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CCPA

This Supplemental Privacy Notice applies solely to California residents


January 01, 2020

California Residents Only

This Supplemental Privacy Notice applies solely to California residents. It applies to Personal Data we collect as a business; it does not apply to Personal Data we collect or otherwise process as a service provider.

California law makes a distinction between organizations that process Personal Data for their own purposes (known as “Businesses”) and organizations that process Personal Data on behalf of other organizations (known as “service providers”). Depending on the circumstances, CellarPass may act as either a business or service provider with respect to your Personal Data. If you have a question or a complaint about how your Personal Data is handled, these should always be directed to the relevant business since they are the ones with primary responsibility for your Personal Data.

For example, if you generate an account with us to manage and organize your activities and/or events, CellarPass will be a business with respect to the Personal Data that you provide as part of your account.  We will also be a business as to the Personal Data that we have obtained about the use of the Services, which could relate to Businesses or Guests.  We use this to conduct research and analysis to help better understand and serve Users of the Services as well as to improve our platform and provide you with more relevant recommendations about services or products we think may be of interest to you. 

However, if you register for an activity or event as a Guest, we will process your Personal Data to help administer that activity or event on behalf of the Business (for example, sending confirmation, promotional, and feedback emails, processing payments, etc.) and to help the Business manage their event, target, and understand the success of their event and event planning (for example, providing event reports, guest lists, using analytics to determine effectiveness of various sales channels, etc..). In these scenarios, CellarPass just provides the tools for Businesses; CellarPass does not decide what Personal Data to request on registration forms, nor is it responsible for the continued accuracy of any Personal Data provided. Questions that you may have relating to your Personal Data and your rights under California law should therefore be directed to the Business, not CellarPass.

Information We Collect

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

We may collect the below categories of information for the following business or commercial purposes (as those terms are defined in applicable law):

  • Our or our service provider’s operational purposes;
  • Auditing Guest interactions on our site (e.g. measuring ad impressions);
  • Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
  • Bug detection and error reporting;
  • Customizing content that we or our service providers display on the Services (e.g., contextual ads);
  • Providing the Services (e.g., access to your account and maintenance, order processing and fulfillment, customer service, advertising and marketing, analytics, and communications about the Services);
  • Improving our existing Services and developing new services (e.g. by conducting research to develop new products or features);
  • Other uses that advance our commercial or economic interests, such as third-party advertising and communicating with you about relevant offers from third party partners;
  • Other uses about which we notify you.

Examples of these types of uses are identified below

We may also use the above categories of Personal Data for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.

Your Rights as a California Resident

  • If you are a California resident, you may have certain rights. California law may permit you to request that we:
  • Provide you the categories of Personal Data we have collected or disclosed about you in the last twelve (12) months; the categories of sources of such information; the business or commercial purpose for collecting or selling your Personal Data; and the categories of third parties with whom we shared Personal Data.
  • Provide access to and/or a copy of certain information we hold about you.
  • Delete certain information we have about us.

You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services. Deleting Personal Data may also negatively affect existing reservations or registrations for activities or events that you have registered for are scheduled to take place after the date of your Personal Data deletion request.

If you would like to exercise any of your California Consumer rights, please submit a request to legal@cellarpass.com.  You will be required to verify your identity before we fulfill your request. To do so, you will need to provide us with certain account information, such as the full name and email address you used to create the account and your most recent activity or ticket purchase.  You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization for the agent to act on your behalf. You will still need to verify you identify directly with us.

The CCPA sets for certain obligations for businesses that “sell” Personal Data. Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity.  We do share certain information as set forth in section 4 of the Privacy Policy and allow third parties to collect certain information about your activity, for example through cookies, as explained in our Cookies statement.

California Shine the Light

We do not share personal data with third parties for their direct marketing purposes.

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Contact Author
Sarah Elliman

CellarPass
(855) 423-4448 ext 304
Email