Privacy & Security Policy
Summary
Privacy at Winmore Wares LLC
Winmore Wares LLC. (“Winmore Wares LLC” or “we” or “us”) is deeply committed to the relationship of trust we have with you, our customer. Accordingly, your privacy is important to us. When we do collect your personal information, our goal is to use it to make your experience with us better—wherever that experience takes place—be it a physical store, an event or online in the digital world. We also strive to be transparent about how we collect and use your personal information so you can make informed decisions and be in control of the information you share with us. For example, we do not sell your personal information to third parties and would never do so without your express permission. We are also committed to protecting the security of your personal information and in that regard we use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure.
Privacy Policy - Overview
In connection with the use of a specific website, application or other interactive service (“Services”) provided by Winmore Wares LLC, this privacy policy governs the personal information and other information of yours that we may collect and use. For example, as a Winmore Wares LLC customer, you may be asked for information like your name, address, email address or telephone number when making a purchase or creating an account with us. We collect and use this personal information as set forth in this privacy policy.
The remainder of this privacy policy will provide you with details on the personal information we may collect from you and how we use it. It also discusses the options that you may have for how we can use your personal information and your rights with respect to accessing your personal information and/or having your personal information deleted.
To make reading easier we sometimes use short terms that have longer definitions or meanings so we have included a separate Appendix to describe those in more detail. Also, supplemental notices may be added to this privacy policy from time to time. For example, if you provide us with personal information because you are interested in a job, we may change or supplement this privacy policy with more or different terms in a supplemental notice or separate policy to address employment related concerns.
Categories of Information We Collect
Personal information (or "PI") generally means information that personally identifies you, or that could reasonably be used to identify you. The categories of PI that we may collect from you include:
✔ Contact PI such as name, postal or email address, or phone number. For example, we'll ask for: an address if you create an account with us; a phone number to notify contest winners or to help authenticate you; your cell number if you sign up for SMS alerts; and other personal information to help us anticipate your shopping needs or to make suggestions.
✔ Registration & Account PI such as PI you provide, or that we otherwise collect, when open an account with us. Such PI includes things like your name, email, mailing or billing address, telephone number, order history, and birthday. You may also provide additional PI if you choose to personalize your account, for example, by adding items to a wish list.
✔ Transactional PI for all purchases & returns. This includes things like credit, debit or gift card data, mailing & email addresses, phone number, IP or device addresses or identifiers, and other related information such as receipts, confirmations, shipping, billing, adjustments, loyalty programs and so on. This PI can be about you or others (such as a gift recipient's data).
✔ Activity or Qualification PI includes supplying PI to meet an age or experience limit, or indicating your likes or dislikes by clicking a "thumbs up/down" type of icon. Please note that if one of your activities is posting PI in publicly available areas (with us or with others), that information becomes public. So please think before you post (because anyone may be able to see or copy it).
✔ PI you give us that we didn't request, such as PI that you voluntarily put into a message to us or that happens to be in a picture or video that you provide to us.
✔ Community PI, such as PI that you post in areas of our websites or applications, or in interactive areas or communities that we or others maintain, such as social media sites, when the information you post is accessible to other users or the public (for example, posting a product review or creating a tag).
✔ PI about others could include things like a picture you submit to us containing an image of a friend, or a friend’s contact information if you use a find a friend or refer a friend feature. Please don't submit PI about somebody else unless they've said okay and you've obtained their consent to this privacy policy (or unless you're otherwise authorized to provide their consent to it).
✔ Sensitive Data: This may consist of what you consider sensitive PI, such as financial related information, certain geo-location data or other stored information such as contacts, photos, and videos.
✔ Event PI such as a name badge or other attendance data. Event information varies with the event, but could include things like your hometown or emergency contact information.
