1. What Information Do We Collect?

Personal information you disclose to us

In Short:  We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Channels, express an interest in obtaining information about us or our products and Channels, when you participate in activities on the Channels (such as by posting messages in our online forums or entering competitions, contests or giveaways) or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Channels, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You. We collect names; phone numbers; email addresses; mailing addresses; usernames; passwords; billing addresses; and other similar information.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below.

Information automatically collected

In Short:  Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Channels.

We automatically collect certain information when you visit, use or navigate the Channels. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Channels and other technical information. This information is primarily needed to maintain the security and operation of our Channels, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies, including:

Cookies and Local Storage. “Cookies” and local storage are pieces of information (data files) transferred to an individual’s browser on their device when the device is used to visit a Channel. These technologies are able to store a unique identifier for a device to allow a certain Internet site to recognize the device whenever the device is used to visit the site. These technologies may be used for many purposes by us and our third-party service providers, such as automatically collecting Usage Information, enabling features, remembering your preferences, and providing you with targeted advertising elsewhere online. If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. You can find more information about cookies and how they work at www.allaboutcookies.org.

Certain browsers or browser add-ons, such as Adobe Flash, may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our Channels may make use of this local storage. For example, a Flash cookie is a data file placed on a device via the Adobe Flash plug-in that may be built into or downloaded by you onto your device. Flash cookies may be used for various purposes, including, without limitation, enabling a Flash feature and remembering your preferences. For more information about Flash and the privacy choices Adobe offers, visit https://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. If you choose to disable cookies, to adjust your Flash privacy settings on your device, or to otherwise restrict local storage, some features of the Channels may not function properly, including the shopping cart and ordering processes.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “pixel tags,” “1x1 GIFs,” or “clear GIFs”) may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to a Channel, to monitor how users navigate the Channel, to count how many emails that were sent were actually opened or to count how many particular links were actually viewed.

Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Channels, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider, is active only while you are connected to a Channel, and is deactivated or deleted thereafter.

In addition, we may use a variety of other technologies that collect similar information for security and fraud detection purposes.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Channels and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Channels (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Channels. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.

Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Channels. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Channels.

Community Forums and User Submission. The Channels may provide you the opportunity to submit information to us, through interactive features, and through other communication functionality ("Community Forums"). You may choose, through such features or otherwise, to submit or post “User Submissions” (which means any and all information and content that you submit or post to the Channels, including without limitation, text, writings, video, audio, photos, audio, video, photographs, graphics, text, messages, comments, suggestions, or personal information, files or other content or material that you provide to us or are submitted through your account on a Channel, and as further described in our Terms of Use ). Some features, such as user reviews, may be operated by a third party and your postings also may be subject to the third party’s privacy policy and terms of use.

Please note that certain information, such as your name and/or place of residence, may be publicly displayed on the Channels along with your User Submissions. Your use of any Community Forum is subject to our Terms of Use, including without limitation the “User Submissions” section. Note that anything you submit through a public-facing Community Forum may be made public – others will have access to your User Submission and may use it or share it with third parties. We are not responsible for the actions of third parties and the use of your information and other User Submissions by such third parties is not subject to the protections of this Privacy Policy.

Social Networking Features.  Functionality on the Channels may permit interactions between the Channels and a third-party service such as Facebook or Instagram (“Social Networking Features”). Examples of Social Networking Features include enabling you to “like” or “share” content from the Channels or to “like” or “share” our page on a third-party service; to automatically or selectively show your social media posts on the Channels; and to otherwise connect the Channels to a third-party service. If you choose to share content or to otherwise post information through the Channels to a third-party service, or vice versa, that information may be publicly displayed. Similarly, if you post information on a third-party service that references us (for example, by using a hashtag associated with us in your post), your post may be published on the Channels or otherwise in accordance with the terms of that third party. Also, both we and the third party may have access to certain information about you and your use of the Channels and the third-party service. These third-party social networking companies may collect information about your visit to a Channel through the Social Networking Features we have integrated into the Channel, and - if you are signed into your account with such a third-party social networking company – it may collect additional information in accordance with the terms of your agreement with that company. In addition, we may receive information about you if other users of a third-party service give us access to their profiles and you are one of their “connections” or information about you is otherwise accessible through your profile or similar page on a social networking or other third-party service. The information we collect in connection with Social Networking Features is subject to this Privacy Policy. The information collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third-party service.

