PRIVACY POLICY

WinnCompanies (“we” or “us”) and its affiliates are committed to protecting and preserving your privacy. This policy, together with our Terms of Use , and any other underlying agreements or terms, sets out the basis on which any data we collect from you, or that you provide to us, will be processed by us. By using our website (“Site”), you are accepting the practices described in this Privacy Policy. This Privacy Policy also describes the manner in which we process, use and disclose information that you provide to us when you use our Site.

By using this Site and providing your personal information to us through the Site, you consent to the use of the information that you provide to us in accordance with this Privacy Policy. We do update this Privacy Policy from time to time so please review this Privacy Policy regularly. If we materially alter our Privacy Policy, we will let you know of such changes by posting a notice on our Site and/or contacting you at the e-mail address provided to us. Your continued use of the Site will be considered your agreement that your information may be used in accordance with the new policy. If you do not agree with the changes, then you should stop using the Site, and you should notify us that you do not want your information used in accordance with the changes.

What Information We Collect

In operating our Site, we may collect and process the following data about you:

Details of Your Visits and Use of Our Site. We may collect details of your visits to our Site and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data, including your IP address, timing, and content of what you viewed. Some parts of our Site use cookies and other tracking technologies to collect this information about your general internet usage and provide you with targeted advertising. See section below ‘How We Use Cookies and Other Tracking Technologies” to learn more.

Information You Provide Directly to Us.

We may collect information that you voluntarily provide to us. The information we may collect includes, but is not limited to, your name, address, email address, telephone number, and other contact information.

You may also voluntarily provide information to us if you submit a job application through our Site, including your name, address, telephone number, resume, and background check information.

We may also collect information automatically from our users such as country, region/state, city, metro code/zip code, organization, IP address, geolocation and ISP based on the user’s geolocation.

By submitting a telephone number or other contact information to WinnCompanies, you agree that WinnCompanies, and/or a representative acting on its behalf, can contact you at the telephone number you provide, potentially using automated technology (including texts/SMS messaging) or a pre-recorded message. Your consent is not an obligation to receive our products and/or services.

How We Use and Disclose Your Information

The information that we collect and store relating to you is primarily used to enable us to provide our products and/or services to you in the best possible manner. In addition, we may use the information for the following purposes:

To provide you with information relating to our services and/or products;
To fulfill or meet the reason you supplied the information to us;
To send marketing communications (e.g., through email or text).
To fulfill a legal requirement or respond to law enforcement requests, or as otherwise required by applicable law, court order or governmental regulations;
To identify potential fraud or illegal activities.
To third party service providers to facilitate our services to you (e.g., payment processing, order fulfilment, customer service, auditing, and/or other administrative services).
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site users is among the assets transferred.
To any affiliated business entities

We may anonymize personal information or aggregate it so that it will no longer be considered personal information, which we may use and disclose for any purpose in accordance with applicable law(s), as the anonymized and/or aggregated data no longer contains identifiable information about you.

We will not use your personal information for purposes other than as expressly stated herein or as otherwise allowed by applicable law. We will not use personal information we collected for materially different, unrelated, or incompatible purposes without providing you with notice and/or updating this Privacy Policy.

Where we disclose personal information for a purpose set forth herein, we may enter into a contract with the third party that describes the purpose and requires the third-party recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

How Long Do We Keep Your Personal Information
We keep personal information for as long as it is needed based on the purpose(s) for which it was collected within the bounds of the applicable law(s) and regulation(s). We may keep your personal information for as long as you have a registered account on our Site. It may also be necessary for us to keep your information due to a legal obligation.

How We Use Cookies and Other Tracking Technologies.

Cookies are small text files placed on your device when you visit our Site. Our Site uses cookies and other tracking technologies to enhance your experience, analyze the Site’s functionality and performance, and provide personalized advertising related to your interests, such as recommendations and special offers. By continuing to browse the Site, you are agreeing to our use of cookies and other tracking technologies, which may include data exchange and/or disclosure with third parties.