✔ Promotional PI & Surveys. This is PI such as information relating to a survey or poll, contest, sweepstake, or other activity or promotion sponsored or presented by us alone or with others. This PI varies, but tends to include things like name, gender, email, postal code, birthday and mailing address (e.g., if a prize or catalog will be shipped).
Below are examples of types of PI we tend to collect from other sources or, indirectly, from you:
✔ PI from our previous records such as PI you gave us for one activity that we use for another (e.g., re-using data from one transaction to pre-populate fields in a subsequent transaction to decrease ordering hassle).
✔ PI we obtain from public or other sources, to the extent permitted by law, such as from phone books, websites, mobile applications, and other information that others may have about you.
✔ Indirect Transactional PI. When directly collecting "Transactional PI" we also indirectly collect information that is used for things such as fraud prevention or for authentication (e.g., time, date, store location, items purchased).
✔ Indirect PI. If you participate in an event or visit one of our retail locations, PI such as your image may be captured on surveillance cameras, which we use for safety, security and fraud prevention purposes. If you deal with us (or those who help us) over the phone or in a "live" meeting we may record the conversation for quality, training and record keeping purposes.
✔ PI we may lawfully obtain from commercial providers of information such as a data broker, ad network, marketing participant and so on.
✔ Social Media PI. If you create or log into a Winmore Wares LLC account using a social media platform, connect with us on social media, or use social media functionality that is imbedded into our Channels, the social media network usually shares some PI with us, in accordance with the social media network's privacy policy or other rules. You may be able to control the amount and type of PI that is shared by changing your privacy settings on the social media platform.
✔ Metadata. Digital items often have embedded data that you might or might not know about. For example, a digital picture might have a record of where and when you took it. Unless you remove such data, it would be an example of PI we may collect and use.
Cookies and Technology and the Information They Collect
When you visit one of our websites, such as winmorewaresllc.com, (this and any others we own or operate are referred to as a "Site") or interact with us at one of our stores or at an event (this and our Sites and our Apps are collectively referred as "Channels"), we may use different kind of technologies for multiple reasons, including to improve your shopping experience, for example by reducing the amount of information required at checkout or by otherwise personalizing your experience with us.
Here are some examples:
• Browsers: a "browser" is essentially an application (such as Chrome, Firefox or Safari) used to access and view websites by processing HTML, the code used to help you see text, links and other items.
• Cookies: "Cookies" are basically a small text file that we or others put on your access device so it can be used to help us serve you better by improving our website design, services, or promotions. They also recognize you (or your device) and may be used to deliver services or ads or otherwise collect some types of PI. There are several kinds of cookies, e.g., "session" cookies allow our Channels to collect information about what you do during a browsing session but are temporary and set to be deleted at the end of a session; "functional or persistent" cookies tend to last more than a session and are set to expire in a set number of days; and "performance" cookies are basically persistent cookies that collect data for managing performance and design issues. Some cookies operate with other technologies and there are more kinds of cookies. You may be able to set your browser to refuse cookies or to notify you before a cookie is set. If you choose to refuse cookies or other technologies (if they can be refused), some access to or functionalities of a Channel might not work properly or may be slower or unavailable.
• Tracking pixels or tags, web beacons, clear GIFs, API calls, SDKs, JavaScript and similar technologies are items that can function similarly to cookies or that otherwise assist tracking by collecting certain information about your interaction with our Channels (e.g., counting users who open an HTML-formatted email message, distinguishing visitors and counting pages they visit and authenticating them, etc.).
• Identifiers, including unique identifiers such as an IP address (basically, this is a number that is automatically assigned to a device such as a computer by your Internet Service Provider); a Media Access Control (or "MAC") address which basically is a hardware ID number that is part of a network card such as a Wi-Fi or Ethernet card and that identifies each device on a network, or other identifiers (e.g., Android ID, Apple IDFA, or other identifiers that might otherwise relate to you or devices you use, or identifiers that are used by ads, advertisers, networks, platforms or other third parties). The above is not necessarily a complete list and we will change and add Technologies and Channels from time to time. Technologies are complex and can differ per Channel. Also, certain kinds of Technologies are likely to be used in multiple Channels.
