PRIVACY POLICY
Last Updated July 1, 2023
E. & J. Gallo Winery and its brands, affiliates, and subsidiaries (collectively “Gallo,” “we,” “us,” or “our”), created this Privacy Notice to inform our consumers, 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 telephone, SMS (text message), email or QR Code, those who visit our tasting rooms and other physical locations, and those who purchase or inquire about our products and services (collectively referred to as “you” or “your”) about our practices regarding collection, use and disclosure of Personal Information (as defined below). Unless otherwise expressly stated, this Notice applies to each of our websites and mobile applications that link to this Notice, and to information we collect offline.
Table of Contents
- How can a consumer with a disability access this Notice?
- Notice at Collection
- California Privacy Rights
- California Notice of Financial Incentive
- Additional Information for Consumers in Other US States
- Visitors from Outside the United States
- Cookies and Other Tracking Technologies
- Website Analytics
- Targeted Advertisements
- Do Not Track Signals
- Social Features on Our Websites and Apps
- Online Chat
- Session Replay
- Contact Preferences and Email Opt-Out
- SMS Messaging Opt-Out
- Not for Children
- Security
- Changes to This Privacy Notice
- How To Contact Us
- How can a consumer with a disability access this Notice?
- Notice at Collection
- How and Why We Collect Personal Information
Categories of Personal Information | Purposes for Collection | Categories of Sources |
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers | To process your purchases In connection with registration for events, memberships, accounts, etc. To communicate with you To permit your participation in online communities/provision of user-generated content To facilitate your participation in contests, sweepstakes and other promotions For marketing and advertising To administer our websites and mobile applications To analyze trends relating to our products, websites, mobile applications, communications, and advertisements To detect and prevent fraud against you and/or us For security purposes To comply with law (e.g., to confirm legal drinking age) | Directly from you From our service providers (such as marketing, analytics, and fulfillment companies) Through technologies used on our websites and mobile apps Advertising partners Internet service providers Government entities Social networks Data brokers and similar third parties |
Personal Records, including name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, credit card number, debit card number This includes the information described in Cal. Civ. Code § 1798.80(e). | To process your purchases In connection with registration for events, memberships, accounts, etc. To communicate with you To permit your participation in online communities/provision of user-generated content To facilitate your participation in contests, sweepstakes and other promotions For marketing and advertising To administer our websites and mobile applications To analyze trends relating to our products, websites, mobile applications, communications, and advertisements To detect and prevent fraud against you and/or us For security purposes To comply with law (e.g., to confirm legal drinking age) | Directly from you From our service providers (such as marketing, analytics, and fulfillment companies) Data brokers and similar third parties |
Characteristics of protected classifications under California or federal law, including age, gender, marital status, and disability | To facilitate your participation in certain services we provide. For example, we ask for your wedding date, location, etc. for wedding promotions. To gather demographic information for aggregate use For marketing and advertising To analyze trends relating to our products, websites, mobile applications, communications, and advertisements To otherwise help us tailor our communications to individual consumers To detect and prevent fraud against you and/or us To comply with law (e.g., to confirm legal drinking age) | Directly from you From our service providers (such as marketing, analytics, and fulfillment companies) Data brokers and similar third parties |
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies | To process your purchases To tailor our communications with you To facilitate your participation in contests, sweepstakes and other promotions For marketing and advertising To analyze trends relating to our products, websites, mobile applications, communications, and advertisements To detect and prevent fraud against you and/or us | Directly from you From our service providers (such as marketing, analytics, and fulfillment companies) Through technologies used on our websites and mobile apps Advertising partners Social networks Data brokers and similar third parties |
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement | To process your purchases To tailor our communications with you To permit your participation in online communities/provision of user-generated content For marketing and advertising To administer our websites and mobile applications To analyze trends relating to our products, websites, mobile applications, communications, and advertisements To detect and prevent fraud against you and/or us For security purposes | Directly from you From our service providers (such as marketing, analytics, and fulfillment companies) Through technologies used on our websites and mobile apps Advertising partners Internet service providers Social networks |
Geolocation data | To tailor our communications with you For marketing and advertising To administer our websites and mobile applications To analyze trends relating to our products, websites, mobile applications, communications, and advertisements To detect and prevent fraud against you and/or us For security purposes | Inferred from other information (e.g., your IP address or a scanned QR code) From our service providers (such as marketing, analytics, and fulfillment companies) |
Audio, electronic, visual, thermal, olfactory, or similar information | To provide customer service To process your purchases To analyze trends relating to our products, communications, and advertisements To detect and prevent fraud against you and/or us For security purposes | Directly from you |
