About this Notice
This California Privacy Notice applies to California residents and supplements our general Privacy Policy. It describes our practices under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, "CCPA"), including the categories of personal information we collect, the sources, purposes, disclosures, and the rights California residents have.
Categories of Personal Information Collected
In the preceding twelve months, we have collected the following categories of personal information from California residents:
- Identifiers: name, email address, phone number, postal address, account ID, device identifiers, IP address.
- Customer records: billing address, payment information (processed by third-party payment processors), order history.
- Protected classifications: age and gender, where relevant to care pathways.
- Commercial information: products purchased, memberships, browsing and purchase activity.
- Internet or network activity: interaction with our Services, pages viewed, referrers.
- Geolocation: approximate location from IP address, precise location only when you provide a shipping address.
- Sensory data: communications you send us, including messages to clinicians and customer support.
- Professional information: only if voluntarily provided, for example on an employment application.
- Inferences: preferences and characteristics derived from the above.
- Sensitive personal information: health information you provide through questionnaires, consultations, and community interactions; account log-in credentials; and precise geolocation where provided.
We do not collect education information as defined under the Family Educational Rights and Privacy Act.
Sources
We collect this information directly from you, automatically through your use of the Services, and from service providers, identity verification partners, laboratories, clinicians, and fraud prevention vendors.
Business Purposes for Collection
- Providing, maintaining, and improving the Services.
- Processing telehealth visits, prescriptions, lab orders, memberships, and product purchases.
- Communicating with you about your account, orders, and care.
- Marketing with your consent and subject to your opt-out rights.
- Security, fraud prevention, and legal compliance.
Disclosure of Personal Information
In the preceding twelve months, we have disclosed the categories of personal information listed above to the following categories of recipients for business purposes: licensed clinicians, pharmacies, laboratories, payment processors, shipping providers, hosting and infrastructure providers, analytics providers, customer support platforms, fraud prevention vendors, and legal and regulatory recipients where required.
Sale and Sharing
We do not sell personal information in exchange for money. We do not "share" personal information for cross-context behavioral advertising as defined by the CCPA. We do not knowingly sell or share personal information of consumers under sixteen.
To be transparent: certain advertising cookies on our marketing pages may constitute "sharing" under a strict reading of the law. You can opt out at any time through our Your Privacy Choices page, by broadcasting a Global Privacy Control signal, or by adjusting preferences in our cookie banner.
Your California Privacy Rights
- Right to know the categories and specific pieces of personal information we have collected.
- Right to delete personal information, subject to legal and clinical retention exceptions.
- Right to correct inaccurate personal information.
- Right to opt out of the sale or sharing of personal information.
- Right to limit the use and disclosure of sensitive personal information to purposes reasonably necessary to provide the Services.
- Right to non-discrimination for exercising your rights.
- Right to appeal a denied request.
Submit any request by emailing privacy@finewineshealth.com, calling [toll-free number], or using our data rights request form. We will verify your identity before completing a request and will respond within the time period required by law, generally forty-five days, extendable by an additional forty-five days with notice. An authorized agent may submit a request on your behalf with appropriate proof of authority.
Retention
We retain personal information for the periods described in our Privacy Policy. Medical records retained by your clinician follow the retention laws of the state of treatment.
Shine the Light
California Civil Code Section 1798.83 permits California residents to request information about our disclosures of personal information to third parties for those parties' direct marketing purposes. We do not make such disclosures.
Contact
Fine Wines Health, Inc., Attn: Privacy Team, [Street Address], [City], California [ZIP]. Email: privacy@finewineshealth.com.
