PRIVACY POLICY

This Privacy Policy (the “Privacy Policy”) describes the information that (i) relates to or could reasonably be associated with an individual or household and (ii) is subject to applicable data protection laws (“Personal Information”) that Windfall Data, Inc. (“Windfall,” “we,” “us,” “our”) collects as part of the normal operation of providing actionable financial data (including https://windfalldata.com/, the “Services”) relating to individuals (“Consumers”) to our customers (“Customers”), and how we use and disclose this information. All of the different forms of data, content, and information described below are collectively referred to as “information.” .. In consideration for visiting and using the Services, you expressly consent to our collection, use and disclosure of your information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to our Terms and Conditions. Capitalized terms that are used but not defined in this Privacy Policy have the meaning given them in our Terms and Conditions. If you need a copy of your terms and conditions, please contact support@windfalldata.com. California residents – please click here to learn more about your privacy rights.

  1. The Information We Collect And Store

We may collect and store the following information when running the Services:

Consumer Data.  We may collect Consumer Personal Information that may include name, email address, telephone number, occupation, employer, bank account details, taxation details, charitable contribution history, and accounting and financial information. From the foregoing, we may identify causes that Consumers are interested in (for example we may assess that a Consumer who has donated to an environmental non-profit in interested in supporting environmental conservation efforts).

Customer Account Data. When Customers create an account or authorize someone to use the Services on their behalf (a “User”), we may collect some Personal Information, such as your entity’s name, and the User’s name, phone number, a credit card or other billing information, email address and business postal addresses. We may also receive Personal Information through other Customers, for example if they have tried to give you access to a Windfall account or refer Windfall to you.

Social Media Data. When you interact with our pages on social media sites like Twitter and LinkedIn (“Social Media Pages”), we will collect Personal Information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Others’ Personal Information.  If you provide Personal Information about someone else, you must ensure and hereby agree that you are authorized to disclose that information to Windfall and that, without Windfall taking any further steps required by applicable data protection or privacy laws, Windfall may collect, use and disclose such information for the purposes described in this Privacy Policy. You must take reasonable steps to ensure that the individual concerned is aware of and consents to the various matters detailed in this Privacy Policy, including the fact that that person’s Personal Information is being collected, the purposes for which that information is being collected, the intended recipients of that information, Windfall’s identity, and how to contact Windfall.

Sensitive Personal Information. You are prohibited from uploading any Personal Information about yourself or others that relates to health or medical conditions, Protected Health Information (as defined in 45 CFR 160.103), social security numbers or taxpayer identification numbers, driver’s license numbers, information concerning criminal charges or convictions, or racial or ethnic origin.

Log Data.   When you use the Services, we may automatically record information from the computer used to access the Services, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device (a “Device”), its software, and your activity using the Services. This may include the Device’s Internet Protocol (“IP”) address, browser type, the web page visited before you came to our website, information you select or search for on our website, locale preferences, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata concerning your files, and other interactions with the Services.

Cookies Data.   We also use “cookies” to collect information and improve our Services. A cookie is a small data file that we transfer to your Device. We may use “persistent cookies” to save your registration ID and login password for future logins to the Services. We may use “session ID cookies” to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage and web traffic routing on the Services. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of the Services.

Online Tracking and Do Not Track Signals: We and our third party service providers may use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Services. We make reasonable commercial efforts to recognize and support “Do Not Track” signals.

  1. How We Use Personal Information 

Personal Information. Personal Information is or may be used: (i) to provide and improve our Services, (ii) to administer your use of the Services, (iii) to better understand your needs and interests, (iv) to personalize and improve your experience, and (v) to provide or offer software updates and product announcements. If you no longer wish to receive communications from us, please follow the “unsubscribe” instructions provided in any of those communications, or update your account settings information.

Analytics.   We also collect some information (ourselves or using third party services) using logging and cookies, such as IP address, which can sometimes be correlated with Personal Information. We use this information for the above purposes and to monitor and analyze use of the Services, for the Services’ technical administration, to increase our Services’ functionality and user-friendliness, and to verify users have the authorization needed for the Services to process their requests. We may use Google Analytics for these purposes. To learn more about the privacy policy of Google Analytics, click here, and to learn how to opt out of that service, click here.

  1. Information Sharing and Disclosure

Your Use.   Unless you specified otherwise, Customer Data that you provide to us may be shared with your Users. Under no circumstances will we sell your Personal Information to third parties.

Service Providers, Business Partners and Others.   We may use certain trusted third party companies and individuals to help us provide, analyze, and improve the Services (including but not limited to data storage, maintenance services, database management, web analytics, payment processing, and improvement of the Services’ features). These third parties may have access to your information only for purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy.

Third Party Applications.   We may share your information with a third party application with your consent, for example when you choose to access our Services through such an application. We are not responsible for what those parties do with your information, so you should make sure you trust the application and that it has a privacy policy acceptable to you.