If you submit User Submissions or use Social Networking Features, we may publish that information or content online or offline, including in connection with our advertising, marketing, publicity, and promotional activities, as further described in our Terms of Use.

Information Provided by Third Parties. We may obtain information about you from third parties, including our joint marketing partners, third-party websites, affiliate program service providers, the our bank partner, users who provide us with information about others (i.e. purchasing a gift card for someone else), or other unrelated third parties. We may combine information about you that we have with information we obtain from business partners or other companies. In those cases, we will apply this Privacy Policy to the combined information. Please note that if you apply for or utilize a branded credit card from one of our brands or open an account with us, you are providing your information to the bank that administers the credit card and/or the account, which will share that information with us.

Send-to-a-Friend Features. We may make available on the Channels a “send-to-a-friend,” “refer a friend,” “wishlist” or similar function that permits you to send Channel content directly to a third party through the Channels. If you send a friend a communication using such functionality, the information you provide about your friend (e.g., name and e-mail address) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person.

Information the Channels Automatically Collect When You Interact with Us. Winden and our third-party service providers, including analytics providers, advertisers, and third-party content providers, may automatically or passively receive and record certain information about your use of the Channels whenever you visit or interact with the Channels, such as: your IP address, mobile device identifier, or similar device identifier; browser type; type of device you use to access the Channels; the domain name from which you arrived at the Channels; the time of day you visit our Channels; Location Data (defined below); and specific pages or areas of the Channel through which you navigate and how you interact with those pages or areas ("Usage Information"). This information helps us create a better experience for our users and provide you with targeted advertising. Please see the “Online Advertising and Analytics Providers” section below for more information about how to control the use of your personal information for the purposes of advertising. We typically consider Usage Information to be non-personal, but as stated above, we will treat certain Usage Information, such as IP addresses, as personal information where required by applicable law.

Information collected through our App

In Short:  We collect information regarding your mobile device, push notifications, when you use our App.

If you use our App, we also collect the following information:

Mobile Device Data. We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID and information about the features of our App you accessed.

Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.

2. How Do We Use Your Information?

In Short:  We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Channels for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. See the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS" for further information.

To post testimonials. We post testimonials on our Channels that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at support@winden.co and be sure to include your name, testimonial location, and contact information.

Request feedback. We may use your information to request feedback and to contact you about your use of our Channels.

To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.

To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

Fulfill and manage your orders. We may use your information to fulfill and manage any orders, payments, returns, and exchanges made through the Channels.

Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.

To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Channels.

To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Channels, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).

Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

3. Will Your Information Be Shared With Anyone?

In Short:  We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.We may process or share your data that we hold based on the following legal basis:Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.More specifically, we may need to process your data or share your personal information in the following situations:Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.Cobranded Winden Credit Card and Accounts. When you apply for and use a branded credit card or apply for and open an account, you will provide certain information to the issuing bank directly and Winden may share certain information at your direction to facilitate your application and use of the card and/or account. In addition, Winden may share information with the issuing bank for our Winden Credit Card (or any other credit or debit card products that may be issued by us) and our Winde Account and its affiliates, for purposes related to those credit cards and/or accounts. For example, we may share information in order to send joint offerings, including information on how to apply for an Winden cobranded credit card or open an account, and in connection with your use of an Winden cobranded Credit Card and/or account, such as to maintain or service accounts and to effectuate transactions. We may also share information with these parties for analytics purposes.Other Cobranded Partners. Cobranded partners are entities with whom we work to offer a service or feature. You can typically tell when you are accessing a service offered by a cobranded partner because the cobranded partner’s name will be featured prominently. You may be asked to provide information about yourself to utilize a feature offered by a cobranded partner. In doing so, you may be providing your information to both us and to the cobranded partner, or we may share your information with the cobranded partner in order to allow you to participate in the feature. Please note that the cobranded partner’s policies will apply its collection and use of your information, not this policy.Scrip and Loyalty Reward Programs. We may also offer scrip programs (which allow you to instruct us to divert a percentage of the amount you spend on purchases to participating schools and other non-profit organizations) or third-party loyalty programs (which allow you to earn “points” on purchases through a Channel and use the points toward certain rewards offered by the loyalty program). If we offer any scrip, loyalty, or similar program in which Winden is a participating vendor and you choose to participate, you authorize Winden or our payment processor to provide information about your purchases to the company administering the program. In such case, the information we will share with that program administrator may include your name, payment information, the date and amount of your purchase, and other information. Please note that once we disclose this information, the scrip or loyalty company may use and share it with others in accordance with its own privacy policy. We do not control the privacy practices of third parties and you should review the privacy policy of any scrip or loyalty partner or other cobranded partner before participating.

