PRIVACY OF CHILDREN
We do not intentionally collect personal information from users of the Sites who are under the age of thirteen (13). If you are under 13, do not provide any information on the Sites, register on the Sites, use any interactive or public comment features of the Sites, or provide any information about yourself on the Sites, including your name, address, telephone number, email address, or any screen name or user name you may use. If we become aware that a user of one or more of the Sites is under the age of 13 and has provided information to us (e.g., joined a mailing list, entered a sweepstakes, contest, or other promotion, etc.) using the Sites, we will make reasonable efforts to remove that child’s personal information from our files. We may use the information to provide notices to the parents of users under the age of 13 where that may be necessary. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org
THE INFORMATION WE COLLECT AND HOW WE USE IT
When you visit the Sites, you may provide us with two types of information that we collect and store: “personal information” and “automatic information.”
Personal Information. Personal information is information you voluntarily provide that tells us who you are, such as your first and last name, your postal address and zip code, your email address, your telephone number, your hobbies and interests, and/or information regarding your purchases.
We may collect information from you if you register with one or more of the Sites, sign up for a newsletter or mailing list, enter a sweepstakes or contest, submit a rebate or coupon request, or otherwise voluntarily provide information to us (e.g., by submitting your email by contacting us via our “Contact Us” webpage or in connection with ratings, reviews, requests for advice, suggestions, testimonials or any user generated content, such as photographs and/or videos).
Winston Products may use collected personal information internally, separately, or in combination with pre-existing information, for the following purposes:
- To develop, enhance, market, sell or otherwise provide information, products, or services;
- To establish and conduct commercial relationships, including to process purchases or other transactions and to conduct or administer other transactions that you may engage in with Winston Products on or through the Sites;
- To conduct or administer contests, sweepstakes, or other promotions in which you have participated;
- To contact you and to respond to any communications that you may have had with us;
- To troubleshoot problems with the Sites;
- To customize your experience or homepage on the Sites;
- To develop and manage our business and operations;
- To detect and protect Winston Products and other third parties against error, negligence, breach of contract, fraud, theft, and other illegal activity, and to audit compliance with Winston Products’ policies and contractual obligations;
- To engage in business transactions involving Winston Products;
- As permitted by, and to comply with, any legal or regulatory requirements or provisions;
- To access, preserve, disclose, and use your personal information contained in your account, all Submissions (as defined in the Terms), all communications to and from you, all information relating to your use of the Sites, if Winston Products is required to do so by law or legal process or if Winston Products determines, in its sole discretion, that such action is necessary to protect the rights of Winston Products, third parties, or other users of the Sites or for purposes of responding to your request for customer service; or
- For any other purpose to which you consent.
Automatic Information. Automatic information is information automatically collected by our webserver (which may be hosted by a third party), or third party services, that your web browser makes available whenever you visit the Sites. As you navigate through and interact with the Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: (a) details of your visits to the Sites, including traffic data, location data, logs, other communication data, and the resources that you access and use on the Sites, and (b) information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties.
The technologies we use for this automatic data collection may include:
Cookies: Like many websites, Winston Products uses “cookies” to maintain a record of your visit to the Sites. A cookie is a small text file that is transferred by a webserver and stored on the hard drive of your computer or mobile device. It can only be read by the server that sent it to you. This information does not identify you personally and you remain anonymous unless you have otherwise provided Winston Products with personal information.
Cookies help us to improve the Sites, and to deliver more personalized service by enabling us to estimate audience size and usage patterns; to store information about your preferences; to speed up your searches and to recognize you when you return to the Sites.
Most web browsers automatically accept cookies. If you would prefer to prevent your computer from accepting our cookies, you may follow your Internet browser’s steps for doing so. Please note, however, that if you do disable cookies from your browser, you may not be able to access certain sections of the Sites or receive certain information/services.
Flash Cookies. Flash cookies track a person’s Internet use across websites and are not deleted or controlled by users in the same manner as standard HTML Cookies.
