Privacy Policy

Last Updated June 7th, 2016

GCH, Inc. and its affiliates, subsidiaries and other related companies (“GCH”, “Willie’s Reserve”, “we”. “us” or “our”) is committed to protecting your privacy.  This Privacy Policy describes our policies and procedures regarding the collection, use and disclosure of personal information we receive from you when you use GCH’s website at williesreserve.com and any other website for which GCH owns the domain registration (the “Site”), products, content, online or mobile applications, software, or other services (collectively the “Services”). Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Use, accessible at williesreserve.com/terms-of-use/.

This Privacy Policy governs all use of this Site. By using this Site, you are deemed to consent to our privacy practices set forth in this Privacy Policy, including our collection, use and sharing of your information and data, and other activities, as described below. If you do not consent to these privacy practices, do not use this Site or download any materials from it, and you should immediately discontinue use of the Services.  This Privacy Policy does not govern privacy practices associated with offline activities, web sites other than the Site, or Services not available or enabled via the Site, except as expressly set forth in this Privacy Policy.

If you accept or agree to this Privacy Policy on behalf of a company or other legal entity, you represent and warrant that you have the authority to bind that company or other legal entity to this Privacy Policy and, in such event, “you” and “your” will refer and apply to that company or other legal entity.

We reserve the right, at our sole discretion, to modify this Privacy Policy at any time and without prior notice. If we modify this Privacy Policy, we will notify you of any material changes by posting the new Privacy Policy to the Site. We will also update the “Last Update Date” at the top of this Privacy Policy. You are advised to consult this Privacy Policy regularly for any changes. By continuing to access or use the Site or the Service after we have posted a modification on the Site or have provided you with notice of a modification, you are indicating that you agree to be bound by this Privacy Policy as modified.

As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates.

 

Information Collection and Use

We mainly use your Personal Information (defined below) for the following purposes:

  • To improve and personalize our Site and Services
  • To send you information or communications you have requested
  • To send you links to downloadable archive information you have requested
  • To gather broad demographic information about user trends and visitors to our website.
  • To enable GCH, its contractors, partners and distributors to alert you to Services changes, special offers, updated information and other new Services.

 

Types of Information Collected
There are two types of information collected by us: Personally Identifiable Information and Non-Personally Identifiable Information.

Personally Identifiable Information. Personally Identifiable Information (“Personal Information”) is information that identifies you as an individual, such as your name, mailing address, email address, age range, etc. Personal information is only obtained when you voluntarily provide the information to us. Examples of how we may collect Personal information from you include, but are not limited to:

  • When you subscribe for Services or updates, register for any account or otherwise interact with the Services in any way;
  • When you make a purchase via the Site;
  • When you download content, apps, software or software updates from the Site;
  • When you seek customer support, technical assistance or otherwise contact us;
  • When you use our Services provided online, by way of your mobile device or our software;
  • When you subscribe to newsletters, promotions, alerts, updates or other materials from us.

If you choose to make a purchase via the Site, our third party payment processor service providers may also collect billing information such as your credit card number or billing address.

Non-Personally Identifiable Information.  Non-Personally Identifiable Information (“Non-Identifying Information”) is information that does not identify you as an individual, such as your browser type, IP Address and/or the URL of the previous web site you visited.   We may automatically collect certain types of Non-Identifying Information from you when using the Site. We may also collect Non-Identifying information that you voluntarily provide, such as information included in response to a questionnaire or survey.

We use your Personal Information (in some cases, in conjunction with your Non-Identifying Information) mainly to provide the Services, complete your transactions and administer your inquiries.

Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other Non-Identifying Information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other users of the Site to attempt to provide you with a better experience, to improve the quality and value of the Service and to analyze and understand how our Site and Services are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a service to you according to your preferences or restrictions.

We also use your Personal Information to contact you with our newsletters, marketing or promotional materials and other information (“Marketing Information”) that may be of interest to you.

 

Opt-Out

If you decide at any time that you no longer wish to receive Marketing Information from us, please follow the opt-out or unsubscribe instructions provided in any of the communications or update your “Settings” information. (See “Changing or Deleting Information” below.).

 

Surveys

From time to time we may provide you the opportunity to participate in surveys, promotions, contests or sweepstakes (collectively, “Promotion” or “Promotions”) through the Site. If you participate, we will request certain Personal Information from you. Participation in these Promotions is completely voluntary and you therefore have a choice whether or not to disclose this information. We use this information to administer your participation in each Promotion.