Professional or employment-related information If you are a Gallo employee, please see our California Employee Privacy Notice for additional disclosures. If you are a job applicant, please see our California Applicant Privacy Notice on the GalloCareers.com site for additional disclosures. | To process your purchases (e.g., employee discounts) To tailor our communications with you For marketing and advertising To analyze trends relating to our products, websites, mobile applications, communications, and advertisements To detect and prevent fraud against you and/or us | Directly from you From our service providers |
Inferences used to create a profile reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | To analyze trends and to otherwise help us tailor our communications to individual consumers To tailor our communications with you For marketing and advertising For security purposes | Inferred from other categories of Personal Information we collect |
Among the categories listed above, are the following types of sensitive Personal Information:
Categories of Sensitive Personal Information | Purposes for Collection | Categories of Sources |
Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number. Depending on the document provided, this may include your citizenship | To confirm legal drinking age To confirm eligibility for contest winners For tax purposes To detect and prevent fraud against you and/or us For security purposes | Directly from you |
Personal information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account | To facilitate your membership or participation in one of our wine clubs or rewards programs. To process purchases and/or maintain an account for the purpose of processing purchases. | Directly from you |
Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation | To facilitate your participation in certain services we provide. For example, we ask for your wedding date, location, spouse’s name, etc. for wedding promotions. To gather demographic information for aggregate use | Directly from you |
- Retention of Personal Information
- Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
- Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;
- The Personal Information is reasonably necessary to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
- We are otherwise required or permitted to keep your information by applicable laws or regulations.
- Disclosure of Personal Information
i. Disclosures for a Business or Commercial Purpose
Category of Personal Information or Sensitive Personal Information | Categories of Recipients | Purposes for Disclosure | |
Personal Information | |||
Identifiers | Our brands and affiliated companies Service providers that we use to support our business and operations (e.g., financial institutions, fulfillment services, technical support, advertising, analytics, media and marketing, promotions, campaigns and contest-related services, e-commerce and other web-related services, and event-related services) Government entities | Services performed on our behalf relating to: Processing your purchases Registration for events, memberships, accounts, etc. Communicating with you Supporting our online communities Contests, sweepstakes and other promotions Marketing and advertising (except for cross-context behavioral advertising) Administration of our websites and mobile applications, including debugging and repair of errors Analyzing trends relating to our products, websites, mobile applications, communications, and advertisements Research and development Short-term, transient use Detecting and preventing fraud against you and/or us Ensuring security and integrity Otherwise processing, maintaining, or collecting Personal Information on our behalf To fulfill our tax and other reporting obligations | |
Personal Records | Our brands and affiliated companies Service providers that we use to support our business and operations (e.g., financial institutions, fulfillment services, technical support, advertising, analytics, media and marketing, promotions, campaigns and contest-related services, e-commerce and other web-related services, and event-related services) Government entities | Services performed on our behalf relating to: Processing your purchases Registration for events, memberships, accounts, etc. Communicating with you Supporting our online communities Contests, sweepstakes and other promotions Marketing and advertising (except for cross-context behavioral advertising) Administration of our websites and mobile applications, including debugging and repair of errors Analyzing trends relating to our products, websites, mobile applications, communications, and advertisements Research and development Short-term, transient use Detecting and preventing fraud against you and/or us Ensuring security and integrity Otherwise processing, maintaining, or collecting Personal Information on our behalf To fulfill our tax and other reporting obligations | |
Characteristics of protected classifications | Our brands and affiliated companies Service providers that we use to support our business and operations (e.g., financial institutions, fulfillment services, technical support, advertising, analytics, media services, promotions, campaigns and contest-related services, e-commerce and other web-related services, and event-related services) Government entities | Services performed on our behalf relating to: Facilitating your participation in certain promotions. For example, we ask for your wedding date, location, etc. for wedding promotions Gathering demographic information for aggregate use Tailoring our communications Marketing and advertising (except for cross-context behavioral advertising) Analyzing trends relating to our products, websites, mobile applications, communications, and advertisements Research and development Detecting and preventing fraud against you and/or us To comply with law (e.g., to confirm legal drinking age) | |
Commercial information | Our brands and affiliated companies Service providers that we use to support our business and operations (e.g., financial institutions, fulfillment services, technical support, advertising, analytics, media and marketing, promotions, campaigns and contest-related services, e-commerce and other web-related services, and event-related services) Government entities | Services performed on our behalf relating to: Processing your purchases Communicating with you Supporting our online communities Contests, sweepstakes and other promotions Marketing and advertising (except for cross-context behavioral advertising) Analyzing trends relating to our products, websites, mobile applications, communications, and advertisements Research and development Short-term, transient use Detecting and preventing fraud against you and/or us Ensuring security and integrity Otherwise processing, maintaining, or collecting Personal Information on our behalf | |
