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Privacy Policy

Treasury Wine Estates and your privacy

Treasury Wine Estates Limited and its related entities and brands (“TWE,” “we” or “us”) are committed to protecting the privacy of individuals’ personal information. This Privacy Policy applies to the information we collect about you (“personal information”) in the course of our business, including through our websites, mobile applications, and services that link to this Privacy Policy and our related marketing activities, research, and other related offline offerings operated by or on behalf of TWE (collectively, the ”Services”). Please do not provide us with your personal information if you are not of legal age to purchase alcohol in the jurisdiction where you live or if you do not agree to the terms in this policy.

This Policy applies across all jurisdictions in which TWE conducts business. Residents in various regions (for example, California and the People’s Republic of China (“PRC”)) can find additional information in region-specific subsections below. Where there is any conflict between the region-specific subsection and the generalized provisions, the region-specific subsection controls. 

This Policy applies to consumers’ personal information and not employee or applicant personal information. If you are an employee or applicant, your People and Culture or recruiting contact can provide information on TWE's employee and applicant-related privacy practices.

1.    Summary

This Policy explains how TWE collects, uses, and discloses information about you, and your rights and choices with respect to such information. Below is a summary of our practices; please read the full Policy for more details:

  • Information we collect: We collect information directly from you when you interact with us (e.g., when you purchase wine, sign up for mailing lists, or enter a contest), as well as automatically through the use of cookies and similar technologies. We do not knowingly collect information from individuals under the legal drinking age.
  • Use of your information: We use your information for a variety of purposes, including to fulfill orders, provide and personalize the Services, support website functionality, improve the Services, secure the Services, advertise and market the Services, defend and exercise our rights, and as required by law.
  • Disclosure of information: We disclose information to our service providers and contractors, as well as to third parties that provide advertising and advertising analytics services, and social media services. We may also disclose information in connection with a business transaction, at your direction, or as otherwise required by law.
  • Data retention and security. Generally, we will retain your information for the period necessary to fulfil the purposes for which we collected it, and take a variety of measures to keep that information secure.
  • Your Rights and Choices: Depending on where you live, you may have the right to request access to, or correction or deletion of, your information, and to opt out of “sales” and targeted advertising. You may also opt out of receiving marketing communications from us.

Our full Policy contains additional information for residents of California and the PRC; please see below for more details.

2.    Information We Collect

The information we collect about you depends on the Services you use, how you use them, and how you otherwise interact with us. We collect information when you provide it directly to us, and through automated technology when you use the Services. Although you can decide whether to provide information to TWE, in some instances, the provision of information to us is required to allow us to provide the Services.

A. Information you provide to us

We collect personal information that you provide to us. This includes information you provide us when corresponding with us, entering our competitions, buying our wines, selling goods or services to us, visiting us at our cellar doors or tasting rooms, becoming a member of a wine club, or when using or registering on our websites. This category also includes information that you provide to us through TWE-branded ads on third-party websites, including social media sites.

B. Information collected through automated technologies

Apart from the information you give us directly, we and our vendors also automatically collect information about you when you visit our websites, including through the use of cookies, tags, pixels, web beacons, and similar automated tracking technologies. Cookies are small data files that are downloaded onto your computer when you visit a particular website. Pixels work similarly, but the information is sent to a third-party server. For purposes of this policy, we collectively refer to these tracking technologies as “cookies.” The information we and our vendors collect via cookies may include information such as:

  • technical information such as your computer’s IP address, device or cookie ID, hardware type, browser type, operating system, device identifier and screen type/resolution;
  • any search terms entered on our website;
  • general location data based on your device or IP address;
  • any technical errors or exceptions; and
  • information about your visit such as the products you viewed or searched for, the length of your visit, time visited, page load speed, and the pages that you visited.

Cookies help us gather and store information about visitors to our websites. They help our websites remember what you chose on previous pages (to avoid having to re-enter information) and can help us to identify you as a unique visitor, tailor content based on past visitation and provide you with an optimised experience. They can also help us understand when you have found our brands or products through third-party websites.

We use the following general categories of cookies on our websites (though the exact wording and category names may change depending on the specific TWE website you are using):

  • Essential (required);
  • Performance;
  • Functionality;
  • Targeting, advertising, or marketing;
  • Statistics;
  • Unclassified.