We may use these types of third party technologies to collect information and when we do we work closely with these third parties to protect your PI. Third parties may offer some options that may be helpful to restrict some kinds of tracking. If you would like more information about this practice and to know your choices for not having this information used by third-party service providers, please visit: www.networkadvertising.org/managing/opt_out.asp
Set forth below are some examples of information that might be PI that can be collected by technologies we use.
• Information such as browser type and version; access device type (e.g., phone, tablet, laptop or whatever); operating system; Internet Service Provider; IP address, MAC address and/or other unique device identifier(s); phone number; hardware/software types, authentication data, demographic data, search history, screen resolution, and other data that might create a unique "fingerprint" or the like of your device.
• Domain name from which you came or a page, link, ad, website or source that referred you; time and date stamps; how long you stay and whether you are a return visitor; where and what you do in our Channel, including what's in your shopping cart and details of items purchased; clickstream data and clicks on particular items such as an ad; other acts you take and pages you view; account holder activities
• General location data (e.g., country or postal code) or precise location data (e.g., an App of ours might ask if it's okay to collect exactly where you are).
• Other types of information such as: user history on use of Apps; social media check-ins or other types of log in information at stores and/or events; coupon information,
How we use your Personal Information
Set forth below are some non-exclusive illustrations of how we tend to or may make use of PI.
We may collect and use your PI to provide you products and services, notify you of product recalls or safety issues, process and respond to your application for current or future career opportunities, to respond to your comments or questions, determine your satisfaction with our programs and service, to personalize your experiences, if you ask us to, send you marketing communications and other information you have chosen to receive regarding our products, services, marketing or special events. We may also use push notification on our Apps. We also may use your PI for our everyday business purposes such as security, payment processing, analytics, operations, fraud detection and prevention, reporting, making back-ups and legal compliance. In addition, we may also use the personal information you provide:
• To pre-populate a form for you such as populating address information at check out.
• To deal with companies or celebrities or other third parties that participate with us in events, promotions, videos, and other activities.
• To deal with Third Party Services and other service providers, including data analytic providers such as Google Analytics. Third parties that we use, or even just third parties that you might reach via links from our Channels, may have their own privacy policies or separate terms & conditions.
• To receive and review a question or request from you.
• To deal with our current or future affiliates. This may include things like the transfer of personal information and other information from Winmore Wares LLC to one of its affiliates.
• To make common uses of it (i.e., uses that an ordinary reasonable person should expect or that are typically thought to be legally acceptable).
• To make extraordinary uses (e.g., in a merger or bankruptcy etc.).
• To respond to a domestic or foreign legal process (e.g., a governmental or non-governmental subpoena).
• To make secondary uses (e.g., collecting information for one reason but using it for another when such use appears useful or relevant to our business).
• To include you in relevant lists (like club or customer lists, newsletters, blogs, feeds, alerts or other communications).
• To deal with social networks. We and you will be subject to their applicable policies and rules, some of which may allow you to restrict some disclosures.
• To make and disclose Aggregate Data
• For other purposes that are not in this privacy policy but that are provided or otherwise indicated in connection with a particular collection.
How we share your Personal Information
Business Transactions. We may disclose PI to third parties in connection with a proposed or actual business transaction, such as a merger or acquisition, reorganization, sale of all or part of our stock or assets, spinoff, bankruptcy or dissolution. Our successors and assigns may use your PI for the purposes described in this privacy policy.
Service Providers. PI may be transferred to, or collected by, service providers (including affiliates acting in this capacity) for a variety of purposes such as credit card processing, shipping, authentication, email distribution, loyalty program management, market research, promotions management, call centers, information technology and data hosting or processing services.
