Effective Date: February 3, 2017
Personal Information Collected
When you use our services or make a purchase, you voluntarily share certain personal information with us such as your name, e-mail address, address, telephone number, and/or credit/debit card information. You may also share personal information when you connect to our sites through social media networks. We may collect additional information from you (e.g. unique device identifier, device’s operating system, or mobile carrier) if you access our sites through a mobile device. More Info
Tracking Technologies (Cookies, etc.)
We use tracking technologies such as cookies and similar technologies to measure usage during your visits to our services to provide information and advertising that will be of most interest to you. More Info
Third parties may also use information gathered from your use of the services to serve targeted, interest based advertisements to you on websites and mobile applications. More info
Use and Sharing of Information
Your Information Access and Managing Options
Your Information Choices
You can control whether you want to receive promotional communications from us. More info
Your California Privacy Rights
Effective Date: February 3, 2017
1. INFORMATION WE COLLECT
Information Collected Directly From You. You can browse our Services without telling us who you are or revealing any personal information. If you create an account, contact us or purchase any of our Services, you are choosing to give us your personal information, including but not limited to your name, address, email address, phone number, mobile telephone number, or physical contact information about yourself. You may also provide payment information such as credit or debit card information and billing address to purchase our products and services.
Information You Post/Social Networks. The Services are designed to enable you to communicate with others and any information or content you post when participating with the Services and Social Networks, plug ins or other applications becomes public information, depending upon your privacy settings, and is subject to redistribution by Winston Brands and third parties. There is no expectation of privacy when posting content or otherwise participating in such interactive forums and we have no control over how those users may use the information you make public. Therefore, you should exercise caution and discretion when deciding to disclose your personal information in a submission or posting.
Mobile Devices. We may collect additional information from you if you access our Services through a mobile device; for example, your unique device identifier, device’s operating system, mobile carrier, and regional location. We may also collect your location information from your IP address or zip code. The degree to which your location can be identified depends on the device you are using, e.g. laptop, smartphone, tablet or other access device (each a “Device”) and how you are connected to the internet (e.g. via cable broadband connection, WiFi, etc.).
Information about Others/Inviting Friends. From time to time you may choose to submit personal information about other people to invite them to join a Service. Inviting friends is always optional. Please be aware that when you use any send-to-a-friend functionality on the Services, your e-mail address may be included in the communication sent to your friend.
Information We Collect From Third Parties. We acquire information from other trusted sources to update or supplement the information we collect, such as information to validate or update your address or demographic and lifestyle information.
2. INFORMATION COLLECTED THROUGH TRACKING TECHNOLOGIES
- Operationally Necessary. We may use Tracking Technologies for system administration, to prevent fraudulent activity, to improve security or to allow you to make use of our Services.
- Performance Related. We may use Tracking Technologies to assess the performance of our Services, including as part of our analytic practices to improve content offered through the Services.
- Functionality Related. We may use Tracking Technologies to tell us, for example, whether you have visited the Services before or if you are a new visitor and to help us identify the features in which you may have the greatest interest.
- Targeting Related. We may use Tracking Technologies to deliver content, including ads, relevant to your interests on the Services and third party sites based on how you interact with our advertisements or content, as well as to track the content you access. For more information, see Section 3 below.
Location Functionality. Information gathered from your use of the Services may be combined with information from third-party sources to identify your location by state and region (“Regional Location”). If you enable location services for our Services, we may collect Regional Location data periodically as you use or leave open our Services.
3. TARGETED ADVERTISING
Interest Based Advertising. We may use Tracking Technologies to collect information about your visits over time and across the Services and other third party web sites, as well as information received from other sources, in order to serve more targeted advertising to you. To serve our ads, we use a variety of third party advertising service providers, including networks, data exchanges, ad servers, analytics providers and others. These third parties may use Tracking Technologies to send directly to your Device the advertisements and links that appear on the Services. They automatically receive your Device identifier when this happens. Their tools may also limit the number of times you see the same ad and help measure the effectiveness of our advertising campaigns. These third parties may also use information gathered from your use of the Services to serve targeted, interest based advertisements to you on third party websites and applications. Some of the advertising service providers may be members of the Network Advertising Initiative, which offers a single location to opt-out of ad targeting from member companies. If you opt-out of receiving targeted ads in this manner, you will continue to receive advertising messages, but they will not be customized to you based on your use of the Services and third party sites. If you would like more information about advertisers’ use of tracking technologies and about your option not to accept them, you can go to www.networkadvertising.org. To learn more about how interest-based information is collected, whether the companies we use are part of an industry network regarding behavioral advertising, or to know your choices about not having information used in this manner, you can go to www.aboutads.info. Some newer mobile device operating systems allow you to limit the use of information to deliver interest-based advertising in mobile applications. You can check the settings on your mobile Device for such options in your mobile Devices’ operating system. Alternatively, you may wish to download the TrustE mobile application and/or the Digital Alliance “App Choices” mobile application and follow the instructions provided.