If you prefer not to have your non-essential cookies tracked, you can choose this option when visiting our websites. However, some parts of our websites will not function if cookies are turned off. We therefore strongly recommend that you leave cookies fully functional. For more information about cookies please see https://www.allaboutcookies.org/cookies/. For information about how to manage cookies, including how to disable cookies in most Internet browsers, see here. You can also opt-out of targeted ads from Facebook and Google by visiting

www.facebook.com/help/568137493302217
or
https://support.google.com/ads/answer/2662922?hl=en-AU.

3.    Our use of your information

We may use or disclose the personal information we collect for one or more of the following purposes in order to conduct our business and pursue our legitimate business interests:

  • To fulfill or meet the reason you provided the information. 
    • For example, if you provide your personal information to purchase our products, we will use that information to process and manage your order.
  • To provide, support, personalize, and develop the Services and to help us gain a better understanding of your preferences in order to improve the Services and products we offer.
  • To help maintain the safety, security, and integrity of the Services, and our business.
  • To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, third-party sites, and via email or text message (consistent with any consent elections you have made, as required by applicable law)(This article does not apply to personal information collected within the territory of the PRC).
  • To allow you to participate in interactive features of our websites and administering our promotions and competitions.
  • To verify that you are of legal drinking age in your jurisdiction (if applicable).
  • To fulfill a contract we may have with you, such as where you make a purchase from us, sell us goods and services, or enter one of our competitions.
  • In connection with legal claims, compliance, regulatory and investigative purposes as necessary (including to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations).
  • To analyze usage of our Services and produce consumer insights (e.g., general research on our consumers; conduct consumer testing, surveys, and panels; data analytics and modeling).
  • As described to you when collecting your personal information.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TWE's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by TWE about our website users is among the assets transferred.
  • For other purposes for which you provide your consent.

4.    Our disclosure of your information

There will be times when we disclose your personal information to others for the purpose of providing services to you, to facilitate our legitimate interests or if you consent. We do so for the same reasons explained in the “Our use of your information” section, above. 
We may disclose your information to:

  • Internal TWE Entities and Brands in the performance of our business and for the purposes described in the “Our use of your information” section, above. You can find a list of our brands here.
  • Service Providers who globally support our business and help us administer certain activities on our behalf, such as providing technical infrastructure services, marketing services, customer service, data hosting and management services, processing credit card payments services for us, and providing logistics and delivery services to help us deliver our products and services. The specific entities that receive your personal information will depend on why we are using the information.
  • Contractors and Third Parties, including those that provide advertising, content, or other functionality, and those that provide information technology implementations and formal audits. Third parties may collect or receive certain information about you and/or your use of the Services to provide ads (including targeted ads), content, or functionality, or to measure and analyze ad performance, on our Services or other websites or platforms.
  • Social Media Services, if you log into the Services with a social media service or if you connect a social media account with the Services. In that case, we may disclose certain of your personal information to that social media service depending on your settings. The social media service’s privacy policy then applies to their practices regarding your information.
  • Other Parties When Required by Law or As Necessary to Protect Our Users and Services including as we believe is necessary or appropriate to protect, enforce, or defend the legal rights, privacy, safety, or property of the Services, our employees or agents or users, or to comply with applicable law or legal process, including responding to requests from public and government authorities.
  • Other Parties in Connection with a Corporate Transaction. We may disclose information we have about you in the event that we sell or transfer all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition, or in connection with a bankruptcy reorganization, or in contemplation of or due diligence related to such a corporate transaction.
  • Otherwise With Your Consent or At Your Direction. We may also disclose information about you with third parties whenever you consent to or direct such sharing.

5.    How long we keep your information

We retain the data we collect for different periods of time depending on what it is and how we use it. Generally, we will retain your personal information for the period necessary to fulfil the purposes for which your personal information has been collected unless a longer retention period is required by law.