We use the following types of cookies and trackers:

Strictly necessary cookies. These are cookies that are needed for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site.
Analytical/performance cookies. These are cookies that allow us to recognize and count the number of visitors to our Site and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are cookies used to recognize you when you return to our Site. This enables us to personalize our content for you and remember your preferences.
Targeting and advertising cookies. These cookies record your visits to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Third Party Service Providers.

The Site works with third-party products and/or services (“Service Providers”) to offer and present our Site to you. These Service Providers may include, but are not limited to, Google, and other Service Providers who help us track and analyze our Site user activity, measure the effectiveness of our advertising efforts, and support the optimization of our digital marketing campaigns and carry out targeted advertising campaigns.

Our Service Providers may get more information about your activity on our Site, including pages you visit, access times, visit duration, how you arrived at our Site and your IP address. An IP address is a number that identifies a device connected to the internet. For most devices, the IP address changes on at least a weekly basis. Our Service Providers may also get device identifiers and specific information about the browser you use. In some cases, this information may be unique to you. We may share and/or sell your information collected from you on the Site with third party vendors, advertising companies, or analytics providers including, but not limited to, Google. The Site also participates in targeted advertising wherein it contracts with Service Providers to collect certain information when you visit the Site to provide measurement services to the Site and target ads to Site users, such as Google Ads. These companies use information collected from the Site (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over, hardware or software information, cookie and session ID) and personal information (e.g., IP address) during your visits to this Site and other websites in order to tailor advertisements about goods and services to you. These Service Providers typically use a cookie, third party web beacon, or other similar tracking technologies to collect this information. The Site also works with third parties that collect information across various channels including, but not limited to, computers, mobile devices, and other connected devices, over time, for advertising, analytics, attribution, and reporting purposes. Your data may be transferred outside the country from which it was originally collected. Our Site provides you with the option to opt out of targeted advertising via its cookie preferences. To learn more about this type of advertising or to opt-out of this type of advertising, click here.

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational website here.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

How do you change your cookie settings?

Most internet browsers accept cookies by default, but you can change your browser preferences to block or restrict cookies if you do not want your web browsing activity tracked. Please note that some cookies are necessary for our Site to run and, as such, cannot be declined. If you choose, you may use the Digital Advertising Alliance (DAA) WebChoices Tool here to globally opt out of third-party tracking via website cookies. There are also a variety of other tools publicly available to manage cookies and similar technologies that collect information related to your use of our Site. To learn more about cookies and modifying your browser settings related to these cookies you can review guidance from the Federal Trade Commission here.

We are not responsible for the effectiveness or compliance of third-party opt-out mechanisms or programs. Please note that if you remove your cookies or upgrade your browser after having opted out, you will need to opt out again. Your opt out is specific to the browser you are using and the device you use to access the Site. Therefore, if you use multiple browsers or devices you will need to opt out on each browser or device. You can access the information on our Site without enabling cookies in your browser, but disabling cookies may result in a diminished ability to take advantage of the services and related informational content on our Site.

Opt-Out Signals

We will comply with opt out preference signals (OOPS) that inform us that you don’t want your personal information to be sold or used for targeted advertising, if the signal is sent from a platform or mechanism, such as Global Privacy Control, that enables us to accurately determine whether you are a resident of a state with an applicable privacy law regarding OOPS. You can learn how to enable Global Privacy Control here.

If your OOPS conflicts with your previously given privacy choice we will still comply with the opt out preference signal. We may notify you of the conflicting signals and ask you to confirm your choice with the understanding that it will affect your previously given privacy choice.

Third Party Websites and Hyperlinks

By accessing third party websites through our Site, you are consenting to the terms and privacy policies of those websites. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

Security

To secure your information, we have put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the information we collect on our Site. Nonetheless, the transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically, and the transmission of such data is therefore entirely at your own risk.

Users Only of Legal Age of Majority

Our Site is designed and intended only for those who have reached the legal age of majority (18 years of age). By using this Site, you affirm that you are at least 18 years of age or older. We are not liable for any damages that may result from any user’s misrepresentation of age.

No one under the age of 13 is authorized to use our Site or share any information with us, including personal information. Under no circumstances may anyone under age 13 use the Site. Parents or legal guardians of children under 13 cannot agree to these terms on their behalf.

