Privacy
Policy

Club-member information

To verify access and carry out membership requests, we process customer, club, and membership identifiers and relevant membership information returned by Commerce7. This includes membership status, hold and cancellation dates, requested actions, selected pause durations, cancellation reasons, and optional comments submitted by the member.

We also record limited service activity, such as cancellation starts, pause offers displayed, completed actions, timestamps, and technical errors. These records support the applicable winery's reporting, confirm the outcome of requests, and help prevent duplicate submissions.

Commerce7's standard cancellation reasons include health-related and pregnancy-related categories. If you select one, we process that selection only for your membership request, its necessary action records, and the winery's basic reporting. Please do not include medical details or other unnecessary sensitive information in optional comments. Free-text comments are not included in activity analytics or audit summaries.

Winery administration

We process authorized staff identifiers and roles, winery and club identifiers, installation and configuration information, website origins, timezones, and records of settings changes. This allows staff to administer the integration and view their winery's reports.

Website visits and support

Our hosting and security providers process limited technical request information, such as IP address, browser information, requested URL, and timestamps. If you contact us, we process the contact details and information you choose to provide so we can respond and resolve your request. Do not send passwords, payment-card details, or unnecessary member information in a support message.

Payments

123retention does not collect or store full payment-card numbers or CVV codes. The winery and its payment providers handle members' wine purchases and membership charges. Commerce7 or the billing provider disclosed at purchase handles a winery's subscription payments for 123retention.

We use club-member information only to:

• Verify access and the member's authority to act on a membership.
• Carry out and confirm the action the member requests.
• Provide basic service reporting to the applicable winery.
• Maintain necessary security and action records, prevent abuse and duplicate submissions, and resolve service issues.
• Assist with privacy requests and fulfill legal obligations.

We do not use club-member information for advertising, marketing outreach, consumer discovery recommendations, cross-winery benchmarking, model training, or creating consumer profiles. We do not sell or rent it or provide it to other wineries for their use. Aggregating or de-identifying this information does not authorize unrelated uses.

We use staff, installation, website, and support information to operate and secure the Services, administer subscriptions and configuration, respond to inquiries, and understand how authorized staff use the administration tools. Shared Lava Labs infrastructure does not expand the permitted uses of club-member information.

• The applicable winery and Commerce7. The winery authorizes the integration, and members submit requests through its website. We exchange the information needed to verify access, read membership state, and submit and confirm the selected change. The winery receives its service reports.
• Google Cloud and Firebase. Cloud hosting, database storage, and supporting infrastructure process service records.
• Vercel. Website hosting and delivery infrastructure process technical request information.
• Umami Cloud. Cookieless usage analytics for the administration tools and this website process limited, sanitized page and interaction information. Member identifiers and free-text comments are not included in those analytics.
• Support and business operations. Communications and billing providers process the information needed for the support or subscription transaction in which they are involved.
• Legal and safety purposes. We may disclose information when required by law or legal process, or as reasonably necessary to protect the security and rights of the winery, users, us, or others.

Information may be transferred in a merger, acquisition, or sale of the relevant business or assets. Such a transfer does not itself expand the uses permitted by this Policy. We will provide notice of material changes and obtain any consent required by law.

123retention uses the existing Commerce7 session on the winery's website to verify member access and Commerce7 authorization to verify staff access. It uses short-lived authorization for service requests. It does not require a separate consumer account or automatically link a member to another product.

Authentication tokens are processed for access checks and are not included in persistent activity analytics or business audit records. The winery's and Commerce7's notices describe their own cookies and session handling.

The widget records the limited service activity described above for the winery's reporting and reliable operation. Administration usage analytics are configured without analytics cookies. We do not use the Services for cross-context behavioral advertising or cross-site consumer profiling. We do not respond differently to browser “Do Not Track” signals; these limits apply regardless of that setting. A winery's website may have its own analytics or other technologies, governed by that winery's notices.

On this website, we use Umami Cloud to measure page views, link clicks, FAQ use, viewed sections, and scroll depth without analytics cookies. We remove URL query strings and fragments from website analytics and do not send club-member identifiers or support-message contents.

Using 123retention does not subscribe a club member to our marketing communications. The winery or Commerce7 may send its usual membership confirmations under its own settings and policies. We may contact authorized winery staff about installation, support, security, billing, or operation of the service.

If you separately request marketing communications from 123Commerce, that is a separate choice. You may withdraw that choice using the unsubscribe instructions or by contacting us.

• Completed action receipts. Records used to confirm a requested change and prevent duplicate submissions are scheduled to expire 30 days after the action succeeds or fails. Unresolved actions may be kept longer while their outcome is confirmed.
• Reporting and action history. Records are retained for the applicable winery's basic reporting, verification of requested actions, support, security, and legal obligations. They do not automatically expire on the action receipts’ 30-day schedule and remain subject to applicable deletion requirements. We act on the winery’s lawful deletion or return instructions, subject to permitted legal retention.
• Installation and configuration records. We retain records needed to administer access, preserve winery settings, and maintain necessary service history.
• Support and technical records. We retain information for as long as reasonably necessary for the request, operation, troubleshooting, security, and related legal or audit purposes.

We do not retain personal information longer than reasonably necessary for its disclosed purposes. Where legally permitted, deleted information may remain in protected backups until routine expiry and will not be used for ordinary business purposes. Uninstalling revokes service access but does not automatically erase reporting or action history, reverse completed requests, or delete records independently held by the winery or Commerce7.

You may ask about the information we process, request access, correction, or deletion, and raise a privacy concern by contacting the applicable winery or support@123commerce.co. You do not need to create an account with us to make a request.

Where we process information on a winery's behalf, we will assist the winery and may coordinate with it to verify identity and carry out its lawful instructions. We may need information to verify your identity or authority, and some records may be retained where permitted or required by law. A request to us does not automatically remove records independently held by Commerce7 or the winery.

Depending on applicable law, you may have rights to know or access information; correct inaccuracies; delete information; limit certain uses of sensitive information; and exercise applicable opt-out or appeal rights. We will respond within applicable legal timeframes and will not discriminate against you for exercising privacy rights. If applicable law provides an appeal and we decline a request, email support@123commerce.co with “Privacy Appeal” and we will review it and explain any further available complaint process.

We do not sell personal information or share it for cross-context behavioral advertising. Health-related reason selections are used only to provide the requested service and its necessary records and are not used to infer characteristics about you. California residents may contact us to exercise applicable rights under the California Consumer Privacy Act, as amended.

We use reasonable administrative, technical, and organizational safeguards, including authentication, access controls, rate limits, and protections against duplicate or unauthorized requests. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

Member-facing features are intended for adults age 21 or older. We do not knowingly provide them to children. Contact us if you believe information from a child has been submitted so we can investigate and take appropriate action.

The service is currently intended for use with wineries in the United States. Information may be processed and stored in the United States and other locations where the relevant hosting and service providers operate, subject to applicable legal requirements.

We may update this Policy by posting a revised version with a new "Last updated" date. For material changes, we will provide additional notice where appropriate or required by law. We will obtain additional consent before changes take effect where required by law.

Privacy contact: Lava Labs, LLC, operator of 123retention under the 123Commerce brand. Email support@123commerce.co.

Our Terms of Service describe the service and winery responsibilities.