Internet or other electronic network activity information | Our brands and affiliated companies Service providers that we use to support our business and operations (e.g., financial institutions, fulfillment services, technical support, advertising, analytics, media and marketing, promotions, campaigns and contest-related services, e-commerce and other web-related services, and event-related services) | Services performed on our behalf relating to: Processing your purchases Registration for events, memberships, accounts, etc. Communicating with you Supporting our online communities Marketing and advertising (except for cross-context behavioral advertising) Administration of our websites and mobile applications, including debugging and repair of errors Analyzing trends relating to our products, websites, mobile applications, communications, and advertisements Short-term, transient use Detecting and preventing fraud against you and/or us Ensuring security and integrity Otherwise processing, maintaining, or collecting Personal Information on our behalf | |
Geolocation data | Our brands and affiliated companies Service providers that we use to support our business and operations (e.g., financial institutions, fulfillment services, technical support, advertising, analytics, media and marketing, promotions, campaigns and contest-related services, e-commerce and other web-related services, and event-related services) | Services performed on our behalf relating to: Communicating with you Supporting our online communities Marketing and advertising (except for cross-context behavioral advertising) Administration of our websites and mobile applications, including debugging and repair of errors Analyzing trends relating to our products, websites, mobile applications, communications, and advertisements Short-term, transient use Detecting and preventing fraud against you and/or us Ensuring security and integrity | |
Audio, electronic, visual, thermal, olfactory, or similar information | Our brands and affiliated companies Service providers that we use to support our business and operations (e.g., financial institutions, fulfillment services, technical support, advertising, analytics, media and marketing, promotions, campaigns and contest-related services, e-commerce and other web-related services, and event-related services) | Services performed on our behalf relating to: Providing customer service Processing your purchases Analyzing trends relating to our products, communications, and advertisements Detecting and preventing fraud against you and/or us Ensuring security and integrity | |
Professional or employment-related information | Our brands and affiliated companies Service providers that we use to support our business and operations (e.g., fulfillment services, technical support, advertising, analytics, media services, promotions, campaigns and contest-related services, e-commerce and other web-related services, and event-related services) | Services performed on our behalf relating to: Processing your purchases Communicating with you Marketing and advertising (except for cross-context behavioral advertising) Analyzing trends relating to our products, websites, mobile applications, communications, and advertisements Detecting and preventing fraud against you and/or us | |
Inferences | Our brands and affiliated companies Service providers that we use to support our business and operations (e.g., financial institutions, fulfillment services, technical support, advertising, analytics, media services, promotions, campaigns and contest-related services, e-commerce and other web-related services, and event-related services) | Services performed on our behalf relating to: Communicating with you Marketing and advertising (except for cross-context behavioral advertising) Analyzing trends relating to our products, websites, mobile applications, communications, and advertisements Research and development Short-term, transient use Detecting and preventing fraud against you and/or us Ensuring security and integrity Otherwise processing, maintaining, or collecting Personal Information on our behalf | |
Sensitive Personal Information | |||
Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number | Government entities Our brands and affiliated companies Service providers that help support our contests and promotions | For tax and other legal reporting purposes Services performed on our behalf relating to: Processing your purchases Registration for events, memberships, accounts, etc. Contests, sweepstakes and other promotions Detecting and preventing fraud against you and/or us Ensuring security and integrity | |
Personal information that reveals a consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. | Service providers that we use to support our business and operations (e.g., technical support) | Services performed on our behalf relating to: Maintaining account logins for our electronic services Ensuring security and integrity | |
Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation | Service providers that help support our wedding services | Services performed on our behalf relating to: Participation in certain wedding-related services. For example, we may share your wedding date, location, spouse’s name, etc. with vendors that support our wedding promotions. Analyzing trends relating to our products, websites, mobile applications, communications, and advertisements |
ii. Targeted Advertising / Sales and Sharing of Personal Information
Category of Personal Information or Sensitive Personal Information | Categories of Recipients | Purposes for Selling / Sharing |
Identifiers | Third-party advertising partners, social networks, data brokers, and certain analytics providers | To show you targeted ads while you browse the internet or use social media For analytical purposes (e.g., to better understand our customers by appending to our records additional information obtained from data brokers or other third parties) |
Personal Records | ||
Commercial information | ||
Internet or other electronic network activity information | ||
Geolocation data | ||
Inferences |
- California Privacy Rights
You may designate an authorized agent to make a request on your behalf. If you use an authorized agent, we may request that you verify your identity directly with us. An authorized agent may submit a request on your behalf through our Consumer Engagement team at DataPrivacy@ejgallo.com or the toll-free number listed above.