Please note that the opt-out is cookie-based and will only affect the specific computer or mobile application, and browser or operating system, on which the opt-out is applied. You can also accept or decline cookies through your browser settings. To learn more, please look at the cookie settings available in your specific web browser(s).
Browser “Do Not Track” Signals. Some third party browsers provide “do not track” machine readable signals for websites, which are automatically applied by default and therefore do not necessarily reflect our visitors’ choice as to whether they wish to receive advertisements tailored to their interests. As a result, we do not respond to these signals.
4. HOW WE USE AND SHARE YOUR INFORMATION
Service Providers. We may disclose information to our third party service providers in order to monitor the activity of the Services, conduct surveys, administer contests or sweepstakes, send marketing communications, and provide other Services to you, such as customer service.
Process Payments. Information may be disclosed to process credit card transactions, which are handled by established third party banking, processing agents and distribution institutions. They receive the information needed to verify and authorize your credit card or other payment information and to process your order. In addition, we may disclose information to third parties to verify the authenticity of any financial transaction involving our company or its affiliates or to update your billing information.
Direct Mail Promotional Offers. We may send you our catalog and/or offers through direct mail. Names and postal mailing addresses may be shared with our marketing partners. If you do not want us to send you our catalog or any direct mail promotional offers or offers or sell, rent or share your information with other companies so that they can send you direct mail offers about their products and services, you may follow the instructions in Section 6 Choice and Opt-Out, set forth below. Note that California residents have additional rights with regard to direct marketing as described in the Section below titled, Your California Privacy Rights.
Telephone Transactions. If you have provided your telephone number when registering with us or when ordering merchandise from us, we may use that telephone number to reach out to you to follow up on your order of merchandise. We might also share that information to third parties doing verifications on our behalf.
Analyze and Aggregate Non-Personal Information. We use aggregate or non-personal information about our users to analyze our Services and user behavior and prepare reports which we may share with third parties.
Promotional Communications. We may use your contact information to send you electronic updates and communications about our products and services or other promotional communications, such as newsletters, emails, or special offers or share your information with our trusted marketing partners so they can contact you using your contact information to provide promotional offers to you (“Promotional Communications”). If you wish to opt-out of receiving Promotional Communications from us or our marketing partners or change your preferences for Promotional Communications, you may follow the instructions in Section 6 Choice and Opt-Out, set forth below.
Information from Other Sources. The information we collect may be combined with information from outside records (e.g., demographic, navigation, and additional contact information) that we have acquired in accordance with the law. We may also acquire information from other sources about your visits over time and across other third party websites, in order to serve targeted advertising to you on the Services.
Legal Matters; Safety. We may, without your consent, access and disclose your information, any communications sent or received by you, and any other information that we may have about you or your account as may be permitted or required by law (including, but not limited to court order or subpoena), or to prevent or investigate suspected fraud, violations of our Terms, or activity that appears to us to be illegal or may expose us to legal liability. Additionally, we may disclose your information in situations that we believe may involve potential threats to the physical safety of any person or property.
Sale or Transfer of Business or Assets. If Winston Brands or any of its affiliated companies or businesses is sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, information of our users may be one of the assets sold or merged in connection with that transaction. Information about our users may also be disclosed in connection with a commercial transaction where we are or any one of our businesses is seeking financing, investment, and support or funding.
Transactional Communications. We may use your information to send you notices from time to time relating to your account or your purchases. These may include order confirmations, invoices or customer service notifications. We may also send you Service-related announcements when it is necessary to do so; for instance, if our Service is temporarily suspended for maintenance, or the delivery of a product is delayed or there are policy changes.
5. ACCESSING AND MANAGING YOUR PERSONAL INFORMATION
We believe it is important for you to be able to access and manage your account and the information you have provided to us and make choices about how it is used. To inquire about or update your information, or change your preferences, you may contact customer service at firstname.lastname@example.org or call us at (866) 584-8010.
If you have a registered account, you may change your preferences by logging in to your account.
You may also contact us by mail as set forth in Section 8 below.
