' Privacy Policy - Orin Swift

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
1. How can a consumer with a disability access this Notice? 
2. Notice at Collection 
3. California Privacy Rights 
4. California Notice of Financial Incentive 
5. Additional Information for Consumers in Other US States 
6. Visitors from Outside the United States 
7. Cookies and Other Tracking Technologies 
8. Website Analytics 
9. Targeted Advertisements 
10. Do Not Track Signals 
11. Social Features on Our Websites and Apps 
12. Online Chat 
13. Session Replay 
14. Contact Preferences and Email Opt-Out 
15. SMS Messaging Opt-Out 
16. Not for Children 
17. Security 
18. Changes to This Privacy Notice 
19. How To Contact Us 

1. How can a consumer with a disability access this Notice? 

Consumers who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this notice. If this notice is needed in an alternative format, please call us at 1-888-295-0247. 


2. Notice at Collection 

This Notice applies to your Personal Information. “Personal Information” (a/k/a “Personal Data”) is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include information that is deidentified, aggregated, publicly available, or lawfully obtained, truthful information that is a matter of public concern. 

A. How and Why We Collect Personal Information 

We have set out below the categories of Personal Information we collect about consumers, and for each category of Personal Information collected, the categories of sources from which that information was collected, and the business or commercial purposes for which the information was collected. 

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Among the categories listed above, are the following types of sensitive Personal Information:

In addition to the other purposes for collection, use, and disclosure of Personal Information described in this Notice, we may collect, use, and disclose Personal Information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our (or others) rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may use and disclose Personal Information to third parties in connection with the sale, assignment, merger, reorganization, or other transfer of any of our brands or companies. 

B. Retention of 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: 

    • 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. 

      Where 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 policies, please contact us using the contact details below.  

C. Disclosure of Personal Information

We disclose PPersonal IInformation as indicated below. The first chart shows the categories of Personal Information we disclose to our service providers and contractors for a business or commercial purpose. Although we do not sell Personal Information in exchange for money, some of our advertising, marketing, and analytics practices may be classified as “sales” or “sharing” under some state privacy laws. The second chart shows the categories of Personal Information we share for purposes of targeted / cross-context behavioral advertising, or otherwise “sell” for non-monetary consideration. We do not have actual knowledge that we sell or share the Personal Information of consumers under 16 years of age. 

i. Disclosures for a Business or Commercial Purpose

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ii. Sales and Sharing of Personal Information

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3. California Privacy Rights
If you are a California consumer, you have the right to submit certain requests relating to your Personal Information under the California Consumer Privacy Act (“CCPA”). To exercise any of these rights, please submit a request through our Contact Us webform on this site 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 About Personal Information Collected, Disclosed, Sold, or Shared. California consumers have the right to request more information regarding the following:

(1)    The categories of Personal Information we have collected about you, including:

a.    The categories of sources from which the Personal Information was collected

b.    Our business or commercial purposes for collecting, selling, or sharing Personal Information

c.    The categories of recipients to which we disclose Personal Information

d.    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

e.    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.
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, please click on the Do Not Sell or Share My Personal Information homepage link for each Gallo brand you have engaged with. 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.
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.
4. California Notice of Financial Incentive

Summary. We sometimes offer discount codes or perks like a branded item in connection with you opting in to receive marketing emails. You receive such discount codes or perks because we want to show you that we are excited you want to hear from us and because we hope you will want to buy our products.

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.

5. Virginia Privacy Rights

This Section supplements the other parts of our Privacy Notice, and provides additional information for Virginia consumers, including how to exercise their rights under the Virginia Consumer Data Protection Act (“VCDPA”).

A. Additional Information about Certain Data Uses  

Targeted Advertising. We may process your Personal Data for targeted advertising (as the term is defined in the VCDPA). To opt out, please click on the Do Not Sell or Share My Personal Information homepage link for each Gallo brand you have engaged with.

Sales of Personal Data. We do not sell Personal Data as defined under the VCDPA.

B. Making a Privacy Rights Request

If you are a resident of Virginia, you have the right to submit certain requests relating to your Personal Data as described below. To exercise any of these rights, please submit a request through the Contact Us webform on this site. Please note that we will need to authenticate your identity before your request can be processed. For authentication, you will be asked to log into your account or to provide 2-3 pieces of Personal Data that we will match against our records.

Right to Access and Data Portability. You have the right 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.

Right to Correct. You have the right to request that we correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and our purposes for processing it.

Right to Delete. You have the right to request that we delete your Personal Data.

Right to Opt Out. Under the VCDPA, you have the right to 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. We do not use your Personal Data in ways that qualify as sales or profiling under the VCDPA. To opt out of targeted advertising, please submit a request as outlined above.

Right to Appeal. Sometimes we are unable to process requests relating to your Personal Data, in which case, your request will be denied. If you are a resident of Virginia whose 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 using the Contact Us webform on this site.

Please note that if you make a privacy rights request, we will retain a record of your request for recordkeeping purposes.

6. Nevada Privacy Rights

Nevada residents may opt-out of the “sale” of “covered information” to third parties, including but not limited to name, address, social security number, telephone number, email address, and other information through which a person may be contacted. Our uses of your Personal Information are not sales under Nevada law. If you have any questions or if you would like to receive notice by email in the event we should engage in sales of Personal Information under Nevada law in the future, please contact us.

