Privacy Policy
Last updated: September 20, 2024
This Privacy Policy describes the personal information that Windfall Data, Inc. (“Windfall”) handles in connection with providing actionable financial data about individuals (“Consumers”) to our business customers (“Customers”). This Privacy Policy applies to information we collect in connection with our platform, our website (https://windfall.com/), and any related services (collectively, the “Services”).
1. Personal Information We Collect
We may collect and store the following information when running the Services:
Consumer Data. We may collect, or generate through analytics, Consumer personal information that may include name, email address, telephone number, occupation, employer, charitable contribution history, and other financial asset and demographic information. We may collect this information from third-party data providers, and publicly-available sources.
Customer Data. When a Customer creates an account or authorizes someone to use the Services on their behalf (a “User”), we may collect some personal information, such as the Customer’s name, the User’s name, phone number, a credit card or other billing information, email address and business postal addresses.
We may also receive personal information through other Customers, for example, if they refer you to Windfall to set up an account with us.
Social Media Data. When you interact with our pages on social media sites like Twitter and LinkedIn (“Social Media Pages”), we will collect personal information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.
Log Data. When you use the Services, we may automatically record information from the computer you used to access the Services, including, without limitation, a desktop, laptop, mobile phone, tablet, or other consumer electronic device (a “Device”), its software, and your activity using the Services. This may include the Device’s Internet Protocol (“IP”) address, browser type, the web page visited before you came to our website, information you select or search for on our website, locale preferences, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata concerning your files, and other interactions with the Services.
We may collect this information using cookies and other similar technologies. Cookies are text files that websites store on a visitor‘s device or in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating interest-based advertising. For more information on how you can control cookies, please see the Online Tracking Opt-Out section below.
2. How We Use Personal Information
Personal information is or may be used: (a) to provide and improve our Services, including by sharing information we derive from Consumer Data with our Customers; (b) to administer your use of the Services; (c) to better understand your needs and interests; (d) to personalize and improve your experience; (e) for marketing and advertising; (f) to provide or offer software updates and product announcements; and (g) to comply with legal obligations, and to defend us against legal claims or disputes.
3. How We Share Personal Information
Our Customers. We may share Consumer Data with our Customers who may use that information for their own business purposes.
Service Providers. We may use certain trusted third party companies and individuals to help us provide, analyze, and improve the Services (including but not limited to data storage, maintenance services, database management, web analytics, payment processing, and improvement of the Services’ features). These third parties may have access to your information only for purposes of performing these tasks on our behalf.
Marketing Partners. We may share your information with third-party marketing partners for commercial/advertising purposes.
Third-Party Applications. We may share your information with third-party applications with your consent, for example when you choose to access our Services through such an application. We are not responsible for what those parties do with your information, so you should make sure you trust the application and that it has a privacy policy acceptable to you.
Compliance with Laws and Law Enforcement Requests; Protection of Windfall’s Rights. We may disclose to parties outside Windfall information that you provide and that we collect when we have a good faith belief that disclosure is reasonably necessary to (a) comply with a law, regulation or compulsory legal request; (b) protect the safety of any person from death or serious bodily injury; (c) prevent fraud or abuse of Windfall or its users; or (d) to protect Windfall’s property rights.
Business Transfers. If we are involved in a merger, acquisition, sale of all or a portion of our assets, or other change in corporate control (collectively a “Transaction”), your information may be transferred as part of that Transaction or during the diligence process related to the Transaction.
4. Changing or Deleting Customer Data
It is Customers’ responsibility to ensure that Customer personal information is up-to-date. Each Customer may review, update, correct, or delete Customer Data. When you choose to close an account, we will remove Customer Data from our marketing and billing systems.
5. Data Retention
We will retain your information for as long as your account is active or as needed to provide you the Services. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Consistent with these requirements, we will try to delete your personal information quickly upon request. Please note, however, that there might be latency in deleting information from our servers and our backup systems.
6. Security
We employ a number of technical, organizational and physical safeguards designed to protect the information submitted to us, both during transmission and once we receive it. No method of electronic transmission or storage is 100% secure, however. Therefore, we cannot guarantee its absolute security.
7. Privacy Rights and Choices
Privacy Rights
Consumers and Users who reside in California, as well as Consumers in Virginia, Colorado, Connecticut, Texas, Oregon, Montana, and Utah, are entitled to exercise certain rights regarding their personal information.
Subject to applicable exceptions, you may have the following privacy rights in relation to the personal information we collect:
- The right to know what personal information we have collected and how we have used and disclosed that personal information. We provide this information within this Privacy Policy.
