on your browser or hard drive. Cookies save you time because you do not need to manually re-enter the information stored on your hard drive. Cookies also help us upgrade our website by showing when and how users use our website. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject any cookies. Please note that certain features of our website might not work without cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it. You may not disable certain types of cookies that are essential to the operation of our websites. For more information on how to opt-out of cookies, please visit the Digital Advertising Association at http://www.youradchoices.com/ or the Digital Advertising Association of Canada at: http://youradchoices.ca/.

Our website may also use IP addresses for the same purposes identified above, as well as to analyze trends, administer our website, track users' movements and online activity and gather broad demographic information for aggregate use.

We may use web beacons (also known as Internet tags or clear GIFs) on our website to access and set cookies and otherwise help us to better understand how users are moving through our website. Information provided by the web beacon includes the computer's IP address, the type of browser being used and the time that the web beacon was viewed. We may also use web beacons in emails and newsletters so that we know when such communications have been opened and to otherwise help us tailor our communications to individual users.

We use personal data about customers for a wide range of purposes. We use it to respond to your requests (including requests for newsletter subscriptions, materials, coupons/rebates/discounts and so on); to provide products or services that you have ordered; to process your order transactions and contact you regarding your order; to invite and help you to participate in a range of online and offline events, activities and/or clubs; to allow you to post information and other content online; to improve our products, services and websites; to follow up with you after you have communicated with us or submitted information to us; to send promotional communications or offers (unless you have requested that we not send such communications); for marketing, research and legal purposes and other purposes (including, without limitation, call center recordings); to permit you to participate in and to otherwise administer sweepstakes, promotions, campaigns and contests; to allow you to contact another person; to address your interests and concerns; and as otherwise specified in this Privacy Policy and/or at the point of personal data collection.

We use personal data about customers in contexts that include the following:

• Conducting and following up on transactions. We may use personal information such as name, title, street address, phone number, email address, title, company name, payment information and debit/credit card information to conduct transactions with you, process your order, contact you about your order and so on.


• Registration, such as for events, memberships, accounts (i.e., log-ins and passwords, etc.). Customers may be given an opportunity to register for a variety of reasons, including to become/be a member of a wine club; to receive promotional communications/offers; to attend an event (e.g., a winery tasting panel); to join/participate in an online community, blog, chatroom or other interactive areas or to otherwise provide user-generated content (such as posting favorite photos/videos/audio recordings, providing testimonials, sharing experiences about Winery products, etc.); and so on. Such activities may entail collection of name, title, contact information, birth date, user name and password, beverage preferences, experiences with such products and personal information/preferences related to the subject matter of the particular activity. In some cases, you will select a user ID and password when you register and you will use this to gain access to certain registration-restricted areas. Note that using our website as a registered user enables information that is passively collected as you navigate our website to be associated with personal data actively collected from you or your activities on our website.


• Participation in online communities/provision of user-generated content. Our website may provide online community features and may allow you to submit user-generated content for posting on our website. You are responsible for any postings you make in any online community. Before using such areas or submitting any user-generated content, you should review and adhere to the applicable Terms of Use and also keep in mind that anything you make available as a participant in an online community or submit for posting by us may be made available for others to see; you should therefore carefully consider whether you wish to submit personal data, or any data, for these purposes. Any content submitted to an online community will be subject to the applicable Terms of Use; therefore, read such terms carefully prior to submitting or posting any information. We also reserve the right not to post or make available, or to take down, any data submitted to us, as further described in the Terms of Use.


• Contacting others on your behalf. We may offer opportunities to reach out to friends through "tell-a-friend" features (e.g., about our website) or "invite-a-friend" features (e.g., to a party you are hosting). We may ask you for your name and contact information (plus registration information, where applicable) as well as your friend's name, email address, other applicable contact information and birth date (the latter for age verification, given restrictions associated with alcoholic beverages). We use the personal data that you provide about others to fulfill your one-time request and do not use it to contact the friend again unless you or your friend request that we do so.


• To follow up with you after you have completed a form, business reply card or survey, whether online or offline. When you visit our tasting room or attend an event where we are present, you might fill in an optional form, telling us your name, title, email address, beverage consumption preferences, whether you attended past events, your postal code, comments, whether you would like us to contact you in the future and/or other information. Likewise, you might choose to participate in an online or offline survey (anonymously or with name/contact information) where you provide demographic information, your beverage consumption information and survey-specific preference data. We use the personal data you provide to improve our products, services and website content and otherwise to more effectively communicate with you.


• To allow you to contact us with questions, comments or concerns and to address your communications. We provide a number of ways for you to contact us to ask questions, provide comments or share concerns. This may occur, for example, via our Consumer Information Center (by calling a designated phone number), "contact us" sections on our website or postal mail. Depending on the circumstances, we may collect your name, title, contact information, age group, product UPC number, message type, case number (if tied to a previous issue), comments and other types of data relevant to the specific situation (e.g., product involved, use of the product, any problems with the product and the like).


• To provide materials you request. We provide a number of ways for you to request materials from us, such as newsletters, coupons, rebates, brochures, product literature and the like. We may collect and use contact name, title, contact information, age-indicative information, demographic information, preferences, transaction information (such as related to rebates) and other information relevant to responding to your request.


