Privacy Policy
At Bolero & Company LLC (“the Company”), we are committed to protecting your privacy. This Privacy Policy applies when you visit our website www.chonguri.com, the websites of any of our brands that expressly link to this Privacy Policy including “www.bolero.ge”, and when you participate in a sales or marketing promotion, subscribe to any of our mailing lists, newsletters, or sign up for any of our events.
We refer to these products and services collectively as the “Services.”
“Personal Data” means data that reasonably can be used to identify a living person, or that reasonably relates to a living person.
Not Directed To Individuals Under The Legal Drinking Age
Our Site is not intended for people under the legal drinking age of 21. We do not seek or knowingly collect any Personal Data from or about individuals under the age of 21. If we become aware that we have unknowingly collected Personal Data from an individual under the legal drinking age, we will make commercially reasonable efforts to delete such information from our database.
Information We Collect
When you use our Services, you may provide us with information about you, including identifiers, such as your name, address, email address, phone number, date of birth, and commercial information such as credit card information and your purchasing or consuming histories. We use this information to process your requests and to communicate with you about your orders. Additionally, we may also use your name and contact information to notify you of changes to our Sites, new wines and releases, special offers, and events we think you will find valuable or of interest. If you do not wish to receive this information via email, you may opt out by clicking the “Unsubscribe” link at the bottom of the email. Alternatively, you may send an email to info@chonguri.com from the email address you would like removed and include the word “Unsubscribe” in the subject line.
When you use our Services, we collect certain internet or other electronic network activity information automatically as described in this section. As discussed further below, we and our service providers (which are third party companies that work on our behalf) may use a variety of technologies, including cookies and similar tools, to assist in collecting this information. We collect information on your use of the Services, such as pages visited, links clicked, non-sensitive text entered, and mouse movements, as well as information such as the referring URL, browser, operating system, and Internet Protocol (“IP”) address. We use publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address. We use the term “Usage Data” to refer to this information about your use of the Site that we collect. Our purpose in collecting Usage Data is to better understand how our visitors use the Site. We collect automatically information that may constitute Personal Data, such as IP addresses.
We perform ongoing demographic data gathering and analysis to complete data profiles and better understand our customers. Our purpose in collecting demographic data and completing customer profiles is to better understand our customers and provide the best experiences, services, and products in our offerings. We collect information that may constitute Personal Data, such as names, email addresses, phone numbers and addresses.
We collect this Personal Data to fulfill contracts, comply with laws and for our legitimate business interests. Our purposes for collecting and using this information include:
In some cases, we rely on your consent for processing your Personal Data, but only in those cases where we specifically ask for your consent.
Disclosure Of Your Information To Third Parties
In addition to informing you about our own products and services, from time to time, we may also share your information with select marketing partners who offer products or services that we believe will be of interest to you. Although we do not disclose your Personal Information for money, we may share Personal Data with our marketing partners, who may provide referrals or other benefits to us, and to our data hygiene service provider(s) who update and augment customer data profiles. Our marketing partners may use this information to contact you directly regarding their own offers of interest. The Personal Data we may disclose include: name, mailing and email addresses, phone number and demographic data. Such disclosures could be considered “sales” under certain laws, including the California Consumer Privacy Act (“CCPA”). You may choose to opt-out of having your Personal Data shared with these third-party companies by sending an e-mail to info@chonguri.com with the phrase “Do Not Share” in the subject line.
Additionally, we may disclose your information to third parties for other business purposes, such as if we conclude that we are required by law or have a good faith belief that access, preservation, or disclosure of such information is reasonably necessary to protect the rights, property, or safety of our Company, its customers, or the public. We may also contract with other companies and individuals to perform certain functions and services, including processing, storing, tracking, and organizing information on our behalf. These service providers may have access to Personal Data to perform their functions, but are prohibited from using Personal Data for direct or indirect marketing purposes or for any purpose other than providing services to us. We may disclose your information to a third party in connection with a corporate reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or capital, including in connection with any bankruptcy or similar proceedings.
Aggregate Information
We may track visits to the pages and links on our websites so we can make decisions about the design and usage of the Sites. We may choose to share this aggregate and de-identified information on consumer behavior to third parties.
Cookies And Related Technologies
As part of our ongoing efforts to ensure the best possible experience for all users of our Sites, we may use “cookies” and related technologies, such as tags, SDKs, tracking pixels, and other similar technologies to collect the information described in “Information We Collect Through Automated Means.” “Cookies” are small pieces of information that are stored by your browser on your computer’s hard drive. Cookies enable us to provide special features such as storing items in your shopping cart between visits, tailoring products or services offered to you based on past preferences or geographic location. Most Web browsers automatically accept cookies but allow you to turn off cookies as part of the browser options. Even without cookies, you can still use most of the features of our Sites, but you will be unable to place items in your shopping cart or make purchases.
