Privacy Policy
Last Updated: February 18, 2026
Effective Date: February 18, 2026
This Privacy Policy explains how Chianti Reserve collects, uses, and protects your personal data when you visit our website. We are committed to transparency and compliance with the General Data Protection Regulation (GDPR), UK GDPR, and applicable Canadian privacy laws including the Personal Information Protection and Electronic Documents Act (PIPEDA).
1. Cookie Categories
We use cookies and similar tracking technologies to enhance your browsing experience and measure website performance. Cookies are divided into three categories based on their purpose and your consent requirements.
1.1 Essential Cookies
Purpose: Essential cookies are necessary for the core functionality of our website. They enable basic features such as page navigation, secure access to specific areas, session management, and security protections.
Examples: session_id, csrf_token, cookie_consent_status
Consent Required: No. Essential cookies are activated automatically when you visit our website because they are strictly necessary for the site to function properly.
Retention Period: Session duration or up to 12 months for preference storage cookies such as language settings and cookie consent choices.
1.2 Analytics Cookies
Purpose: Analytics cookies help us understand how visitors interact with our website by collecting and reporting information anonymously. This data allows us to measure traffic patterns, identify popular content, and improve user experience.
Tools Used: Google Analytics 4
Examples: _ga, _ga_XXXXXXX, _gid, _gat
Consent Required: Yes. Analytics cookies are activated only after you explicitly accept them through our cookie consent banner or preferences panel.
Retention Period: Up to 14 months from the date of your last interaction with our website.
1.3 Marketing and Advertising Cookies
Purpose: Marketing cookies are used to deliver personalized advertisements based on your browsing behavior and interests. These cookies enable remarketing campaigns, track conversions from advertising efforts, and measure the effectiveness of our advertising across various platforms.
Consent Required: Yes. Marketing and advertising cookies are activated only after you provide explicit consent by clicking "Accept All Cookies" in our consent banner.
Retention Period: Up to 540 days, which is the default retention period for Google Ads conversion tracking cookies.
2. Marketing Cookies — Detailed Disclosure
When you consent to marketing cookies, the following practices and technologies are activated on our website. We provide this detailed disclosure to ensure full transparency regarding how your data is used for advertising purposes.
2.1 Third-Party Ad Serving
Third-party vendors, including Google, use cookies to serve ads based on a user's previous visits to this website and other sites on the internet. These cookies allow advertising networks to recognize your browser and deliver relevant advertisements across the web.
2.2 Advertising Partners
We may work with advertising partners such as Google and Meta to deliver advertisements tailored to your interests across various websites and platforms. These partners use the data collected through cookies and tracking pixels to build interest profiles and deliver more relevant advertising content.
2.3 Remarketing Services
We may use remarketing services to advertise to previous visitors of our website. After visiting our site, you may see our ads on other websites, apps, or platforms you visit. Remarketing allows us to show targeted advertisements to users who have demonstrated interest in our content by visiting specific pages on our website.
2.4 YouTube and Google Display Network
Advertisements may appear across Google services including YouTube, Gmail, and the Google Display Network. If you are signed into a Google account while browsing our website, Google may associate your visit with your account for the purpose of delivering personalized advertising on these platforms.
2.5 Tracking Technologies
We use the following tracking technologies on this website:
- Cookies (first-party and third-party)
- Tracking pixels (Google Ads tag / gtag.js, Meta Pixel)
- Device identifiers (browser fingerprint, IP address)
- Conversion event tags
2.6 Advertising Measurement and Conversion Tracking
We use conversion tracking to understand which advertisements lead to actions on our website — such as form submissions, phone calls, or content downloads. This allows us to measure campaign effectiveness and allocate advertising budget appropriately. Conversion data may be shared with Google Ads and Meta to optimize advertising performance and improve targeting accuracy.
