PRIVACY POLICY

Our website address is: https://neroclub.co.za.

BOSMAN FAMILY VINEYARDS CLIENT INFORMATION PROCESSING POLICY

 Bosman Family Vineyards is committed to protecting your privacy. We recognise our obligation to respect and protect the confidentiality of your personal and financial information.  For this reason, we have developed this policy, together with our Terms and Conditions, to govern the processing of your information. Please read and consider this document carefully since it sets out our intended use of your personal and financial information. We require you to consent to this policy before we can process an order submitted by you or render any services to you.

 WHO WE ARE

 When we refer to “we”, “us”, “our” or “BFV” herein we are referring to  Bosman Adama (Pty) Ltd , a private company incorporated in accordance with the laws of the Republic of South Africa with registration number 2001/012743/07) , trading as “Bosman Family Vineyards” and its affiliated group companies, or any of them, as the context requires, as well as our assignees and successors in title. Our principal place of business is at Lelienfontein Farm, Hexberg Road, Wellington, 7655 but we recommend you contact us at +27 (0)21 873 3170 or electronic mail at hello@neroclub.co.za

All references to “you”, “user” and “your” are deemed to refer to any user and/or visitor of www.neroclub.co.za, and other related URLs, and/or any ancillary services (“Website”).

ACTIVE COLLECTION OF PERSONAL INFORMATION

 To access or take advantage of certain features of the Website, we may request that you provide personal information. “Personal Information” is information about you that is associated with your name or identity, such as, name, mailing address, e-mail address, credit or debit card account number, birth date, telephone number, or purchase information. Personal Information may also include “Demographic Information”, such as your gender, marital status, salary, purchasing habits, or similar information.

Personal Information may be requested and collected at various locations and on various forms on the Website, including but not limited to:

 * registration forms for newsletters and other e-mail communications;

 * registration for membership to the Website;

 * when you submit an inquiry via the Website;

 * when you submit an order for wine or other products; or

 * when you communicate or otherwise interact with us via the Website.

You may always select not to submit Personal Information, however, as a result, you may not be able to access certain of the Website’s features and/or functionality.

We may also provide you opportunities to submit Personal Information about other individuals. For instance, you may choose to send a notice through the Website to a friend regarding content offered by the Website. Or when you gift wine to a friend. We will not use the Personal Information of these individuals for any other purpose unless we disclose otherwise at the time you provide the information. It is your responsibility to ensure that you are permitted to share such third party information with us to use on the basis as described under these terms.

We will also collect information of how you have used the Website in order to improve the user experience.  This is done by means of cookies.  When you visit the Website, a cookie is a piece of information sent to your computer by our web server.  To optimise your experience, a cookie helps to recognise you when you re-visit the Website.

If you have registered as a member, you may update or modify some of the information that you actively provided through the Website, including your e-mail marketing preferences, by logging into your member account. In addition, you may deactivate your member account.

We may use a third-party company to monitor website traffic, which may, in some instances, store your information, including the Personal Information you submit to such third parties.

By continuing to use the Website, you consent to processing, collection, storage, retention and use of the Personal Information you provide for the purposes set out in this Privacy Policy, and you consent to our collection of any changes or updates that you may provide to any information you provide that is collected by us. If you do not agree to this Privacy Policy, please do not use the Website.

Where you provide us with Personal Information relating to a third-party data subject (for example, your friends, customers and/or clients), you warrant that you have obtained all necessary consents from such data subject, including the data subject’s consent for you to share such Personal Information with BFV to process. We shall protect, store and process this Personal Information in the same manner and equal level of security as Personal Information about you.

HOW DO WE STORE YOUR PERSONAL INFORMATION?

 Your Personal Information is digitally stored on a Website with a third party in South-Africa. We also keep a backup on premises and/or hard copies (as applicable).  We have agreements with service providers to keep Personal Information secure and they are using appropriate and reasonable security measures to ensure the handling of Personal Information receives at least the same level of protection as it is given in this Privacy Policy.

PROTECTION OF YOUR PERSONAL INFORMATION

We recognise that protecting your privacy is important to you. For this reason, we are committed to protecting the Personal Information you provide in a variety of ways.

 We will:

* treat your Personal Information as strictly confidential;

* take appropriate technical and organisational measures to ensure that your Personal Information is kept secure and is protected against unauthorised or unlawful processing, accidental loss, destruction or damage, alteration, disclosure or access;

* promptly notify you if we become aware of any unauthorised use, disclosure or processing of your Personal Information;

* provide you with reasonable evidence of our compliance with our obligations under this Privacy Policy on reasonable notice and request; and

* Upon your request, promptly return or destroy any and all of your Personal Information in our possession or control.

We will not retain your Personal Information longer than the period for which it was originally needed, unless we are required by law to do so, or you consent to us retaining such information for a longer period.

WHY WE NEED YOUR INFORMATION

We will collate the Personal Information which you give to us to provide you with services and personalise your use and visits of this Website. We may also use such Personal Information to inform you, the user, about changes in the services we offer and/or about features we think you would find of interest. We may also permit the affiliated entities in our company group to inform you about products or services they offer that might interest you. By giving us this Personal Information, you consent to our use of it for these purposes, including for the purpose of processing your orders and instructions.

