Last Updated: December 31, 2019
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. Please note, if you are a resident of, or reside in, a European Union Member State, you are not permitted to use the Site, the Program and/or the other Winloot offerings featured by and through the Site.
Your California Privacy Rights
Shine the Light. 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 emailing us at [email protected]; or sending us U.S. mail to: Globalizer, LLC, Attn: Winloot Member Services (Privacy), 100 Duffy Ave, Suite 510, Hicksville, NY 11801.
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 emailing us at: [email protected]; or sending us U.S. mail to: Globalizer, LLC, Attn: Winloot Member Services (Privacy), 100 Duffy Ave, Suite 510, Hicksville, NY 11801. 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.
California Consumer Privacy Act of 2018 (“CCPA”). In addition to the foregoing, if you are a resident of the State of California certain other privacy-related rights may apply to you in accordance with the CCPA, including the right to opt-out of our sale of your personal information, as well as the right to know what personal information about you we have collected, whether your personal information was shared with third-parties in the preceding year and, if so, what categories of personal information were shared, as well as the categories of third parties with whom we shared that personal information. Please see our “Provisions for California Residents” below for a more complete description of your rights under the CCPA as a California resident.
Your Nevada Privacy Rights
If You are a resident of the State of Nevada, while we feel that it is important to note that we do not sell or rent your data to third parties, please note that if you would still like to notify us of your intent to opt-out from the sale of Your personal information to any third party data broker, please e-mail us at: [email protected]; or send U.S. mail to: Globalizer, LLC c/o Winloot, 100 Duffy Ave, Suite 510, Hicksville, NY 11801.
1. Collection of Information
Please see our Provisions for California Residents below for additional details regarding the categories of personal information collected] 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
[Please see our Provisions for California Residents below for more details regarding the categories and types of non-personal information collected] When you sign-in to the Site (or access the Site via e-mail, push or text), 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 that we are able to properly credit activity generated on the Site. Third-party cookies are also used to record unique page views, email responses and future transaction activity corresponding to specific offers.
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 targeted advertisements, please see the Behavioral Marketing/Do-Not-Track section below, and for more information regarding our practices related to third-party ad servers, please see Section 8, herein.
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
Approximate geographic location for compliance purposes
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.
Behavioral Marketing/Do-Not-Track: Without limiting the foregoing, we allow third-party companies to collect certain information when you visit the Site. These companies may utilize cookies, pixels or other technologies to collect and use both personally identifiable information (e.g., your name, phone number, physical or electronic address, etc.) and non-personally identifiable information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, etc.) during your visits to the Site, as well as when you visit other websites, in order to provide advertisements about goods and services likely to be of greater interest to you. To the greatest extent permissible under applicable law, we are not responsible for the tracking practices of third parties in connection with the Site.
Users may be able to disable some, but not all, of this tracking activity by utilizing the “Do Not Track” setting or similar options within most major Internet browsers. To learn more about this behavioral advertising practice, as well as to learn about other options for opting-out of this type of advertising, you can visit the websites of the Digital Advertising Alliance at www.aboutads.info and/or Networking Advertising Initiative at www.networkadvertising.org/choices.
3. Information Collected at Registration
In order to take advantage of the offers available on the Site, you must register for our Program and become a Member. We collect personal information when you register with us and when you use the Winloot Program and other products and/or 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, e-mail address and mobile telephone number) 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.
4. Information Collected Via Sweepstakes and Other Promotions
We provide you with the opportunity to participate in contests or sweepstakes. If you choose to participate, we will request certain personally identifiable information from you. Participation in these 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.
5. Use and Disclosure of Personal Information
We reserve the right to release current or past personal information (including sensitive information): (i) in the event that we believe that the Site and/or Program are being or have been used in violation of the Winloot Terms of Service or to commit unlawful acts; (ii) if the information is subpoenaed; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any personal information pursuant to a subpoena; or (iii) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if Winloot is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via e-mail and/or a prominent notice on the Site of any change in ownership or uses of your personal information, as well as any choices that you may have regarding your personal information..
6. Opting Out, Member Communications, Email and SMS Text Messaging
[Please see our Provisions for California Residents below for instructions on how California Residents can opt-out of the sale of their personal information to third parties] Winloot employs a strict policy against sending unsolicited email. Because email is an integral part of the Program, you automatically sign up to receive email from Winloot, including Winloot offers, as well as third party offers, that Winloot thinks may be of interest to you. If you later decide that 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: [email protected] In addition, Winloot employs a strict policy against sending unsolicited SMS text messages. Because SMS text messages can be an integral part of the Program, subject to obtaining your “prior express consent” as set forth in Section 6 above, Winloot may contact you with periodic SMS text messages related to the Program and other Winloot products and/or services. If you decide you wish to cease participation in this portion of the Program, you may do so at any time by replying with the word “STOP” in response to one of the SMS text messages that you receive from Winloot, or sending an email to: [email protected] with the telephone number you used to subscribe to the this service.
