PRIVACY POLICY
WinnCompanies (“we”) and its affiliates are committed to protecting and preserving your privacy. This policy, together with our Terms of Use and Conditions, 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, 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 notify you 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 deemed 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.

Website Privacy Notice
Please read this Policy carefully to fully understand how we collect, share and protect information about you. This Policy is incorporated into and is a part of the Terms of Use and Conditions for this Site. To access the Terms of Use and Conditions click here.

By accessing and using the Site, you agree that you have read and understand this Privacy Policy and that you accept and consent to the privacy practices and uses and disclosures of your information as described herein.

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

  1. 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, the date and time you accessed or left the Site and which pages you viewed. Some parts of our Site use cookies and other technologies to collect this information about your general internet usage. See section below ‘How We Use Cookies” to learn more.
  2. Information that you provide directly to us, such as when you contact us directly through the Site, including your name, email address, and the content of your message.
  3. Information that you provide to us if you submit a job application through our Site, such as name, address, telephone number, resume, and background check information.
  4. Information that we collect 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.
  5. Information provided to us when you communicate with us for any reason.


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

How We Use Cookies
A “cookie” is a piece of text which asks permission to be placed on your device’s hard drive. Once you agree, this cookie file is stored on the hard drive of your device. They help us and our affiliates to improve our Site. They present the content from our Site in the most effective manner for you and your device.

All devices have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. You can also visit https://www.aboutcookies.org for more information on how to manage and remove cookies across a number of different internet browsers. It is important to note that if you change your settings and block certain cookies, you will not be able to take full advantage of some features of our Site, and we might not be able to provide some features you have previously chosen to use.

Further, some internet browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked across time or across websites. If you are a California resident, you have the right to opt-out of this online tracking. For more details, see section below, “California Privacy Rights.”

We do not use flash cookies on our Site.

This Site uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on Site activity for Site operators and providing other services relating to Site activity and internet usage. Google may use the data collected to contextualize and personalize the ads of its own advertising network. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this Site. By using this Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Please review Google's privacy policy here.
 

You can 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.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.


Third parties may use pixels, cookies, web beacons, and other storage technologies to collect or receive information from our Site and to use that information to provide measurement services and target ads. If you wish to opt-out of this online tracking, please visit the Digital Advertising Alliance’s website available at http://www.aboutads.info/choices/  or https://www.youronlinechoices.com/  or the Network Advertising Initiative’s website available at http://www.optout.networkadvertising.org for more information.

Cookie data may also be used by our marketing partners to enhance the advertising experience on our Site or other websites across the internet.

However, while some websites allow users to decline cookies, some of our third-party service providers who provide data analytics services through our site, do not necessarily respond to do-not-track requests. These third-party service providers do use cookies or pixels to collect standard internet log information and website user behavior information. The information generated by the cookie or pixel about your use of our Site (including your IP address and geo-location) is transmitted to these service providers. This information is then used by the service providers to evaluate our users’ use of our Site and to compile statistical reports on Site activity for us. Please note that we have not control over these third-party service providers’ cookie use.

Use of 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:

  1. To provide you with information relating to our services and/or products;
  2. To fulfill or meet the reason you provided the information;
  3. To provide third parties with statistical information about the users of our Site;
  4. To monitor and conduct an analysis of our Site traffic and usage patterns;
  5. For geomarketing and geotargeting based on a user’s location;
  6. To respond to law enforcement requests and as required by applicable law, court order or governmental regulations;
  7. To analyze trends;
  8. 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.

We may also use your information for targeted advertising. This means that WinnCompanies may display interest-based advertising using information you make available to us when you interact with our Site, content, or services and/or products. Interest-based ads, also sometimes referred to as personalized or targeted ads, are displayed to you based on information from activities such as purchasing on our Site or visiting certain parts of our Site. Advertisers or ad companies working on our behalf sometimes use technology to serve the ads that appear on our Site directly to your browser. Those third parties automatically receive your IP address when this happens. They may also use cookies to measure the effectiveness of their ads and to personalize ad content. We do not have access to or control over cookies or other features that advertisers and third-party web sites may use, and the information practices of these advertisers and third-party web sites are not covered by our Privacy Policy.