4. Do We Use Cookies and Other Tracking Technologies?

In Short:  We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

5. How Do We Handle Your Social Logins?

In Short:  If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Channels offers you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such social media platform.

We will use the information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you on the relevant Channels. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their Privacy Policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

6. What Is Our Stance On Third-party Websites?

In Short:  We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our Website.

The Channels may link to or incorporate websites, advertising or content hosted and served by third parties not affiliated with us, over which we have no control and which are governed by the privacy policies and business practices of those third parties, including the bank that operates our private-label credit card programs and accounts. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Privacy Policy. We are not responsible for the content or privacy and security practices or business practices of any third party, including other websites, services or applications that may be linked to or from the Channels. You should review the policies of such third parties and contact them directly to respond to your questions.

7. How Long Do We Keep Your Information?

In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this Privacy Policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. How Do We Keep Your Information Safe?

In Short:  We aim to protect your personal information through a system of organizational and technical security measures.

We employ commercially reasonable security methods and technologies to help secure your personal information, including physical, technological, and organizational protections. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. We therefore cannot ensure or warrant the security of any information that you transmit to us, or that we transmit to you, or guarantee that it will be free from unauthorized access by third parties. You use the Channels and provide us with information at your own initiative and risk.

9. Do We Collect Information From Minors?

In Short:  We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Channels, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Channels. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.  If you are the parent or legal guardian of a child younger than age 18 and believe that we have inadvertently collected personal information from your child, please contact us at support@winden.co

10. What Are Your Privacy Rights?

In Short:  You may review, change, or terminate your account at any time.

If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html

If you have questions or comments about your privacy rights, you may email us at support@winden.co

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Channels. To opt-out of interest-based advertising by advertisers on our Channels visit http://www.aboutads.info/choices/

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

Access your account settings and update your preferences.
Contact us using the contact information provided.

11. Your Privacy and Online Advertising And Analytics Providers

We may work with network advertisers, ad agencies, analytics service providers, and other vendors to serve our advertisements on third-party websites, apps, and elsewhere online and to provide us with information regarding use of and traffic on the Channels (including without limitation the pages viewed and the actions users take when visiting the Channels) and the effectiveness of our advertisements. For example, if you click on an advertisement for Winden, our service provider(s) may be able to tell us the advertisement you clicked on and where you were viewing the advertisement. The advertisements you see may be served by one or more third parties, who may use information about your activities on the Channels, and other websites and services you visit across the various devices you use, to provide you targeted advertising based upon your interests. Our service providers may collect certain information about your visits to and activity on the Channels and other websites and services and may use this information to target advertising to you.

These service providers may set and access their own tracking technologies on your device (including without limitation cookies and web beacons) and may otherwise collect or have access to information about you (such as Usage Information and device identifier). Some of these parties may collect personal information over time when you visit the Channels or other online websites and services. Cookies and web beacons, including without limitation those set by third-party network advertisers, may be used to (among other things): target advertisements, prevent you from seeing the same advertisements too many times, and conduct research regarding the usefulness of certain advertisements to you. We may share certain information such as device identifiers, Usage Information, records of transactions you conduct on our Channels or offline, and de-identified information with third-party advertising companies, analytics providers, and other vendors for advertising and analytics purposes. In addition, we and our third-party service providers may use this information to perform matching with third-party cookies in order to provide targeted online marketing.

