Effective date: April 17, 2017
- 2. Types of Information Collected
a. Information We Collect Automatically When You Access & Use the Sites. We and our third-party service providers may use a variety of technologies that automatically or passively track and collect certain information when you visit our Sites, including (i) the IP address or other unique identifier (a set of numbers or characters that is assigned to your computer, mobile phone, or other device when you are on the Internet) (“Device Identifier”) for any computer, mobile phone, tablet or other device (any of which are referred to herein as a “Device”) used to access the Sites; (ii) your domain server (a computer that stores web site files and provides them to people who request them), which may be controlled by your internet service provider; (iii) the type of Device you use to access the Sites; (iv) the URL of an advertisement that led you to the Site or the search terms you entered into a search engine that led you to the Site (if applicable); (iv) the type of web browser and operating system you use; and (v) all of the areas within our Site that you visit or use, and the time of day you visited the Site, among other information (collectively "Usage Data"). Usage Data is generally information that does not personally identify you, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information. In addition, the Sites may collect information about your location using a variety of technologies, such as GPS, IP address, and Wi-Fi networks connected to or nearby.
The methods that may be used to collect Usage Data include the following:
Cookies. "Cookies" are data files sent to and stored on the Device you use to view a web site. Cookies can be used for many purposes, including to monitor use of our Sites, to customize content specific to your interests, to ensure that you do not see the same advertisement repeatedly and to store your user name and password so you do not have to re-enter it each time you visit the Sites. If you choose to disable cookies on your Device, some features of the Sites or our content may not function properly.
Web Beacons. Small graphic images or other web programming code called web beacons (also known as "1x1 GIFs" or "clear GIFs") may be included on the Sites and in our e-mail messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Sites, to monitor how users navigate the Sites, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Sites, such as the links you click. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Sites.
Our mobile applications may use similar technologies.
c. Community Forums and User Content. The Sites may provide you the opportunity to participate and post content publicly through chat rooms, forums, interactive features, or other communication functionality (“Community Features”). We may provide functionality for you to submit or post text (including questions, comments, and suggestions), pictures, audio, videos, or other content (collectively, "User Content") through Community Features, by linking the Site to a third-party service, or otherwise. Please note that certain information, such as your username and profile picture, may be publicly displayed on the Sites along with your User Content. User Content consisting of uploaded files may contain metadata, which may contain Personal Information or other information about or relating to you. You may wish to remove metadata from your files before transmitting such files to Raleigh.
e. Send to a Friend Features. If you send a friend a communication from one of the Sites, we may use the information you provide (e.g., name and e-mail address) to contact that friend.
- 3. Third Party Interactions
Certain functionality on the Sites may permit interactions that you initiate between the Sites and a third party web site or service (“Third Party Interactions”). Examples of Third Party Interactions may include technology that enables you to “like” or “share” content from the Sites on or to other web sites or services; to transmit content to the Sites from your account on a third party web site or service; and to otherwise connect the Sites to a third party web site or service, such as through an application programming interface (API) made available by Raleigh or a third party.
If you choose to use Third Party Interactions, information you post or provide access to may be publicly displayed on the Sites or by the provider of the Social Feature that you use. Similarly, if you post information on a third party platform that references the Sites (e.g., by mentioning one of the Sites or using a hashtag associated with one of the Sites in a tweet or status update), your post may be published on our Sites in accordance with the terms of the third party web site or service. Also, both Raleigh and the third party may have access to certain information about you and your use of the Sites and the third party site or service. In addition, we may receive information about you in connection with other users’ use of Third Party Interactions (e.g., we may learn that you are a “friend” or “connection” of the third party or receive other information about you that the other user enables us to receive).
- 4. Uses of Information Collected
- 5. Third Party Analytics Providers & Ad Servers; Online Tracking
Raleigh works with certain third parties (including network advertisers, ad agencies, and analytics companies) to provide us with information regarding traffic on the Sites, to serve advertisements, including our advertisements elsewhere online, and to provide us with information regarding the use of the Sites and the effectiveness of our advertisements. For example, if you clicked on one of our advertisements that led you to one of the Sites, our service provider(s) may be able to tell us which advertisement you clicked on and where you were viewing the advertisement. These third parties may set and access their own tracking technologies (including cookies, embedded scripts, and web beacons) and may otherwise collect or have access to your Device Identifier, Usage Data and related information about you. Cookies and web beacons, including those set by third party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times, conduct research regarding the usefulness of certain advertisements to you, and assist in providing analytics. We may share Device Identifier and Usage Data about visitors with third party advertising companies, analytics providers and other vendors for similar purposes. While we may use a variety of service providers to perform advertising and analytics services, some of these companies may be members of the Network Advertising Initiative ("NAI”) or the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising.
