Privacy Policy
1. Introduction
At Silicon Valley Wine Auction (“we,” “us,” or “our”), accessible at siliconvalleywineauction.com, we are committed to protecting and respecting your privacy. We recognize the importance of safeguarding personal data and are dedicated to ensuring that your personal data is collected, handled, stored, and processed in a lawful, fair, and transparent manner. This Privacy Policy outlines how we process your personal information in accordance with applicable data protection regulations, including the European Union’s General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).
2. Scope of Policy and Role as Data Controller
This Privacy Policy applies to all personal information processed by Silicon Valley Wine Auction through our website, communications, and associated services (collectively the “Services”). Silicon Valley Education Foundation, as the owner of siliconvalleywineauction.com, acts as the Data Controller with respect to the collection and processing of personal data under this Policy.
If you have any questions regarding this Privacy Policy or the processing of your data, you may contact us at [email protected].
3. Categories of Data We Process
We process the following categories of personal data:
3.1 Usage Data
We collect data regarding your interactions with our Services, including IP address, browser type and version, geographic location, referral source, length of visit, pages viewed, and website navigation paths.
3.2 Account Data
Provided by you when registering or participating in our events, this includes your full name, mailing address, email address, telephone number, and password or login credentials when applicable.
3.3 Profile Data
This includes information associated with your engagement, such as wine preferences, prior auction participation, event attendance history, and user behavior on siliconvalleywineauction.com.
3.4 Communication Data
Any correspondence you send to us, including email messages, contact forms, customer support requests, and event inquiries, may be retained along with metadata necessary for proper response and recordkeeping.
3.5 Technical Data
Data relating to the devices and systems you use to access our Services: including hardware model, operating system, screen resolution, language preferences, browser plugins, JavaScript support, and time zone settings.
3.6 Transaction Data
Details associated with financial transactions carried out through siliconvalleywineauction.com, including billing information, payment methods or confirmation, shipping or delivery instructions, and product orders.
3.7 Preference Data
This includes your selected preferences regarding communications, such as marketing consents, subscription choices, and interests in particular categories of products offered in auctions.
4. Legal Bases for Processing
We process your personal data on the following lawful bases, as prescribed under GDPR and related laws:
– Contractual Necessity: Where processing is necessary to fulfill a contract to which you are a party or to take steps at your request prior to entering into such contract (e.g., auction participation or ticket purchase).
– Consent: Where you have expressly provided consent for particular uses such as receiving marketing communications.
– Legitimate Interests: Where processing is reasonably necessary to pursue our operational or commercial interests, such as improving website functionality, preventing fraud, or understanding user behaviors—provided such interests are not overridden by your rights.
– Legal Obligation: Where we are required to process your data to comply with a legal obligation.
5. Your Rights
Under applicable law, including GDPR and CCPA, you have the following rights in relation to your personal data:
– Right to Access: You may request a copy of your personal data being processed.
– Right to Rectification: You may ask us to correct inaccuracies in your data.
– Right to Erasure: You may request the deletion of your personal data, subject to certain legal limitations.
– Right to Restrict Processing: Under certain conditions, you may request limited use of your data.
– Right to Data Portability: You have the right to receive your data in a structured, commonly used format and to have it transferred to another controller without hindrance.
– Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes.
– Right Not to be Subject to Automated Decision-Making: We do not use algorithms to make decisions that significantly affect you without human involvement.
To exercise any of these rights, please email [email protected]. We may need to verify your identity before responding.
6. Security Measures
We are committed to ensuring the continued confidentiality, integrity, and availability of your data. Accordingly, we implement technical and organizational measures including, but not limited to:
– Strong encryption for data during transmission and storage;
– Role-based access controls and multi-factor authentication;
– Regular secure backups and tested recovery procedures;
– Network monitoring and intrusion detection systems;
– Security training and awareness for all employees and contractors.
7. International Data Transfers
Where personal data is transferred outside of the United States or European Economic Area (EEA), such transfers are made in accordance with international data protection standards. We implement safeguards such as Standard Contractual Clauses approved by the European Commission, and abide by regional data protection regulations. We will ensure that your data remains protected consistent with this Privacy Policy and applicable law.
8. Data Retention
We retain personal data only as long as is necessary for the purposes for which it was collected or to comply with legal obligations. The following general retention periods apply:
– Account and Profile Data: Retained while account is active and for up to 5 years thereafter;
– Transaction Data: Retained for 7 years for tax and accounting compliance;
– Communication Data: Retained for 3 years for quality assurance and legal defense;
– Preference and Marketing Information: Retained until consent is withdrawn or data is deemed inactive;
– Technical and Usage Data: Retained for up to 36 months for analytical purposes.
Anonymized or aggregated data, which no longer constitutes personal data, may be retained indefinitely.
9. Cookie Policy
Our website uses cookies and similar technologies to enhance user experience and analyze usage patterns. Categories include:
– Essential Cookies: Necessary for the operation of siliconvalleywineauction.com (e.g., navigation and secure login).
– Functional Cookies: Enable the site to remember choices you’ve made to improve usability.
– Analytics Cookies: Collect information to evaluate the performance and operation of the site.
– Performance Cookies: Monitor how users interact with the platform to optimize speed and functionality.
10. Cookie Management and Legal Compliance
Upon visiting siliconvalleywineauction.com, you will be presented with cookie consent options in accordance with GDPR and CCPA. You may choose to accept or decline specific categories of cookies. Additionally, most browsers allow users to manage and delete cookies through settings and preferences. If you are a California resident, you have the right to opt out of the sale or sharing of your personal information and to request disclosure regarding cookies that track you across websites.
11. Children’s Privacy
Our Services are not directed to children under the age of 13. We do not knowingly collect or process personal data of minors without explicit parental consent. If a child under 13 has provided us with personal data, a parent or guardian may contact us immediately at [email protected], and we will take appropriate steps to remove such information.
12. Changes to This Policy
We may revise this Privacy Policy from time to time in order to reflect updates in our practices or in accordance with changes in applicable laws and regulations. Any material changes will be communicated appropriately. Continued use of siliconvalleywineauction.com constitutes acceptance of such changes.
13. Contact
For any questions, concerns, or data requests related to this Privacy Policy or your personal information, please contact us at:
Email: [email protected]
Website: https://siliconvalleywineauction.com
We are committed to complying with the GDPR, CCPA, and all other applicable data protection laws. Please do not hesitate to contact us if you believe your data has been handled incorrectly or if you wish to exercise your data rights.