6.    Your rights and choices

A. Privacy Rights

If you reside in certain jurisdictions, including but not limited to the European Economic Area (EEA), United Kingdom, and certain US states (such as California, Colorado, Connecticut, Oregon, Montana, Texas, Utah, and Virginia) you have certain rights regarding your personal information. These rights may include the following:

  • The right to access your personal information;
  • The right to rectification/correction of inaccurate personal information;
  • The right to erasure/deletion of your personal information under specific circumstances;
  • The right to object, on grounds relating to your particular situation, to your personal information being processed on the basis of legitimate interests;
  • The right to opt out of the sale or processing of your personal information for targeted ads;
  • The right to request the restriction of processing of your personal information;
  • The right to data portability—receiving your personal information in a format that can be transmitted to another company or system—where technically feasible;
  • The right to withdraw your consent to certain types of processing;
  • The right to not be discriminated against for exercising your rights; and
  • The right to lodge a complaint with the relevant data protection supervisory authority.

However, these rights may be limited, for example if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.

If you live outside of a jurisdiction that requires these rights, we retain full discretion to extend these rights to you.

If you wish to exercise these rights please visit our privacy portal.  For information about opting out of the sale or processing for targeted ads see below.

We will take reasonable steps to verify your identity prior to fulfilling the above requests, such as by verifying your name and email address.

In certain locations, authorized agents may submit requests on behalf of a consumer. We will verify the agent’s authority and may also follow up with you to verify your identity before processing the authorized agent’s request.

In certain jurisdictions, you may have the right to appeal the denial of a request.  You can do so by following the instructions in our communication with you.

Certain personal information may be exempt from such requests under applicable law. In addition, we need certain types of personal information so that we can provide products and Services to you. If you ask us to delete it, you may no longer be able to access our products and Services. 

B. Opting out of electronic marketing communications from TWE

If you receive electronic marketing communications from us, we will always provide you with an opportunity to withdraw your consent and unsubscribe from receiving further information from us by, for example, clicking on the unsubscribe link provided in the communication or sending a simple text message in response.

Please note that even if you opt out, we may still send you email communications for transactional or legal purposes, such as updates about orders you have placed with us or notices of updates to our terms and privacy policies.

C. Opting out of the sale or processing for targeted ads

If you are a California, Colorado, Connecticut, Montana, Oregon, Texas, Utah or Virginia resident, you may opt out of the sale or processing of your personal information, including for targeted advertising, under applicable law. Targeted advertising is when we or our partners display ads to you based on your personal information that is collected across different businesses.

We and our advertising partners collect certain information from our visitors, such as device identifiers, cookies, advertising IDs, IP addresses and usage activity. We and our ad partners share this information with third parties or combine it with information from other businesses to deliver more relevant (targeted) ads to you and for related advertising activities. This activity is known as “sharing” or processing your personal information for targeted ads and may be considered “selling” your personal information under applicable law.

If you (or, where applicable, your authorized agent) would like to opt out of activities that constitute “sharing” or “selling” your personal information, please click the “Cookie Preferences” (or similarly-named) link at the bottom of our sites, click "Change your consent"  and/or "Customize" (where applicable), turn off the toggle for “Advertising” or "Marketing" cookies, and click “Save Preferences” or "Allow Selection." Note, if you use a cookie blocker such as Ghostery, it may block visibility of this tool or link, including in your web footer. You may also need to submit a request through TWE’s privacy portal.

Even if you opt out, you will still see advertising, it just may be less relevant to you. Your preference may be lost if you clear, or your browser is set to clear, cookies. If you have enabled a legally recognized browser-based opt out preference signal (such as Global Privacy Control) on your browser, we recognize such preference in accordance and to the extent required by applicable law. You will need to turn this on for each device and browser you use.

7.    Security

We take appropriate measures to keep your personal information secure. We have implemented appropriate physical and electronic procedures to protect the personal information we collect.

If you have an account with us, you are responsible for maintaining the confidentiality of your account details including your password, and are responsible for any activity under your account. We will not be responsible for any loss arising from your failure to comply with this obligation.

8.    Contact Us

If you have any questions or concerns about our collection, use or disclosure of personal information, wish to exercise your rights in relation to data protection or you wish to make a complaint in relation to our privacy practices, please visit our privacy portal.

If you have a complaint or concern about how we use your personal data, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You also have a right to lodge a complaint with your national data protection supervisory authority at any time.