We use a variety of service providers to perform advertising and analytics services, and some of these companies may be members of the Network Advertising Initiative (“NAI”) or Digital Advertising Alliance (“DAA”). You may wish to visit optout.networkadvertising.org, which provides information regarding targeted advertising and the opt-out procedures of NAI members. You may also want to visit optout.aboutads.info, which provides information regarding targeted advertising and offers an opt-out for DAA-participating companies. If you are a California resident, please see our “DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?” section below regarding additional rights you have, including how to exercise your “Do Not Sell” right.

We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Channels and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online resources. You can learn about Google’s practices by going to google.com/policies/privacy/partners, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at tools.google.com/dlpage/gaoptout.

For mobile apps, you may be able to limit certain advertising practices using the settings on your phone, tablet or other mobile device. You may also download the AppChoices app at youradchoices.com/appchoices to opt out of the delivery of interest-based advertisements in participating mobile apps.

Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive non-targeted advertisements while online.

12. Controls For Do-not-track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. At this stage no uniform technology standard for recognizing and implementing “Do Not Track” signals has been finalized There is no consensus among industry participants as to what “Do Not Track” means in this context. As such, like many websites and online services, we do not currently respond to “Do Not Track” browser signals or any other mechanism that automatically communicates your choice not to be tracked online, unless specifically required by law. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

To find out more about “Do Not Track,” please visit www.allaboutdnt.com

13. Consent To Transfer And Storage In the United States

By using our Channels and our services, you represent and warrant that you reside in the United States; and your use of our Channels and our services or products does not violate any applicable law or regulation.

Winden is a United States company. Please be aware that information we collect will be transferred to and processed in the United States and other countries. By using the Channels, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing, and storage of your information in the United States and other jurisdictions, for which the privacy laws may not be as comprehensive as those in other countries or jurisdictions. As a result, this information may be subject to access requests from governments, courts, or law enforcement in the United States and other countries according to laws in those jurisdictions. Your information will also be disclosed to third parties as described in the “Sharing of Information” section above.

14. Sweepstakes, Contests and Promotions

We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern that Promotion, which may contain specific requirements of you (including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, personal information may be disclosed to third parties (including, without limitation, a co-sponsor) or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s terms or official rules (such as on a winners list).

15. Do California Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with a Service, you have the right to request removal of unwanted data that you publicly post on the Channels. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Channels, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category Example Collected

A. Identifiers        Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name        NO

B. Personal information categories listed in the California Customer Records statute        Name, contact information, education, employment, employment history and financial information        NO

C. Protected classNameification characteristics under California or federal law        Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name        NO

D. Commercial information        Transaction information, purchase history, financial details and payment information        NO

E. Biometric information        Fingerprints and voiceprints        NO

F. Internet or other similar network activity        Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements        NO

G. Geolocation data        Device location        NO

H. Audio, electronic, visual, thermal, olfactory, or similar information        Images and audio, video or call recordings created in connection with our business activities        NO

I. Professional or employment-related information        Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us        NO

J. Education Information        Student records and directory information        NO

K. Inferences drawn from other personal information        Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics        NO

We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:

Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Channels and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this Privacy Policy.

You may contact us by email at support@winden.co, by visiting https://winden.co , or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.

Winden has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Winden will not sell personal information in the future belonging to website visitors, users and other consumers.

Your rights with respect to your personal data

You have the right to request that we disclose to you what Personal Information we collect, use, disclose, and sell, including the right to request that we provide to you the specific pieces of Personal Information we have collected about you in the prior 12 months (“Right to Know”) and you have the right to ask us to delete the Personal Information we collect about you (“Right to Delete”), subject to exceptions set forth in the CCPA.  You also have the right to opt-out from the sale of their Personal Information. These rights are subject to some limitations, such as when we are retaining data to comply with our own legal obligations. You will not be required to create an account with us in order to submit a request. More information on each of these rights is below.

Right to be informed - Request to know

Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell your personal information to third parties;
the categories of personal information that we sold or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to request deletion of the data - Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Opt-Out from Future Selling of Personal Information

You may request to opt-out from future selling of your personal information to third parties.

Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission

Please note that an opt-out choice expressed by web form or telephone will not affect automated data sharing for targeted advertising and similar purposes that may occur when you visit our Channels, which sharing may constitute a “sale” of Personal Information under California law.

