Winnow Digital Services Inc.
Privacy Notice for California Residents
Last Updated: May 26, 2022
Information We Collect
WinnowPro collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). In particular, within the last twelve (12) months WinnowPro has collected the following categories of personal information from the sources and for the business or commercial purposes described below and disclosed such information to third parties as follows:
Personal Information does not include:
- Publicly available information from government records.
- Anonymized or aggregated consumer information.
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In addition to the business or commercial purposes for collection described above, we have in the preceding twelve (12) months collected all categories of Personal Information described above for the following purposes:
- To process your requests, purchases, payments, and transactions and to prevent transactional fraud;
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
- To create, maintain, customize, and secure your account with us;
- For testing, research, analysis, and product development, including to develop and improve this Site and our products and services;
- To provide, support, personalize, and develop this Site and our products and services;
- To help maintain the safety, security, and integrity of this Site and our products, services, databases, other technology assets, and business; and
- To deliver content and product and service offerings relevant to your interests, including targeted offers and ads through this Site, third-party sites and via email or text message (with your consent, where required by law).
We will continue to collect the categories of Personal Information described above from the sources and for the business or commercial purposes described above.
We may also use or disclose the Personal Information we collect for one or more of the following purposes:
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- As described to you when collecting your Personal Information; or
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of WinnowPro’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by WinnowPro about the users of this Site is among the assets transferred.
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 notice.
We will continue to disclose your Personal Information to third parties as described above. We will not disclose your Personal Information in any materially different way without providing notice to you. In the preceding twelve (12) months, we have not sold Personal Information, and we will not sell your Personal Information without providing notice to you.
Disclosures of Personal Information for a Business Purpose
We do not sell your Personal Information.
When we disclose your Personal Information to a service provider, we enter into a contract with the service provider that describes the business purpose for which your Personal Information is disclosed and restricts the service provider from using your Personal Information for any purpose except performing the contract or as permitted by applicable law.
Your Rights and Choices
California law provides you as California residents with specific rights regarding your Personal Information. This section describes your rights and explains how to exercise those rights.
Knowledge 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 consumer request (see Exercising Knowledge, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of Personal Information we collected about you;
- The categories of sources for the Iersonal information we collected about you;
- Our business or commercial purpose for collecting that Personal Information;
- The categories of third parties with whom we share that Personal Information;
- The specific pieces of Personal Information we collected about you; and
- If we disclosed for a business purpose your Personal Information, a list detailing such disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
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 consumer request (see Exercising Knowledge, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality
- Exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal obligation; or
- Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
Exercising Knowledge, Data Portability, and Deletion Rights
To exercise the knowledge, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. If your authorized agent submits a request on your behalf, the authorized agent must provide either (1) a copy of your written permission for the authorized agent to submit a request on your behalf and information sufficient to verify the authorized agent’s identity or (2) power of attorney pursuant to California’s Probate Code. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request to know or for data portability twice within a twelve (12)-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
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 the Personal Information relates to you.
Making a verifiable consumer request does not require you to create an account with us, but we may require authentication of the consumer that is reasonable in light of the nature of the Personal Information requested.
We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (for a maximum total of 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 a verifiable consumer 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 consumer request unless the request 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. Alternatively, we may decline to respond to the request and notify you of our reason for doing so.
We will not discriminate against you for exercising any of your rights under California law. Specifically, unless permitted by law, we will not:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits or imposing penalties;
- Provide you a different level or quality of goods or services, including denial of goods or services; or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to this Privacy Notice
WinnowPro reserves the right to update or change this Privacy Notice at any time. When we make changes to this Privacy Notice, we will post the updated notice on this Site and update the date on which this Privacy Notice was last updated. The date this Privacy Notice was last updated is at the top of this page. You are responsible for periodically reviewing this Site and this Privacy Notice to check for any updates or changes. Your continued use of this Site following the posting of changes constitutes your acceptance of such changes.
If you have any questions or comments about this privacy notice or our privacy practices, your choices and rights regarding use of your personal information, or wish to exercise your rights under California law, please contact us at:
Winnow Digital Services Inc.
777 Mariners Island Blvd., Suite 115
San Mateo, CA 94404
Attn: Legal Department