Effective Date: August 31, 2016
We primarily collect and maintain three categories of personal information: (i) account information (including your contact information) provided when you activate, subscribe for or otherwise use the Services (“Customer Information”); (ii) data collected through the Services about the behavior and demographics of your customers and other third parties that consent to the receipt of marketing and other content from you, or that otherwise interact electronically with you or your website (“Target Data”); and (iii) data about visitors to the Site who may or may not be our customers, including technical information and information about the use of our Site. All personal information received from member states of the European Economic Area in reliance on the Privacy Shield will be subject to the EU-U.S. Privacy Shield Principles.
Although we do not actively collect such information, certain information we collect and/or that is provided to us by our customers may relate to or contain personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information specifying the sex life of an individual (any such information, “Sensitive Information”).
The Site and Services are not intended to be used by children under the age of thirteen (13), and we do not knowingly collect information from children. If we become aware that a child under the age of thirteen (13) has provided us with information, we will remove it from our systems.
If you enter into any agreement with us for Services, you warrant you have obtained the requisite consent from your customers for us to collect and use the Target Data as necessary for the provision of the Services.
1) Marketing Services. If you have provided your contact information to us, you agree we may use such information to contact you for marketing purposes via direct mail, email, telephone, pre-recorded messages, text messages, instant messages or other communications methods. If you are a customer, we will only contact you by electronic means with information about goods and services similar to those which were the subject of a previous sale or negotiation of a sale to you. If you do not want us to use your information in this way, or to pass your details on to third parties for marketing purposes, please opt-out by following the instructions set forth below.
2) Customer Support. If you have a problem, comment, or request concerning the Site or the Services, we will use the contact information provided by you to respond to those problems, comments or requests. In certain instances, our response may be provided to other Windsor Circle customers or third parties as necessary to respond to any problem, comment, or request, but any such response shall not include your personally identifiable information.
3) Target Data. Windsor Circle may use Target Data in connection with its performance of the Services; and non-personally identifiable Target Data in aggregate and blinded formats that do not identify, reference or imply an association with, Customer or its customers, for the purposes of creating benchmarking, statistical, research and marketing analyses, surveys, reports and studies.
As part of the Services, the Site may contain links to websites operated by third parties. We are not responsible for the privacy practices or the content of any third party websites. Customers and visitors who link to third party websites from the Site should check the privacy and security policy statements of such third party websites to understand the policies and practices of such third party websites as we are not responsible for those policies and practices. Customers and visitors who access a linked site may be disclosing their private information to the owner of such third party websites. Please review these policies before you submit any personal data to these websites. It is your responsibility to keep such information private and confidential.
In addition to Disclosures Required by Law, we may engage subcontractors and/or service providers to help us maintain, upgrade, create, or improve the Site and/or the Service, and these parties may have access to certain of your information in the course of providing such services. Further, we may share your information with third parties in connection with our analysis of Site usage, as discussed below, under “Cookies.” In the event you do not agree to any such disclosure, you may contact us as discussed below to modify or delete the information we hold. Additionally, aside from in connection with Disclosures Required by Law, any disclosure to a third party will only be made if such third party satisfies the requirements of the EU-U.S. Privacy Shield (as defined below), or has entered into a written agreement with us providing that it will provide at least the level of privacy protection as is provided in the EU-U.S. Privacy Shield Framework.
You may request access to and correction of, amendment to, or deletion of any information provided to us at any time by contacting us at email@example.com. You may also request your information by mail addressed to Windsor Circle, 212 W Main St, Suite 400, Durham, NC 27701. We will respond to any written requests within thirty days.
If you received one or more e-mails from us, it means one of two things: (i) your e-mail address is on our list of customers, free trial users or prospective customers; or (ii) you have provided us your e-mail address so that we could contact you. If you believe you received an email from us in error, please contact us immediately at firstname.lastname@example.org.
We provide you with the opportunity to opt-out of receiving certain communications from us at any point in time. If you wish to cease receiving e-mails and other communications from us, you can opt-out of by contacting us at email@example.com.
In the event we collect Sensitive Information, we will obtain your consent prior to revealing such Sensitive Information to any unauthorized third party or to using it for purposes other than those for which it was originally collected.
We use technical, administrative, and physical security measures to protect against the loss, misuse, alteration, disclosure, and unauthorized access of data used by our system, and to ensure that all data used by our system is reliable for its intended use, and is accurate, complete, and current. Also, we provide each customer with a unique user name and password that must be entered each time a customer logs into its account. No data transmissions over the Internet, however, are guaranteed to be completely secure. While we strive to protect your data from unauthorized use or disclosure, Windsor Circle does not warrant or guarantee the security of the data that you provide to us; any transmission of data is at your own risk.
There are two types of cookies: session-based cookies and persistent-based cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. They include such information as a unique identifier for your browser. Standing alone, cookies do not contain personal data, and therefore do not identify you personally; they merely recognize your browser. Unless you choose to identify yourself to Windsor Circle, either by responding to a promotional offer, using the Services, or registering for a free trial, you will remain anonymous to Windsor Circle.
The cookies we use do not transmit personally identifiable information to us or to our service providers. You have the choice to opt-out of receiving cookies from both Windsor Circle and third parties which will prevent Windsor Circle and third parties from tracking information about the online advertisements that you visit. Please note that you still will have the ability to view our online advertisements even if you opt-out of receiving cookies OR if you choose to disable cookies, you may still use the Site; however, you may have limited access to some areas within the Site.
You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies; however, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our Site.
Windsor Circle’s accountability for personal data that it receives under the EU-U.S. Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Windsor Circle remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Windsor Circle proves that it is not responsible for the event giving rise to the damage.