Effective Date: May 21, 2018
We primarily collect and maintain three categories of information, which categories may include both information that can be used to identify or contact an individual (“personal information”) and other non-personal information:
(i) Customer Information. You may provide, and we may collect, information when you activate, subscribe for or otherwise use the Services (“Customer Information”). Examples of Customer Information include your account information such as username and password, billing information, name, email address, mailing address, phone number, usage details of the Service, information related to support or service requests, and current geographic location and language.
(ii) Target Data. We collect data stored or uploaded by you into 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”). All Target Data is controlled by our Customers, who are the data controllers for such information with respect to EU data protection laws and regulations. Each Customer is responsible for obtaining the requisite consent in accordance with applicable law from its customers and third parties for us to collect and use the Target Data as necessary for the provision of the Services. Except as provided herein, we will not process Target Data for other purposes or by other means than as instructed by our Customers.
(iv) Information from Other Sources. We may obtain Customer Information, including personal information, about you or a prospective customer from our business partners or other third parties, for the purposes of providing you with improved Services.
Although we do not actively collect such information, certain information 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 sixteen (16) for residents of the European Economic Area (“EEA”) and under the age of thirteen (13) for all others, and we do not knowingly collect information from such children. If we become aware that a child under the age of thirteen (13) (or a child from the EEA under the age of sixteen (16)) has provided us with information, we will remove it from our systems. If you believe we might have any information from or about underage children, please contact us at firstname.lastname@example.org.
We use information that we collect about you or that you provide to us, including any personal information, in various ways, including the following:
Windsor Circle reserves the right to share any information that is not deemed personal information or is not otherwise subject to contractual restrictions.
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.
From time to time, personal information from data subjects in the EEA that we collect may be transferred or accessed by entities who may be based outside of the EEA. We may also allow our service providers or assistance providers, who may be located outside the EEA, access to your personal data. We may also make other disclosures of your personal data overseas, for example, if we receive a legal or regulatory request from a foreign law enforcement body. We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests. For example, transfers to our service providers and other third parties will always be protected by contractual commitments, further assurances where appropriate, such as the European Commission's approved Standard Contractual Clauses, or certification schemes such as the EU - U.S. Privacy Shield for the protection of personal data transferred from within the EU to the United States of America.
Windsor Circle will not retain your personal information longer than is necessary to fulfill the purposes for which it was collected unless a longer retention period is required or permitted by law.
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.
You may always decline to share certain personal information with us, in which case we may not be able to provide to you some of the features and functionality of the Services.
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 become aware that we have collected 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.
In addition to the above rights of access, correction, amendment or deletion, if you live in the EU, you may, subject to applicable law, have some or all of the following rights with respect to your personal information:
to obtain, or see a copy of the appropriate safeguards under which your personal data is transferred to a third country or international organization;
to object, at any time, to the processing of your personal information, on legitimate grounds, except if otherwise permitted by applicable law;
to erase your personal data (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed); and
to file a complaint with your local supervisory authority for data protection.
If you are seeking to exercise any of the foregoing rights, please contact us at firstname.lastname@example.org.
Please note that Windsor Circle has no direct relationship with our Customer’s customers or other third parties whose personal information we may process as Target Data on behalf of a Customer. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, or has other inquiries with respect to their personal information should direct his or her query to the Customer they deal with directly.
California Civil Code Section § 1798.83 permits users of our Site or Services that are California residents to request certain information, including the categories of personal information disclosed to third parties for their marketing purposes and the names and addresses of those third parties, regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are California resident and would like to make such a request, please submit your request via email to email@example.com.
Some Internet browsers include the ability to transmit "Do Not Track" signals. We do not currently process or respond to “Do Not Track” signals. To learn more about "Do Not Track", please visit “All About Do Not Track."
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.
Pages of our the Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us for example, to count users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain delivered content and offers). Our web beacons may collect some contact information (e.g., the email address associated with an email message that contains a web beacon)
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.