2.7 Technologies in Use
The following advertising and analytics technologies are active on this site when you provide consent:
- Google Ads (gtag.js / Google Tag Manager)
- Google Analytics 4
- Google Remarketing Tag
- Meta Pixel (Facebook / Instagram)
2.8 Opt-Out from Personalized Advertising
You may opt out of personalized advertising at any time through the following channels:
- Google Ads Settings: https://adssettings.google.com
- Your Online Choices (EU): https://www.youronlinechoices.eu
- Network Advertising Initiative: https://optout.networkadvertising.org
- Digital Advertising Alliance: https://optout.aboutads.info
Please note that opting out of personalized advertising does not remove ads entirely. You will continue to see non-personalized advertisements that are not based on your browsing behavior or interests.
2.9 Cookie Preference Management
You can manage your cookie preferences at any time by clicking the "Manage Cookie Preferences" link in the footer of our website. This will open a panel where you can accept or reject each category of cookies independently. Essential cookies cannot be disabled as they are necessary for the website to function.
3. Consent Requirements
3.1 Consent Banner
When you first visit our website, you will see a cookie consent banner offering three options:
- Accept All: Activates all cookies including analytics and marketing cookies
- Reject Non-Essential: Only essential cookies are activated; analytics and marketing cookies remain disabled
- Manage Preferences: Opens a detailed panel where you can choose which cookie categories to enable
Analytics and marketing cookies will NOT be activated until you explicitly click "Accept All" or enable them through the "Manage Preferences" panel. Your choice is stored in your browser's local storage for 12 months.
3.2 Consent Statement
By clicking "Accept All Cookies", you consent to the storing of cookies on your device for analytics and advertising purposes, including personalized advertising delivered by Google and Meta. You may withdraw consent at any time through the cookie preferences panel without affecting the lawfulness of processing that occurred before withdrawal.
3.3 EEA and UK Users
Users in the European Economic Area and the United Kingdom receive this consent notice in compliance with the General Data Protection Regulation (GDPR) and UK GDPR. Marketing and analytics cookies are activated solely after explicit, informed, freely given consent under GDPR Article 6(1)(a). Consent is recorded with a timestamp and may be audited upon request.
3.4 Withdrawal of Consent
You may withdraw consent at any time by clicking "Manage Cookie Preferences" in the website footer, or by clearing cookies via your browser settings. Withdrawal does not affect processing that occurred while consent was valid. Once you withdraw consent, analytics and marketing cookies will no longer be set, and existing cookies may be deleted depending on your browser settings.
4. Data Sharing with Advertising Partners
We share certain data with advertising partners for campaign delivery and measurement. The recipients and the data categories shared include:
4.1 Google LLC
We share cookie identifiers, conversion events, anonymized behavioral data, and remarketing lists with Google LLC. This data is used to deliver personalized advertisements through Google Ads and to measure the effectiveness of our advertising campaigns. Google processes this data in accordance with its Privacy Policy, available at https://policies.google.com/privacy.
4.2 Meta Platforms, Inc.
We share pixel events, conversion data, and custom audiences with Meta Platforms, Inc. for advertising on Facebook and Instagram. Meta processes this data according to its Data Policy, available at https://www.facebook.com/privacy/policy.
4.3 Data Processing and Transfer
We do not sell personal data. All transfers to Google and Meta operate under Standard Contractual Clauses where applicable to ensure appropriate safeguards for data transferred outside the European Economic Area. Data is processed for ad targeting and campaign measurement only and is not resold to unaffiliated third parties.
Google and Meta may use this data across their own platforms in accordance with their respective policies. We encourage users to review those policies directly to understand how your data is processed by these third-party platforms.
5. Contact Forms and Requests
When you submit a contact form on our website, we collect the information you voluntarily provide. This typically includes your full name, email address, phone number, and the content of your message or inquiry.
5.1 Legal Basis
The legal basis for processing contact form data is consent under GDPR Article 6(1)(a). When you submit a form, you provide explicit consent for us to process the information you have shared. Where a service relationship exists or is being established, we may also rely on performance of a contract under GDPR Article 6(1)(b).
