Windsor Circle, Inc. Privacy Policy

PRIVACY POLICY

Effective Date:  December 9, 2013

Windsor Circle Privacy Policy

At Windsor Circle, Inc. (“Windsor Circle,” “we,” “us,” or “our”), we respect and protect the privacy of our customers (“you,” “customer,” or “your”), website visitors and, to the extent required under applicable law, certain third parties associated with our customers.  This “Privacy Policy” describes our practices for how your personal information is collected and used.  This Privacy Policy applies to information that we collect and maintain about you when you visit the Windsor Circle website (“Site”) or use any Windsor Circle product or service (“Services”), and from other sources.  By visiting the Site, you expressly consent to the use and disclosure of your information as described below.  If you are a customer, this Privacy Policy is made subject to, and is a part of, our standard terms of use.

Information Collected

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. 

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.

Target Data

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.

Uses and Disclosures of Personal Information

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.

4)         Disclosures Required by Law.   Under certain circumstances, Customer Information and Target Data may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders or we may be required to disclose such information in order to enforce or apply our terms of use or other agreements, or to protect the rights, property, or safety of Windsor Circle, our customers, or third parties.  In such circumstances, you agree Windsor Circle may disclose such information to the extent necessary to comply with such legal order or requirement (“Disclosures Required by Law”).

Third Party Websites

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 Safe Harbor (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 Safe Harbor.

We may also provide your Information to a third party in connection with a merger, sale, or acquisition transaction, in which case we will require any such third party to agree to treat your personal information in accordance with this Privacy Policy.

Information Sharing

Except as otherwise set forth herein (and, in the case of a customer, set forth in our standard terms of use), we will not sell, rent or lease to others your Customer Information or your Target Data.

Control, E-mail and Opt-Out

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 privacy@windsorcircle.com. You may also request your information by mail addressed to Windsor Circle, 111 E Chapel Hill St, 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 privacy@windsorcircle.com.

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 privacy@windsorcircle.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.

Security of the Information 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. 

Cookies

Cookies are files that web browsers place on a computer’s hard drive to tell site owners whether an individual has interacted with the website previously.  Windsor Circle uses cookies to recognize repeat visits by users of the Site and to collect information about our Customers’ interactions with the Services. The use of cookies enables us to make your experience with the Site and Services easier and more meaningful.

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.

From time to time, we may engage third parties to track and analyze non-personally identifiable usage and volume statistical information from visitors to the Site to help us administer the Site and improve its quality.  Such third parties may use cookies to help track visitor behavior, including visitor responsiveness to online advertisements.  Such cookies will not be used to associate individual Site visitors with any personal data.  All data collected by such third parties on our behalf is used only to provide us with information on Site usage and will not be shared with any other third parties, and any such third party either satisfies the requirements of the Safe Harbor or have entered into a written agreement with us providing that it will provide at least the level of privacy protection as required by the Safe Harbor.

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. 

Safe Harbor

We abide by the principles of the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework, each as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union member countries and Switzerland, respectively (collectively, the “Safe Harbors”), and have certified our compliance with the Safe Harbors.  We conduct periodic internal reviews, and provide employee training, to ensure our compliance with this Privacy Policy.  To learn more about the Safe Harbors, and to view Windsor Circle’s certifications, visit http://www.export.gov/safeharbor/.  Any questions or complaints regarding this Privacy Policy, our use of your information, or the Safe Harbor should be directed to Windsor Circle, at privacy@windsorcircle.com.  Any complaints regarding this Privacy Policy or our use of your information will be investigated, and if we are unable to resolve the complaint to the satisfaction of all parties, the parties agree to utilize the dispute resolution mechanisms provided for by JAMS ADR (see http://www.jamsadr.com/) at a proceeding to be conducted in Durham, North Carolina.

Privacy Policy Changes

This Privacy Policy may be amended from time to time, consistent with the requirements of the Safe Harbor.  Any changes to this Privacy Policy will be posted here, so please check this page regularly and make sure to check the effective date of the policy as set forth above. If you have any questions or concerns about the changes, please contact us at privacy@windsorcircle.com.