Analytics Providers. An example is Google Analytics whose tracking cookies collect traffic data (e.g., data about where Site visitors come from, what they do, where they go, etc.). You may read Google's privacy policy at //www.google.com/policies/privacy/. It includes Google's instructions on how to block some cookies associated with Google services.
Advertising Networks. We may use a variety of third party advertising networks, traffic measurement service providers, marketing analytics service providers and other third parties to, for example, facilitate targeting of advertisements and/or measure and analyze advertising effectiveness and/or traffic on our Sites. Some of these third party service providers participate in the Network Advertising Initiative's Opt-Out Tool (//www.networkadvertising.org/choices/) and/or the Self-Regulatory Program for Online Behavior Advertising (//www.aboutads.info/choices/). You can learn more about these tools by clicking on the referenced links. Please note the following with respect to opting out:
• The opt-out tools discussed above are "cookie based." This means that the tools rely on cookies to remember your choices with respect to the use of your information by the parties that offer you those choices. If you delete tracking technologies using the controls in your Web browser after opting out, you may have to opt out again to re-establish your opt-out preferences.
• Opt-outs are "browser-specific." The opt-out preferences that you choose will apply only to the Web browser that you used when you selected these preferences. This means, for example, that if you opt-out while using Internet Explorer this choice will not affect the use of information collected by tracking technologies when you use Mozilla Firefox on the same Device. It also means that opting-out on one device will not affect the use of information by tracking technologies on other devices that you may use to access out Site.
Other. We may disclose PI as necessary to exercise, enforce or preserve our rights, to meet legal, regulatory, self-regulatory and insurance requirements, for security, fraud prevention, authentication and verification purposes, and to respond to a domestic or foreign legal processes (e.g., a governmental or non-governmental subpoena or a warrant or production order). We may also disclose PI for other purposes with your consent or as permitted or required by law, including foreign laws applicable to us, our affiliates and service providers.
How we Protect your Personal Information
The file containing your PI will be maintained on our servers (or those of our affiliates or service providers) and will be accessible to our authorized employees, representatives and agents who require access in connection with their job responsibilities. We use physical, electronic, and procedural safeguards to protect your PI from unauthorized access, use or disclosure. We use what we believe are commercially reasonable security measures to protect your PI that we possess or control. You also have a role in security, for example you are in charge of the security of any applicable password for a Channel and you control the access device you use (some of which devices can be insecure). An unfortunate reality of our digital age is that security measures are seldom infallible, accidents happen and individuals (including, but not limited to, employees, or service providers) might fail to follow policies or contracts.
Phishing attacks attempt to steal consumers' personal information and financial account credentials. "Phishers" use 'spoofed' e-mails to lead consumers to counterfeit websites designed to trick recipients into divulging Information such as credit card numbers, account usernames, passwords and social insurance numbers. WE DO NOT SEND EMAILS ASKING YOU TO PROVIDE OR CONFIRM CREDIT CARD NUMBERS, SOCIAL INSURANCE NUMBERS OR YOUR USERNAME OR PASSWORD! If you receive such email communication, please forward it immediately to us at winmorewaresllc.com with the subject of "Privacy/Identify Theft", and take appropriate actions to review the security of your computer or other device.
Links to Other Websites and Services
Our Site, Apps or other Channels might link or have functionalities that lead to third parties. We provide linked sites to you solely as a convenience, and the inclusion of linked sites does not imply endorsement by us of the linked sites. Once you access the third party locations, you are subject to any privacy policies of those third parties.
Your Opt-out/Opt-in Options
Options Offered By Us. You have the option to opt-in or opt-out to marketing emails and text messages. Many of the ways are straightforward. For example, if we ask you to participate in a survey and you participate we may ask that you provide PI. If you don't want to provide any PI then one option you have is to not participate in the survey. Similarly, if you use a social media network to share your favorite finds from Winmore Wares LLC you may exchange PI with us. Once you provide PI or use such technologies such as a "like/dislike" button the data may be disclosed or used by us. Again, one option you have is to not utilize social media in this way if you have concerns about sharing your PI.