5.2 Retention Period
Form submission data is retained for up to 2 years from the date of submission, unless a longer retention period is required by applicable law or legitimate business purposes. After this period, data is securely deleted or anonymized.
5.3 Data Deletion Requests
You may request deletion of your contact form data at any time by contacting us at [email protected]. We will process your request within 30 days and confirm deletion in writing.
5.4 Privacy Policy Link
A link to this Privacy Policy appears adjacent to every submission button on our website. Submitting a form constitutes acknowledgment of this policy and consent to the processing described herein.
6. Google Services and Advertising
This website uses the following Google services when you provide consent through our cookie banner:
6.1 Google Analytics 4
Google Analytics 4 collects anonymized usage data, device information, and behavioral signals to help us understand how visitors use our website. IP anonymization is enabled to protect user privacy. Data retention is set to 14 months. Users may opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.
6.2 Google Ads Conversion Tracking
Google Ads conversion tracking records when a user completes a defined action such as form submission, phone call, or content download after clicking one of our advertisements. This data is used solely for measuring ad campaign performance and optimizing our advertising strategy. Conversion data is shared with Google Ads to improve targeting accuracy.
6.3 Google Remarketing
Google Remarketing allows us to show ads to previous visitors across Google's advertising network, including the Google Display Network and YouTube. Remarketing lists are not created from sensitive data categories such as health information, financial status, religion, or sexual orientation. We use remarketing solely to promote educational content about wine culture and heritage.
6.4 Google Tag Manager
Google Tag Manager deploys tracking tags on our behalf. No personal data is collected by GTM itself; it acts as a container for the analytics and advertising tags listed above. Tag Manager allows us to manage tracking codes without modifying website code directly.
6.5 Google Advertising Policies
Google's advertising products are governed by Google's Advertising Policies and Privacy Policy, available at https://policies.google.com/technologies/ads.
7. Meta Advertising Services
This website uses the Meta Pixel to measure the effectiveness of our advertising on Facebook and Instagram. The pixel may record the following when you consent to marketing cookies:
- Page views and time spent on site
- Specific conversion events such as form submissions
- Custom audience membership for retargeting purposes
7.1 Data Processing by Meta
We do not use the Meta Pixel to collect sensitive personal data, nor to target users based on health status, financial situation, religion, political views, sexual orientation, or any other special-category attribute prohibited under Meta's advertising policies. All advertising complies with Meta's Community Standards and Advertising Policies.
Meta acts as an independent data controller for data collected via its Pixel and processed within its own platform. Refer to Meta's Data Policy at https://www.facebook.com/privacy/policy for details on how Meta processes your information.
7.2 Managing Meta Ad Preferences
To manage your ad preferences on Meta platforms, visit https://www.facebook.com/adpreferences/. You can control which advertisers can reach you and adjust your ad settings directly within your Facebook or Instagram account.
8. Prohibited Content Self-Declaration
This website does not promote, sell, or facilitate access to prohibited product or service categories including but not limited to: weapons, controlled substances, counterfeit goods, gambling services without appropriate licensing, adult content, or services that make misleading health or financial claims. All advertising conducted through Google Ads and Meta Ads complies with the respective platform policies in full.
9. Landing Page Integrity Statement
The content of this website accurately represents the educational services and informational resources offered. No bait-and-switch practices are employed. The experience delivered to users arriving from paid advertisements is identical to the experience for all other visitors. Cloaking, automatic redirects, and content variation by traffic source are not used on this website. All visitors receive the same content regardless of how they arrived at our site.
10. Children's Privacy
This website is not directed at individuals under the age of 16. We do not knowingly collect personal data from minors. If we discover that data has been collected from a person under 16 without verifiable parental consent, we will delete it promptly. Contact us at [email protected] if you believe we have received data from a minor.