In addition to the above, we collect and process your Personal Information for the following purposes:

* to process orders for products or services and for making related decisions including by verifying your identity, credit status, contact details, financial track record and otherwise ascertaining that you qualify for our products or services from time to time;

* to take such actions as may be required to enable and improve your access to and/or use of our products and/or services and to exercise our rights and comply with our obligations in respect thereof, including by processing and recording your product orders and service requests and transactions, managing your accounts and policies, delivering our products and services to you, communicating with you regarding your use of our products and services and collecting payments you may owe us;

* to ensure that the information we receive and hold about you is accurate, complete and up to date;

* to prevent, investigate and prosecute fraud, money laundering, abuse of our services and other unlawful activities;

* to comply with legal and regulatory requirements, for audit purposes and legal proceedings;

* to conduct market research and business analysis, understand your preferences, learn more about the products and services that you are interested in and improve the products and services we offer to you;

* to inform and provide you with the opportunity to make use of products, services and benefits that we offer and what we believe may be of interest to you to the extent that we are lawfully permitted to do so; and

* for such other purposes as you may consent to or as may otherwise be lawfully permitted, including for the purposes of protecting our and/or your legitimate interests and/or that of our suppliers and other customers.

Please note that we will not contact you telephonically for unsolicited marketing purposes or send unsolicited marketing communications to you by mail, facsimile, SMS or electronic mail if you have objected to receiving such communications by way of a public register recognised for such purposes by law or by notifying us of your objection in the prescribed manner. We will provide you with reasonable opportunities to object to and/or opt-out from receiving marketing communications in the manner prescribed by law, including on each occasion when we send you such communications.

DISCLOSURE OF INFORMATION

By proceeding to submit your Personal Information, you give consent for the storage, transmitting and access of your Personal Information by third parties in overseas jurisdictions for the purposes described herein.

We may, in our sole discretion, share Personal Information with third parties that is not associated with your name or identity, such as website usage information, anonymous Demographic Information, and aggregate user statistics.

In addition, we may share Personal Information with such third parties and for the purposes as described below:

Service Providers: We may share your Personal Information with third party service providers so that they may perform certain services for us, such as website hosting, order fulfilment, clearing and processing credit and debit card payments, or performing other services on our behalf.

Business Transfers: We reserve the right to disclose and transfer Personal Information about you including, without limitation, during the course of any due diligence process: (i) to a subsequent owner, co-owner or operator of the Website; or (ii) in connection with a corporate merger, consolidation, restructuring, sale of substantially all of the winery stock and/or assets or other corporate change.

Legal and Safety Obligations: We may disclose your Personal Information: (i) if we are required to respond to summons, court orders, legal process or other valid law enforcement measures; (ii) at the request of governmental authorities conducting an investigation; (iii) when we believe in good faith that the law requires disclosure; (iv) to verify or enforce compliance with our Terms and Conditions or other policies governing the Website; (v) whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests, or safety of the Website, visitors to the Website or other third parties; or (vi) to respond to an emergency.

PARENTAL/AGE ADVISORY AND LIABILITY

The Website is not directed to children or individuals younger than 18. We do not knowingly collect or solicit Personal Information from anyone younger than 18. In the event that we discover that we collected Personal Information about a child or individual younger than 18, we will delete the Personal Information.

No data transmission over the Internet or electronic storage of information can be guaranteed to be 100% secure or hacker proof. While we have implemented high security measures, we cannot ensure or warrant the security of any information and/or Personal Information you transmit to us or through the Website, and accordingly shall not be liable for any loss, damage and/or cost which you may suffer or incur as a result of a data breach or cyber-attack.

MODIFICATIONS TO THE PRIVACY POLICY

We reserve the right, at any time, for any reason in our sole discretion and without prior notice or liability, to change, modify, amend and/or update this Privacy Policy. Therefore, you should review this Privacy Policy before submitting any information to us. We will collect, store, use and share your Personal Information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless we receive your consent to the new or revised policy. 

YOUR RIGHTS REGARDING YOUR INFORMATION

Provided that you give us suitable and adequate proof of your identity, you have a right to know which records we hold about you and to know the identity of all third parties which have been or are to be given access thereto. This can be done by submitting a written request to us. We will not be obliged to provide you with information to the extent that we are prohibited or permitted thereto by applicable law.

You also have the right to require us to correct or erase any records we hold about you that we are no longer permitted to retain, is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or has been unlawfully obtained. This can be done by submitting a written request to us. We will notify you of the steps taken as a result of your request.

Please contact us if you want to submit any request to us hereunder. We will provide you with the prescribed form and the amount of any applicable prescribed fee.

OBJECTIONS

Please contact us if you want to object to our collection, processing, recording, protection, use or sharing of your information. Please note that we may require a reasonable period to comply with your objection and can only do so if permitted thereto by law and such compliance does not unreasonably prejudice our legitimate interests or that of a third party.

QUESTIONS/CONTACT US

If you have questions about the Website, our Terms and Conditions or this Privacy Policy, including how we may collect, store, use or share information about you, please contact us at hello@neroclub.co.za . Should you have a question or complaint, you can contact us by calling +27 21 873 3170 or email hello@neroclub.co.za. We appreciate your feedback and will always respond within a reasonable time.