Even if you opt-out (or do not opt-in), you will still receive other communications from us such as transactional emails and messages related to your questions, orders, updates about products or services you purchased and information about your account. You will also continue to receive communications relating to particular things you signed up for such as for a contest or at an event.
Options Offered By Others; Third Parties on Our or Other Websites. Some browsers, devices, distribution platforms, or applications help you refuse to accept some technologies or allow you to create some privacy settings (for example, establishing a "Do Not Track" (DNT) signal to third parties; or being able to say yes or no to the collection of certain data). These technologies may or may not be successful. For example in the case of browsers, not all technologies are controlled by browsers; unique aspects of your browser or device might be recognizable even if you disable a technology; not all settings will necessarily last or be honored; and even if a setting is honored for one purpose data still may be collected for another. Also, you can control tools on your mobile devices. For example, you can turn off the GPS locator or push notifications on your phone. To modify the push notifications you get from our Apps, you can alter your preferences in your profile.
For all options, opting-out does not apply to PI that was disclosed before opting-out or to disclosures to which opting-out is not allowed by law, this privacy policy, a supplemental notice, our other terms and conditions or any other relevant arrangement we have with you (e.g., terms of a contest). If you opt-out and then do so something inconsistent with that opt-out (e.g., again use a Channel that collects the "opted-out" PI), we will assume you have changed your mind and may rely once again on all of your previous consents (subject to applicable law) or any new consents relating to your new actions.
As referenced earlier, we may use a variety of third party advertising networks, traffic measurement service providers, marketing analytics service providers and other third parties to, for example, facilitate targeting of advertisements and/or measure and analyze advertising effectiveness and/or traffic on our Sites. Some of these third party service providers participate in the Network Advertising Initiative's Opt-Out Tool (//www.networkadvertising.org/choices/) and/or the Self-Regulatory Program for Online Behavior Advertising (//www.aboutads.info/choices/). You can learn more about these tools by clicking on the referenced links. Please note the following with respect to opting out:
• The opt-out tools discussed above are "cookie based." This means that the tools rely on cookies to remember your choices with respect to the use of your information by the parties that offer you those choices. If you delete tracking technologies using the controls in your Web browser after opting out, you may have to opt out again to re-establish your opt-out preferences.
• Opt-outs are "browser-specific." The opt-out preferences that you choose will apply only to the Web browser that you used when you selected these preferences. This means, for example, that if you opt-out while using Internet Explorer, this choice will not affect the use of information collected by tracking technologies when you us Mozilla Firefox on the same Device. It also means that opting-out on one device will not affect the use of information by tracking technologies on other devices that you may use to access our Site.
California Do Not Track Disclosure and Direct Marketing Information Disclosure/California Shine the Light Law
Unless legally required, we do not commit to honoring "Do Not Track" signals in your browser because honoring it would prevent much of the tracking and disclosures described in this privacy policy. Even if we were to decide to honor such a signal, we would not make any commitment that our efforts would be successful. Getting a DNT signal actually to work as you might want can be very difficult for the kinds of reasons that we listed above in "Your Opt-Out/Opt-In Options".
California Civil Code Section 1798.83 permits you to request and obtain from us, once a year, free of charge, a list of the third parties to whom we disclosed your personal information (if any) and as defined under that statute for direct marketing purposes in the preceding calendar year and the categories of that kind of personal information that was disclosed to them. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to contact@winmorewaresllc.com
Children's Privacy
The Services are not directed to or intended for use by minors. Consistent with the requirements of applicable law, if we learn that we have received any information directly from a minor without his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the minor that he or she cannot use the Services and subsequently will delete that information.
California Minors
While the Service is not intended for anyone under the age of 18, if you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at: contact@winmorewaresllc.com. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the Content or information. Removal of your content or information from the Service does not ensure complete or comprehensive removal of that content or information from our systems or the systems of our service providers. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.
