Privacy Statement
Last Updated: February 29, 2024, and effective from that date.
This Privacy Statement provides information on the practices of Colio Estates Wines Inc. (“we”, “our”, “us”) regarding the Personal Information collected, used, processed, and disclosed:
- Through the Websites of our different brands, www.coliowinery.com, www.thornburycraft.com and www.girlsnightoutwines.com (the “Websites”), including through forms found on our Websites;
- When shopping on our online store, as available on the Websites, or in person at one of our locations;
- When you visit the Thornbury Cider & Brew House or the Colio Winery; and
- When you interact with us or our representatives in person, by email or by phone.
COLLECTION AND USES OF PERSONAL INFORMATION
In this Privacy Statement, Personal Information means any information that can be used to identify you, either alone or in combination with other information. (“Personal Information”).
We may collect the following Personal Information:
- When contacting us directly (by phone, email or through social media) with inquiries: Contact information (such as your name, phone number and/or email address and/or social media username) and the contents of your message, in order to contact you regarding your inquiries or reservations, and in order to prepare for your reservation. This could also include details regarding your reservations (time and date, number of guests, occasion (if applicable), special requests you choose to provide to us;
- When making a purchase in person at one of our locations and boutiques: Transaction information and payment information, such as your method of payment, credit card number, cheque information and other billing information, in order to process your payment;
- When you sign-up in person to be contacted regarding future sales: Name and phone number and email.
- When visiting our premises: We have installed video surveillance at the Thornbury Cider and Brew House to monitor our premises for security purposes, for fraud and loss prevention purposes, and for incident reporting purposes.
On the Colio Winery website
- When making an account on our website: your username, password, first and last names, and your purchase history, in order to create, manage and administer your account and to save your information for future purchases;
- When signing up for our newsletter: your email address, in order to contact you;
- When making a purchase online through our online shop: Payment information and information related to your order, such as your method of payment, credit card number, other billing information and contact information, in order to process your payment, fulfill and deliver your order;
- When contacting us via our website: your name and email, in order to respond to your inquiry.
On the Thornbury Craft Co. website
- When making an account on our website: your username, password, first and last names, and your purchase history, in order to create, manage and administer your account and to save your information for future purchases;
- When signing up for our newsletter: first and last names and email address, in order to contact you;
- When making a purchase online through our online shop: Payment information, such as your method of payment, credit card number and other billing information, in order to process your payment and fulfill your order;
- When booking a tour at the brewery or reserving an Igloo Experience online: First and last names, phone number, email address, details regarding your reservation (time and date, number of guests, special requests (optional)), payment information, in order to hold your reservation and to welcome you during your visit. With your prior consent, we may also collect your email preferences, if you choose to sign-up to receive commercial emails from us, at the time you book your reservation.
- When contacting us via our website: your name and email, in order to respond to your inquiry.
On the Girls Night Out Wines website
- When signing up for our newsletter: first and last names and email address, in order to contact you;
- When making a purchase online through our online shop: Payment information and information related to your order, such as your method of payment, credit card number, other billing information and contact information, in order to process your payment, fulfill and deliver your order;
- When leaving a review on our website for our products: Name, email address, website (if applicable) and the contents of your comment/review, in order to publish your comment/review on the website;
- When contacting us via our website: your name and email, in order to respond to your inquiry.
Note that, as required by law, all of our Websites require that we confirm a website visitor’s age of majority (through an age gating mechanism) to ensure that the individual has reached the age of majority in the province. This information is only collected for the purpose of allowing visitors to access the Websites.
Information Collected Automatically Through Cookies and Other Technologies
In general, you can visit our Websites without telling us who you are or submitting any Personal Information. However, our Websites use technology called “cookies” as well as other similar tracking tools.. The tools are elements of data that our Websites can send to your browser, which may then be stored on your hard drive so we can recognize you when you return. Through these tools, we may collect information such as the IP (Internet protocol) addresses of all visitors to our Websites, information on whether the visitor has indicated they are of the age of majority via the age gating mechanism, language preferences, browsing behaviour (e.g. when a page or product is viewed on the Websites, when you make a search on the Websites, when adding products to your cart, clicks on the Websites, when completing a purchase, …), and other related information such as page requests, browser type, operating system, and average time spent on our Websites. We use this information, in aggregate form which we cannot use to identify you, to help us understand activity on our Websites including traffic, to personalize the Websites according to your preferences, and to monitor and improve our products and services and our Websites for customer needs and interests. We may also use this information for statistical analysis purposes. We may also use this information to promote our services through marketing and advertising.