Opt-Out of Marketing Emails and/or SMS Text Messaging

You may opt out of receiving marketing-related emails from us by following the instructions in any marketing or promotional email you receive (e.g., clicking on the ‘unsubscribe’ button in the footer of the email). As applicable, if you no longer want to receive marketing SMS/text messages from us, you may opt out by replying to the SMS/text message with “STOP”.

WinnCompanies does not share your information with third parties for marketing or promotion purposes; your opting-in to receive text messages from WinnCompanies does not equal consent to share your data with third parties for those third parties’ own marketing or promotional purposes.

Consumer Privacy Rights under U.S. State-Specific Laws

If you are a resident of certain states, you may have the following rights under applicable consumer privacy rights laws, and/or any other applicable state consumer privacy rights laws promulgated or amended from time to time. Such rights may include the right:

to know what categories of personal information we have collected and used, including how the personal information was collected;
to know what categories of personal information are being sold or disclosed, and if it is being sold or disclosed to third parties, as well as a list of categories of information that are sold or disclosed;
to opt out of the sale and/or sharing of your personal information for targeted advertising purposes;
to access your personal information, including the right to download or transfer your information;

to correct your personal information;

to the extent we collect any such information, to ask that we limit our use of your sensitive personal information;
to request that we delete your personal information;
to appeal any decision regarding your privacy requests;
to request a copy of your data in an electronic and portable format;
to equal service and equal price for goods or services even if you exercise your rights under applicable law(s).

You may make these requests by calling us at 888-598-2710, emailing us at winninfosec@winnco.com, mailing a request to WinnCompanies, One Washington Mall

Suite 500, Boston, Massachusetts 02108 or by clicking here.

For all written requests, it is helpful to put the statement “Consumer Privacy Rights” in the body of your request, describe the nature of your request, and supply your name, street address, city, state, and zip code. In your request, you need to attest to the fact that you are a resident in the state in which you provided an address and provide a current address for our response. We will honor requests received to the extent required by applicable law and within the time provided by the applicable law. If you would like to use an authorized agent registered with the Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests on your behalf.

To appeal a decision made by us related to your rights, please email us at winninfosec@winnco.com with the subject line of “Appeal Request” and a detailed explanation as to why you are appealing our decision. Once received, a representative will review the request and respond to you within 30 calendar days.

We will not discriminate or retaliate against you if you exercise your rights under applicable law(s) related to your personal information that produce legal or similarly significant effects. Specifically, unless allowed by applicable law, 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.

Generally, we will provide a response to a verifiable consumer request within forty-five (45) days of its receipt (or other time period as required by applicable law). If we require more time (up to an additional 45 days, or other time period as set forth in applicable law), we will inform you of the reason and extension period in writing. Any disclosures we provide will only include information that exists within our current records. The response we provide will also explain the reason(s) we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. For more information on your rights under applicable consumer privacy rights laws, click here.

Pursuant to applicable laws, you may request to opt-out of the sale and/or sharing of your personal information for cross-context behavioral advertising and/or targeted advertising, by clicking here.

California Shine the Light Law

California law permits residents of California to request notice of how their personal information is shared with third parties for direct marketing purposes. If you are a California resident and would like a copy of this notice, please submit a written request to the contact address in the “Contact Us” section below.

Accessibility Statement

We are committed to making sure that our Site is accessible to everyone. To access this Privacy Policy in an alternative form, please call 1-888-598-2710 or email us at winninfosec@winnco.com. For more information, please see our Accessibility Statement here.

Questions or Complaints About Your Data or this Privacy Policy?

We understand data privacy is important. If you still have questions or complaints after reviewing our Privacy Policy, please reach out to winninfosec@winnco.com, call us at 888-598-2710 and we will be happy to look into any questions, concerns or complaints that you have regarding your data privacy rights, or this Site's Privacy Policy.

Our Contact Information

WinnCompanies

One Washington Mall

Suite 500

Boston, Massachusetts 02108

winninfosec@winnco.com

617-742-4500 or 888-598-2710

Effective Date: July 2025