Winloot™ Privacy Policy 
Last Updated May 30, 2013 

Globalizer, LLC, Winloot, Ltd. and Winloot.com (collectively "Winloot™," "we," "our" or "us") are committed to protecting your privacy. This Winloot™ Privacy Policy (“Privacy Policy”) applies to the Winloot.com website (the “Site”) and governs data collection and usage including Winloot™ Site and email services (the "Program"). This Privacy Policy is effective: (a) when you access the Site;  (b) when you register as a Winloot™ member (“Member”); and (c) otherwise, with respect to certain changes hereto, on the date noted above for all existing Members. 

We firmly believe that both our Members and our clients benefit because we market only to people who have given us express permission to do so. 

While the word "privacy" may mean different things to different people, we believe that once you understand how we use your information, the steps we take to protect it, and the resulting benefit to you, you will not only feel confident when sharing information with us, but will also find your participation in the Program a most rewarding experience. 

 

Your Privacy Rights

If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what categories of personal information that we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please contact us by clicking here or send us correspondence to Globalizer, LLC, Attn: Winloot Member Services (Privacy), 77 Arkay Drive, Suite C1, Hauppauge, NY 11788.

Further, if you are a resident of the State of California and would like to opt-out from the disclosure of your personal information to any third party for marketing purposes, please contact us by clicking here or send us correspondence to Globalizer, LLC, Attn: Winloot Member Services (Privacy), 77 Arkay Drive, Suite C1, Hauppauge, NY 11788.  Please be advised that where California State residents opt-out from permitting their personal information to be shared, such individuals may still receive selected offers directly from us, in accordance with applicable law.

1. Collection of Information
Winloot™ collects both personal and non-personal information using the methods listed below. Our primary purpose in collecting such information is to provide you with a personalized experience by displaying content and delivering offers that are likely to be of interest to you according to your preferences. 

2. Automatic Information and Cookies Collected though Participation in the Winloot™ Program
When you sign in to the  Site, the server automatically recognizes you by your “cookies,” which are small text files that are placed on your computer by the Site upon arrival. The cookies that we use are “analytical” in nature, in that they act as unique identifiers and are linked to your personal information, allowing us to access your personal information and personalize the Site and Program to your specified interests. The cookies also allow us to keep track of your activity on the Site, properly credit entries to your account and help ensure that only you can access your account. The information collected by the cookies may be added to your personal profile and used to deliver offers and advertisements that are relevant to your interests. 

The Program makes active use of third-party companies to display advertisements on the Site or in Winloot™ email. Many of Winloot’s™ third-party advertisers, shopping affiliates and merchants utilize “analytical” cookies, similar to Winloot’s™ described above, to identify you as a Member of Winloot™.  This enables the cookies to report transactions back to us so we are able to properly credit activity generated on the Site.  Third-party cookies are also used to count unique page views, email responses and future transaction activity corresponding to specific offers.  For these reasons, full participation in the Program is dependent upon you setting your browser configuration to accept third-party cookies.

 

Additionally, we and our third-party advertisers use cookies and clear pixel GIFs (also referred to as "web beacons") to measure page views on the Site, advertiser websites, and email responses.  These devices allow us to identify unique visitors to the Site, Member visits to advertiser websites, and act as a counter for ongoing monitoring of Site, email and corresponding future transaction activity related to a specific offer for both Winloot™ and its advertisers. These commonly used cookies collect absolutely no personal information and are only used to enhance the Program and make it more relevant to your personal interests.  Winloot™ and its third-party ad networks may also place “persistent” cookies on your computer, which recognize your computer each time you receive an online advertisement.  In this way, information is compiled about where you, or others who are using your computer, saw the advertisement and to determine which ads are clicked on.  This information allows targeted advertisements to be sent that will be of interest to you.  Winloot™ does not have access to or control over the cookies that may be placed by third-parties on your computer, and has no control over these parties' privacy policies or information collection practices.  For more information regarding our practices related to third-party ad servers, please see Section 8, herein.

Winloot™ will also capture and store your transaction details, which may include the items and quantities purchased, purchase price, date and time of purchase.  This information is used to credit your account balance in the event of returns and exchanges.  This information is used by the Member Services department while assisting you in resolving account inquiries.  We may also use your transaction information to provide you more timely relevant offers, products and services. 