Web Beacons. Pages of the Sites and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Winston Products, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
In addition to these tools, for each visitor to the Sites, our webserver automatically recognizes and/or collects (where possible) certain information, such as your domain name, IP address, type of computer, type of web browser, screen size and characteristics (e.g., color, resolution), and operating system, and the city, state, and/or country in which you are located. We may also collect information regarding your Internet browsing history (e.g., the site you visited before accessing the Sites, the search engine and search terms that you used, and information about your previous visits to the Sites), the length of your visit, the pages you viewed, your Internet service provider, the language settings on your computer, and certain software (e.g., Java support).
We may use such information for purposes of system administration, to improve the design and content of the Sites, to speed up searches, and/or to enable us to personalize your Internet experience. We may also use such information in the aggregate to analyze the Sites usage and/or to assess the traffic to the Sites.
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We, like many businesses, sometimes work with other companies to perform certain business-related functions. These companies may include marketing agencies, social media platforms, database service providers, backup and disaster recovery service providers, email service providers, payment processors, and others. When we engage another company to perform such functions, we may provide it with personal information and automatic information about our customers, sales, website traffic patterns, and related website information, in connection with its performance of such functions. However, we do not collect or store credit card information or internet protocol addresses directly; rather, we employ a third party payment processor who may collect, store, and use such information. We take measures to select service providers that are responsible and afford privacy protections to their customers, such as those that comply with the Payment Card Industry Data Security Standards. However, we cannot make any representations about the practices and policies of these third-party companies.
Without limiting the generality of the foregoing, we may transfer or otherwise disclose such information to third parties (a) for their marketing purposes; (b) that perform services on behalf of Winston Products; (c) in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Winston Products’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Winston Products about the Sites users is among the assets transferred; (d) to meet any applicable law, regulation, legal process or enforceable governmental request; (e) to protect and defend the rights or property of Winston Products or its affiliated companies; (f) to identify, contact and/or bring legal action against someone who may have breached our Terms; (g) to act to protect the interests of the Sites, users, or others as we deem necessary; and/or (h) to fulfill the purpose for which you provide it, and/or (i) with your consent.
We work with third parties, including social media sites like Facebook, YouTube, Instagram, Pinterest, and Google+, and with application developers who specialize in social commerce so you can connect to Winston Products through your social networks. All of these companies operate websites not operated or controlled by us (“Third Party Sites”). We provide access to the Sites by third parties and business partners so we can generate interest in our products and services among members of your social networks and to allow you to share your interests with friends in your network.
If you use features made available on the Sites by a third party social media site, your personally identifiable information may be collected or shared by us or by the third party. We consider information collected or shared through any such social media features as public information because the third party social media sites made it publicly available. If you do not want us to be able to access information about you from Third Party Sites, you must instruct the Third Party Sites not to share the information with us. Winston Products does not control how these third parties use information collected from or about you, so be sure to review the privacy policies and privacy settings on your social media sites to make sure you understand the information they are sharing. If you do not want a Third Party Site to share information about you, you must contact that site and determine whether it gives you the opportunity to opt out of sharing such information.
We use features on third party social media sites that allow you to express opinions about products, services, or your interests and purchase our products. Those Third Party Sites may collect or register your views (including whether you liked or purchased a product) and make those views available to Winston Products and on public portions of the Third Party Sites. You can avoid such collection and use of your personal information by declining to buy products through Third Party Sites or to express your views on Third Party Sites. Third Party Sites may also give you the option to limit such data collection and disclosure in the privacy settings on their sites. Winston Products reserves its right not to display your personal information or content on our social media accounts and Sites, even if you express an opinion about our products or services or consent to our use of such information or content. We reserve the right to remove personally identifiable or other information of any person for any reason. We may also remove from our social media accounts and Sites, in our sole discretion, any product offering or any photo or product description.
PROTECTION OF INFORMATION
To prevent unauthorized access or disclosure, maintain data accuracy and facilitate the appropriate use of information, Winston Products uses physical, technological, and administrative procedures to protect the personal information collected from loss, unauthorized access, modification, disclosure, or other misuse.