- The right to request a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable and readily-usable format.
- The right to correct personal information that is inaccurate or out of date.
- The right to request deletion of your personal information.
- The right to opt out of sale, and the right to opt out of the processing and sharing of personal information for targeted advertising. To exercise these rights, click on the “Your Privacy Choices” link in the footer of our website.
Exercising Your Rights: Residents of U.S. states that provide these rights can exercise their rights as provided in our “Your Privacy Choices” form or by calling us at (800) 946-6710. You are entitled to exercise these rights free from discrimination. If you are unsatisfied with how we managed your request, you may appeal as provided in our “Your Privacy Choices” form.
Verification: In order to protect your personal information from unauthorized access or deletion, we may require you to verify your identity and proof of residency before you can submit a request. If we cannot verify your identity, we will not process your request.
Authorized Agents: Depending on your jurisdiction, authorized agents may submit requests on your behalf by using the form here and presenting signed written permission to act on an individual’s behalf. If you submit a request through an authorized agent you may also be required to independently verify your identity and submit proof of your residency directly to us.
Unsubscribe from Direct Marketing Communications
You may opt out of marketing-related communications by following the opt-out or unsubscribe instructions contained in the marketing communication we send you, or by updating your account settings information. You may continue to receive service-related and other non-marketing communications.
Online Tracking Opt-Out
You may limit online tracking by:
- Blocking cookies in your browser. Most browsers let you remove or reject third-party cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org.
- Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
- Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
- Platform opt outs. The following advertising partners offer opt out features that let you opt out of use of your information for interest-based advertising:
- Google: adsettings.google.com
- Facebook: https://www.facebook.com/about/ads
- Advertising industry opt out tools. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:
- Digital Advertising Alliance for Websites: aboutads.info
- Digital Advertising Alliance for Mobile Apps: https://youradchoices.com/appchoices
- Network Advertising Initiative: networkadvertising.org
Note that because these opt out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.
Do Not Track
We and our third party service providers may use cookies or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Services. We make reasonable commercial efforts to recognize and support “Do Not Track” signals.
8. Our Policy Toward Children
Our Services are not directed to persons under 18, and we do not knowingly collect personal information from children under 18. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us at (800) 946-6710. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information from our files.
9. Contacting Us
If you have any questions about this Privacy Policy, would like to exercise your privacy rights, or need to access an alternative format of this Privacy Policy, please contact us at (800) 946-6710.
10. Changes to Our Privacy Policy
This Privacy Policy may change from time to time. Windfall reserves the right to modify this Privacy Policy at any time, effective upon Windfall posting an updated version of this Privacy Policy on the Services, at which time we will update the “last updated” date.
11. Privacy Snapshot
Here is a high-level snapshot of our privacy practices, but you need to read the entire Privacy Policy for complete information.
|
Data Categories Collected |
How We Collect |
Primary Purposes of Processing |
Key Disclosures |
Can You Limit Sharing?* |
|
Identifiers such as a real name, Internet Protocol address, email address, or other similar identifiers |
When you visit or use our Services; from third-party sites and services |
To provide and improve our Services; for marketing and advertising |
Service providers |
No |
|
Advertising partners |
Yes |
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|
Our Customers |
Yes |
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|
Personal information categories listed in the California Customer Records Statute (e.g., name, contact details) |
When you visit or use our Services; from third-party sites and services |
To provide and improve our Services; for marketing and advertising |
Service providers |
No |
|
Advertising partners |
Yes |
|||
|
Our Customers |
Yes |
|||
|
Commercial information, including but not limited to records of products or services purchased |
When you visit or use our Services |
To provide and improve our Services; for marketing and advertising |
Service providers |
No |
|
Advertising partners |
Yes |
|||
|
Our Customers |
Yes |
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|
Internet or other electronic network activity information, including but not limited to browsing history and search history |
When you visit or use our Services |
To provide and improve our Services; for marketing and advertising |
Service providers |
No |
|
Advertising partners |
Yes |
|||
|
Inferences drawn from information to create a profile about your behavior, preferences, etc. |
When you visit or use our Services; from third-party sites and services |
To provide and improve our Services; for marketing and advertising |
Service providers |
No |
|
Advertising partners |
Yes |
|||
|
Our Customers |
Yes |
|||
|
Geolocation data |
When you visit or use our Services |
To provide and improve our Services; for marketing and advertising |
Service providers |
No |
|
Advertising partners |
Yes |
*Only residents of states identified in our "Your Privacy Choices" form can limit sharing.