For additional information regarding targeted advertising and the “opt-out” procedures of NAI members and DAA Self-Regulatory Program participating companies, you may visit:
- NAI Opt-Out Tool (for website users): http://www.networkadvertising.org/managing/opt_out.asp
- DAA Consumer Choice (for website users): http://www.aboutads.info/choices/
- DAA AppChoices (for mobile app users): http://youradchoices.com/appchoices
Please note that opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while visiting the Site and elsewhere online. Some third parties may collect Personal Information about your online activities over time and across different websites.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, the Sites currently do not alter their practices when they receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.
- 6. Children; Underage Users
Please note that the Sites are not intended for children. We do not knowingly collect personally identifiable information from children. If Raleigh discovers that it has inadvertently collected Personal Information from anyone younger than the age of 13, it will delete that information.
In addition, the www.rosenthalestatewines.com web site and any features, mobile applications, or online services associated with Rosenthal – The Malibu Estate, are not intended for persons under twenty-one (21) years old. We do not knowingly collect Personal Information from anyone younger than the age of 21 in connection with such web site, features, mobile applications, or online services.
- 7. Disclosure of Information to Third Parties
We may share non-personally identifiable information, such as aggregated user statistics, in our discretion and without restriction.
Third Party Service Providers
We may share Personal Information with third party service providers in connection with the service providers’ performance of services to, or on behalf of, the Sites. For example, we use a third-party service provider to accept online reservations at www.sunsetmarquis.com and to accept orders for wine at www.rosenthalestatewines.com. Some of our service providers may store or process your information outside of the United States.
When You Agree to Receive Information From Third Parties or Request That We Share Your Information
Administrative & Legal Reasons
Sharing Between Raleigh Companies; Business Transfers
Raleigh may share information including Personal Information with its parent, subsidiaries and affiliates (including, without limitation, the Sunset Marquis, Cavatina at Sunset Marquis Hotel, Raleigh Studios, Rosenthal – The Malibu Estate, and File Keepers) for a variety of purposes, including for business, operational, and marketing purposes. Raleigh may, and reserves the right to, share your information with any other company that is not presently, but becomes, a Raleigh parent, subsidiary, or affiliate. Raleigh may also disclose and transfer your Personal Information: (i) to a subsequent owner, co-owner or operator of the Sites or applicable database, or of our products or services; (ii) if Raleigh (or any of its affiliated, parent, or subsidiary companies) assigns its rights regarding any of your information to a third party; or (iii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of Raleigh’s ownership interests, assets, or both, or other company change, including, without limitation, during the course of any due diligence process.
Sweepstakes, Contests & Promotions
We may offer sweepstakes, contests, and other promotions (any, a "Promotion") that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion's official rules, such as on a winners list.
Third Party Marketing
We do not share your Personal Information with unaffiliated third parties for those unaffiliated third parties' marketing purposes unless you consent to such sharing.
- 8. Your Choices Regarding Your Information, Preferences, and Subscriptions
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you contact us with changes, we will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. Note, however, that information may persist internally for our administrative purposes and that residual data may remain on backup media or for other reasons.
You may choose not to provide us with any Personal Information. In such an event, you may still be able to access and use some of the Sites; however you may not be able to access and use those portions of the Sites that require your Personal Information. You may opt out of receiving marketing e-mails by following the opt-out instructions provided to you in those e-mails. Please note that we reserve the right to send you certain communications relating to your account or use of any of the Sites (for example, administrative and service announcements, shipping notices, and order or reservation confirmations) and these transactional account messages may be unaffected if you opt-out from marketing communications. You may opt-out of receiving text messages (e.g., SMS or MMS messages) that we may offer by replying "STOP” to one of our messages.
- 9. Information Security
Raleigh takes commercially reasonable security measures to help protect the Personal Information submitted to us, both during transmission and once we receive it. However, please note that transmission over the Internet or wireless networks cannot be guaranteed to be 100% secure; and therefore we cannot ensure or warrant the security of any information we collect. You use our Sites and provide us with your information at your own risk.
- 10. Users Residing Outside of the United States and Consent to Transfer
The Sites are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us may be transferred to and processed in the United States. By using the Site, or providing us with any information, you consent to this transfer, processing and storage of your information in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen.
- 11. Third Party Content, Links to Other Web Sites, and Raleigh Content Found Outside the Site
Certain content on the Sites may be hosted and served by third parties, and the Sites may contain links to third-party web sites that Raleigh does not control. In addition, Raleigh content may be included on web pages and web sites that are not associated with Raleigh and over which we have no control. These third parties may collect Usage Data through the use of their own cookies and web beacons, independently collect data or solicit Personal Information, and may have the ability to track your use of their sites and services. Raleigh is not responsible for the privacy practices or the content of any third party.
- 13. California Residents – Your California Privacy Rights
Pursuant to California Civil Code Section 1798.83, residents of the State of California have the right to request from companies conducting business in California certain information regarding Raleigh’s disclosure within the immediately preceding calendar year of that California resident’s personal information to third parties (and in some cases, affiliates) for their direct marketing purposes.
- 14. Contacting Us