Nevertheless, Internet transmissions are never completely private or secure, and you understand that any messages or information you send to the Sites may be read or intercepted by others. As a result, we do not ensure, warrant, or guarantee the security or integrity of such information. We will not be responsible for disclosure of any information due to errors in transmission or the unauthorized acts of third parties. If you have any questions about the security of personal information collected by Winston Products, please contact: email@example.com
You should also be aware that certain aspects of the Sites are not confidential and are available for public viewing. For example, any Submissions that you may post to any publicly available features of the Sites are not confidential and may be viewed by others. By making personal information publicly available where the Sites allow, you consent to such publication by Winston Products, its service providers, and/or agents. Please refer to the Terms for additional provisions relating to Submissions that may apply to you.
ACCESSING AND CORRECTING PERSONAL INFORMATION
Winston Products takes reasonable steps to ensure the personal information it holds is accurate, complete, and current. Upon your written request, subject to certain exceptions provided by law, we will inform you of the existence, use, and disclosure of your personal information and give you access to that information. Additionally, if you have any questions relating to our privacy practices or procedures, or if you believe that the personal information that we hold about you is not accurate, complete, or current, you may contact us as set forth below. If you are able to establish that the information is not accurate, complete, or current, we will take reasonable steps to correct the information.
If you would like to review the personal information that we have collected about you through the Sites, please send your name, street address, telephone number and email address to us by regular mail to the following address:
Winston Products, LLC
30339 Diamond Parkway, Suite 105
Cleveland, OH 44139
We will send you the personal information that we have collected about you online. If you would like to correct any factual errors, please note such correction and send them to us at the same address listed above so that we may make the corrections that you have requested.
YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits users of the Sites that are California residents to request a notice identifying the categories of personal information we share with third parties for their direct marketing purposes. To make such a request, please submit a written request, specifying that you would like a “California Privacy Notice,” to the following address: firstname.lastname@example.org. We may provide this information in a standardized format that is not specific to you.
CHOICE AND OPT-OUT PREFERENCES
If you are a resident of the European Union, you have the right to prompt deletion of your personal information upon request. If you would like us to delete the data we have collected about you that we have received through your use of the Sites or any social media provider or Third Party Site, please email us at email@example.com with the phrase “Privacy Opt-out: Delete My Information” in the subject line. If your information is deleted, you may not have access to certain functionality of the Sites, such as promotions, product information, or opportunities.
THIRD PARTY ANALYTICS
THIRD PARTY TRACKING
Winston Products collects transactional information and browse behavior on our website. Winston Products may use such information to offer you recommendations for products and services that are relevant to your interests. Winston Products uses the services of trusted third parties to offer you meaningful recommendations during the online experience. Winston Products shares IP address, unique identification number, and shop and browse behavior with the third party service provider on an aggregate basis, but does not share personal information for these purposes.
Winston Products may, from time to time in our sole discretion, offer users the ability to download and use mobile applications. By downloading and/or using these mobile applications, you agree to any applicable terms for using the applications (which will be provided when you download such applications). You may be required to provide personal information to use the mobile application, including your first name, last name, email address, and password. You will have the option of providing other personal information in connection with your use of the mobile application (e.g., your picture, your physical location, your birthday, etc.).
If you have granted permission through your device to allow us to collect location information, we may obtain pinpointed physical location information from technologies like GPS, Wi-Fi, or cell tower proximity. You are able to withdraw your permission for us to acquire pinpointed location information from your device through your device settings, although Winston Products does not control this process. The mobile application may use the geolocation features of that application (GPS or network-based) to support your use of location-based tools such as locating stores or products near you.
You will have the option to opt-out partially or completely from any of our mobile applications or withdraw any permission granted to Winston Products.
LINKS TO OTHER WEBSITES
Winston Products, LLC
30339 Diamond Parkway, Suite 105
Cleveland, OH 44139