Effective as of August 1, 2019
“IP Address” refers to “Internet Protocol Address” and means the unique number that allows computers attached to the Internet to know where to send you data (such as the webpages you view) and where the data that you are sending is coming from.
“Personal Identifiable Information (PII)” or “Personal Information (PI)” means information that, alone or when in combination with other information, may be used to identify, contact, or locate you personally. Your Personal Information includes your name, address, email address, and phone number. Your Personal Information does not include information that we obtain in or transform into an anonymous format from which a third party cannot easily identify you. However, if we collect your IP address (which is typically Non-Personal Information) and link it to your full name or other type of Personal Information, the combination of this data would be “Personal Identifiable Information.” PII is more commonly used in the United States and PI is more commonly used in the European Union. They mean essentially the same thing. We use the terms interchangeably.
“Non-Personal Information” means information that does not identify you as a specific individual, including without limitation IP type, ISP address, cookie IDs (and segment IDs associated with cookie IDs), pages viewed, and/or search terms entered, browser type, operating system, duration and frequency of visits, anonymous usage statistics including frequency of messaging and interaction with other users, clickstream data other log file data, or social analytics and tracking measurements. With respect to mobile devices, “Non-Personal Information” also may include device type, make and model, operating system, carrier, user ID, similar device IDs, and information about various apps that you use. We may link your Non-Personal Information link to your Personal Information which, in combination, may become Personal Information.
“Aggregate Data” means Non-Personal Information that we collect about a group or category of customers or products. Aggregate data helps us to understand trends so that we can better consider new products and services, analyze usage, facilitate payments, or otherwise improve or tailor our offerings. For example, we may collect data about the shopping habits of residents of a particular state (without linking this data to any specific personal information about those residents).
To “use” or to “process” information means to handle or utilize the information in any way, including without limitation by subjecting the information to statistical or other evaluation or analysis, or by collecting, storing, modifying, deleting, combining the information (including by using cookies on a computer), or by disclosing and/or transferring the information within our company or among our affiliates within the United States or internationally.
IV. TYPES OF INFORMATION WE COLLECT ABOUT YOU
We collect Personal Information, Non-Personal Information, and Aggregate Data as defined above.
The categories of information we collect from you include:
- Name and Contact Information: We may collect your name, email address, phone number, and other similar contact information.
- Demographic Information: We may collect demographic information such as age, gender, city, state, and country.
- Usage Information: We may collect data about how you and your devices interact with the Sites and our related services. This could include features you use, the web pages you visit, the products you view, and the search terms you enter. This could also include data about your devices and the network you use to connect to our services, including IP Address, device identifiers, and data about the performance of the services you use on the Sites and any problems you experience with them.
- Content and Other Information You Provide to Us: We collect additional content and information that you voluntarily provide us, such as transaction information (e.g. purchase date, purchase amount) when you purchase something from us or inquire about one of our products, or content you submit when you contact us via the Sites or by e-mail.
- Location Information. We may also collect your location if you choose to allow us to track your location through our Sites or through other means, or if your Personal or Non-Personal Information indicates a certain geographic location. This information may help us provide recommendations to you based on your location, serve you with advertisements, or direct you to offerings that may be of interest to you and/or are marketed to persons near your location.
V. HOW WE COLLECT YOUR INFORMATION
We do not collect Personal Information from you unless you voluntarily provide it to us. For example, we will ask you to provide us with certain Personal Information when you Purchase a Product from the Site or when you communicate with us about a Product that you have Purchased from us. When you make a payment for a Product that you Purchased via the Site, you will likely need to provide Personal Information to our third-party service providers (i.e., payment processors), such as your credit card number. We may also collect Personal Information from you if you send us Personal Information in an email, via the chat functionality on the Sites, or when you type information into certain fields (e.g., an email address field) on the Sites.
We also collect any information that you may choose to post on or via the Site, such as Postings or Feedback. If you choose to submit any such information, it will not be subject to the privacy protections set forth herein because it will be considered public information. We are not responsible for use by others of information that you post publicly.
We use your IP Address to deliver our Site to you upon request, to tailor the Site and our Products and advertising to the interests of our customers, and to measure traffic within the Site.
Here are general definitions and descriptions of the types of technologies that we may use to collect Non-Personal Information via our Site.
Web Beacons. A web beacon is an electronic image, also called a "gif", that may be in the form of a "png" image, as well as iframe, script, input link, embed, object, and other tags that are used to track usage. We may use these web beacons on our Site to deliver cookies, to attribute sales to any advertising media or affiliate partners with whom we may have a relationship, to count visits, to compile statistics about usage, to help determine the effectiveness of promotional or advertising campaigns, and/or in emails that we may send you in order to tell if you have opened or acted on email that we have sent you.
Pixels. A pixel is a piece of code or an electronic image embedded on the Site (but ordinarily not visible to users) that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page within the Site or clicked on a particular advertisement, to deliver branded services, and/or to help determine the effectiveness of promotional or advertising campaigns.
Server Log Data. When you visit the Site, our servers automatically record information that your browser sends whenever you visit a website. This data may include information such as your IP Address, browser type, the webpage you were visiting before you came to our Site, the pages of our Site that you visit, the time spent on those pages, information for which you may search on our Site, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and for general technical administration of the Site, to improve the Site’s functionality and convenience, and to better serve our customers’ needs and preferences. We also may use Server Log Data to verify that Site visitors meet criteria that we have established as necessary before processing their purchase.