Winloot™ retrieves the following information from your browser:

·                Your browser type (e.g., Internet Explorer, Chrome, Safari)

·                Platform-dependent information (e.g., Windows, iOS)

·                Requested document (the page you're looking at)

·                Referrer URL (the page you came into the Site from)

·                Date and time of your visit

·                Your registered Winloot™ account information

·                Purchase transaction detail (from merchants on the Site)

·                IP address associated with member transaction in the system



Additionally, for each visitor to the Site, our server automatically recognizes the following:

·                Host origin of the request (your IP address or that of your ISP if using proxy servers)

·                Requested document (the page you're looking at)

·                Referrer URL (the page that you came to the Site from)

·                Your registered Winloot™ account information

·                Date and time of your visit


This information, sometimes called log-file or clickstream data, is used to monitor Site performance and analyze traffic patterns and usage to ensure the Program functions properly. It may also be appended to your personal profile so that we may further tailor the Program to your interests. 

3. Information Collected at Registration
In order to take advantage of the offers available at Winloot™, you must register for our service and become a Member.  We collect personal information when you register with us and when you use the Winloot™ services.  We may combine information about you that we have with information we obtain from business partners or companies.  During registration, we require members to give us basic contact information (such as your first name, last name and e-mail address) and demographic information (such as your zip code, age and gender). The registration form information requests may change from time to time. Although additional demographic information may be requested at the time of registration, only information marked "required" is necessary for registration and utilization of our services.


We do not accept registrations from persons under the age of eighteen (18). The Site will automatically block enrollment of any person once he/she indicates that he/she is under the age of eighteen (18). If we later learn that a user is under the age of eighteen (18), we will terminate their account and delete the user's information. Inherent in the Program is the responsibility of parents and/or guardians to ensure that their children's privacy is protected. Winloot™ will not be liable for any content or advertisements viewed by minor children in violation of the terms of this Privacy Policy.

 

4. Information Collected Via Online Surveys, Sweepstakes and Other Promotions
We may also provide you with the opportunity to participate in contests, sweepstakes or surveys, from time to time.  If you choose to participate, we will request certain personally identifiable information from you.  Participation in these surveys or contests is completely voluntary and you therefore have a choice as to whether or not to disclose this information.  The requested information typically includes contact information (such as name and shipping address) and demographic information (such as gender and zip code). 

We use this information to notify contest winners and award prizes. We may also use the information gathered to better personalize your Program experience. 

We may use a third party service provider to conduct these surveys, contests and sweepstakes. That company is prohibited from using your personally identifiable information for any other purpose. We will not share the personally identifiable information you provide through a contest, sweepstakes or survey with any third party except as allowed under this Privacy Policy or with your prior notice and choice. 

5. Information Collected at Enrollment for a Paid or Other Enhanced Product or Service
If you choose to enroll for any paid or other enhanced product or service beyond a basic registration as described in Section 2 above, you may be required to provide us with certain contact information, such as your name, e-mail address and billing address. We may also require other information necessary to access the paid or other enhanced product or service or process any applicable payment, such as a credit card or debit card number and expiration date. We may use the information you provide us to bill you for products and services you request, or to notify you of additional products and services we may offer. When you sign up for a paid or other enhanced product or service on the Site, you are consenting to our delivery of this information to our service providers, which may include banks and credit card companies that we use to process a transaction or other third parties who may provide all or a portion of the underlying product or service on our behalf. 

6. Use and Disclosure of Personal Information
We do not rent, share, trade or sell your personal information to anyone for promotional purposes without your express consent. When we do share data with our advertisers it is in aggregate form and is designed to ensure you are not identified personally. If you purchase a product or service from a third party or agree to co-register on a third party's website, any of which requires you to submit financial and/or personally identifiable information, you are also consenting to our delivery of this information to that party. The offer will notify you if any financial or personally identifiable information will be shared. Such third party will be authorized to use this information in keeping with our contractual relationship with them and in accordance with their own privacy policy and information practices. We do not control these third parties and you agree that Winloot™ is not liable for their acts or any failure to act on their part. 