For the purposes of the EU General Data Protection Regulation and the Data Protection Act in the UK, the data controller is Treasury Wine Estates EMEA Ltd of Regal House, 70 London Road, Twickenham, Middlesex, TW1 3QS.

9.    Third Party Websites

Our websites sometimes contain links to other websites. With the exception of other sites owned by us, we do not control the privacy practices of sites reached through links from our websites. Please note that you should carefully read and agree with third party’s privacy practices before visiting third party’s website. If you have any questions about the privacy practices of those websites then you should contact the relevant companies directly.

10.    Children’s Privacy

TWE does not knowingly collect or disclose any personal information from children under the age of 18. If TWE learns that a child under the age of 18 has submitted personal information without parental consent, we will take reasonable measures to delete the information as soon as possible and to not use such information for any purpose, except where required or allowed by law. If you believe a child under the age of 18 has provided us with personal information, please contact us as described in Contact Us, above.

11.    International Users

A. Cross-Border Transfers

In some cases, providing the Services involves transferring your personal information to other countries (including those outside the European Economic Area) for the purposes of data processing and storage (including if applicable, to fulfil any orders you have placed with us). Depending on the location of the brand, winery or office you engage with or register with, transfers are made to Australia, USA, UK, People’s Republic of China, Singapore and other countries where we operate. We have taken steps to ensure that your personal information is appropriately protected and is processed only in accordance with this Policy.

B. Legal Basis for Processing

Our use of your information is described in more detail in the “Our use of your information” section, above. Where applicable under the GDPR or similar laws, the legal basis for our processing of your personal information may include any of the following:

  • Performance of a contract.
  • Consent.
  • Compliance with a legal obligation.
  • TWE's legitimate interests that are not overridden by your interests or your fundamental rights and freedoms.

12.    Additional Information for California Residents

If you are an eligible California resident, the California Consumer Privacy Act and California Privacy Rights Act (together, the “CCPA”) require us to provide you with specific information about our collection and use of your personal information and your rights with respect to your personal information. This California Privacy Rights Section supplements this Privacy Policy and applies solely to eligible California consumers. Any terms not defined in this section have the same meaning as defined in the CCPA.

A. Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, TWE has collected the following categories of personal information from its consumers within the last twelve (12) months:

A. Identifiers (such as your name, email, postal address, and device identifiers);

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (such as postal address and telephone number);

C. Protected classification characteristics under California or federal law (such as gender);

D. Commercial information (such as products purchased through the Services);

E. Internet or other electronic network activity information (such as browsing history and interactions with our website)

F. Geolocation data (such as general location inferred from your IP address, or if you choose to interact with location-based activities, your device’s location within a “geofence”);

G. Inferences drawn from other personal information (such as inferences about your preferences, characteristics, or similar behavioral information).

H. Sensitive personal information, specifically: (1) 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; and (2) precise geolocation information.

Please note that some of the categories of personal information described in the CCPA overlap with each other; for instance, your name is both an Identifier and a type of data described in Cal. Civil Code 1798.80(e).

TWE obtains the categories of personal information listed above directly from you (for example, from forms you complete or products and services you purchase) and/or indirectly from you (for example, via our use of cookies and similar technologies on our Website).

B. Use and Disclosure of Personal Information

We may use or disclose the personal information we collect for the purposes described in the “Our use of your information” Section above.

C. Opt Out of Selling/Sharing Personal Information

We and our advertising partners collect certain information from our visitors, such as device identifiers, cookies, advertising IDs, IP addresses and usage activity and share this information with third parties or combine it with information from other businesses to deliver more relevant (targeted) ads to you and for related advertising activities. This activity is known as “sharing” and may be considered “selling” your personal information under the CCPA.

If you (or, where applicable, your authorized agent) would like to opt out of activities that constitute “sharing” or “selling” your personal information, please click the “Cookie Preferences” (or similarly-named) link at the bottom of our sites, click "Change your consent"  and/or "Customize" (where applicable), turn off the toggle for “Advertising” or "Marketing" cookies, and click “Save Preferences” or "Allow Selection." Note, if you use a cookie blocker such as Ghostery, it may block visibility of this tool or link, including in your web footer. You may also need to submit a request through TWE’s privacy portal.

