Security Compliance Policy

This privacy notice describes how we, B601 Labs Inc. dba Winware, and our subsidiaries and affiliates, from time to time (“Winware,” “we,” “us,” “our”), process, maintain, use and share information about individuals (each a “User,” “you,” “your”) who use our website (www.winware.ai) and related features (collectively, the “Site”) or who we communicate or interact with. Winware complies with various privacy laws globally, including, but not limited to, the European Union General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

This notice sets out:

1. Information we collect about you
2. Cookies and other technologies
3. How we use your information
4. Our promotional updates and communications
5. Who we give your information to
6. Where we store your information
7. How we protect your information
8. How long we keep your information
9. Child Safety 
10. Your rights
11. Changes to this notice
12. Contact us

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

By engaging with our Site, you acknowledge you have read and understood this privacy notice.

For the purposes of the applicable data protection law, the Data Protection Officer is: 

Steven Cohn,

CEO

privacy@winware.ai

1. INFORMATION WE COLLECT ABOUT YOU

We will collect and process the following personal data from you:

Information you give us

• This is information about you that you give us directly when you interact with us. This is information about you that you have given us by filling in forms on our site or by corresponding with us by phone, e-mail, or otherwise. It includes information you provide when you use our site, subscribe to our service, search for a product, submit a query, and when you report a problem with our site.
• The information you give us may include demographic information, such as your name, job title, company name, country, e-mail address, and phone number.
• If you register for an event we organize, you may submit additional information, including your interest in compliance topics and products.
• If you respond to an advertised job vacancy or make a general inquiry regarding employment opportunities with us, you may submit various employment details about yourself, including a CV, resume, or other details of your educational and employment history. For further information on recruitment, please review Winware Human Resources & Job Applicant Privacy Notice. [what is that?]

Information we collect about you from your use of our site: We will automatically collect technical information each time you visit our site. This includes:

• The Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• Product usage behaviors. 

Information we receive from other sources. This is the information we receive about you:

• If you use any other websites or Apps we operate or our other services.
• From third parties we work closely with (including, for example, business partners, sub-contractors in technical, payment, and delivery services, advertising networks, analytics providers, and search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

2. COOKIES AND OTHER TECHNOLOGIES

Our site uses cookies and/or other similar technologies to collect and store certain information. These typically involve pieces of information or code that a website transfers to, or accesses from, your computer hard drive or mobile device to store and sometimes track information about you. Cookies and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services. They can manage various features and content, store searches, and present personalized content.

Our site uses cookies and similar technologies to distinguish you from other users. This helps us to provide you with a good experience when you browse our site and allows us to improve our site.

Several cookies and similar technologies we use last only for the duration of your web session and expire when you close your browser. Others are used to remember you when you return to the site and will last for longer.

We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that your rights do not override these), and, in some cases, where required by law, where you have consented to their use.

If you disable cookies on our site, however, you may not be able to take full advantage of our site.

3. HOW WE USE YOUR INFORMATION

We use information held about you in the following ways:

Information you give to us:

• We will use this information to:

• Take steps to enter any contract or carry out our obligations arising from any existing contract entered between you and us.
• Ensure in our legitimate interests that:

• Content from our site is presented most effectively for you and your computer.
• We provide the information, products, and services you request.

Information we collect about you from your use of our site

• We will use this information in our legitimate interests, where we have considered your rights do not override these:

• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• To keep our site safe and secure.
• To measure or understand the effectiveness of advertising we serve to you and others and to deliver relevant advertising.
• To improve our site to ensure that content is presented most effectively for you and your computer.

Information we receive from other sources

• We may combine this information with information you give us and information we collect about you in our legitimate interests (where we have considered that your rights do not override these). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

4. OUR PROMOTIONAL UPDATES AND COMMUNICATIONS

Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications by email and social media platforms about our products/services.

You can object to further marketing at any time by selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you or by sending us an email at privacy@winware.ai.

5. WHO WE GIVE YOUR INFORMATION TO

We may give your information to any member of our group.

We may also give your information to selected third parties:

• We may give your information to any of our subsidiaries, our ultimate holding company, and its subsidiaries, who support our processing of personal data under this notice. If any of these parties use your information for direct marketing purposes, we will only transfer the information to them with your prior consent.