Occasionally, we may offer these Promotions together with another party, or we may use a third party service provider to help us conduct the Promotions. In order to administer the Promotions and/or provide the winner(s) with a prize, we may need to share your Personal Information with a third party who is helping us conduct the Promotion or co-sponsoring the Promotion with us. We will notify you within the Official Rules of the Promotion if another party is co-sponsoring the Promotion with us. If we are using a third party service provider, the third party service provider will be prohibited from using your Personal Information for any other purpose.

 

Location-Based Information

Our Services may use location-based services in order to locate you so that we may verify your location, deliver you relevant content based on your location.

 

Log Data

When you visit the Site, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s browser type or the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, information you search for on our Site, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and the Service and for the Site’s technical administration, to increase our Site’s functionality and user-friendliness, and to better tailor it to our visitors’ needs. We also use this information to verify that visitors to the Site meet the criteria required to process their requests.

 

Cookies and Pixel Tags

Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use cookies for two purposes. First, we utilize persistent cookies to save your username and password for future logins to the Site. Second, we utilize session ID cookies to enable certain features of the Site and to better understand how you interact with the Site. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site and Service and then close your browser. Third party advertisers on the Site may also place or read cookies on your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the Site or all functionality of the Services.

We may also use “pixel tags,” “web beacons,” “clear GIFs” or similar means (individually or collectively “Pixel Tags”) in connection with our Service to collect usage, demographic and geographical location data. A Pixel Tag is an electronic image, often a single pixel that is ordinarily not visible to users and may be associated with cookies on a user’s hard drive. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded services and to help determine the effectiveness of promotional or advertising campaigns.

 

Phishing

Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your username, password or credit card or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.

 

Information Sharing and Disclosure

Aggregate Information and Non-Identifying Information. We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.

Service Providers. We may employ third party companies and individuals to facilitate our Services, to provide the Services on our behalf, to perform Site-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Site’s features) or to assist us in analyzing how our Site and Services are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Distribution of User Content. We may provide your User Content (defined in our Terms of Use) that you submit to us to third parties for distribution on third party distribution channels selected by us. In such instances, although we will not provide your Personal Information to the third parties separately along with your User Content, if there is any information about you in the User Content, that information could be Personal Information that will be provided to the third party and may be virally distributed via the third party distribution channels.

Other Corporate Entities. We may disclose information (including Personal Information) about you to our Affiliates in the United States and internationally. For purposes of this Privacy Policy, “Affiliates” means any person or entity which directly or indirectly controls, is controlled by or is under common control with GCH, whether by ownership or otherwise. Any information relating to you that we provide to our Affiliates will be treated by those Affiliates in accordance with the terms of this Privacy Policy.

Compliance with Laws and Law Enforcement. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of GCH or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.

Business Transfers. We may sell, transfer or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.  Should such an event occur, we will require that the new or combined entity follow this Privacy Policy with respect to your Personal Information. If your Personal Information will be used contrary to this Privacy Policy, you will receive prior notice in as provided herein.

SNS. When you subscribe for Services or updates, register for any account or otherwise interact with the Services, you may be given you the option to share information with certain social networking services (e.g., Twitter, Facebook, Instagram).

 

Changing or Deleting Your Information

You may review, update, correct or delete the Personal Information in your profile by unsubscribing or contacting us. If you completely delete all such information, then your account, if you have one, may become deactivated. If you would like us to delete your record in our system, please contact us at support@gchusa.com with “Privacy” as the subject line of the email with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

 

Security

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on this Site in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100 percent secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us or from our online products or Service, and you do so at your own risk.

 

Links to Other Sites

Our Site may contain links to other websites. If you choose to visit an advertiser by “clicking on” a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party’s website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other sites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

 

Our Policy Toward Children

This Site is not directed to individuals under 18. We do not knowingly collect personally identifiable information from individuals under 18. If a parent or guardian becomes aware that his or her minor child under 18 has provided us with Personal Information without their consent, he or she should contact us at Privacy@gchusa.com. If we become aware that a person under 18 has provided us with Personal Information, we will delete such information from our files.

 

Contacting Us

If you have any questions about this Privacy Policy, please contact us at privacy@gchusa.com or at:

 

GCH, Inc.

3457 Ringsby Court

Unit 108

Denver, Colorado 80216

Attn: Privacy Officer