We also use these tracking tools as part of advertising our products and/or services. For example, if you visit any of our Websites, you may see advertisements for our products and/or services on other third-party sites, or on other portions of our own Websites.
As part of our advertising and marketing efforts, we use third-party advertising companies such as Meta (Facebook), and Google Ads. Web beacons and Pixels are used to gather information about your visit and provide you with a more personalized online experience. These third-party advertising companies may collect information about your online activity and use this information to make predictions about your preferences and then deliver advertisements on our behalf that are more relevant to you.
Please visit these third-party advertisers’ websites to review their privacy policies and how they manage their cookies, beacons and/or pixels, and for information on how to opt-out of some of these practices:
- Google Analytics is a web analytics service that provides statistics and analytical tools for tracking and marketing purposes. We use Google Analytics on our Websites to analyze how users use the Websites, and to serve relevant advertisements to you on other Websites. Google Analytics may collect information such as user location as inferred from IP address, the amount of time a visitor spends on our Websites, which pages are more frequently accessed, how the Websites are accessed (either directly, a search engine, or from a link), what sort of software is used (e.g. operating system, browser type, etc.), as well as demographics. For more information on how Google Analytics collects and processes information, please visit: www.google.com/policies/privacy/partners/.
For information about how to opt out of having your information used by Google Analytics, visit: https://tools.google.com/dlpage/gaoptout/.
- We also work with Meta (Facebook) to collect data that helps us track conversions from Facebook or Instagram ads, optimize ads, build targeted audiences and remarket users. Meta provides us with aggregate and/or de-identified data that cannot identify you (which may include general demographics and interests) about ads and commercial content these individuals engage with, when they engage with these ads and content, where such ads and content are posted. We then obtain some information on conversion (when someone views ads and content and takes a certain action, e.g. conversions). For more information on Facebook’s and Instagram’s advertising tools and your options to opt-out, please visit.
Facebook: https://www.facebook.com/policies/cookies.
You can also obtain more information or opt-out of receiving targeted ads by advertising networks participating in certain opt-out programs, by visiting: https://youradchoices.ca/choices.
You may set your web browser settings to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Websites, you may not be able to take full advantage of all of the features of our Websites.
In addition to the uses listed above, we may also use your Personal Information for the following purposes:
- To provide our services and make the Websites available to you;
- To administer your account on the Websites, including verifying your identity via credentials, when you log on to your account;
- To communicate with you about the Websites and our products and services;
- To provide customer service, including technical support, and to respond to inquiries;
- To comply with our regulatory and legal obligations;
- To detect, prevent or investigate security breaches or fraud and to protect our business, including to enforce ours or others’ legal rights or to comply with applicable laws; and
- For any other purposes for which you provide consent.
In the course of our activities and for the same purposes as those listed in this Privacy Statement, your Personal Information can be accessed by, or transferred to certain recipients on a need-to-know basis to assist us with such purposes on our behalf. For example:
- our personnel, including staff and our fulfillment center, as well as our contractors;
- our suppliers and services providers providing us with services associated with providing our products and services to you, such as payment processing providers, platform providers (e.g. Shopify) and online reservations;
- our systems providers that provide us with IT solutions, including web service providers, web hosting, cloud service providers, database providers, analytics and advertising services such as Google Analytics and Meta; and
- our professional advisors, including accountants and lawyers, as part of requesting advice or as part of a business transaction involving part of our business or its assets.
Your Personal Information will remain protected in accordance with this Privacy Statement. Prior to any transfer of Personal Information, we ensure to have agreements in place with third-party service providers to ensure the protection of Personal Information, as required by law.
DISCLOSURE OF PERSONAL INFORMATION
We will disclose your Personal Information to third parties under the following circumstances:
- Personal Information you have given us express permission to disclose to a specific third-party;
- In response to a search warrant or other legally valid inquiry, request or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required or permitted by law;
- If the disclosure is necessary or appropriate for the establishment, exercise or defence of legal claims, to protect our rights or those or our employees, contractors and/or customers, to prevent actual or suspect loss or harm to persons or property or to resolve a dispute between us; or
- in connection with business transaction (e.g. a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings)) involving all or part of our business.
