WINNOW PRIVACY POLICY

Last Update: August 1, 2020

Welcome to Winnow, provided by Winnow Digital Services. Your privacy is important to us, so please take the time to familiarize yourself with our policies. As you use our Website and/or Services, we want to be clear how we are using your information and the ways in which you can protect your privacy. Our Privacy Policy explains:

This Policy applies to all Personal Information we have about you, including information obtained via the Winnow Website ("Website" or "Site") and Services ("Service" or "Services").

This Policy is incorporated into and is subject to the Winnow Terms of Service ("Terms of Service" or "Terms"). Any terms not defined in this Privacy Policy will have the meanings set forth in our Terms of Service or in our Cookie Policy.

I. THE INFORMATION WE COLLECT AND HOW WE USE IT

We gather and use information as described below. "Personal Information" ("PI") means any information that can be used to identify an individual. PI does not include information that has been aggregated or de-identified such that it can no longer be associated with a specific individual.

1. INFORMATION YOU PROVIDE

To register for the Services. To gain access to our Services, you must register on our Website and subscribe to our Service. When you register as a user, we may ask you to provide us with the following type of PI:

The fields of the registration form that are marked as mandatory describe the minimum amount of PI that we need in order to provide the Services.

To provide you with the Services. We use your PI to provide the Services to you, including helping you process your Content through the Website, and enable you to share your Content on social networks.

To communicate with you: We may use the contact information you provide to us to communicate with you, including through e-mail communications, mobile text messages, in-Website messages, Facebook Messenger, and phone calls. For example, we may use your email address, phone number, or other information that you provide to us (i) to contact you to verify your email address or phone number; (ii) to contact you for administrative purposes such as customer service, to respond to your inquiries, to manage your account, or otherwise provide user support; and (iii) to provide service-related messages such as notifications, confirmations, updates, and security alerts. Where required by applicable law, we will obtain your consent to send you marketing communications by electronic means.

2. INFORMATION WE RECEIVE FROM YOUR USE OF OUR WEBSITE AND/OR SERVICES

We may receive or collect various types of PI when you use our Website and/or Services:

II. HOW WE SHARE THE INFORMATION WE COLLECT

Winnow does not sell or rent your PI to marketers or third parties. We may, however, share or disclose your PI as follows:

III. THE CHOICES YOU HAVE WITH YOUR INFORMATION

Subject to applicable law, you may have the right to request access to and receive information about the PI we maintain about you, update and correct inaccuracies in your PI, and have the information blocked or deleted, as appropriate. The right to access PI may be limited in some circumstances by local law requirements.

To update or correct your profile information and preferences please visit the Website. You also have the right to withdraw your consent to the transfer of your PI. Note however that if you exercise your right of blocking or deletion, or if you decline to share certain PI with us, or if you withdraw your consent, we may not be able to provide to you some of the features and functionality of our Website and/or Services.

If you receive promotional email from us, you may unsubscribe at any time by following the instructions contained within the email. Even after you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us regarding the Services.

If you wish to opt-out of having cookies set on your browser (as described above), the only way to ensure that this happens is to manage the settings on your web browser to delete all cookies and disallow further acceptance of cookies. For more information, refer to your browser's technical information. You may also consider visiting aboutcookies.org, which is a helpful informational site on cookies. Note that disabling cookies on your browser prevents Winnow from following your activities in relation to our Website and/or Services. However, it may also disable many of the features available through our Website and/or Services.

In addition, although you may terminate your use of the Website and/or Services, we may maintain transactional or automatically generated data about your account for Website and/or Services improvement, recordkeeping, and compliance purposes, as described elsewhere in this Privacy Policy. Further, we cannot control the actions of other users with whom you may choose to share your information. Thus, even after information posted on the Website and/or Services is removed from the Website and/or Services, other users or third parties may have copied or stored information that was available on our Website and/or Services.

IV. CHILDREN’S PRIVACY

We take the online protection of children very seriously. Our Website and/or Services are not directed to children under the age of 13, and we do not knowingly collect PI from children under the age of 13. If we learn that we have inadvertently collected PI from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 13, please alert us at legal@winnow.co.

V. DATA SECURITY & PRIVACY SETTINGS

We maintain reasonable administrative, technical and physical safeguards designed to protect the personal information you provide or we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

VI. THIRD PARTY WEBSITES AND CONTENT

Our Website may provide links to other websites for your convenience and information. These websites may operate independently from Winnow. Linked websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by Winnow, we are not responsible for the websites’ content, any use of the websites, or the privacy practices of the websites.

Advertisements that Winnow runs on your behalf on Third-Party Platforms are subject to the privacy policies of those third parties and this Privacy Policy does not apply to them.

VII. CHANGES AND UPDATES TO THIS POLICY

We reserve the right, in our sole and absolute discretion, to make changes to this Privacy Policy from time to time. Please review this Privacy Policy periodically to check for updates. If any changes are material and apply retroactively to data collected under a prior policy, we may provide additional notice and/or an opportunity to "opt-in," as appropriate under the circumstances.

Winnow will provide you with disclosures and alerts regarding this Privacy Policy by posting them on our Website, by emailing the email address listed in your Winnow account, and/or by mailing to the physical address listed in your Winnow account. Your continuous use of the Site and/or Services after the revised Privacy Policy has become effective indicates that you have read, understood and agreed to the then-current version of the Privacy Policy.

VIII. INTERNATIONAL DATA TRANSFERS

The Website is an online service and as such may store and process information in the United States and/or in a variety of other international locations. If you reside in a jurisdiction where transfer of your Personal Information to another jurisdiction requires your consent, then you provide your express and unambiguous consent to such a transfer.

IX. OUR CONTACT INFORMATION

The entity responsible for the collection, use and processing of your PI is Winnow Digital Services. If you have any questions or suggestions about this Privacy Policy, any of our privacy-related practices, your Personal Information, or to exercise your rights of choices, please contact us. You may also send your questions or suggestions to:

Winnow Digital Services Inc.
777 Mariners Island Blvd
Suite 115
San Mateo, CA
94404
legal@winnow.co