We will not use your information to target, segment, or profile individuals based on health (including pregnancy), negative financial status or condition, political affiliation or beliefs, racial or ethnic origin, religious or philosophical affiliation or beliefs, sex life or sexual orientation, trade union membership, data relating to alleged or actual commission of a crime, or for any unlawful or discriminatory purpose or in a manner that would be inconsistent with your reasonable expectation of privacy.

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.

Security
To secure your information, we have put in place commercially suitable 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 on our Site, and transmission of such data is therefore entirely at your own risk.

Disclosing Your Information
Where applicable, we may disclose your personal information to any affiliated business entities or third parties necessary to provide products and/or services to you. This includes, where applicable, our subsidiaries, our holding company and its other subsidiaries (if any), as well as third parties involved in the administration and operation of our products and/or services, and/or third parties involved in our employment application processes and/or other employment-related purposes. We may also disclose your personal information to other third parties, such as:

  1. Where we sell any or all of our business and/or our assets to a third party, whether through bankruptcy proceedings or other sale or merger.
  2. Where we are legally required to disclose your information, including, but not limited to, pursuant to a valid subpoena, order, search warrant or other law enforcement request.
  3. When we are contractually obligated to disclose it.

Where we disclose personal information for a purpose set forth herein, we enter 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.

We do not sell your personal information to third parties. However, under California law, the disclosure of your personal information to Google and other third party advertising partners may be considered a sale. For more information on this, and your opt-out rights related to the same see section below, “California Privacy Rights.”


Third Party Websites
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.

Users Only of Legal Age of Majority
Our Site is designed and intended for those who have reached the age of majority (18 years of age). By using our 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 a user’s misrepresentation of age.

No one under age 13 is authorized to submit or post any information, including personally identifying information, on our Site. Under no circumstances may anyone under age 13 use our Site. Parents or legal guardians of children under 13 cannot agree to these Terms on their behalf.

CALIFORNIA PRIVACY RIGHTS

If you are a resident of California, you have the following rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively the “CCPA”):

  1. to know what categories of personal information about you we have collected and used, including how the personal information was collected;
  2. to know what categories of personal information are being sold (if applicable) or disclosed, if it is being sold or disclosed to third parties and a list of categories of information that are sold or to know that your personal information has not been sold;
  3. to opt out of the sale of your personal information and/or sharing of your personal information for cross-context behavioral advertising, as applicable;
  4. to access your personal information, including the right to download or transfer personal information collected during the previous 12 months;
  5. to request that your personal information be deleted;
  6. to request that your personal information be corrected;
  7. to request that we limit our use of your sensitive personal information; and
  8. to equal service and equal price for goods or services even if you exercise your rights under the CCPA.

If you are a California resident, you may request to opt-out of the sale of, or sharing of for cross-context behavioral advertising, your personal information by contacting us at winninfosec@winnco.com or 188-598-2710.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout

If you are a California resident and you want to exercise any of your rights as set forth above, please contact us at winninfosec@winnco.com or 1-888-598-2710. For all requests, it is helpful to put the statement “California Privacy Rights” in the body of your request, describe the nature of your request, and provide your name, street address, city, state, and zip code. In your request, you need to attest to the fact that you are a California resident and provide a current California address for our response. For more information click here.

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.

If you reside in California and have provided personally identifiable information to us, you may request information about our disclosure of certain categories of personal information to third parties for their direct marketing purposes under California’s Shine the Light law. Such requests must be submitted to us at one of the following addresses: WinnCompanies, One Washington Mall, Suite 500, Boston, MA 02108 or call 1-888-598-2710.

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. For more information, please see our Accessibility Statement here.

Contacting Us
We welcome any queries, comments, complaints or requests you may have regarding this Privacy Policy. Please do not hesitate to contact us at:

WinnCompanies
One Washington Mall
Suite 500
Boston, Massachusetts 02108
winninfosec@winnco.com
617-742-4500 or 888-598-2710


Effective Date: May 1, 2023