• To permit your participation in contests, sweepstakes and other promotions. To participate in sweepstakes, contests, campaigns and other similar promotions, we often collect name, title, contact information, age-indicative information and gender, and/or your geographic location as well as other information related to the particular activity.


• For marketing purposes (unless you have told us otherwise). We may use your contact information to tell you about other products and services (including those of our other brands, affiliates and companies) that we believe might be of interest. If at any time you do not want communications from us for promotional purposes, please let us know (see the "It's Your Choice" section of the Privacy Policy).

We may disclose personal data you provide to any of our other brands and to our affiliates, companies and/or their related brands, and to consultants, service providers, promotional partners and contractors that we use to support our business and operations (e.g., delivery services, financial institutions, fulfillment services, technical support, advertising, public relations, media and marketing services, sweepstakes, promotions, campaigns and contest-related services, call-in centers, e-commerce and other web-related services such as web hosting and web monitoring services and event-related services such as online and offline data capture) who have agreed to keep the information confidential and use it only to provide the applicable service(s). In some cases, we work with other companies who help to gather information from you or help us to communicate with you. For example, our mobile applications or SMS correspondence campaigns may be administered by a third party service provider.

Where the law allows it, we may share customers' personal data with affiliates, companies and/or their related brands or selected third-party partners to enable them to market their or other selected third parties' products and services to you. You may let us know that you do not want your personal data shared in this way by contacting us as specified in the "Contact Us" section below.

We may also disclose personal data to third parties (including, without limitation, governmental agencies) if required to do so by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our (or others') rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may disclose personal data to third parties in connection with the sale, assignment or other transfer of the business of our website or the sale, assignment, merger, reorganization or other transfer of any of our brands or companies.

The recipients of customers' personal data, and more generally these disclosures, may be located in the United States or other jurisdictions that might not provide a level of protection equivalent to the laws in your jurisdiction. By submitting personal data to us, you consent to the transfer of such personal data outside your jurisdiction.

We may make full use of all information that is de-identified or otherwise not in personally identifiable form. We (including any of our other brands) may also make full use of all user-generated content you submit to us, in accordance with our Terms of Use.

Facebook Ads from E. & J. Gallo Winery

We may display interest-based ads to you when you are using Facebook. We do this using tools that Facebook makes available to us. Using a tool provided by Facebook, we convert your e-mail address or telephone number that you provided to us to a unique number that Facebook uses to match to unique numbers that Facebook generates from information you provided to Facebook. We also use Facebook pixel tags on our website that allows Facebook to recognize that you visited our website. These tools allow Facebook to show you Facebook Ads from E. & J. Gallo Winery and will provide us with analytics information regarding the effectiveness of Facebook Ads from E. & J. Gallo Winery. You may opt-out of customized ads by adjusting your Facebook Ads setting on Facebook or selecting “Why am I seeing this” in the Facebook Ad from E. & J. Gallo Winery. You may also opt-out of us using your e-mail address or telephone number to create personalized Facebook Ads from E. & J. Gallo Winery by contacting us as specified in the “Contact Us” section below. You may opt-out of Facebook pixel tags by visiting the Digital Advertising Alliance http://www.aboutads.info/choices.

Security

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. Moreover, you are responsible for maintaining the confidentiality of any user name and password you use.

It's Your Choice: Contact Preferences; Opt-In and Opt-Out

We want to keep in touch with you in ways that you find to be beneficial. If you don't want us to use your contact information to communicate with you for promotional purposes (such as to tell you about other products and services that might be of interest or to offer coupons/discounts), please tell us that when you provide your contact information. You can also let us know your preference later by contacting us as specified in the "Contact Us" section below, by accessing your account via our site (if applicable) or by following the instructions in various communications that we may send you. 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 order you placed, an inquiry you made, a message that a friend or acquaintance requested be delivered (such as through our tell-a-friend/invite-a-friend features), a newsletter to which you may have subscribed, a membership you undertook, an event for which you registered, a legally required notice and so on.

SMS Messaging Opt-Out

If you have participated in our general SMS correspondence campaign, you may opt-out by texting "STOP" to the short code provided in that message. Text "HELP" to the code for help or call us at the Consumer Relations number below for more assistance. Message and data rates may apply.

Access

To keep personal data provided by you accurate, current and complete, please contact us as specified in the "Contact Us" section. We can then take appropriate steps to update or correct such information in our possession or to delete your information from our contact list.

Contact Us

If you have questions or concerns related to this Privacy Policy or our information practices, would like to update or correct information you have provided or would like to opt-out of promotional communications from us, please contact us as follows:

Consumer Information Center
Attention: Consumer Relations
1541 Cummins Drive
Modesto, CA 95358.
1-855-366-9463
consumerrelations@apothic.com

Changes to This Privacy Policy

This Privacy Policy may be revised from time to time for any reason. If this Privacy Policy changes, the revised policy will include a new effective date, and we will notify you of such changes by posting the revised policy on this page. Any such changes will automatically apply to all uses of our website and collection and use of your personal data by us, on or after such effective date, until such time as this Privacy Policy is subsequently revised. If you don't want us to use your personal data according to the terms of the new policy, you can opt-out here. Be sure to check the Privacy Policy whenever you submit personal data or use our website. The effective date of this Privacy Policy is August 2019.