“Personal Information” is data about an individual who can be identified from that data, or by combining it with other data. Personal Information is usually your name in combination with another identifier, such as date of birth, postal address, telephone number, or government-issued identification number. Personal Information does not include anonymous or aggregated data that can no longer be used to identify a specific person, even if combined with other data. The specific definition of Personal Information varies from one jurisdiction to another.
2. Personal Information Collected
The Personal Information WIN collects depends on how you interact with WIN. When you book an inspection, connect to our Services, contact us (including by social media), participate in an online survey, or otherwise interact with WIN, we may collect a variety of information, including:
- Device Information. Data such as computer or mobile device type, browser type, online and/or unique personal identifiers, IP address, and geolocation information.
- Identity. Data such as name.
- Contact Information. Data such as email address, physical address (or other property details), phone number, or other contact information
- Other Information You Provide to Us. Details such as the content of your communications with WIN, including interactions with customer support and contacts through social media channels, and information regarding services you have obtained or are considering obtaining
If you interact with us on social media platforms (such as Instagram, Facebook, Twitter, Google, and YouTube), we may collect information that you or the platform shares with us. For more information about these platforms’ privacy practices, please review their privacy policies and privacy settings.
You are not required to provide the Personal Information that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our Services or respond to requests you may have.
3. Personal Information from Other Sources
WIN may receive Personal Information about you from other individuals, from businesses or third parties acting at your direction, from our partners who work with us to provide our services and assist us in security and fraud prevention, and from other lawful sources.
- Individuals. WIN may collect data about you from other individuals — for example, if that individual has added you as a contact for an inspection order.
- At Your Direction. You may direct other individuals or third parties to share data with WIN. For example, you may direct your real estate agent to share data about a property you currently own or are considering for purchase, or your contact information.
4. Use of Personal Information
In addition to the purposes mentioned above, WIN uses Personal Information to power our Services, to communicate with you, for security and fraud prevention, and to comply with law. We may also use Personal Information for other purposes with your consent.
- Communicate with You. To respond to communications, reach out to you about your services, market our products and services, provide other relevant information, or request information or feedback. From time to time, we may use your Personal Information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with WIN, you may not opt out of receiving these important notices.
- Security and Fraud Prevention. To protect individuals, employees, and WIN and for loss prevention and to prevent fraud, including to protect individuals, employees, and WIN for the benefit of all our users.
- Comply with Law. To comply with applicable law — for example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request.
5. Sharing of Personal Information
WIN may share Personal Information with WIN-affiliated companies, employees who perform their jobs and service your needs, service providers who act on our behalf, our partners, and developers, or others at your direction:
- Employees. Our employees may access your Personal Information to perform their jobs and service your needs.
- Service providers. We may share information with service providers who help us provide, maintain, and improve the Services, including IT service and hosting providers, web analytics providers, and payment processors. In some instances, service providers will be directly responsible to you for their use of your Personal Information. They may be obliged by law to provide you with additional information regarding the Personal Information that they hold about you and how and why they process that information. Further information may be provided to you in a separate notice or may be obtained from such service providers directly, for example, via their websites.
- Franchisees. WIN may share information collected through this Site with our franchisees, which may be permitted to use your information for their own marketing purposes and in any manner otherwise consistent with this Policy.
- Partners. At times, WIN may partner with third parties to provide services or other offerings. For example, WIN offerings like WIN 360 and WIN Concierge are offered by WIN and our partners. Before doing so, however, we may offer you the opportunity to “opt out” or “opt in,” as required by applicable law.
- As Described in a Privacy Notice or Click-Through Agreement. We reserve the right to disclose your information as described in any Privacy Notice posted on a page of this Site where you provide that information. By providing your information on that page you will be consenting to the disclosure of your information as described in that Privacy Notice. We also reserve the right to disclose your Personal Information as described in any click–through agreement to which you have agreed, including at the time of purchase of inspection services.
- Others. WIN may share Personal Information with others at your direction or with your consent. We may also disclose information about you if we determine that for purposes of law enforcement disclosure is necessary or appropriate. We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, or in the event of a reorganization, financing, merger, or sale.
In addition, we may share aggregate, non-individual information, incapable of identifying a particular person, with third parties for lawful purposes.
6. Cookies and Third-Party Tools
Cookies are small, sometimes encrypted text files that are stored on computer hard drives by websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the websites. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, please visit (www.allaboutcookies.org)[www.allaboutcookies.org].