Right to Know About Personal Information Collected, Disclosed, Sold, or Shared. California consumers have the right to request more information regarding the following:
- The categories of Personal Information we have collected about you, including:
- The categories of sources from which the Personal Information was collected
- Our business or commercial purposes for collecting, selling, or sharing Personal Information
- The categories of recipients to which we disclose Personal Information
- The categories of Personal Information that we sold, and for each category identified, the categories of third parties to which we sold that particular category of Personal Information
- The categories of Personal Information that we disclosed for a business purpose, and for each category identified, the categories of recipients to which we disclosed that particular category of Personal Information
- The specific pieces of Personal Information we have collected about you
Right to Correct Inaccurate Personal Information. If you believe that Personal Information we maintain about you is inaccurate, you may submit a request for us to correct that information. Upon receipt of a verifiable request to correct inaccurate Personal Information, we will use commercially reasonable efforts to correct the information as you direct.
Right to Opt-Out of the Sale and Sharing of Personal Information. You have the right to opt out of the sale of your Personal Information, and to request that we do not share your Personal Information for cross-context behavioral advertising. To opt out of cookie-based sales and sharing, please click on the Do Not Sell or Share My Personal Information homepage link for each Gallo brand you have engaged with, and follow the instructions provided. If you choose to use a browser-based opt-out signal (such as the Global Privacy Control (GPC) signal), you will be opted out of cookie-based sales and sharing of Personal Information. Because we are unable to recognize you across different websites, visiting one of our sites with the signal enabled will have the effect of opting you out of sales and sharing with respect to that specific site, but will not impact sales and sharing for our other websites or brands. Additionally, you will need to turn on the opt-out signal for each browser that you use. To submit a request to opt out of offline sales and sharing, please email our Consumer Engagement team at DataPrivacy@ejgallo.com or call the toll-free number.
Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the CCPA.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights. If you choose to exercise any of the privacy rights described above, you also have the right not to receive discriminatory treatment by us. This means that, consistent with California law, we will not deny providing our products or services to you, charge you different prices or provide a different level or quality of products or services to you unless those differences are related to the value of your Personal Information.
California’s Shine the Light Law. California residents may request a list of the third parties to which we have disclosed personal information, as defined under California Civil Code Section 1798.83(e) (a/k/a the “Shine the Light Law”), during the preceding calendar year for third-party direct marketing purposes. To make such as a request, please contact our Consumer Engagement team at DataPrivacy@ejgallo.com.
- California Notice of Financial Incentive
Material Terms. The details of each program are contained in the program offering but in general, we invite you to provide us with your email address or cell phone number, and we provide you with a sign of our appreciation such as a discount code or a perk like a branded item. We value the opportunity to market to you.
How To Opt In. You can opt in using a prompt on our websites that links to this notice.
Right to Withdraw. You can opt out of receiving marketing communications from us at any time by clicking on the unsubscribe link contained in our emails and text messages, or you may email us at DataPrivacy@ejgallo.com.
Value of Financial Incentive. The incentives we offer in exchange for the opportunity to market to you may be a discount coupon that can be used when you buy products from us or a branded item. Details of the incentive will vary depending on market conditions at the time the incentive is offered, and the value of your data will also fluctuate. Under most circumstances, the value of your Personal Information is less than the incremental administrative costs of the marketing program, including storage of your Personal Information. Retail prices for our products and branded items vary.
