PRIVACY POLICY FOR GALLO GATEWAY APPLICATION

Effective Date: January 31, 2023

This Privacy Policy describes how E. & J. Gallo Winery ("Gallo," "we," or "our,") collects, uses, and discloses your personal information when you use the Gallo Gateway web and mobile applications (together, the "App"). The App is designed to provide easy access to sales and marketing resources, and is intended for use solely by Gallo employees and authorized distributors. By downloading, using, creating an account, or registering to use the App, you consent to the collection and use of your Personal Information as described in this Privacy Policy.

I. HOW AND WHY THE APP USES PERSONAL INFORMATION

"Personal Information" is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated. The chart below summarizes the categories of Personal Information we collected through the App within the preceding 12 months and, for each category of Personal Information collected, the categories of sources from which that information was collected, the business or commercial purposes for which the information was collected and disclosed, and the categories of recipients to which the information was disclosed.

Category of Personal Information

Purposes for Collection, Use, and Disclosure

Categories of Sources from Which Collected

Categories of Recipients to which Information was Disclosed

Identifiers and Personal Records including such as a real name, alias, employee/user ID, IP address, email address, telephone number, or other similar identifiers
(Includes information described in Cal. Civ. § 1798.80(e).)

To facilitate your usage of the App

To communicate with you

To permit your participation in the App's Chatter groups

To support our sales and marketing

Auditing, research and analysis, maintaining and improving the App, and other business purposes

To detect and prevent fraud and abuse

Directly from you

Through technologies running on our App

Other users of the App

Our brands

Service providers that help us run our App, provide analytics, or communicate with you

Language Preferences

To facilitate your usage of the App

Auditing, research and analysis, maintaining and improving the App, and other business purposes

Directly from you

Our brands

Service providers that help us run our App, provide analytics, or communicate with you

Commercial Information, including product feedback, status as a distributor or employee, and likes or comments on posts in the App's Chatter wall

To facilitate your usage of the App

To support our sales and marketing

Auditing, research and analysis, maintaining and improving the App, and other business purposes

Directly from you

Through technologies running on our App

Other users of the App

Our brands

Service providers that help us run our App, provide analytics, or communicate with you

Internet or Other Electronic Network Activity Information, including App usage data, browsing history, search history, and information regarding interactions with the web and mobile versions of the App

To facilitate your usage of the App

To verify the location of Gallo product displays

To support our sales and marketing

Auditing, research and analysis, maintaining and improving the App, and other business purposes

To detect and prevent fraud and abuse

Directly from you

Through technologies running on our App

Other users of the App

Our brands

Service providers that help us run our App, provide analytics, or communicate with you

Geolocation Data, including precise geolocation

To verify the location of Gallo product displays

Auditing, research and analysis, maintaining and improving the App, and other business purposes

To detect and prevent fraud and abuse

 

When you enable Bluetooth and location tracking, the App uses Bluetooth to identify when your mobile device is in proximity to a Gallo product display. The App collects the GPS location of your device as a proxy for the location of the display

Geolocation may also be inferred from your IP address   

Our brands

Service providers that help us run our App, provide analytics, and support our marketing functions

 

Audiovisual Information, including photos and videos

To facilitate your usage of the App

To support our sales and marketing

Auditing, research and analysis, maintaining and improving the App, and other business purposes

Directly from you

Service providers that help us run our App, provide analytics, and support our marketing functions

Inferences reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

To support our sales and marketing

Auditing, research and analysis, maintaining and improving the App, and other business purposes

To detect and prevent fraud and abuse

Derived from other Personal Information we collect

Our brands

Service providers that help us run our App, provide analytics, or communicate with you

We may use and share information for any purpose if it is publicly available, de-identified, or aggregated with other information so that it can no longer identify you.