When you visit the Site, we may place a “cookie” or other online tracking device (e.g. web beacons, clear GIF, pixels, internet tags, code snippets, and app embeds) that recognizes you when you visit the Site. These are used for technical convenience to store information on your computer. The Site utilizes, when enabled, advertising cookies to inform targeted advertising initiatives. These cookies further track advertising performance to deliver relevant WIN products and services through third party platforms.
You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. If you block cookies you may not be able to access certain parts of the Site. You can disable cookies from your computer system by following the instructions on your browser or at www.youradchoices.com. To manage your cookies within our Site, click here.
This Site also uses tools to collect web traffic data to better understand how visitors engage with us. Please refer to the following privacy policies for more information about each tool:
- Cookies and Google Analytics on websites https://developers.google.com/analytics/resources/concepts/gaConceptsCookies
7. Targeted Advertising
Our Site allows for third party “targeting” advertisements which permits tracking information to be shared with advertisers and marketing partners, data analytics providers, and social media networks.
For more information about targeted advertising, visit the Network Advertising Initiative (“NAI”) at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
Some third parties like Google and Facebook may know if you visited the Site if you use their services. You can opt out of Google targeted advertising at https://www.google.com/settings/ads/anonymous.
WIN uses Google Analytics to better understand how customers use the Site. For more information about how Google collects and processes data, visit: https://policies.google.com/technologies/partner-sites. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
To manage third party targeted advertising on our Site, click here, or on the “Manage Cookies” or “Do Not Sell My Personal Information” links on our home page.
8. Your Privacy Rights
- In General. We respect your right to make choices about the ways we collect, use, and disclose your Personal Information. This Policy describes some of your choices, such as your choice to opt out of receiving “cookies.” We may ask you to indicate your choices at the time and on the page where you provide your information.
- Do Not Track. “Do Not Track” is a privacy preference that users can set in certain web browsers. We currently do not respond to browser do not track signals.
- Unsubscribe. If you no longer want to receive our newsletter or other marketing communications, you may unsubscribe at any time by following the unsubscribe options in the communication itself. To opt-out of text messages, you may text “STOP” in reply to any WIN marketing text message. Please note that you cannot unsubscribe from certain correspondence from us, including messages relating directly to your account or inspections you have booked.
- Edit and/or delete your Information. If you would like to edit any of your information or delete or cancel your account, please contact us at the information below in the How to Contact Us section.
9. Security and Retention of Personal Information
We take reasonable precautions to provide a level of security appropriate to the sensitivity of the information we collect. Although we use reasonable measures to help protect your Personal Information against unauthorized use or disclosure, we cannot guarantee the security of information provided over the Internet or stored in our databases and, to the extent permitted under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized access by third parties, or other causes beyond our control. We will not keep your Personal Information for any longer than is necessary for the purposes we collected it.
10. External Links
The Site is not intended for users under the age of 13 and WIN does not knowingly collect, use or disclose personal information from individuals under the age of 13. If you are aware of, or suspect that, someone under the age of 13 is using the Site without permission, please notify us immediately by contacting us as detailed below. If you have questions or concerns about the Internet and privacy for your child, we encourage you to check out the FTC Guidelines for protecting your child’s privacy online.
12. California Privacy Rights Act (CCPA)
Under the California Consumer Privacy Act, residents of California are provided with certain rights regarding their personal information:
- the right to “opt-out” of WIN’s sale of your Personal Information to any third parties;
- the right to request WIN to stop sharing your Personal Information with third parties;
- the right, with some exceptions, to have your Personal Information deleted from WIN’s possession or control;
- the right to correct inaccuracies in your Personal Information; and
- the right to receive equal service and pricing from WIN even if you exercise any of your privacy rights.
For all California residents, any such inquiries shall be responded to within forty-five (45) days and at no cost to you. We must verify your identity with respect to such inquiries. Depending on the nature of the Personal Information at issue, we may require additional measures or information from you as part of that verification. You (or a person registered with the California Secretary of State you have authorized to act on your behalf) may make up to two such inquiries within a twelve-month period.
WIN does not provide your Personal Information to third parties who would directly market to you via mail, telephone, or email.
Our Site allows for third party “targeting” advertisements which permits tracking information to be shared with advertisers and marketing partners, data analytics providers, and social media networks. You can opt out of third party targeted advertising on our Site here, by clicking on the “Manage Cookies” or “Do Not Sell My Personal Information” links on our home page.
To contact us to exercise any of the California rights listed above, please email us at firstname.lastname@example.org with “Privacy” in the subject line.
13. Changes to This Policy