6. CHOICE AND OPT-OUT
Opting Out of Promotional Messages:
Direct Mail Promotions. To opt out of receiving any direct mail promotional messages from us please call customer care at (866) 584-8010 or you may write to us at Unsubscribe from Mailings c/o Winston Brands, Inc., 2521 Busse Rd, Elk Grove Village, IL 60007, or email us at email@example.com with "Unsubscribe from Mailings" in the subject line. Please be sure to provide us with the mailing address you wish to opt-out.
Third Party Direct Mail Promotions: if you want to opt out of mailing promotions from third parties please call customer care at (866) 584-8010 or you may write to us at Unsubscribe from 3rd Party Mailings c/o Winston Brands, Inc., 2521 Busse Rd, Elk Grove Village, IL 60007, or email us at firstname.lastname@example.org with "Unsubscribe from 3rd Party Mailings" in the subject line. Please be sure to provide us with the mailing address you wish to opt-out.
Phone Messages: If you wish to opt-out of receiving Promotional Communications from us via phone, us please call customer care at (866) 584-8010 or you may write to us at Unsubscribe from Phone c/o Winston Brands, Inc., 2521 Busse Rd, Elk Grove Village, IL 60007, or email us at email@example.com with "Unsubscribe from Phone" in the subject line. Please be sure to provide us with the phone numbers you wish to opt-out.
Email: If you wish to opt-out of receiving Promotional Communications from us, you may click the unsubscribe link in the footer of any email. You can also call customer care at (866) 584-8010 or you may write to us at Unsubscribe from Email c/o Winston Brands, Inc., 2521 Busse Rd, Elk Grove Village, IL 60007, or email us at firstname.lastname@example.org with "Unsubscribe from Email" in the subject line. Please be sure to provide us with the email address you wish to opt-out.
Interest Based Ads: Please refer to Section 3 for opt-out information.
Transactional Messages: You may not opt-out of transactional or administrative e-mails, for example e-mails about your account, transactions or policy changes).
Timing and Third Parties. We will endeavor to comply with your request for changes as soon as reasonably possible. Unless required by law, we are not responsible for informing third parties with whom we have already shared your information of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such entities.
7. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION
Security. We implement security measures to protect against the loss, misuse and alteration of personal information under our control. We use “Secure Socket Layers” or SSL to protect your personal information when collecting and transmitting your billing information to our payment processor. However, despite our efforts, no system can completely guaranty that there will never be unauthorized access to your personal information, and your use of our Services indicates that assume this risk.
Children’s Privacy. The Services are directed to an adult audience. We do not knowingly collect personal information from individuals under 18 years of age and, if we obtain actual knowledge that a user is under 18 years of age, we will take steps to remove that user’s personal information from our systems.
Your California Privacy Rights. California Civil Code Section 1798.83, known as the "Shine The Light" law, permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. To make such a request, please contact us at Winston Brands, Inc., 2521 Busse Rd, Elk Grove Village, IL 60007. For all requests, you must put the statement "Your California Privacy Rights" in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. You need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via the telephone, email, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
8. CONTACTING US
When contacting us, please include your full name, address, phone number, and email address, and indicate the specific nature of your request.
HTML5. We use HTML5 in some of our applications, including in our mobile website for the iPhone or iPad. HTML5 has browser web storage that does not rely on traditional browser cookies. HTML5 cookies are not stored in a browser “cookies” file and can be used to track users across websites. To our knowledge there is currently no known way for a user of a mobile Device to remove HTML5 tracking and storage.
Web Beacons/GIFS. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our web pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts. An embedded script is programming code that is designed to collect information about your interactions with the Services such as the links you click on. The code is temporarily downloaded onto your Device used to access Services from our web server or a third party service provider, is active only while you are connected to the Services, and is deactivated or deleted thereafter.
e-tags/cache browsers/web logs. Like most standard website servers, we log IP addresses (a unique number assigned to every computer on the Internet) and Device identification in order to improve security, analyze trends and administer the Services. We may track your movement within the Services, the pages from which you were referred, access times and browser types. This information may include the browser you are using, the Internet address from which you linked to our Services, the operating system of your computer, the unique IP address of the computer or Device identification from the mobile Device that you used to access our Services and usage and browsing habits. We use this information in the aggregate to gauge the effectiveness, usage, and popularity of our Services, track information for statistical purposes, help diagnose and troubleshoot server malfunctions, analyze trends, track user movement in the aggregate, and gather broad demographic information. We may also use individual information we collect through web logs to send you targeted offers and other communications.
Device Fingerprinting. We may use Device fingerprinting in some of our Services, which allows us to collect information about a remote computing Device for the purpose of identification. It can be used to prevent fraud or collect information about you.
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