Privacy Policy

Paircraft™ SITE PRIVACY NOTICE 

Introduction

• Who we are. Gueno Gardner LLC (“we” or “us”) is a U.S.-based company that provides expert wine advice to passionate cooks under the name Paircraft™.
• What the Paircraft™ Site does. This site (“the Paircraft Site”) offers subscriptions to our sommelier-tested pairings (“Pairings”), along with written and video explanations of how our sommeliers came up with each Pairing, and  connects you to sites where you can review and buy the wines or categories of wines that we recommend for each Pairing. Our provision of this information and other information on the Paircraft Site will be referred to as “the Services.”
• Personally Identifying Information. “Personally Identifying Information” (or, “PII”) is information that identifies you as an individual or relates to you as an identifiable individual.  Personally Identifying Information, may include, but is not limited to, your first and last name, Social Security number, and home address. Under some privacy laws, Personally Identifying Information may include online and device identifiers such as your IP address, usage data such as your browsing history (where you came from to get to the Paircraft Site), protected classifications such as email address, your gender or sexual orientation, and information about your personal preferences that may be collected through cookies and other tracking devices.
• What this Privacy Notice does. This Privacy Notice describes how we collect and use your personally identifying information through the Paircraft Site.
• Capitalized terms. Unless otherwise noted, capitalized terms in this Privacy Notice have the same meaning that those terms have in our Terms of Use.
• For questions about this Privacy Notice and how your PII may be collected, stored, used, and shared, please contact us by email at privacy@paircraft.com
• Changes to this Privacy Notice. We may make changes to this Privacy Notice at any time. If and when we do, we will inform you by posting the revised Privacy Notice here on the Paircraft Site. You are responsible for periodically visiting the Paircraft Site and this Privacy Notice to check for any changes. Any changes that are made to this Privacy Notice will apply to both any PII that we hold prior to the effective date of the amended Privacy Notice and any PII that we collect on or after such effective date. Your continued use of the Paircraft Site after this Privacy Notice has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Privacy Notice, as amended.

COLLECTION OF PII

Information collected when you use the Paircraft Site.

• If you set up an account with us (a “User Account”), which you will need to subscribe to our Pairings, we will collect the items of PII that you provide in the User Account registration form, other than your payment information. Your payment information will go directly to the third-party Service Provider that handles our payments and will not be stored on the Paircraft Site.
• You can see certain Pairings and use certain other aspects of the Paircraft Site without setting up a User Account or signing in. But if you click on the links to see Pairings that are made available to everyone, a user record will be created that will contain your email address and certain online identifiers that are listed below under “Information collected automatically.”
• If you click through the Paircraft Site to a linked site to get more information about wines or other products or services being offered there, any PII you provide will go directly to that company and its use and disclosure will be governed by that company’s privacy notice. It will not go to us and the other company will not share it with us.

Other PII you choose to give us

• If you e-mail us, we will have your e-mail address and whatever other PII you include in the e-mail.

Information collected automatically

• What we collect. When you use the Paircraft Site, we automatically collect certain information that includes PII. This information may include:
  • Online identifiers: Geo location/tracking details, mobile device type and unique mobile device identification numbers, mobile device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), browser fingerprint, operating system, browser name and version, and/or personal IP addresses.
  • Usage data: Authentication data, security questions, click-stream data, public social networking posts, the web pages or sites that you visited just before or just after coming to the Paircraft Site, searches on the Paircraft Site, the pages or other content that you view or interact with on the Paircraft Site, and, each time you visit the Paircraft Site, the date and time of that visit, as well as information regarding your interaction with email messages that we send you, such as whether you open, click on, or forward a message, data on your interaction with our advertising and your interactions with our partners (conversion data).
  • Information from social networks. When you interact with the Paircraft Site through a social media platform (a “Social Network”), that Social Network may collect your PII and other information about you even when you are not directly interacting with that Social Network through the cookies and other digital tracking mechanisms that it places on your devices. You should review the privacy notice and information-sharing choices of any Social Network that is connected to the Paircraft Site.
• How cookies work. A cookie is a small data file that a website transfers to a user’s hard drive when a user visits a website. A cookie file can contain information such as a unique ID that the site being visited uses to track the pages visited and is a standard method of registering website user preferences. These preferences are stored in a file on your computer’s hard disk drive. The Paircraft Site uses cookies for various purposes. Some cookies, called first-party cookies, are placed by us. We also use third-party cookies, which are cookies set by third-party tracking and advertising providers who act on our behalf to track and analyze your usage of the Paircraft Site. At our request, these third parties collect, and share with us, usage information about visits to the Paircraft Site, measure and research the effectiveness of our advertisements, track page usage and paths followed during visits through the Paircraft Site.