What about Identity Theft
If you believe you are a victim of identity theft, we want to assist you. You may be entitled by law to request certain information from us. You can do this by writing us at Our Privacy Policy Address. If we receive a request, we will then explain what information we need from you in order to respond. Once we have all of the required information, we will supply, without charge, any information that we legally able to provide to you (subject to applicable law, and reserving all rights and defenses).
We Store Information in the United States
If you live outside of the United States, you understand and agree that we may transfer your information to the United States. Our Sites are subject to United States laws and United States laws may not afford the same level of protection as those in your home country. If you are located in the European Economic Area and you contact us, information you provide is transferred to the United States.
What about Amendments
We may amend this privacy policy from time to time. When the privacy policy changes, we will post the substitute version and change the effective date listed at the beginning of privacy policy. Subject to applicable law, amendments will apply to PI that we already have and to PI obtained after amendment.
California Consumer Privacy Act
We process your personal information in accordance with the California Consumer Privacy Act (“CCPA”). The CCPA became effective on January 1, 2020 and creates a variety of privacy rights for California consumers. While Winmore Wares LLC is using this CCPA section of our privacy policy to make disclosures required by the CCPA, we share this information with, and provide the same privacy rights to, all of our United States customers.
Transparency
You have the right to know what kinds of personal information we collect and our business purposes for that collection. We make this information available to you in the “Categories of Information We Collect” section of the privacy policy. You also have the right to know how personal information is obtained, how it is used, and our business purposes for that use. We make this information available to you in the “How We Use Your Personal Information” section of the privacy policy.
You have the right to know if your personal information is shared with any third parties. We may share personal information have our service providers perform services by written contract. In addition, we may share personal information with third parties for other notified purposes, as permitted by the CCPA. For example, we share your personal data with your consent or to complete any transaction or provide any product you have requested or authorized. For more information on how we share your personal information, refer to the “How We Share Your Personal Information” section of the privacy policy.
You have the right to know whether your personal information is being sold. Your personal information is sold when it is shared with a third party for monetary or other valuable consideration for a purpose that is not a “business purpose” as set forth in the CCPA. Winmore Wares LLC does not sell your personal information.
Right to Access; Right to Delete and Information Regarding Personal Information
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
• The categories of personal information we collected about you;
• The categories of sources for the personal information we collected about you;
• Our business or commercial purpose for collecting that personal information;
• The categories of third parties with whom we share that personal information; and
• The specific pieces of personal information we collected about you.
You have the right to request that we delete any of your personal information that we collected from you and retained. Once we receive and confirm your verifiable consumer request (discussed more below), we will delete your personal information from our records, unless we need the personal information to:
• Provide a good or service requested by you;
• Provide a good or service reasonably anticipated within the context of our ongoing business relationship with you;
• Detect security incidents or malicious or illegal activity;
• Debug or repair existing intended functionality;
• Exercise, or allow you to exercise, free speech or another legal right:
• Enable internal uses that are reasonably aligned with your expectations based on your business relationship with us;
• Engage in certain scientific research;
• Comply with a legal obligation; or
• Use the personal information internally in a lawful manner compatible with the context in which you provided the personal information to us.
Requests to Exercise Your Rights
You may request to exercise the foregoing rights by submitting a request to us by emailing us at:
contact@winmorewaresllc.com
Once a request is received, your identity will need to be verified. To accomplish this please provide the email address and phone # you have previously used when interacting with Winmore Wares LLC. This information will be used to verify your identity and process your request. Winmore Wares LLC will confirm request received by email to the account provided.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), then we will inform you of the reason and extension period in writing. We will deliver our written response electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. We will select a format to provide your personal information that is readily useable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination and Financial Incentives
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
The CCPA permits businesses to provide differing levels or quality or different prices where the business can demonstrate that the difference is reasonably related to the value to the business of the consumer’s personal information.
