Privacy Policy

Last modified: June 1, 2021


Concept Four, a part of Foley Family Wines, Inc., a Delaware corporation, (“Company” or We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Policy describes (i) the types of information we may collect from you or that you may provide when you communicate with us (whether electronically, by telephone or in writing), visit the website ( (our “Website”) and our mobile applications for use with IOS and Android (our “Apps”; the Website and Apps will be collectively referred to herein as our “Online Services”) and (ii) our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On this Website.
  • Through our Apps.
  • In email, text, and other electronic messages between you and our Online Services or our personnel with regard to anything discussed, referenced or described on our Online Services (e.g. our wine clubs).
  • Through telephone, written or other communication methods which are then used with our Online Services.
  • Through written correspondence, applications or enrollments.
  • In person, including at our wineries, tasting rooms or retail locations.
  • From our business partners and third party service providers, including, but not limited to, data providers, data brokers or other data aggregators.
  • From our affiliates and subsidiaries.
  • It does not apply to information collected by any third party (other than our affiliates, subsidiaries and data service providers described above), including through any application or content (including advertising), whether or not such is linked to, or accessible from or on, the Online Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, your choice is not to use our Online Services.  This policy may change from time to time (see Changes to Our Privacy Policy).

Persons Under the Age of 21

Our Online Services are not intended for persons under 21 years of age. No one under age 21 may provide any information to or on the Online Services. We do not knowingly collect personal information from persons under 21. If you are under 21, do not use or provide any information on the Online Services or on or through any of its features/register on the Online Services, make any purchases through the Online Services, use any of the interactive or public comment features of the Online Services or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a person under 21, we will delete that information. If you believe we might have any information from or about a person under 21, please contact us either (i) by email at or (ii) by telephone at 844-285-2209.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Online Services, including information:

  • by which you may be personally identified, such as name, birthdate, age, postal address, e-mail address, telephone number, veteran status, personal preferences, credit card information, including billing address, or any other identifiers by which you may be contacted online or offline;
  • that is about you but individually does not identify you, such as IP address or other online identifiers; and/or
  • about your internet connection, the equipment you use to access our Online Services and usage details (collectively, “personal information”).

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the Online Services. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • From third parties, including, our business partners, service providers, affiliates and subsidiaries.  These service providers include, but are not limited to, data providers, data brokers and data aggregators, like Harte Hanks Direct, Inc. (“Harte Hanks”).  If you would like more information about Harte Hanks, its privacy practices or how to exercise your rights with regard to Harte Hanks’ processing of your personal information, please visit

Information You Provide to Us

The information we collect on or through our Online Services may include:

  • Information that you provide by filling in forms on our Online Services. This includes information provided at the time of registering as a member of the Foley Food and Wine Society, subscribing to one or more of our wine clubs, purchasing products through our online wine shop or contacting us for additional information, products or services. We may also ask you for information when you enter a contest or participate in a promotion sponsored by us, and when you report a problem with any of our Online Services or products.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Online Services and of the fulfillment of your orders. You may be required to provide credit card information before placing an order or registering for one or more of our wine clubs through our Online Services.
  • Your search queries on the Online Services.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Online Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to any of our Online Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Online Services.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. Such personal information helps us to improve our Online Services and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Online Services according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to the particular Online Service.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Online Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Online Services.
  • Flash Cookies. Certain features of our Online Services may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons. Pages of our Online Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website/application statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website, the Apps and their respective content to you.
  • To conduct business with you.
  • To provide you with information, products, or services that you request from us.
  • To answer questions and provide other customer services.
  • To develop new, or modify existing, products and services.
  • To manage, including, but not limited to, providing you with notices about, your account, society membership or wine club subscription(s), including expirations and renewals.
  • To fulfill your wine club subscriptions and other orders.
  • To issue, manage and use your reward points.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To allow you to participate in interactive features on our Online Services.
  • To notify you about changes to any of our Online Services or any products or services we offer or provide though it.
  • To prevent fraud or cybersecurity attacks.
  • To assist in our efforts to implement, maintain and modify our information system, network and cybersecurity protections.
  • To develop and operate financial/credit/conduct and risk models, conduct internal analysis of customers, plan strategy and growth, collate reports, manage information to support our business operations.
  • To fulfill any other purpose for which you provide any information to us.
  • For any other purpose with your consent.

The personal information that we obtain from the third party data providers, data brokers or data aggregators that we engage, like Harte Hanks, is used in support of our legitimate business, advertising and marketing objectives. 

We also use your information to contact you about our own and third-parties’ (including our affiliate’s or subsidiary’s) goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us by email at  For more information, see Choices About How We Use and Disclose Your Information

Disclosure of Your Information

We may disclose aggregated anonymized information about our users without restriction. Additionally, we may disclose your personal information that we collect or you provide as described in this Privacy Policy:

  • To our affiliates and subsidiaries.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Foley Family Wines, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Foley Family Wines, Inc. about our Online Services users is among the assets transferred.
  • To third parties (other than our affiliates and subsidiaries) to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
  • To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “Contact Us” feature of our Website, we will transmit the contents of that email and your email address to the appropriate persons with our Company in order to provide you with the requested information or to otherwise fulfill your request.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our policies, terms and conditions, and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Foley Family Wines, Inc., our affiliates and subsidiaries, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email stating your request to
  • Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our products or services, you can opt-out by changing your preferences in your account profile or at any other time by sending us an email stating your request to This opt-out does not apply to information provided to the Company as a result of a product purchase, product service experience or other transactions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.  If you wish to exercise your rights with regard to Harte Hanks’ processing of your personal information, please visit

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website or the applicable App and visiting your account profile page.

You may also send us an email at to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you wish to exercise your rights with regard to Harte Hanks’ processing of your personal information, please visit California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit Your California Privacy Rights for more information.

California Civil Code Section 1798.83 permits our visitors who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at our wineries, tasting rooms, or retail locations or through one of the following:

  • Email:                       
  • Phone:                             844-285-2209
  • Postal Address:            10300 Chalk Hill Road, Healdsburg, California 95448.

Do Not Track (DNT) is a privacy preference that users can set in their web browsers. At this time, our Online Services do not support DNT codes. However, except in the case of analytics cookies, our Website limits tracking to the uses described above. Except in the case of analytics cookies, our Website does not track your use across multiple websites other than the affiliated websites included within this Privacy Policy, however, other websites to which we link may. Please review their privacy policies to understand how you may be tracked.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and credit card information will be encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Online Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to this Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website or App home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Online Services and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, please contact us our wineries, tasting rooms, or retail locations or through one of the following:

  • Email:                     
  • Phone:                           844-285-2209
  • Postal Address:          10300 Chalk Hill Road, Healdsburg, California 95448