We may also give your information to selected third parties:

• Organizations who process your personal data on our behalf and in accordance with our instructions and the Data Protection Law. This includes supporting the services we offer through the site, particularly those providing website and data hosting services, providing fulfillment services, distributing any communications we send, supporting or updating marketing lists, facilitating feedback on our services, and providing IT support services occasionally. These organizations (which may include third-party suppliers, agents, sub-contractors, and/or other companies in our group) will only use your information to the extent necessary to perform their support functions.
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may use the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience and subject to the cookie section of this notice.
• Analytics and search engine providers that assist us in the improvement and optimization of our site and are subject to the cookie section of this notice (this will not identify you as an individual).
• Business partners who, jointly with us, provide services to you and with whom we have entered into agreements in relation to the processing of your personal data.

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy notice.
• If Winware or substantially all its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data to comply with any legal obligation, to enforce or apply our terms of supply terms and other agreements with you, or to protect the rights, property, or safety of Winware, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction to prevent cybercrime

When you visit our website, we use the following third parties to process your information:

Company / Processing Type / Learn More

Google, Inc. / Hosting, Analytics, Advertising / “How Google uses data when you use our partners’ sites or   apps”, located at www.google.com/policies/privacy/partners/

HubSpot / Customer Relationship Management, Marketing, and Sales / https://legal.hubspot.com/product-privacy-policy

Salesforce / Customer Relationship Management, Marketing, and Sales / https://www.salesforce.com/company/privacy/  

6. WHERE WE STORE YOUR INFORMATION

We are headquartered in the United States of America. Suppose we transfer personal information to any destination outside the European Union (EU), the European Economic Area (EEA), or the United Kingdom (UK). In that case, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, and that it is treated securely and in accordance with this privacy notice.

7. HOW WE PROTECT YOUR INFORMATION

Winware will use appropriate technical and organizational security measures to protect your personal data from loss, misuse, alteration, or destruction. Please be aware that the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorized access.

8. HOW LONG WE KEEP YOUR INFORMATION

Winware will retain personal data reasonably, considering legitimate business needs to capture and retain such information. Information will also be retained for a period necessary to comply with applicable local, state, federal, or country-specific regulations and requirements.

We may also retain aggregate information without time limits for research purposes and to help develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

9. CHILD SAFETY 

Protecting the safety of children when they use the Internet is important to Winware. We do not knowingly collect personally identifiable information from anyone under 13. If you are a parent or guardian and know your child has provided us with Personal Data, don’t hesitate to contact us. Suppose we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent. In that case, we remove that information from our servers.

10. YOUR RIGHTS

We will honor your rights under applicable data protection laws. You may have the following rights under European laws and similar rights under other countries laws.

• Right of subject access: You have the right to make a written request for details of your personal information and to be provided with a copy of your personal data held by us.
• Right to rectification: You have the right to have inaccurate information about you to be corrected or removed.
• Right to erasure: You have the right to erasure certain personal information about you. We will comply with your request unless there is an overriding legitimate ground for retaining the information.
• Right to restriction of processing: You have the right to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example).
• Right to object: You have the right to object to the further processing your personal data, including the right to object to marketing (as mentioned in “Our promotional updates and communications” section).
• Right to data portability: You can request that your provided personal data be transferred to you or a third party in a machine-readable format.
• Right to withdraw consent: Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before withdrawing your consent.

You can also exercise the rights listed above at any time by contacting our Data Protection Officer:

Steven Cohn,

CEO

privacy@winware.ai

For data subjects located in the EU: if we are not able to satisfactorily resolve your questions, concerns, or complaints, or if you believe that the processing of your personal data infringes on your rights under applicable data protection laws, you have the right, without prejudice to any other administrative or judicial remedies, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. Contact information of the supervisory authorities may be found here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

For data subjects in the UK, the Information Commissioner is the supervisory authority in the UK. It can provide further information about your rights and our obligations concerning your personal data, as well as deal with any complaints you have about our processing of your personal data. Contact information for the UK Information Commissioner can be found here: https://ico.org.uk/

11. CHANGES TO THIS NOTICE

Winware keeps this notice under regular review and may modify it occasionally at our discretion. Any changes we make will be posted on this page. This notice was last updated on October 4, 2023.

12. CONTACT US

Suppose you have questions, comments, or complaints about our handling or protection of your personal data or this privacy notice. In that case, you may send a message by email to privacy@winware.ai or may contact our Data Protection Officer:

Steven Cohn,

CEO

privacy@winware.ai