Although we house our data in the United States, it is possible that some of our data processing may occur outside of the United States. While the data protection laws of these countries may vary, we will make every reasonable effort to protect your information based upon the express terms of this Privacy Policy. By enrolling in the Program, you consent to this transfer of your personal data. 

As long as you remain a Winloot™ Member, opting not to receive email does not exempt you from receiving administrative emails, which include, but are not limited to, notices about vital Program and membership status changes or alterations to our Terms of Service. 

We may, without your consent, access and disclose your personal information, any communications sent or received by you, and any other information that we may have about you or your account as may be required by law, regulation, rule or court order; pursuant to requests from governmental, regulatory or administrative agencies or law enforcement authorities; or to prevent, investigate, identify persons or organizations potentially involved in, or take any action regarding suspected fraud, violations of our Terms of Service, or activity that appears to us to be illegal or may expose us to legal liability.


7. Member Communications and Email
Winloot™ employs a strict policy against sending unsolicited email. Because email is an integral part of the program, you sign up to receive email targeted to your interests at the time of enrollment. If you later decide you wish to cease participation in this portion of the Program, you may do so at any time by clicking on the opt-out links contained within each Winloot™ email or by sending an email to:
unsubscribe@winloot.com 

Please note that opting not to receive email does not exempt you from receiving administrative emails that include, but are not limited to, notices about vital Program and membership status changes, Privacy Policy and Terms of Service updates and purchase and redemption confirmation emails (collectively, “Winloot™ Related Email”). 

Our Member Services Department may contact you in response to your inquiries, to provide services at your request and to manage your account. We will communicate with you by email, telephone or fax in accordance with your wishes (collectively, “Winloot™ Administrative Contact”). 

 

To opt-out of receiving Winloot™ Related Email and Winloot™ Administrative Contact from Winloot™, you must cease membership, use of the Program and submitting inquiries to Winloot™, as applicable.

8. Winloot™ Advertisers and Third Party Websites
The Winloot™ Site and emails contain links to various other websites that are not owned by us. While we make reasonable efforts to ensure that our advertisers post clear and complete privacy policies and observe appropriate data practices, each of these websites has a privacy policy that may differ from that of Winloot™. The privacy practices of other websites and companies are not covered by this Privacy Policy. Please be aware that we are not responsible for the privacy practices of such other websites. We encourage you to be aware when you leave our Site and to read the privacy statements of each and every website that collects personally identifiable information. 

Except as specifically set forth below, it is our policy not to provide your personally identifiable information to our advertisers unless you make the choice to share it with them. We occasionally pass personally identifiable information (other than sensitive financial information) via a secure interface to certain of our advertisers for the purpose of making it easier for you to sign up for their offers. However, this information is only to be used by the advertiser if you agree to submit the information to the advertiser for the purposes of completing an offer. 

We occasionally use third parties to provide limited services on our behalf, such as handling the processing and delivery of mailings, providing customer support, processing transactions or performing statistical analysis of our services. We will only provide these third parties the personal information they need to deliver the service. They are required to maintain the confidentiality of your information and are prohibited from using that information for any other purpose. 

In the event that we were unable to capture your transaction detail, we may need to validate your transaction with an advertiser or merchant partner. The validation information shared is used solely for this purpose and may include your first name, last name, email address, mailing address or date of birth. We will require that these third parties comply with the information practices set forth in this Privacy Policy and that the information not be shared or used for any other purpose. 

9. Testimonials
Our users may submit testimonials about Winloot™ on our Site. In such cases, it is the user's choice as to whether their personally identifiable information is posted along with the testimonial. In addition, Winloot™ has forums available to its users that allow them to post opinions or testimonials about third-party products and services. You should be aware that any personally identifiable information that you submit through these forums can be read, collected or used by other users of these forums, which they could then use to send you unsolicited messages. We are not responsible for the personally identifiable information that you choose to submit in these forums. 

10. Refer-a-Friend
If you elect to use any of our referral services for informing friends about our Site, you will be asked to provide your friends' names and e-mail addresses. You may enter this information manually, or you can also choose to import your contacts from your email address book, in which case you will be asked to provide us with your email address and password, which will be used solely for the purpose of importing your contacts to our referral service. We will then automatically send your friends a one-time e-mail, plus a reminder email (both of which may include your name and email address) inviting them to visit our Site. We ask for this information for the sole purpose of sending these emails and tracking the success of our referral program. 