As stated above, Winden does not knowingly collect or sell Personal Information of minors under 18 years of age. Without limiting the foregoing, any user who is under 16 years of age is not permitted to opt-in to the sale of their Personal Information.

Other privacy rights

you may object to the processing of your personal data

you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data

If you would like to authorize an agent to act on your behalf in submitting a request to know, request to delete, or request to opt-out of the sale of your Personal Information, you may do so by submitting to us a declaration for the agent to make a request on your behalf. The written permission must state the full legal name of the agent, be clear about the permission, and be signed by you. Alternatively, if you have provided your authorized agent with a power of attorney under Probate Code sections 4000-4465, your agent may submit a copy of the power of attorney. Your agent’s identity, in addition to your own, will need to be independently verified in order for us to be able to fulfill your request. We may deny a request from an authorized agent that does not submit proof that such agent has been validly authorized to act on your behalf in accordance with the CCPA.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. Depending on what you have used to interact with the Channels and to what you are requesting access, we may also request one or more of the following in order to verify your identity: e.g., phone number and mailing address. We may also use other verification methods as the circumstances dictate. We will also require a signed declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request before providing specific pieces of personal information.

If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to provide the requested information.

We will only use personal information provided in your request to verify your identity or authority to make the request. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

To exercise these rights, you can contact us by email at support@winden.co, by visiting https://winden.co, or by referring to the contact details at the bottom of this document. You must put the statement “My California Privacy Rights” in the subject field of your email or in the address line of your envelope. You must include your name, email address, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

If you have a complaint about how we handle your data, we would like to hear from you.

We will provide the requested information free of charge up to two (2) times in a twelve (12) month period, but please note that where we receive unfounded, excessive, or repetitive requests, we may elect to decline the request. Note also that we will not retain information we do not ordinarily retain in the course of our regular business practices.

Response Timing

When you request access to the Personal Information we have collected or deletion of your Personal Information, we will typically provide the requested information within forty-five (45) days, and we will notify you within that time period if we need additional time to process your request. When you opt-out from the sale of your Personal Information, we will honor your request as soon as feasible, but no later than fifteen (15) days from the date we receive your request.

16. Do Nevada Residents Have Specific Privacy Rights?

Pursuant to Nevada law, you have the right to opt-out of the sale of certain covered personally identifiable information we have collected about you through our websites and online services, as those terms are defined under applicable Nevada law. If you are a Nevada resident and would like to opt-out of the sale of your covered information, please submit your request to support@winden.co. You must put the statement “My Nevada Privacy Rights” in the subject field of your email or in the address line of your envelope. You must include your name, email address, street address, city, state, and ZIP code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

Your request must include your full name and zip code. Please contact us from the email address you have used to interact with us, or else provide us with that email address in your Nevada Opt-Out request email. We may contact you via such email address us as needed regarding this request. If you previously provided a phone number to us, including it in your Nevada Opt-Out request email will assist us in identifying you and processing your request. You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request.

We will respond to your request within sixty (60) days either confirming that your request has been processed or indicating that we need an additional thirty (30) days to complete the request.

17. Do We Make Updates To This Notice?

In Short:  Yes, we will update this Privacy Policy as necessary to stay compliant with relevant laws.

To the extent permitted by applicable law, we reserve the right to change or modify this Privacy Policy in our discretion at any time. We will notify you of material changes by posting the changed or modified Privacy Policy on our Channels. We may also provide notice to you in other ways, such as through contact information you have provided. Any changes will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified. Your continued use of the Channels after the effective date of the revised Privacy Policy (or such other act as specified in the revised Privacy Policy) will, to the fullest extent permitted by applicable law, constitute your consent to those changes. However, we will provide notice and obtain your consent (opt-in or opt-out) if required by law.  Note that you may need to consent to our new policies in order to continue to use the Channels and our services.

18. How Can You Contact Us About This Notice?

If you have questions or comments about this Privacy Policy, you may email us at support@winden.co or by post to:

Winden Technologies, Inc.
10000 Santa Monica Blvd #2104
Los Angeles, CA 90067 United States

19. How Can You Review, Update or Delete The Data We Collect From You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here. We will respond to your request within 30 days.

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