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.
7. Personal Information Shared with Winloot Advertisers; and Third Party Websites
We occasionally use third parties to provide limited services on our behalf, such as handling the processing and delivery of mailings, providing customer support, 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.
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.
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.
10.Deleting, Modifying and/or Updating Your Information
[Please see our Provisions for California Residents below for instructions on how California Residents can access and/or delete personal information that we have collected] 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).
11. 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.
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. 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.
12. Security of Your Personal Information
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). Although we do not anticipate collecting such information, if our registration/application process prompts users to enter sensitive information (such as medical information, driver’s license/ID card number, health insurance information, data collected from an automated license plate recognition system, Social Security Number and credit card information), and if we were to store and transmit such sensitive information, that information would be encrypted and protected with advanced TLS (Transport Layer Security) 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. Children’s Privacy
[Please see our Provisions for California Residents below for more details regarding the personal information of minors] Visitors under eighteen (18) years of age are not permitted to use and/or submit their personal information at the Site. Winloot does not knowingly solicit or collect information from visitors under eighteen (18) years of age.
15. Transfer of Personal Information Internationally
16. Contact Us
Privacy Provisions for California Residents
Categories of Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular CA User or device (“personal information”). In particular, we have collected the following categories of personal information from CA Users within the last twelve (12) months:
|A. Identifiers||Email address, first/last name, mailing address, date of birth and mobile telephone number.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||First/last name, mailing address and mobile telephone number.||YES|
|F. Internet or other similar network activity.||Browsing history, search history, information on a CA User's interaction with the Site, application or advertisement.||YES|
Personal information does not include:
We obtain the categories of personal information for which we indicated “YES” above from the following categories of sources:
Use of Personal Information
We may use or disclose the personal information that we collect (including email address, first/last name, mailing address, date of birth and mobile telephone number) for one or more of the following business purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you with notice.
Sharing Personal Information
When we disclose personal information to a third party service provider or other entity, we enter into a contractual relationship that describes the purpose for which such third party may use the personal information and requires that third party to both keep the personal information confidential and not use it for any purpose other than the performance of its services under the applicable contract. Please note, we do not collect information from CA Users that we actually know are less than eighteen (18) years of age and we do not share or sell the personal information of CA Users that we actually know are less than eighteen (18) years of age. Without limiting the foregoing, we have not shared or sold the personal information of CA Users that we actually know are less than sixteen (16) years of age in the preceding twelve (12) months.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category F: Internet or other similar network activity.
In the preceding twelve (12) months, we have not sold personal information to third parties
We disclose your personal information for a business purpose to the following categories of third parties:
In the preceding twelve (12) months, we have shared personal information ((including email address, first/last name, mailing address, date of birth and mobile telephone number)) for the business purposes set forth above.
Your Rights and Choices
The CCPA provides CA Users (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Opt-Out from the Sale of Your Personal Information
You have the right to opt-out of our sale of your personal information to third parties. To exercise your right to opt-out of our sale of your personal information to third parties, please submit a verifiable CA User request to us by either:
We endeavor to act on all opt-out requests as soon as practicable, but in all cases within fifteen (15) days of the receipt of your request.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable CA User request, we will disclose to you:
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable CA User request, we will delete (and direct our service providers to delete) your personal information from our (their) records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Exercising Access, Data Portability and Deletion Rights
To exercise your access, data portability and/or deletion rights described above, please submit a verifiable CA User request to us by either:
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information.
You may only make a verifiable CA User request for access or data portability twice within a 12-month period. The verifiable CA User request must:
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable CA User request related to your personal information. Where you make a data deletion request, data portability request and/or information access request through an authorized agent, we will require that you or the authorized agent provide us with a valid written authorization executed by both parties, with the validity of such document determined by us in our reasonable, good faith discretion. Please submit such documentation to us by emailing us at: [email protected]; or sending us U.S. mail to: Globalizer, LLC, Attn: Winloot Member Services (Privacy), 100 Duffy Ave, Suite 510, Hicksville, NY 11801.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable CA User request does not require you to create an account with us. We will only use personal information provided in a verifiable CA User request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to all verifiable CA User requests within forty-five (45) days of the receipt thereof. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the receipt of your verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable CA User request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Changes to this Privacy Provisions
We reserve the right to amend these Privacy Provisions in our discretion and at any time. When we make changes to these Privacy Provisions, we will notify you by email or through a notice on the Site’s homepage.
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