LINKS TO THIRD-PARTY WEBSITES FOUND ON OUR WEBSITE
Our Website may include links to third-party Websites as well as content and applications hosted and served by third-parties that we do not own or operate. Clicking on those links may allow the third-party to collect or share Personal Information about you. If you follow a link to a third-party Website, please refer to the third-party’s privacy statement for information on the type of Personal Information it collects, and how it uses or discloses it. We do not endorse and are not responsible for the information or privacy practices of Websites or services owned by third-parties.
SECURITY SAFEGUARDS
We maintain reasonable and appropriate safeguards in an effort to protect against unauthorized access, use, loss, modification, destruction and disclosure of Personal Information in our custody and control. These measures include physical, organizational and technological measures that are proportionate to the quantity and sensitivity of the Personal Information. Part of these safeguards includes obtaining assurances from third-parties to require them to adopt practices that will provide a comparable level of protection for the Personal Information in their custody. However, we cannot guarantee the security of information in transit over the Internet outside of our system.
We take reasonable steps to ensure that the Personal Information in our custody and control is accurate and up-to-date for the purposes for which the information was collected. While we rely on you to provide us with accurate Personal Information and to update this information as necessary, we will make reasonable efforts to keep your Personal Information accurate and up to date, for the purposes for which the information was collected.
LOCATION AND RETENTION OF PERSONAL INFORMATION
The Personal Information we collect may be processed by us and our service providers on servers located inside and outside of Canada.
Please note that your Personal Information may be subject to the laws of general application in the jurisdiction where it is stored, including lawful access. If your Personal Information is transferred outside of Canada, we will take steps to ensure your information is adequately protected in accordance with applicable privacy laws.
Except as required by law, we will only retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, or to meet any legal or regulatory requirements. We have Personal Information retention processes designed to retain Personal Information of our customers for no longer than necessary for the purposes stated above or to otherwise meet legal requirements. We will dispose of the information that is no longer required for the purpose for which it was collected.
INDIVIDUAL RIGHTS
You may choose to exercise any of the following rights related to your Personal Information. Some of these rights will be subject to specific requirements or limitations under applicable law:
- Rights of access and correction: At any time, you may request access to any of your Personal Information that we hold, subject to limited exceptions prescribed by law, such as any Personal Information about another individual that cannot be separated from yours, any information subject to solicitor-client privilege, commercially confidential information, information that may threaten life or security of an individual, or information collected for purposes related to an investigation of a breach of an agreement or contravention of law. You may request information on the types of Personal Information we hold about you, what it is being used for, and with whom it has been shared. You may also request the correction of any inaccurate, outdated or incomplete information related to you.
- Right to opt-out: At any time, you may “opt-out” or withdraw your consent to the collection, use, disclosure or any other form of processing of your Personal Information, subject to contractual or legal restrictions. Please note that if you withdraw your consent to some processing of your Personal Information, we may not be able to provide you with a particular product or service.
- Unsubscribe from email marketing: You may remove yourself from our contact lists by following the unsubscribe instructions in each of the e-mails. You may also remove yourself from our list by contacting us as set out in the “Contact Us” section below.
Whenever we process Personal Information, we take reasonable steps to keep Personal Information accurate and up-to-date as necessary for the purposes identified when it was collected.
If you wish to exercise any of these rights, please contact us at the contact information found in the section “Contact Us” below. We may not accommodate a request if we believe it would violate any law or legal requirement. If we cannot accommodate a request, we will provide you with a justification.
We may request certain Personal Information for the purposes of verifying your identity when requesting access to or correction of your Personal Information.
CHILDREN’S PRIVACY
Our Website and our services are not directed at children. We do not knowingly collect any Personal Information about children on our Website or for the purposes mentioned in this Privacy Statement. If Personal Information about children has been mistakenly provided to us and you would like to request that such Personal Information be removed, please refer to our “Contact Us” section.
CHANGES
We may update this Privacy Statement from time to time to reflect changes in our processing of Personal Information. If we change the way we collect, use, disclose or otherwise process your Personal Information, we will update this Privacy Statement and when required, we will notify you. These changes will take effect immediately upon posting. Where required by law, we may seek your prior consent.
We strongly encourage you to please refer to this Privacy Statement often for the latest information about our Personal Information practices.
CONTACT US
If you have any questions or comments about this Privacy Statement, or regarding your Personal Information, the ways in which we collect and use your Personal Information, or your choices and rights regarding such use, please contact our Privacy Officer using the contact form below.