Please note that we may use third-party service providers or vendors to help us operate and improve the Site and/or transact business (including, without limitation, maintenance services, database management providers, payment processors, or web analytics consultants, etc.). These third-party service providers may also collect or have access to Personal Information and Non-Personal Information from our Site. Such third-party service providers and vendors are not authorized to use the Personal Information or Non-Personal Information for any purpose other than to provide the administrative services for which they are responsible. Please let us know via email@example.com if you want a list of such third-parties.
GW is aware of and concerned about identity theft and unlawful practices known as “phishing.” We do not and will not solicit or request your credit card information or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. If you receive such solicitations or requests that appear to be from GW, please contact us at firstname.lastname@example.org before responding. More information is available on the Federal Trade Commission’s website.
VI. HOW WE USE YOUR INFORMATION
We use your Personal Information (in some cases, in conjunction with your Non-Personal Information) primarily to answer your questions, to process and consummate your transactions with us, to deliver Products that you purchased from us, and try to solve any problems that you may encounter relating to the same.
By using the Site, you are authorizing us to gather, parse, and retain data related to the provision of the Site and your interactions with us. By providing us with your email address, you expressly consent to our sending you emails. However, we will not give your email address to another party to promote their products or services directly to you without your consent.
As noted above, we may use third party service providers or vendors to help us operate and improve the Site and/or transact business. These third parties may have access to your Personal Information, but only to perform these tasks on our behalf.
We may also use your information for advertising, marketing, and promotions. For example, we may use your information for generating web analytics to compile user information for marketing purposes, advertising, conducting marketing analysis, providing you with recommendations for products or services based on your profile, and promotional material planning and distribution.
We do not sell your Personal Information to third parties. We do not give, transfer, disclose or share your Personal Information to third parties except as provided in Section VII below.
VII. HOW WE SHARE YOUR INFORMATION
We may share or disclose your personal information to the following categories of entities and for the following reasons:
- With our affiliates, strategic partners, agents, third party marketers, or other unaffiliated parties who are offering products or services that we believe may be of interest to you or who require your personal information, for research, administrative, and/or internal business purposes.
- To vendors, affiliates, strategic partners, agents, third party marketers, or other unaffiliated parties, for advertising and marketing purposes.
- To unaffiliated third-party service providers, agents or independent contractors to, assist us in operating the Sites, conducting our business, providing our services to you, and for our marketing and advertising purposes.
- To law enforcement, government agencies, and other third parties, for complying with the law (or in the good faith belief that such action is necessary), enforcing our website policies, or protecting our or others’ rights, property, or safety.
- To third parties as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.
- To data aggregators and other third parties, to track and analyze information from our visitors and customers.
- To protect against potential fraud, we may verify with third parties the information collected from the Sites.
We reserve the right to share with third parties, for any reason not disclosed above, any Non-Personal Information, including Aggregate Data and behavioral advertising information about you and our other online visitors, customers, sales, and traffic. We may do this for any legitimate purpose, including industry analysis, demographic profiling, and to deliver targeted advertising about Products and offerings. Any Aggregate Data shared in these contexts will not contain your Personal Information. Please let us know via email@example.com if you want us to delete Personal Information that we have collected about you.
However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. As such, we cannot promise, ensure, or warrant the security of any information that you may provide to us. We likewise do not accept liability for unintentional disclosure or data breach.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes concerning security breach notifications) to you via email or conspicuous posting on the Site as promptly as possible, and without unreasonable delay, taking into account the legitimate needs of law enforcement or any measures necessary to determine the scope of the breach and/or to restore the reasonable integrity of the affected data system.
You may have a legal right to receive any such notice in writing. To receive free written notice of any security breach, or otherwise to withdraw your consent from receiving electronic notices, please notify us at firstname.lastname@example.org.
IX. COMPLIANCE WITH LAW AND LAW ENFORCEMENT
We may access, preserve, and disclose your Personal Information, other account information, and content if we believe that doing so is required or appropriate in order to comply with law enforcement requests, other legal obligations, to respond to your requests, or protect yours’, ours’ or third parties’ rights, property, safety, or welfare.
X. INTERNATIONAL TRANSFER
If you choose to provide us with Personal Information, we may transfer that information to affiliates, subsidiaries, and/or other third parties across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the European Union or other regions that have laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal information to the United States, which does not have the same data protection laws as the E.U. and may not afford you the same rights as the laws of the E.U. afford you. By providing your Personal Information, you consent to the use of your Personal information for the uses identified above in accordance with this Policy and to the transfer of your Personal Information to the United States as indicated above.
XI. LINKS TO OTHER WEBSITES, INCLUDING SOCIAL MEDIA PLATFORMS
The Site also may contain links to and enable interactivity vis-a-vis certain social media platforms, which may place their own cookies or similar technologies on your device and browser. Personal Information that you voluntarily disseminate online in any public forum (such as a social media platform) may be viewed and used by others without any restrictions. We have no control over or liability relating to any information that you disseminate through a public forum.
The Site does not knowingly target children under the age of 13, and GW does not collect Personal Information from any child under the age of 13. If we learn that any such information has been provided to us via the Site, we will delete or destroy it. If you believe that Personal Information about your child or another child under the age of 13 has been transmitted through the Site, please contact us at email@example.com.
XIII. BUSINESS TRANSFERS
In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the Personal and Non-Personal Information collected via the Site to such other party.
We provide you with an opportunity to access your Personal Information to ensure it is correct, accurate and current. To do so, you may contact us at firstname.lastname@example.org.
XV. CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits our Site visitors, who are California residents, to request certain information about our disclosure of personal information to third parties for direct marketing purposes. To make such a request, please contact us at email@example.com.
XVI. CONTACT INFORMATION