Compliance with Laws and Law Enforcement Requests; Protection of Windfall’s Rights.   We may disclose to parties outside Windfall information that you provide and that we collect when we have a good faith belief that disclosure is reasonably necessary to (a) comply with a law, regulation or compulsory legal request; (b) protect the safety of any person from death or serious bodily injury; (c) prevent fraud or abuse of Windfall or its users; or (d) to protect Windfall’s property rights.

Business Transfers.   If we are involved in a merger, acquisition, sale of all or a portion of our assets, or other change in corporate control (collectively a “Transaction”), your information may be transferred as part of that Transaction or during the diligence process related to the Transaction.

Non-Private or Non-Personal Information.   We may disclose your non-private, aggregated, or otherwise non-personal information, such as usage statistics of our Services.

  1. Changing or Deleting Customer Account Data

It is Customers’ responsibility to ensure that Customer Personal Information is up-to-date. Each Customer may review, update, correct, or delete Customer Account Data. When you choose to close an account, we will remove Customer Account Data from our marketing and billing systems. For questions about your Personal Information on our Services, please contact support@windfalldata.com.

  1. Data Retention

We will retain your information for as long as your account is active or as needed to provide you the Services. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain all Anonymized Data. Consistent with these requirements, we will try to delete your Personal Information quickly upon request. Please note, however, that there might be latency in deleting information from our servers and backed-up versions might exist after deletion.

  1. Security

Information may be stored and processed in the United States or any other country in which Windfall or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which Windfall or its subsidiaries, affiliates or service providers maintain facilities and the use and disclosure of your information as described in this Privacy Policy.

If you would like your personal information to be expunged from Windfall, please submit a request to support@windfalldata.com with your name, current address, and other details that may be able to help us purge the information.

We follow generally accepted standards to protect the information submitted to us, both during transmission and once we receive it. No method of electronic transmission or storage is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our website, you can contact us at support@windfalldata.com.

  1. California Privacy Rights

The following table is intended to provide additional information about (1) the categories of Personal Information we collect (as described in Section 1), (2) the source of each category of Personal Information, (3) how we use each category of Personal Information, and (4) how we disclose Personal Information. Nothing in this table limits our ability to use or disclose information as described above.

Category of Personal Information Sources of Personal Information Use of Personal Information Disclosure of Personal Information
Consumer Data We collect Consumer Data from publicly available sources (such as government records) and from Customers. We also process Consumer Data collected from the foregoing sources to derive additional Consumer Data. We use Consumer Data to provide and improve the Services as well as to develop new products and services. We disclose Consumer Data to Customers and to our hosting providers.
Customer Account Data We collect Customer Account Data from Customers and Users. We use Customer Account Data to authenticate Customers and Users, to grant access to the Services, to communicate with Customers and Users, and for analytics and marketing purposes. We disclose Customer Account Data to our hosting and communication providers.
Social Media Data We collection Social Media Data from you and from the companies that host our Social Media Pages. We use Social Media Data to communicate with you and for advertising purposes. We disclose Social Media Data to our customer relationship management and advertising providers.
Log Data We collect Log Data from you when you interact with the Services. We use Log Data for analytics purposes. We disclose Log Data to our analytics and hosting providers.
Cookies Data We Collect Cookie Data from you when you interact with the Services. We use Cookie Data for analytics and marketing purposes. We disclose Cookies Data to our analytics, advertising, and hosting providers.

California Privacy Rights

To the extent provided for by law and subject to applicable exceptions, California residents have the following privacy rights in relation to the Personal Information we collect:

  • The right to know what Personal Information we have collected and how we have used and disclosed that Personal Information;
  • The right to request deletion of your Personal Information;
  • The right to request the categories of Personal Information we disclosed to third parties for their direct marketing purposes in the year preceding the request, the names and addresses of such third parties, and, in certain circumstances, examples of the products or services marketed by such third parties;
  • The right to opt out of sales: we may sell Consumer Data to third parties. To opt out of those sales please click here;
  • The right to be free from discrimination relating to the exercise of these privacy rights.

Exercising Your Rights: California residents can exercise the above privacy rights by emailing privacy@windfalldata.com.

Verification: in order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your login credentials before you can submit a request to know or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information and proof of residency for verification. If we cannot verify your identity, we will not provide or delete your Personal Information.

Authorized Agents: you may submit a request to know or a request to delete your Personal Information through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity and submit proof of your residency with us.

  1. Our Policy Toward Children 

Our Services are not directed to persons under 18. We do not knowingly collect Personal Information from children under 18. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at support@windfalldata.com. If we become aware that a child under 18 has provided us with Personal Information, we will take steps to delete such information from our files.

  1. Contacting Us

If you have any questions about this Privacy Policy or need to access an alternative format of this Privacy Policy, please contact us at support@windfalldata.com.

  1. Changes to our Privacy Policy

This Privacy Policy may change from time to time. Windfall reserves the right to modify this Privacy Policy or its policies relating to the Services at any time, effective upon Windfall posting an updated version of this Privacy Policy on the Services, at which time we will update the “last updated” date below. Continued use of the Services after any such changes shall constitute your consent to such changes.

This Privacy Policy was last updated on January 1, 2020.

           

© 2020 Windfall Data, Inc.
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