Even if you opt out, you will still see advertising, it just may be less relevant to you. Your preference may be lost if you clear, or your browser is set to clear, cookies. If you have enabled a legally recognized browser-based opt out preference signal (such as Global Privacy Control) on your browser, we recognize such preference in accordance and to the extent required by applicable law. You will need to turn this on for each browser you use.

D. Your California Privacy Rights

California residents have the following rights with regard to their Personal Information, as that term is defined in the California Consumer Privacy Act (“CCPA”):

  • The right to know i.e., our disclosure of categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.)
  • The right to access specific pieces of Personal Information we maintain about you
  • The right to deletion of Personal Information
  • The right to correct inaccurate Personal Information we maintain about you

To exercise any of these rights, please visit our Privacy Portal.

We will take reasonable steps to verify your identity prior to fulfilling the above requests, such as by verifying your name and email address. If we are able to verify your identity, we will respond to your request to the extent we are able to and as required by law. If we cannot verify your identity, we may request additional information from you or we may deny your request. If we are unable to fulfill your request(s) in their entirety, we will provide further information to you about the reasons that we could not comply with your request.

Authorized Agents may submit requests on behalf of a California resident. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

Certain personal information may be exempt from such requests under applicable law. In addition, we need certain types of personal information so that we can provide products and Services to you. If you ask us to delete it, you may no longer be able to access our products and Services. We do not discriminate against any consumer for exercising their rights under the CCPA.

E. Your Rights Under “Shine the Light”

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes.

13.    Relevant provisions of the PRC on personal information protection 

A. About Us

The "Relevant provisions of the PRC on personal information protection" Section is a supplement to the information contained in this Privacy Policy and shall be applicable to the processing of personal information collected within the territory of the PRC by Treasury Wine Estates (Shanghai) Trading Co. Ltd. [registered address: Room 2601A, 2608-2610, Building 5, Hubin Road No. 150, Huangpu District, Shanghai] and its affiliates ("we"). The “affiliates” refer to the affiliated companies disclosed in the latest annual report of Treasury Wine Estates.

B. Information We Collect

Under the PRC Personal Information Protection Law, personal information refers to all kinds of information related to identified or identifiable natural persons recorded by electronic or other means, excluding the information processed anonymously. Sensitive personal information refers to the personal information that is likely to result in damage to the personal dignity of any natural person or damage to his or her personal or property safety once disclosed or illegally used.

Based on the principles of lawfulness, legitimacy and minimum necessity, we collect and use the following of your information through websites, Apps, H5 pages, consumer hotlines, offline written documents and other channels for the sole purpose of this Privacy Policy:

I.    Personal information

Collected: Yes

This category include:

  • Basic information: your WeChat nickname, WeChat profile picture, location, username, name, gender, nationality, date of birth;
  • Contact Information: email address, phone number;
  • Information required for logistics distribution: postal address;
  • Your preferences and interests;
  • Information you disclose voluntarily when you contact us;
  • Login data such as your IP address, your terminal specificities and your logs.
II.    Sensitive personal information

Collected: Yes

Examples: This category may include: your credit card number, payment account information, ID Number.

III.    Other rules for collecting and using personal information

In order to ensure the smooth provision of services to you, please ensure that the personal information you provide is true and valid, and complies with relevant laws and regulations. For example, your account information and any information you submit and publish must not contain any content that violates laws and regulations, has adverse effects and infringes the rights and interests of third parties. If the information you provide contains personal information of a third party, you need to ensure that you have obtained legal authorization and ensure the authenticity and legality of such information.

Please understand that the functions and services we provide to you are constantly updated and developed. If a product or service (such as small-scale testing, experimental functions, etc.) does not inform you of the processing rules for collecting and using your personal information in the foregoing description, we will inform you of the purpose, method and scope of information collection through page presentation, interactive text, website announcement, etc., and obtain your consent.

C. Sharing

We will not share your personal information with any company, organization or individual except in the following cases:

  • After obtaining your express consent or authorization;
  • Sharing under legal circumstances;
  • Sharing with our affiliates;
  • Sharing with third party partners.