7. Visitors from Outside the United States

Our websites, mobile applications, and this Privacy Notice are directed to residents of the United States. If you access our US websites and mobile applications 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 of your country.

8. Cookies and Other Tracking Technologies

We use cookies and other tracking technologies (such as web beacons) to collect and store information about your interactions with our websites, including information about your browsing behavior. Our websites also support third-party cookies placed by our service providers and third parties, such as advertising partners.

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.

Cookies vary in how long they last. “Session cookies” terminate shortly after you terminate your internet session. “Persistent cookies” are stored on your device until a set expiration date. We use both session cookies and persistent cookies on our website.

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.

9. Website Analytics

We use Google Analytics to analyze how users interact with our website and to track interactions with our online advertisements. This software may collect information such as your IP address, location, browser type and language, operating system, access time, duration of visit, pages you view within our website, search terms you enter, and other actions you take while visiting us, the pages you view immediately before and after you access our website, how often you use our website, aggregated usage and performance data, application errors, and debugging information. Google Analytics can also associate information collected on our website with information Google collects about you in other ways, which may then be shared with us. 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.

10. Targeted Advertisements

Our websites and mobile applications collect information about you in order to target advertisements to you when you browse the internet or use social media. The primary tool we use for this purpose is Google Ads, which is an advertising service provided by Google. Google uses cookies and other identifiers, in combination with their own data, to show you ads based on your usage of our website or mobile applications. You can personalize the ads you receive or opt-out of ads from Google by visiting the Google Ads Settings page. Additional options for opting-out of interest-based advertising can be found at the NAI’s site here.

11. Do Not Track Signals

Our websites do not respond to “Do Not Track” signals sent by browsers, mobile devices, or other mechanisms. Information for California consumers regarding the Global Privacy Control signal can be found above, under California Privacy Rights.

12. Social Features on Our Websites and Apps

Certain functionalities on our websites and mobile applications permit interactions that you initiate between us and certain third-party social networks (“Social Features”). Examples of Social Features include enabling you to send content such as contacts and photos between our services and a third-party service, “liking” or “sharing” our content, logging into our services using your third-party account, and otherwise connecting our services to a third-party service (e.g., to pull or push information to or from our services). If you use Social Features, information you post or provide access to may be publicly displayed on our websites and mobile applications or by the third-party service that you use. Similarly, if you post information on a third-party service that references us (e.g., by using a hashtag associated with us or our affiliates), your post may be used on or in connection with our services or otherwise by us and/or our affiliates. Also, both we and the third party may have access to certain information about you and your use of our services and any third-party service.

13. Online Chat

Our website also offers online chat features that are supported by third-party service providers – when you use these features, your information may be processed by a service provider who is subject to confidentiality obligations which limit the use and disclosure of your personal information.

14. Session Replay

We use Hotjar, a service provider, to help us understand and analyze how visitors use our services, and to improve the services. Hotjar may collect the following types of information from users of our websites:

  • Device IP Address
  • Device screen size
  • Device type (unique device identifiers)
  • Browser information, geographic location (country only)
  • Preferred language used to display our website

Hotjar stores the above information in a pseudonymized format. Hotjar does not use this information to identify individual users, or match or link the information with other information about users. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For more information regarding Hotjar's collection and use of information, please visit Hotjar's privacy policy here.

15. Contact Preferences and Email Opt-Out

We want to keep in touch with you in ways that you find to be beneficial. If you don’t want us to use your email address to communicate with you for promotional purposes (such as to tell you about products and services that might be of interest or to offer coupons/discounts), please tell us that when you provide your contact information. If you decide at a later time you do not want to receive promotional email communications, you can communicate this to us by accessing your account via our site (if applicable) or by using the Unsubscribe Link in any email you receive from us. You can also communicate with us through the methods described in the “How to Contact Us” section below. Keep in mind that even if you opt out, we may still contact you for other reasons, such as those related to an order you place, an inquiry you made, a membership you undertook, an event for which you registered, or a legally required notice.

16. SMS Messaging Opt-Out

If you participate in our general SMS/text messaging campaign, you may opt-out by texting “STOP” to the short code provided in that message. Text “HELP” to ask for help or call us at the phone number below for more assistance. Message and data rates may apply.

17. Not for Children

Our websites and mobile applications are neither intended for, nor targeted to those under 21 years of age. We use age-verification to exclude under-age individuals. If you are under 21, you are not permitted to use our websites or mobile applications and should not provide any Personal Information to us.

18. Security

We take commercially reasonable and appropriate steps to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration or destruction. Please keep in mind, however, that there is no such thing as perfect security, and no Internet transmission is ever completely secure or error-free. Moreover, you are responsible for maintaining the confidentiality of any username and password you use.

19. Changes to This Privacy Notice

This Privacy Notice may be revised from time to time for any reason. If this Privacy Notice changes, the revised notice will include a new effective date, and we will notify you of such changes by posting the revised notice on this page. Any such changes will automatically apply to all uses of our websites and mobile applications, and to other collection and use of your Personal Information by us, on or after the effective date (until such time as this Privacy Notice is subsequently revised).

20. How To Contact Us

If you have questions or comments regarding our privacy practices, 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