• Different kinds of cookies
  • Strictly necessary cookies. These cookies are necessary for the Paircraft Site to function. We cannot switch these cookies off. They are usually only set in response to actions that you take that are, in effect, a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies (see below), but that will cause some parts of the Paircraft Site to not work. These cookies do not store any PII.
  • Performance cookies. These cookies collect anonymized information about how you and other visitors use the Paircraft Site, for instance which pages are viewed most often, and whether you or other visitors receive error messages from certain pages. They help us see how visitors move around the Paircraft Site. If you disable these cookies, we will not know when you have visited the Paircraft Site. The Google Analytics cookie collects your IP address.
  • Advertising cookies. We may use advertising cookies to let you know about wines or other products that we think may be of interest to you based on your searches for Pairings or wines, use of the Services, and in some cases, other information about you that we have obtained from other sources. We also may use advertising cookies to prevent the same ad from continuously reappearing to you, understand how you interact with ads that are served to you on the Paircraft Site and find out if you have opened emails from Paircraft or clicked on links within such emails.  We also use conversion cookies, which allow us to track conversion on the sites of our advertising partners whose products and services are advertised on the Paircraft Site.
  • Third-party cookies. When you are on the Paircraft Site, you may be directed and/or linked to other sites, for example, to the sites of wine merchants. Those third-party sites may use their own cookies. We do not have control over the placement of cookies by those sites, even if you are directed to them from the Paircraft Site.

• Managing and deleting cookies
  • Browser cookie settings and consequences. You can set your browser to accept all cookies, to reject cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. Rejecting a cookie, however, may preclude you from using, or may negatively affect the display or function of, the Site or certain areas or features of the Site. To learn more about cookies, including how to enable cookies, change your browser settings and find and delete cookies on your hard drive, please refer to your web browser’s help menus or visit allaboutcookies.org.

• • Links to block and delete cookies. You can obtain up-to-date information about blocking and deleting cookies on these browsers at these links:

https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop(Firefox);

https://support.google.com/chrome/answer/95647 (Chrome);

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

https://help.opera.com/en/latest/security-and-privacy/ (Opera);

https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari);

https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge); and

https://support.brave.com/hc/en-us/articles/360050634931-How-Do-I-Manage-Cookies-In-Brave- (Brave).

• • Opting out of Google Analytics. If you do not want your data collected with Google Analytics, you can install the Google Analytics opt-out browser add-on. This add-on instructs the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) running on websites to prohibit sending information to Google Analytics. To opt out of Google Analytics, visit theGoogle Analytics opt-out page and install the add-on for your browser. For more details on installing and uninstalling the add-on, please see the relevant help resources for your specific browser. Updates to your browser or operating system may affect the functionality of the opt-out add-on.

USE (PROCESSING) OF PII

•  Subscription. We will use your email address and credit-card information to process your membership fees, to send you Pairings and renewal notices (unless you have signed up for autorenewals or unless you have canceled your subscription), and to contact you about your membership (for example, if you have signed up for autorenewal and the credit card we have on file no longer works).
• Advertising. We may use your email address to send you information about the Services and similar services and products offered by third parties.
• Responses. If you contact us, we will use your email address to respond and/or send you whatever information you have requested.
• Recordkeeping. We may process your PII for the purposes of creating and maintaining databases related to the Paircraft Site and back-up copies of those databases.
• Security. We may process your PII for the purpose of keeping the Paircraft Site secure and preventing fraud and other criminal activity.
• Policy updates. We will use your email address to send you notices about updates to the Paircraft Site and our Terms of Use and this Privacy Notice.

