A. The Types of Information We Collect
When you visit and browse the site, you may provide us with information, and we may collect certain information automatically.
- Information You Provide to Us
In order to access certain services provided via the site or to request certain information from Wingspire via the site, you may be required to provide information such as your name, postal address, e-mail address, telephone number, facsimile number, investor status, or other information about yourself. And you may be required to provide a username and password to access certain features. If you choose to not provide us with information, you might not be able to gain access to certain information and services on the Site.
- Information We Collect Automatically
We may also collect information about you automatically. For example, when you visit the site, we may collect your IP address, your browser type, your operating system, the pages you view on the site, the pages you view immediately before and after you access the site, and the search terms you enter on the site.
The site may also use other technical methods to track visitor usage, including web beacons. (“Web beacons” are small pieces of data that are embedded in images on the pages of a website.) We use these technical methods to analyze the traffic patterns on the site, such as the frequency with which our users visit various parts of the site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send visitors to the site to determine whether such visitors have opened those e-mails and/or clicked on links in those e-mails.
- Additional Information Collection Practices
The site may contain links to website operated by third parties. Should you choose to visit these third party site, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your information. We do not accept, and do disclaim, any responsibility for the privacy policies and information collection, use, and sharing practices of any third-party website (whether or not such site is linked on or to the site). These links are provided to you for convenience purposes only, and you access them at your own risk.
We may link the information that we collect automatically with the information you provide us. And we may combine the information we collect online with information we collect offline or that is collected by third parties.
B. How We Use the Information We Collect
We may use information we collect about you for a number of purposes, including, without limitation, using information to:
- respond to your requests for forms, literature, or information;
- process transactions;
- provide you with the services you have requested;
- prepare investor disclosure materials;
- improve the site and learn about how visitors use the site;
- to provide, maintain, protect, optimize and improve our products and services;
- enhance and personalize your user experience and for regular business purposes such as authenticating and authorizing access to the Services
- comply with legal obligations;
- protect our rights, your rights, and the rights of others;
- investigate and respond to complaints; and
- diagnosing and addressing technical and service issues
We may use information that does not reasonably identify you for any purpose. For example, we may prepare aggregated reports about how visitors tend to interact with the site for research purposes.
C. How We Share the Information We Collect
- In Connection with Third Party Offers
We may share information about you with third parties when you engage in certain activities on the site that are sponsored by third parties. For example, you may choose to purchase products or services offered by a third party or elect to receive information or communications from a third party. When you engage in such third-party offerings, we may share information (e.g., your e-mail address) with third parties in association with the offerings.
- Service Providers
- Analytics Providers
- Additional Sharing Practices
We may share your information with our affiliates and subsidiaries. Wingspire also may provide information to our attorneys, banks, auditors, securities brokers and other service providers. From time to time, we may team-up with other organizations or companies to provide co-sponsored or co-branded promotions, services, or events, and we may share your information with our co-sponsor(s) and partners.
We may disclose information when we believe in good faith that such disclosures:
- are required by law, including, for example, to comply with a court order or subpoena, or in response to a law enforcement agency’s request;
- will support our detection, prevention, or response to fraud or intellectual property infringement;
- will help protect your safety or security, including the safety and security of property that belongs to you; and
- will protect the safety and security of the site, databases, and/or third parties, including the safety and security of tangible and/or intangible property that belongs to us or to third parties.
We may also share information about you to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets.
Additionally, we reserve the right to share with third parties information that does not reasonably identify you for any purpose.
D. The Security Measures We Take to Safeguard Information
The security and confidentiality of the information we collect or receive is extremely important to us, and we take our responsibility to protect this information very seriously. We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive. From time to time, we review and consider updates for our security procedures. Please be aware though that, despite our ongoing efforts, no security measures are perfect or impenetrable. This means that we cannot absolutely guarantee the security of information we collect about you, but we take this responsibility very seriously.
E. Updating Your Contact Information
You may be able to update your contact information and/or modify your communication preferences by sending us an e-mail to the address listed above, and we may provide tools on the site that facilitate such updates or modifications.
F. Children’s Information
The Site is intended for use by those over 18, and minors under the age of 13 may not use the site. We do not knowingly solicit or collect personal information on the site from children under the age of 13. If we learn that, despite these measures, a child under the age of 13 has submitted personally identifiable information to us through the Site, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).
G. Do Not Track
Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. We do not currently respond to such signals. Third parties, such as our analytics providers, may collect data that relates to you on our site, across time, and over other website. We cannot control third parties’ responses to do-not-track signals or other such mechanisms. Third parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.
H. California Privacy Rights
If you are a California resident, you have the right to request certain information from us regarding the manner in which we share with third parties certain categories of information that identifies you for the third parties’ direct marketing purposes. California users who wish to request further information in compliance with this law or have questions or concerns about our privacy practices and policies may contact us as specified in the How to Contact Us section below.
I. Additional Access Requests
If you believe that personal data relating to you is held by an entity within Wingspire’s group that is subject to data protection legislation that provides you with a right to obtain information about the personal data that the entity holds about you, please contact us at firstname.lastname@example.org. To the extent permitted by applicable law, Wingspire reserves the right to charge a reasonable administrative fee for this service.
J. Where Is Information Processed?
We process information collected via the site in and subject to the laws of the United States, which may not provide the same level protection for your information as your home country. The information may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries. By using the Online Services, you consent to such transfer to, and processing in, the United States and these other countries.
K. Opting out of Communications.
You may “opt-out,” or unsubscribe, from our newsletters, special offers, or other marketing communications by following the unsubscribe instructions in any email or other communication you receive from us or contacting us as set forth in the How to Contact Us section below. After doing so, you will not receive future promotional emails unless you open a new account or sign up to receive newsletters or emails. Please note that even after unsubscribing we may still disclose information as permitted or required by law including, but not limited to, service-related announcements, state required notices, and other non-marketing communications about your account or transactions that you have made. Please note that once you request removal, it may take up to two weeks to stop receiving email from us.
Unless you ask us not to in accordance with the provisions above, by using our site and/or services, you agree that we may contact you via phone, email, push notification, and promotions via the site.
L. How to Contact Us