We may use third-party web analytics services (such as those of Google Analytics) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.
Advertising And Third-Party Data Collection
We may enter into relationships with third-party advertising companies to drive traffic to and serve ads on our Sites. These third-party companies may also collect information through the use of their own cookies and other technology (including JavaScript and web beacons) to measure the effectiveness of their ads and to personalize advertising content. We do not have access to or control over cookies or other features used by these advertisers, and their information practices are not covered by this Privacy Policy. Please contact them directly for more information about their privacy practices. In addition, the Network Advertising Initiative offers useful information about Internet advertising companies (also called “ad networks” or “network advertisers”), including information about how to opt-out of their information collection, here.
Notice Concerning Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals.
Links to Other Sites
Occasionally we provide links to other websites for your convenience and information. These sites operate independently from our Sites and are not under our control. These sites may have their own privacy notices or terms of use, which you should review if you visit any sites linked through our Sites. We are not responsible for the content or use of these unrelated sites.
Data Subject Rights
Depending on your residency, you may have certain data subject rights. These rights vary by state and country, but they may include the right to: (i) request additional disclosures about the Personal Data we collect, use, disclose and sell; (ii) request access to and rectification or erasure of your Personal Data; (iii) restrict or object to the processing of your Personal Data; (iv) opt-out of the sale of Personal Data; and (v) obtain a copy of their Personal Data in a portable format. Where we rely on consent as the basis for processing Personal Data, individuals have the right to withdraw their consent. You may also have the right to lodge a complaint about the processing of Personal Data with a data protection authority, including if we deny your request.
How to Exercise Data Subject Rights
If you wish to exercise any of these rights, please email info@chonguri.com with the phrase “Data Subject Rights” in the subject line. We will review your requests and respond accordingly. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Additionally, if we retain your Personal Data only in de-identified form, we will not attempt to re-identify your data in response to a Data Subject Rights request.
If you make a request related to Personal Data about you, you will be required to supply a valid means of identification as a security precaution. For others, we will follow-up all requests with a phone call from the appropriate member of our team to verify your identity, and if your identity is verifiable, we will proceed with processing the request as directed by applicable law. For requests related to particularly sensitive information, we may require additional proof of identification.
If you make a Data Subject Rights request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.
We will process your request within the time provided by applicable law.
Data Retention
We retain Personal Data pursuant to our records retention program, for as long as is necessary for the purposes set out in the Privacy Policy, unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights.
The criteria used to determine the period for which Personal Data about you will be stored varies depending on why we process such Personal Data:
| Legitimate Business Interests | For a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects. |
| Contractual Necessity | For the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the limitation period for legal claims that could arise from the contractual relationship. |
| Legal Obligation | For the duration of time we are legally obligated to keep the information. |
| Consent | For the period of time necessary to fulfill the underlying agreement with you, subject to your right, under certain circumstances, to have certain Personal Data about you erased (see Data Subject Rights). |
We may face any threat of legal claim and in that case, we may need to apply a “legal hold” that retains information beyond our typical retention period. In that case, we will retain the information until the hold is removed, which typically means the claim or threat of claim has been resolved.
Transfers of Information Across Borders
Any information that you provide to us is stored and processed in, and transferred between, any of the countries in which we and our agents, contractors and affiliated organizations have offices, in order to enable us to use that information as set out in this Privacy Notice. This includes countries such as United States, Canada, and Hong Kong.
Not all of these countries have data protection laws equivalent to those in force in the EEA. The European Commission (in the EU) has yet to make a decision of adequacy in relation to the protection given to Personal Data in the United States and Hong Kong. In order to ensure the protection of your Personal Data we have put in place European Commission approved Standard Contractual Clauses between each of our entities.
Updates To This Policy
The terms of this Privacy Policy may change from time to time. We will notify you of any material changes to this Privacy Policy by changing the “Last Modified” date at the top of this Privacy Policy. We encourage you to check this page periodically for any changes. Your continued use of this Site following the posting of changes to this Privacy Policy will mean you accept those changes.
Governing Law
This Privacy Policy and our privacy practices will be subject exclusively to the laws of the New York State within the United States of America. We make no representation that this Privacy Policy and such practices comply with the laws of any other country. Visitors who use this Site and reside outside the United States do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. If you reside outside of the United States, by using our Site, you consent to the transfer and use of your information outside your country.