- Additional Information for Consumers in Other US States
- Additional Information about Certain Data Uses
Sales of Personal Data. We do not sell Personal Data in exchange for money. However, some of our advertising practices may be considered a “sale” under certain state privacy laws, such as the Colorado Privacy Act and the Connecticut Data Privacy Act. If you would like to opt out of non-monetary “sales” of your Personal Data via cookies, please click on the Do Not Sell or Share My Personal Information homepage link for each Gallo brand you have engaged with, and follow the instructions provided. To submit a request to opt out of offline sales and sharing, please contact our Consumer Engagement team at DataPrivacy@ejgallo.com or the toll-free number.
- Submitting a Request Relating to Your Personal Data
Access and Data Portability. You can use this type of request to confirm whether we are processing your Personal Data, to access your Personal Data, and to obtain a copy of Personal Data you provided to us in a portable format.
Correction. You may request that we correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and our purposes for processing it.
Deletion. You may request that we delete your Personal Data, subject to exceptions.
Opt-Out Requests. You may opt out of the following uses of your Personal Data: (a) targeted advertising; (b) the sale of Personal Data; and (c) profiling in furtherance of decisions that produce legal or similarly significant effects concerning your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. We do not sell Personal Data in exchange for money or engage in practices that qualify as profiling producing legal or similarly significant effects under applicable state privacy laws. To opt out of targeted advertising and/or non-monetary “sales” of Personal Data via cookies, please click on the Do Not Sell or Share My Personal Information homepage link for each Gallo brand you have engaged with, and follow the instructions provided. To submit a request to opt out of offline sales and sharing, please contact our Consumer Engagement team at DataPrivacy@ejgallo.com or call us at 1-888-295-0247. If you are an authorized agent submitting an opt-out request on behalf of a consumer where allowed by law, please contact our Consumer Engagement team at DataPrivacy@ejgallo.com or call us at 1-888-295-0247. We use commercially reasonable efforts to authenticate the identity of the consumer to whom the request relates and the authorized agent’s authority to act on the consumer’s behalf.
Right to Appeal. Sometimes we are unable to process requests relating to your Personal Data, in which case, your request will be denied. If your privacy rights request has previously been denied by us and you believe we denied it in error, you may appeal for reconsideration of your request through our Consumer Engagement team at DataPrivacy@ejgallo.com or call us at 1-888-295-0247.
Please note that if you make a privacy rights request, we will retain a record of your request for recordkeeping purposes.
- Special Notice for Nevada Residents
- Visitors from Outside the United States
- Cookies and Other Tracking Technologies
Cookies are small files that a website transfers to your device through a web browser that enable the site’s or a third party’s systems to recognize your device and capture and remember certain information. Web beacons (also known as tracking pixels) are tiny graphics embedded invisibly on a webpage or in an email that may be used to deliver or communicate with cookies, to count users who have visited certain pages, and to understand usage patterns. In general, our websites use cookies and other tracking technologies as follows:
- Where necessary to run our websites, for example by allowing you to log in and add items to your cart/bag
- To optimize the functionality of our websites, including by personalizing content for you, greeting you by name and remembering your preferences (e.g., your choice of language or other preferences)
- For analytics purposes—for example, to help us understand how our websites are used, to see what products most interest you, and determine how best to market our products to you. More information on website analytics is provided below.
- For purposes of ad targeting and marketing. These cookies collect information about your browsing behavior on our websites in order to show you interest-based advertising when you visit other websites or use social media.
- To determine if our email messages have been opened and acted upon.
- To obtain information about your interactions with our online advertisements, such as whether you clicked on an ad and the website where you may have seen the ad.
If you do not want to have cookies placed on your device, you should set your browser to refuse cookies before accessing our website. Please review your browser’s Help menu for instructions or visit https://cookiepedia.co.uk/ for more information about cookies. Some of our websites may offer additional tools for managing cookies.
- Website Analytics
- Targeted Advertisements
- Do Not Track Signals
- Social Features on Our Websites and Apps
- Online Chat
- Session Replay
- Device IP Address
- Device screen size
- Device type (unique device identifiers)
- Browser information, geographic location (country only)
- Preferred language used to display our website
- Contact Preferences and Email Opt-Out
- SMS Messaging Opt-Out
- Not for Children
- Security
- Changes to This Privacy Notice
- How To Contact Us
Email address: DataPrivacy@ejgallo.com
Telephone number: 1-888-295-0247
Postal address: E. & J. Gallo Winery, Consumer Engagement, 600 Yosemite Blvd., Modesto, CA 95354