11. International Data Transfers
Personal data collected through this website may be transferred to and processed in countries outside the European Economic Area, including the United States, where Google LLC and Meta Platforms, Inc. are based.
These transfers are conducted under Standard Contractual Clauses (SCCs) approved by the European Commission, which provide appropriate safeguards for personal data transferred internationally. A copy of the applicable SCCs can be requested by contacting us directly at [email protected].
12. User Rights Under GDPR
If you are located in the European Economic Area or the United Kingdom, you have the following rights under the General Data Protection Regulation (GDPR) and UK GDPR:
- Right of Access (Article 15): Request a copy of the personal data we hold about you
- Right to Rectification (Article 16): Correct inaccurate or incomplete personal data
- Right to Erasure (Article 17): Request deletion of your personal data, also known as the "right to be forgotten"
- Right to Restriction (Article 18): Limit how we process your personal data under certain circumstances
- Right to Data Portability (Article 20): Receive your personal data in a structured, machine-readable format for transfer to another service
- Right to Object (Article 21): Object to processing based on legitimate interest or for direct marketing purposes
- Right to Withdraw Consent (Article 7.3): Revoke consent at any time without penalty, though this does not affect the lawfulness of processing before withdrawal
12.1 Exercising Your Rights
To exercise any of the rights listed above, email us at [email protected] with your request. Please include sufficient information to identify yourself and specify which right you wish to exercise. We will respond within 30 days of receiving your request.
12.2 Lodging a Complaint
You have the right to lodge a complaint with your local supervisory authority if you believe we have not handled your personal data appropriately:
- EU users: European Data Protection Board — https://edpb.europa.eu
- UK users: Information Commissioner's Office — https://ico.org.uk
13. What Data We Collect
We collect the following categories of data when you interact with our website:
- Contact Information: Full name, email address, phone number (when voluntarily submitted through contact forms)
- Technical Data: IP address, browser type and version, device type and operating system, screen resolution
- Cookies and Identifiers: Cookie identifiers, session IDs, device fingerprints
- Usage Data: Pages visited, time spent on site, click paths, referral sources, search queries used to find our site
- Form Submission Content: Any information you provide in contact forms or inquiry submissions
- Conversion Events: Actions such as form submissions, button clicks, page scrolls, and other defined events for advertising measurement
14. Legal Basis for Processing
For each category of data we collect, the legal basis for processing under GDPR Article 6 is as follows:
- Contact form data: Consent (Article 6.1.a) and performance of a contract (Article 6.1.b) where a service relationship exists
- Analytics data: Consent (Article 6.1.a) obtained through the cookie consent banner
- Marketing and remarketing data: Consent (Article 6.1.a) obtained when you accept marketing cookies
- Security and fraud prevention: Legitimate interest (Article 6.1.f) in protecting our website and users from malicious activity
15. Data Retention Periods
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected. Specific retention periods by data category are as follows:
- Contact form submissions: 2 years from the date of submission
- Analytics data (Google Analytics 4): 14 months from last user interaction
- Marketing cookies (Google Ads): Up to 540 days from last interaction
- Email communications: Duration of the relationship plus 1 year
- Server logs: 90 days for security and troubleshooting purposes
- Cookie consent records: 3 years to meet audit and compliance requirements
After the applicable retention period expires, data is securely deleted or anonymized so that it can no longer be associated with an individual.
16. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or service offerings. When we make material changes, we will notify users via a prominent banner on our homepage at least 14 days before the changes take effect.
Continued use of our website after changes take effect constitutes acceptance of the updated Privacy Policy. We encourage you to review this page periodically to stay informed about how we protect your personal data.
17. Contact Information
If you have questions about this Privacy Policy, wish to exercise your rights, or need to contact us regarding data protection matters, please reach out using the following contact details:
Chianti Reserve
350 Fifth Avenue
New York, NY 10118
United States
Email: [email protected]
Phone: +1 (212) 555-0198
We will respond to all privacy inquiries and data subject requests within 30 days of receipt.