11. Deleting, Modifying and/or Updating Your Information
At your request, we will inform you of what personal information we have on file for you.  In addition, at your request, we will remove, update and/or modify the personal information that you have provided to us, or that we have collected.  You may do so by contacting us by clicking here; provided, however, that we ask individuals to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others or would be extremely impractical (for instance, requests concerning information residing on backup tapes). 

 

Please be advised that, after you delete your personal information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems. In addition, this deletion will not change or delete personal information which may have already been shared with third parties, all as provided in this Privacy Policy.  You will need to contact the third parties that contact you directly to change your preferences regarding their use of your personal information.

 

12. Data Verification and Supplementation
Data verification involves the use of third-party data processing services to standardize and clean your provided enrollment information so that it is easily identified and accessed in our database. Data supplementation involves appending any publicly available information about you to your personal profile. 

In order to provide you with the most rewarding experience, we might send your information to data processors so that they can clean your address and standardize to ensure it is most accurate and up-to-date. Next, we might seek out any information about you that is publicly available on the open market and overlay this data onto ours for comparison purposes. Information collected in this manner could include your spending habits from a mail-order catalogue, demographic information you provided in entering a sweepstakes or your financial history. All of this results in a program that is tailored to your personal interests and provides you with the most relevant reward-earning opportunities. 

We use this information solely for the purpose of enhancing the offerings of the Program, namely to tailor advertisements, updates and reward-earning and spending offers to your particular interests. All such third-party data processors are contractually bound to observe the strict policy stated herein, so you can rest assured that the confidentiality of your personal information will be maintained. 

13. Security

We endeavor to safeguard and protect our users’ personal information.  When users make personal information available to us, their personal information is protected both online and offline (to the extent that we maintain any personal information offline).  Where our registration/application process prompts users to enter sensitive information (such as credit card information), and when we store and transmit such sensitive information, that information is encrypted and is protected with SSL encryption software. 

 

Access to your personal information is strictly limited, and we take reasonable measures to ensure that your personal information is not accessible to the public.  All of our users’ personal information is restricted in our offices.  Only employees or third party agents who need the personal information to perform a specific job are granted access to personal information.  Our employees are dedicated to ensuring the security and privacy of all user personal information.  Employees not adhering to our firm policies are subject to disciplinary action.  The servers that we store personal information on are kept in a secure physical environment.  We also have security measures in place to protect the loss, misuse and alteration of personal information under our control. 

 

Please be advised, however,  that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet can be guaranteed to be 100% secure.  Computer hackers that circumvent our security measures may gain access to certain portions of your personal information, and technological bugs, errors and glitches may cause inadvertent disclosures of your personal information; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law.  For the reasons mentioned above, we cannot warrant that your personal information will be absolutely secure.  Any transmission of data at or through the Site or otherwise via the Internet or wireless network is at your own risk.

 

In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your personal information.  You will be notified via e-mail in the event of such a breach.  Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures. 

14. Changes to this Privacy Policy
We may amend this policy from time to time. If we make any material changes in the way we use your personally identifiable information we will notify you by email and at the top of this Privacy Policy web page. You will have a choice as to whether or not we use your personally identifiable information in this different manner, and we will only use your personally identifiable information in this different manner where you opt-in to such use.  For questions and concerns about the information collected or used at the Site, please contact us by clicking here.

 

15. Mergers; Business Transitions 
In the event Winloot™ goes through a business transition, such as a merger, being acquired by another company, or selling a portion of its assets, users' personal information will, in most instances, be part of the assets transferred, unless such a transfer will violate state or federal law. 

16. Contact Us.

If you have any questions or suggestions regarding this Privacy Policy, please contact us by clicking here or at either: Globalizer, LLC, Attn: Winloot Member Services (Privacy), 77 Arkay Drive, Suite C1, Hauppauge, NY 11788; or Winloot, Ltd., Attn: Winloot Member Services (Privacy), 145-157 St. John's Street, London, EC1V 4PW.