You can obtain the name, contact information, processing purpose, processing method and type of personal information of the third party by sending us a request by either:

  • calling us at +86 21 23130300
  • sending us an email to Privacy@tweglobal.com
D. Entrustment

To ensure the smooth performance of the services we provide to you, we may entrust third parties such as our business partners to process your personal information. Based on the principles of lawfulness, legitimacy, necessity, specificity and clarity, we will only entrust the third parties to process the personal information necessary to provide the services. The third parties are not authorized to use the personal information for any other purpose.

Currently, there are no instances where we entrust the processing of your personal information to a third party.

E. Transfer of Personal Information

We will not transfer your personal information to any company, organization or individual, except for the following circumstances:

Obtaining your express consent or authorization;

In the case of merger, acquisition or liquidation. If personal information is transferred in such cases, the company or organization (hereinafter “recipient”) that newly receives your personal information will continuously be bound by this Privacy Policy. Meanwhile, we will inform you of the name and contact information of such recipient in a reasonable manner. If the recipient changes the original processing purpose and method, your consent will be asked again.

F. Public Disclosure of Personal Information

Except as necessary to display the relevant desensitization information when announcing the winning account, when we confirm your violation of laws and regulations or the relevant agreement and rules signed with us, or with your separate consent, we will not make public disclosure of your personal information.

G. Cross-border Transfer of Personal Information

In principle, the personal information that we collect or generate within the territory of the PRC will be stored within the territory of the PRC.

For the need of unified management of TWE, we will share your personal information to third parties located in countries or regions outside of the PRC (such as Australia) to provide relevant services. The privacy-related laws of these countries or regions may differ from those of the PRC. We will comply with the personal information protection laws of the PRC and endeavour to ensure that these third parties who obtain your personal information will provide similar and/or comparable personal information protection measures.

  • The current status of cross-border transfer of personal information is as follows:
    • Name of Overseas Recipient: Treasury Wine Estates Vintners Limited
    • Contact Information: Privacy@tweglobal.com
    • Purpose of Processing: Secure backup
    • Method of Processing: Storage of personal information
    • Type of Cross-border Personal Information:
      • Personal information:

a)    Basic information: your WeChat nickname, WeChat profile picture, location, username, name, gender, nationality, date of birth;
b)    Contact Information: email address, phone number;
c)    Information required for logistics distribution: postal address;
d)    Your preferences and interests;
e)    Information you may disclose when you contact us;
f)    Login data such as your IP address, your terminal specificities and your logs.

      • Sensitive personal information: your credit card number, payment account information, ID Number.

Other than above, TWE has no personal information cross-border transfer activities in terms of end consumers. We will separately disclose information related to the cross-border transfer of personal information to the relevant subjects.

H. Security

We have implemented appropriate physical and electronic procedures to protect the personal information we collect as described in the “Security” Section above.

I. Your Rights & Choices

(a) Accessing, Copying, Correcting or Supplementing Your Personal Information

You have the right to access, copy, correct and supplement your personal information, unless otherwise provided for by laws and administrative regulations.

(b) Deleting Your Personal Information

You have the right to request us to delete your personal information in the following situations:

  • If our purpose of processing has been fulfilled, is unable or no longer necessary to be fulfilled;
  • If we cease to provide products or services, or the storage period has expired;
  • If you withdraw your consent; and
  • If we process personal information in violation of laws, administrative regulations or the agreement;
  • Other circumstances stipulated by laws and administrative regulations.

(c) Obtaining a Copy of Your Personal Information

You have the right to obtain a copy of your personal information. On the premise of meeting the conditions specified by the national cyberspace department, and where technically feasible, for example the data interface can be matched, we may also transfer a copy of your personal information directly to a third party designated by you at your request.

(d) Changing the Scope of Your Consent or Withdrawing Your Authorization
You have the right to change the scope of your consent for us to continue processing your personal information or withdraw your authorization at any time by contacting us.

Please understand that after you withdraw your consent or authorization, we may not be able to continue to provide part or all services related to such consent or authorization and will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the processing of personal information already carried out based on your previous consent or authorization.

