Last Update: August 1, 2020
What information we collect and why we collect it.
How we use that information and when we disclose it.
How we transfer that information.
How to access and update your information.
The steps we take to protect the information.
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").
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:
Your name, company name and address, email address, and phone number, and account password, to set up your account.
Your Content which may provide.
product and service photos, descriptions, pricing, offerings and any other product and service related information you wish to use in your online advertising Campaign.
Information related to your Third-Party Platform accounts that is required to run your Campaign.
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:
Usage Information. When you use our Website and/or Services, we may record certain information from your device and your use of the Website and/or Services. This information may include your IP address or other device address or ID, operating system, the content you view or otherwise interact with on the Website and/or Services, and the dates and times that you visit, access, or use the Website and/or Services. We may link this information to your account for fraud detection/prevention purposes or to provide you with better services.
Information from Other Sources. We may obtain information, including PI, from third parties and sources other than the Website and/or Services, such as our partners and service providers. If we combine or associate information from other sources with PI that we collect through the Website and/or Services, we will treat the combined information as PI in accordance with this Policy.
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:
Third-Party Platforms: We will share your Content with Third-Party Platforms in order to place advertisements and run your Campaign on those Platforms.
Service Providers and Other Third Parties. We may share your information with service providers who perform services on our behalf, such as providing information technology services. When we work with service providers, we require them by contract to only use or disclose the PI they process on our behalf as necessary to perform certain services on our behalf or comply with legal requirements.
Aggregate and Non-identifying Information. We may share aggregate and other non PI and log data with our partners in order to improve the overall experience of our Website and/or Services. We may publicly share aggregate data about how our Users interact with our Website and/or Services.
Compliance with Laws and Law Enforcement. We will share your information if we, in our good faith judgment, believe it is reasonably necessary to: (i) investigate and defend ourselves against any third-party claims or allegations; (ii) respond to claims and legal process (including valid subpoenas, court orders, or government requests); (iii) take precautions against liability and protect the property, rights, and safety of Winnow, our Users, or others as required or permitted by law; (iii) enforce our Terms of Service or other agreements; (iv) prevent or stop activity we believe to be illegal, fraudulent, abusive, unethical or legally actionable; and (v) detect, prevent, or otherwise address fraud, the security or integrity of our Website and/or Services and facilities or equipment used to make the Website and/or Services available, or any other technical issues.
Other Disclosures. We may also disclose your information with companies, organizations, or individuals outside of Winnow when we have your consent to do so.
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.
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 firstname.lastname@example.org.
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.
VII. CHANGES AND UPDATES TO THIS 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
Winnow Digital Services Inc.
777 Mariners Island Blvd
San Mateo, CA