The CCPA allows businesses to offer consumers financial incentives for sharing personal information. For example, a business can offer a rewards program or provide a premium service to consumers as compensation for their personal information. Where Winmore Wares LLC offers such programs your participation is optional, your participation is subject to any applicable terms, and you may withdraw at any time.
Right to “Opt-Out” of “Sale”
Winmore Wares LLC does not sell your personal information. Accordingly, we do not offer a right to opt out.
For general information about the options offered by us to opt-in or opt-out to marketing emails and text messages, please see the “Your Opt-Out/Opt-In Options” section of the privacy policy.
Appendix
"Aggregate Data" means information that we reasonably believe has been "de-identified" or "anonymized" such that (a) it is not PI, (b) it was PI but no longer is, or (c) it reasonably would only be viewed as PI by use of special knowledge or resources that we and others ordinarily don't have in the ordinary course of their business.
"Common Uses" Another way to describe common uses of PI is to think of uses that should be apparent or relevant in context, i.e., given the circumstances, for what purposes might a business like Winmore Wares LLC collect, use and otherwise disclose PI from time to time? For example, we make disclosures:
To meet our obligations and enforce our rights, to make disclosures to third parties who help us (e.g., service providers, information technology providers, mailing and other business process providers, outsourcing providers and so on), and to operate and improve our business;
For security, fraud prevention, authentication, verification purposes and so on, including (without limitation) searching public records or publicly available information (such as information on the Internet) and participating in industry or private initiatives (such as sharing data to help decrease fraud);
To communicate with you, such as responding to questions or requests or contacting you for lawful purposes, including surveys;
To vendors and their service providers needing data to do their jobs;
To deal with an activity or a contract, or to obtain additional PI from you or others. For example:
If we collect payment card information we will disclose it to third parties throughout the processing system (e.g., banks, networks, card organizations etc.) and to protect ourselves or others, including to law enforcement; and ⁃ We might try to follow up with you such as to help determine who you are or your authority, including doing things like checking records of ours or others, keeping copies, and making disclosures in disputes like, lawsuits or investigations.
To persons appearing to have a lawful interest in the PI (e.g., an insurance company dealing with a claim involving you);
To comply with applicable law, including keeping records for as long as required or that we believe is advisable;
For the kinds of purposes appearing in laws or regulations as exceptions to any privacy rights you may have or to your ability to "opt-out" of disclosures, even if those exceptions do not actually apply to us. An example is the Federal Trade Commission's regulation implementing privacy rules for financial institutions. It lists many typical reasons that those institutions may make disclosures or not offer an "opt-out" choice and you can see them at 16 C.F.R. § 313.14 and § 313.15;
To exercise or preserve our legal rights, such as to attempt to protect or prevent harm (including economic harm) to us, our interests, property (of every nature, including intangible property rights) and business. Without undertaking any duty to do so, we may do the same for someone else such as any third party, including our affiliates or you; and
To make additional disclosures that are consistent with the context or relationship of our transactions with you (or your principal) or that are required or allowed by law, regulation or other relevant guidance.
"Extraordinary Uses" We may disclose PI in out-of-the-ordinary circumstances or emergencies, subject to applicable law. There is no clear line between ordinary and extraordinary purposes, but here are some examples of what we view as more in the nature of extraordinary:
We may disclose PI to third parties with whom we might explore or engage in an extraordinary transaction, such as (without limitation) mergers or acquisitions, reorganizations, sales of all or part of our stock or assets, spinoffs, bankruptcies, dissolutions or anything else. We reserve the right to continue to use and disclose for our own purposes, all PI that we had before we engaged in such a transaction until it is clear that there is no longer a business or legal reason to do so; and
We might hold PI until you or a related person cure a violation of obligations to us (e.g., if you are involved in a breach of a contract relating to us).
