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Privacy Policy

January 9, 2006

We respect your privacy at U.S. Wine Exchange, LLC d/b/a iWineDb (the �Company or �iWineDb�). We believe that you should know how information about you is used and shared, and we appreciate that you trust that we will do so carefully and sensibly. By visiting iWineDb, you are accepting the practices described in this privacy policy (the �Policy�).

If you have any questions about this Policy, please feel free to contact us via our website or write to us at Privacy Concerns, c/o U.S. Wine Exchange, LLC, 1045 Chasewood Trail, Alpharetta, Georgia, 30005 USA.

Information iWineDb collects and its use:

We offer services that do not require you to register for an account or provide any personal information to us, such as basic search and wine-related information. In order to provide our unique and valuable services, we may collect the following types of information:

         Information you provide - When you sign up for an iWineDb account or other service or promotion that requires registration, we ask you for personal information (such as your name, email address and an account password). We may combine the information you submit under your account with information from other iWineDb services or third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information. We use the information that you provide for such purposes as responding to your requests, improving our site, customizing your browsing experience and communicating with you.

         Use of cookies - When you visit iWineDb, we may send one or more �cookies� to your browser that uniquely identifies it. A cookie is a piece of data stored on the user's hard drive containing information about the user. Usage of a cookie is in no way linked to any personally identifiable information while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. We use this information to improve our services by storing user preferences and tracking user trends, such as how people navigate our site. Most browsers accept cookies by default, however, you can set your browser to refuse cookies and to indicate when cookies are being sent. However, some of our features and services may not function properly if your cookies are disabled.

         E-mail Communications - To help us make e-mails more useful and interesting, we may send messages that use e-mail confirmation from iWineDb. If you do not want to receive e-mail or other mail from us, please adjust your communication preferences in your account profile when you set up your iWineDb account.

         Information from Other Sources - For reasons such as improving personalization of our service (for example, providing better recommendations or special offers that we think will interest you), we might receive information about you from other sources and add it to our account information. We also sometimes receive updated delivery and address information from other sources so that we can correct our records and deliver your next communication more easily.

         Links - iWineDb may present HTTP (website) links in a way that enables us to determine whether you have traversed them. This information helps us improve the quality of our navigation and services.

         Affiliated sites - We offer some services in conjunction with other businesses� web sites. Personal information that you provide to these �affiliated sites� may be sent to iWineDb in order to provide services. Such information is treated in accordance with this Policy. Affiliated sites have differing privacy practices and you should read their privacy policies.

         Other sites - This Privacy Policy applies to web sites and services that are owned and operated by iWineDb. We do not exercise control over the sites that link to and from our site services.

iWineDb only processes personal information for the purposes described in the applicable Policy and/or privacy notice for specific services. In addition to the above, such purposes include:

         Providing our products and services to users, including the display of customized content;

         Ensuring the technical functioning of our network;

         Auditing, research and analysis in order to maintain, protect and improve our services;

         Developing new services.

iWineDb processes personal information on servers in the United States of America; this may be extended to servers in other countries. In some cases, we process personal information on a server outside the country in which you may reside. We process personal information to provide our own services. In some cases, we may process personal information on behalf of and according to the instructions of a third party, such as affiliated partners.

Choices for personal information

When you sign up for a particular service that requires registration, we ask you to provide personal information. If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.

If we propose to use personal information for any purposes other than those described in this Policy and/or in the specific service notices, we will offer you an effective way to opt out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this Policy and/or in the specific service notices, unless we have obtained your prior consent.

You may decline to submit personal information to any of our services, in which case iWineDb may not be able to provide some services to you.

Information sharing

iWineDb only shares personal information with other companies or individuals outside of iWineDb in the following limited circumstances:

         We have your consent. We require opt-in consent for the sharing of any sensitive personal information.

         We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.

         We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of iWineDb, its users or the public as required or permitted by law.

If iWineDb becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will provide notice before personal information is transferred and becomes subject to a different privacy policy.

We may share with third parties certain pieces of aggregated, non-personal information, such as the number of users who searched for a particular term, for example, or how many users clicked on a particular advertisement. Such information does not identify you individually.

Please contact us at the address below for any additional questions about the management or use of personal data.

Information security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to personal information to iWineDb employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

However, iWineDb is not responsible for any breach of security. When a user elects to use our referral service to recommend our site to a friend, we ask them for their friend's name and e-mail address. iWineDb will automatically send the friend an e-mail inviting them to visit the site. iWineDb stores this information for the sole purpose of sending this e-mail and tracking the success of our referral program.

You must be of legal age where you reside to use this site

No information should be submitted to iWineDb by anyone under 21 years of age. We do not monitor the age of our users.

Data integrity

iWineDb processes personal information only for the purposes for which it was collected and in accordance with this Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services. We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.

Accessing and updating personal information

When you use iWineDb services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Some of our services have different procedures to access, correct or delete users' personal information. We provide the details for these procedures in the specific privacy notices or FAQs for these services.

Enforcement

iWineDb regularly reviews its compliance with this Policy. Please feel free to direct any questions or concerns regarding this Policy or iWineDb's treatment of personal information by contacting us through this web site or by writing to us at Privacy Concerns, c/o u.s. Wine Exchange, LLC, 1045 Chasewood Trail, Alpharetta, Georgia, 30005, USA. When we receive formal written complaints at this address, it is iWineDb's policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between iWineDb and an individual.

Changes to this policy

Please note that this Policy may change from time to time. iWineDb reserves the right, in its sole discretion, to change, modify, add, or remove portions of this Policy at any time, effective immediately upon notice published on the Services. We suggest that you check these terms periodically for changes. Your continued use of the Service constitutes your binding acceptance of the Policy, including any changes or modifications made by the Company. Each version of this Policy will be identified at the top of the page by its effective date.

If you have any additional questions or concerns about this Policy, please feel free to contact us.

Related Practices and Information

         Terms and Conditions of Use


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