II. TECHNOLOGIES THAT AUTOMATICALLY COLLECT PERSONAL INFORMATION

As shown in the chart above, we collect your Personal Information through various means, including through technologies that automatically collect information about you when you use the App. For example, the web version of the App uses cookies to automatically collect and store information about how you interact with the App. The mobile version of the App includes software development kits ("SDKs"), which are blocks of code developed by our service providers and installed in our mobile App that allow us and our service providers to track user activity on our App and across devices. Cookies and SDKs help keep you logged in, support analytics, enable certain features on the App, and generally help us understand how you interact with our App. Analytics. We use Google Analytics to analyze how you interact with our App. This software may collect information such as your IP address, location, operating system, access time, duration of visit, and actions you take within the App. Google Analytics is owned and controlled by Google LLC. Data collected by Google is subject to its privacy policy. You may opt-out of having your activity on our website made available to Google Analytics by installing the Google Analytics browser add-on, available here.

III. OUR DISCLOSURES OF PERSONAL INFORMATION RELATED TO THE APP

The categories of third parties to which we ordinarily disclose Personal Information are described in the chart above. We may also disclose Personal Information:

We do not, and in the preceding 12 months did not, sell or share for cross-context behavioral advertising Personal Information relating to use of the App, including as the terms “sale” and “share” are defined under California law. If you also interact with us as a consumer, please review our California Consumer Privacy Notice for more information about our practices in that context. We do not use or disclose Sensitive Personal Information for purposes to which the right to limit use and disclosure applies under the California Consumer Privacy Act. We may use and disclose information for any purpose if it is publicly available, de-identified, or aggregated with other information so that it can no longer identify you.

IV. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We keep the categories of Personal Information described above for as long as necessary or permitted for the purposes described in this Notice or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:


Where Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires. For more information about our retention practices, please contact us using the contact details below.

V. CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you have the right to submit certain requests relating to your Personal Information under the California Consumer Privacy Act. To exercise any of these rights, please submit a request through our webform which can be found at www.gallo.com/contact, email us at DataPrivacy@ejgallo.com or call us at 1-888-295-0247. Please note that, if you submit a request to know, request to delete, or request to correct, we will ask that you verify your identity by providing provide 2-3 pieces of Personal Information that we will match against our records to verify your identity. If you have a password-protected account with us, we may verify your identity through our existing authentication practices for your account. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the Personal Information at issue.
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 using the webform or toll-free number listed above.

Right to Know. California residents have the right to request more information regarding the following:

  1. The categories of Personal Information we have collected about you, including:
    1. a. The categories of sources from which the Personal Information was collected
    2. b. Our business or commercial purposes for collecting or disclosing Personal Information
    3. c. The categories of recipients to which we disclose Personal Information
    4. d. 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
  2. The specific pieces of Personal Information we have collected about you
Right to Request Deletion of Personal Information. You have the right to request the deletion of Personal Information we collected from you, subject to certain exceptions. If we cannot delete all of your Personal Information, we will inform you of the reasons. Where we use deidentification to satisfy a deletion request, we commit to maintaining and using the information in deidentified form and will not attempt to reidentify the information.
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 Non-Discrimination. If you choose to exercise any of the privacy rights described above, you also have the right not to receive discriminatory treatment by us.

VI. INTERNATIONAL DATA TRANSFERS

If you access our App from outside the United States, please be aware that your Personal Information may be transferred to, stored, and processed in the United States, and that the data protection and other laws of the United States may not be as comprehensive as those in your country. By using our App, you consent to this transfer, storage, and processing.

VII. INFORMATION SECURITY

We have implemented appropriate and commercially reasonable physical, technical, and administrative safeguards to help prevent unauthorized access to, use of, and disclosure of, your Personal Information. However, there is no perfect security, and we cannot guarantee your Personal Information will always remain secure. You are responsible for maintaining the secrecy of any credentials used to access your account. If you suspect any unauthorized activity associated with your account, please report that activity to us immediately.

VIII. CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time, so you should check our website periodically for changes. Your continued use of our App after the effective date of any modification to the Privacy Policy will be deemed to be your agreement to the changed terms.

IX. HOW TO CONTACT US

If you have questions or comments regarding our Privacy Policy, you may contact us as follows: 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

This Privacy Policy is designed to be accessible to everyone, but if you have any difficulties accessing it in the format in which it is presented, please let us know.