"Legal Process" By "legal process" we mean things that we might have to do to comply with laws or what appears to be a law in the United States and other countries that that have or claim to have jurisdiction over us or information that we own, possess or control. Most countries have laws that allow governments or non-governments, including private persons in litigation, to use laws allowing them to obtain information. Examples include things like subpoenas (private, grand jury or other), warrants, identity theft requests, requests for information about an anonymous speaker, investigative demands (from law enforcement, regulators or others), national or international security letters or demands or the like, and so on. We may be required to comply and we reserve the right voluntarily to comply or cooperate with the requesting party, such as if we think that may help protect someone (including you, us or others) or some property (of ours, yours, or others). We also reserve the right to object to the legal process or to tell you about it so that you can object and obtain an appropriate order permitting us not to comply with the original request.
Sometimes the law will preclude us from telling you about the legal process. In other circumstances we might be allowed to tell you but it might not be practical or advisable to do so. We will determine in our sole discretion whether to contact you (e.g., we might contact you to so that you can object as noted above, or we might not make contact if there is concern that such might facilitate potential harm). You agree that we may do any or all of the above.
"Personal Information," "personal information" or "PI" means information we're required by law to protect and: (a) that personally identifies you, or (b) that does not personally identify you but reasonably may be used to identify you or your computer or other device that you use (e.g., mobile phone, tablet, or other consumer or electronic product or device) and a law requires us to treat it as personally identifying you. PI does not include Aggregate Data or information that is publicly available, including in our Channels (e.g., if you include PI in a comment posted in a publicly accessible area of a Channel, that PI will become public information upon its posting and will cease to be PI). If you are a resident of California, “personal information” has the meaning set forth in the CCPA.
"Third Party Services" We use third party systems and services for a variety of purposes. Many of those types of third parties are mentioned in other explanations in this privacy policy and do things like managing credit card processing, shipping, authentication, email distribution, market research and promotions management and many other things. The third parties may have their own terms & conditions and privacy policies that may apply to you and that can include their sharing of data with other third parties (e.g., members of an ad network). Laws and contracts can regulate some of that sharing depending upon data type, e.g., the third party who does our credit card processing is not free to share that data other than for processing. Here are some examples of Third Party Services that we use (although this may change from time to time):
We use analytics providers. An example is Google Analytics whose tracking cookies collect traffic data (e.g., data about where Site visitors come from, what they do, where they go, etc.). According to the Google Analytics Terms of Service, Google does not want us to supply PI and we do not intend to do so. However, we do not make or control Google's technologies and information it already has or might obtain. Just in case data we send is or becomes PI, you should look at Google's privacy policy at //www.google.com/policies/privacy/. It includes Google's instructions on how to block some cookies associated with Google services.
"Social Networks" We use social networks websites, applications and services in various Channels such as "social plug-ins," "widgets" or other technologies that do various things (e.g. allow you to log-in via social media credentials or to express your "likes/dislikes" or "pin" something). When we use or you interact with social network technologies, we will receive (and you will allow) disclosures contemplated by the social network's privacy policy or other rules, including the network's "developer rules" (which are rules allowing us to use the social technology). Here are a few examples of social networks we use and links to some of their policies or rules:
Facebook (e.g., //www.facebook.com/full_data_use_policy & //www.facebook.com/help/www/443483272359009 & //developers.facebook.com/policy)
Twitter (e.g., https://twitter.com/en/privacy)
YouTube (e.g., //www.google.com/intl/en/policies/privacy/ & //www.youtube.com/t/terms)
Instagram (e.g., https://help.instagram.com/402411646841720)
Pinterest (e.g., https://policy.pinterest.com/en/privacy-policy)
SnapChat (e.g., https://snap.com/en-US/privacy/privacy-policy)
We would recommend that you not use social network technologies if you are not comfortable with their policies and rules.
Last Updated: January 20th, 2024
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