(e) Other Personal Information Rights

According to the relevant provisions of the Personal Information Protection Law, you also have the following personal information rights:

  • Require us to explain this Privacy Policy;
  • In some business functions, we may only make decisions based on the non-manual automatic decision-making mechanism, including algorithms. If these decisions affect your lawful rights and interests, you can contact us at any time. In the interface using personalized push, we will publish the principles, rules and other information of personalized recommendation;
  • In the event of the decease of a natural person, his or her close relatives may exercise the rights to the relevant personal information of the decedent for their own lawful and legitimate rights and interests, unless otherwise arranged by the decedent prior to his or her death.

(f) Exercising Your PRC Rights Related to Personal Information Protection

To exercise your rights described above, please submit a verifiable consumer request to us by either:

  • calling us at +86 21 23130300
  • sending us an email to Privacy@tweglobal.com

(g) Response Time and Format

For security purposes, we may require you to provide a written request or otherwise prove your identity before we process your request. We will respond to your request within 15 working days after we have received your feedback or within the time limit specified by laws and regulations.

In principle, we do not charge any fees for your reasonable requests. However, we will charge certain fees, depending on the circumstances, for repetitive requests that exceed reasonable limits. We may refuse requests that are unwarrantedly repetitive, require excessive technical measures (for example, require the development of new systems or fundamental changes to existing practices), pose risks to the legitimate rights and interests of others, or are highly impractical (for example, involve the backup of information stored on tapes).

If you are not satisfied with our reply, especially if you think that our personal information processing behavior has damaged your lawful rights and interests, you can also seek a solution by filing a lawsuit with the court with jurisdiction in the defendant's domicile, or enjoy the right to lodge complaint and report according to law.

J. Rules for Processing Sensitive Personal Information

We may collect your sensitive personal information, and we will obtain your separate consent before collecting your sensitive personal information.

(a) Necessity of Processing Sensitive Personal Information

The sensitive personal information we may collect includes: your credit card number, payment account information, ID Number. In product sales and other activities, such sensitive personal information will be used for identity verification, transaction confirmation, payment and settlement, delivery, order enquiry, customer service consultation and after-sales service. To protect your transaction security, we will also use it to determine whether there is any abnormality in your transaction.

(b) Impact on Your Rights and Interests

If your sensitive personal information is disclosed or illegally used, it may result in damage to your personal dignity or damage to your personal or property safety.

Please be aware that we have taken strict measures to protect your sensitive personal information from disclosure or illegal use.

In case of security incidents such as personal information disclosure, we will initiate the emergency plan in accordance with the law, and inform you of the relevant situation, impact and measures to be taken by pushing notices, announcements or otherwise.

K. Protection of Personal Information of Minors

TWE does not collect any data or information concerning persons who are under the age of 18, which is the threshold for legally alcohol drinking and/or purchasing in the PRC. We will try to delete the relevant information as soon as we are expressly aware that the user is under the age of 18.

Please do not provide us with your personal information if you are under the age of 18. Please consciously comply with this integrity obligation so that we can better protect your personal information.

L. Retention of Personal Information

Generally, we will retain your personal information for the period necessary to fulfil the purposes for which your personal information has been collected (as outlined in this Privacy Policy) unless a longer retention period is required by law.

Where we process registration information, we retain this for as long as we consider that you are an active user of our sites and for 2 years after this.

Where we process personal information for marketing purposes or with your consent, we process the information until you ask us to stop and for a short period after this (to allow us to process your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your information indefinitely so that we can respect your request in future.

Where we process personal information in connection with performing a contract (such as when you purchase wine from us) or for a competition, we keep the information for 3 years from your last interaction with us.

Where we process personal information for site security and/or fraud management purposes, we retain it for 3 years.

After the retention period of personal information expires, we will delete, anonymize the personal information, or process it in other alternative manners approved by laws and regulations.

M. Scope of Application

“Relevant provisions of the PRC on personal information protection” shall be applicable to processing of personal information within the territory of the PRC. If there is any inconsistency between the “Relevant provisions of the PRC on personal information protection” Section and other sections of this Privacy Policy, the “Relevant provisions of the PRC on personal information protection” Section shall prevail.

14.    Effective Date of Policy

This Privacy Policy is effective and was last updated in July 2025.

We may update this Privacy Policy from time-to-time by posting a new version. We will also inform you of changes to the Privacy Policy in conspicuous ways.

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