DISCLOSURE OF PII TO THIRD PARTIES

• Disclosure to third parties
  • Affiliates. We may share your PII and other information with a parent company, subsidiary, joint venture, or other company under common control with us.
  • Service providers. We may provide your PII to service providers who perform or contribute to the Services, help us operate the Paircraft Site and provide the Services (“Service Providers”). Service Providers include vendors and suppliers that provide us with technology, services or content for sending email, analyzing the operation of the Paircraft Site and the Services, analyzing data generated by user activity, research, advertising, and customer service. These Service Providers’ access to your PII is limited to the information reasonably necessary to perform their limited functions. If a Service Provider obtains access to your PII in the course of providing services, its use of your PII will be governed by its own privacy notice. Our current Service Providers and the current links to their privacy notices are:
    • Google Analytics (https://policies.google.com/privacy?hl=en-US)
    • Stripe (https://stripe.com/privacy)

• • Advertising partners. We may provide your PII and information collected about your visits over time and across the Paircraft Site and multiple devices and other websites with our advertising partners in order to serve targeted advertising to you. For more information on targeted advertising and how to manage your preferences, see Managing and deleting cookies
• Disclosure for legal reasons
  • Safety. We may disclose your PII to protect the safety, rights, or property of the public, any person, or us; to investigate, prevent, or otherwise address suspected fraud, harassment or other violations of any law, rule or regulation or our Terms of Use; to detect, prevent or otherwise address security or technical issues; or as we believe is required by law, regulation, or legal process.
  • Change of control. If we engage in a merger, acquisition, disposition, change of control, bankruptcy, dissolution, reorganization, or similar transaction or proceed-ing, or otherwise transfer the operations of the Paircraft Site that relates to your PII, we will transfer your PII to the successor entity. 
• Disclosure under the CCPA. The Paircraft Site is not currently subject to the California Consumer Privacy Act (“CCPA”). If and when the Paircraft Site does become subject to the CCPA, we will revise the Paircraft Site, this Privacy Notice, and our associated operations to meet the CCPA’s requirements.
• Disclosure under Nevada law. If you are a Nevada resident, you may direct us not to sell certain PII to third parties for resale or licensing purposes by sending an email to privacy@paircraft.com with the subject line, “Nevada Do Not Sell Request, along with your first and last name and ZIP code and a statement that you are a current or former member of Paircraft so that we can match your user information to your User Account.

“Do Not Track” Signals

• With some browsers, it is possible for a user to activate a “Do Not Track” signal, to indicate that the user does not want to be tracked across the websites that the user visits.
• The Paircraft Site does not respond to Do Not Track signals. So, if you have activated a Do Not Track signal in your own browser, the Paircraft Site will not block tracking of your activity on the Paircraft Site by Google, its affiliates, and anyone else.

Storage of information

• We store PII and other information that we collect through the Services on our own servers and/or on servers operated by third parties. Currently, these third-party servers are located in the United States. If, in the future, we begin to use servers that are located in other countries or in other jurisdictions, we will update this Privacy Notice.
• You consent to have your PII and other information that may be collected when you use the Paircraft Site collected, stored and processed on servers in the United States.

Retention and deletion of PII

• We will keep your PII until you cancel your subscription.
• We will dispose of your PII by deleting it from the Paircraft Site database.

Transfer of information

• We may transfer information that we collect about you, including PII, to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world to process your PII there for the purposes set out in this Privacy Notice and permit our Service Providers to do so.
• You acknowledge that any PII that you submit to or through the Paircraft Site may be available, via the Internet, around the world. We cannot prevent the use or misuse of your PII by others.

Security

• We use SSL certificates to protect your personal information as you transmit it from your computer to the Paircraft Site and to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We also use a software program to stop certain kinds of attacks. But no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from the Paircraft Site may not be secure. Be careful about sending us any PII, and keep secure any passwords, ID numbers, or other special access features that you use on the Paircraft Site.
• The Paircraft Site may contain links or references to other sites. Please be aware that we do not control such other sites and that, in any case, this Privacy Notice does not apply to those sites. We encourage you to read the privacy notice of every site you visit.

Protection of information

• You are responsible for maintaining the privacy of your User Account information and for controlling access to your communications from the Paircraft Site at all times.
• Your PII will be stored in secure third-party data centers. Nevertheless, we cannot (i) ensure or warrant the security of any PII that you transmit when you use the Paircraft Site or (ii) guarantee that information stored on or transmitted through the Paircraft Site may not be accessed, disclosed, altered, or destroyed. If any PII under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation, and where appropriate, we will notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

Children

• We do not knowingly collect PII from anyone under 13. If we become aware that a child under 13 has provided us with PII, we will take steps to remove such information and terminate the child’s account.
• If you are a parent and you become aware that your child has provided us with PII without your consent, please contact us at privacy@paircraft.com and we will take steps to remove such information and close the child’s account.

Your rights with respect to your PII.  You can change any of your PII that you have provided to us, or ask us questions about our privacy practices, by emailing us at privacy@paircraft.com.

Date posted/updated.  This Privacy Notice was first posted on June 16, 2022. A previous version was posted on October 28, 2021.