February 19, 2016

Privacy Policy

Last modified: December 15, 2013 This Privacy Policy applies to all of the products, services, and websites offered through or in association with this website.  We may post product specific privacy notices or other materials to explain our products & services in more detail.  If you have any questions about this Privacy Policy, please feel free to contact us using the contact information available through our website.

Information we collect and how we use it.
We may collect the following types of information:

  • Information you provide – When you sign up for an account, we ask you for personal and/or business information.  We may combine the information you submit under your account with information from other Women’s Information Network (WIN) services or third parties in order to provide you with a better experience and to improve the quality of our services.  For certain services, we may give you the opportunity to opt out of combining such information.
  • Cookies – When you visit our website, we may send one or more cookies to your computer or other device.  We use cookies to improve the quality of our service, including for storing user preferences, improving search results and ad selection, and tracking user trends, such as how people search and browse the website.
  • Log information – When you access the website services via a browser, application, or other client, our servers automatically record certain information.  These server logs may include information such as your web request, your interaction with a service, Internet Protocol address, browser type, browser language, the date and time of your request, and one or more cookies that may uniquely identify your browser or your account.  Other information may be collected from time to time.
  • User communications – When you send email or other communications to The WIN, we may retain those communications in order to process your inquiries, respond to your requests, and improve our services.  When you send and receive SMS messages to or from one of our services that provides SMS functionality, we may collect and maintain information associated with those messages, such as the phone number, the wireless carrier associated with the phone number, the content of the message, and the date and time of the transaction.  We may use your email address to communicate with you about our services.
  • Affiliated Services on other sites – We offer some of our services on or through other web sites.  Personal information that you provide to those sites may be sent to The WIN in order to deliver the service.  We process such information under this Privacy Policy.
  • Third Party Applications – The WIN may make available third party applications, such as gadgets or extensions, through its services.  The information collected by The WIN when you enable a third party application is processed under this Privacy Policy.  Information collected by the third party application provider is governed by their privacy policies.
  • Location data – The WIN may offer location-enabled services, such as Google Maps or similar services.  If you use those services, Google or the selected provider may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate a location (such as a cell ID).  These providers may also collect other information.  The WIN recommends you visit their respective websites and review their policies.
  • Other sites – This Privacy Policy applies to The WIN services only.  We do not exercise control over any other websites, whether they are provided directly from our website of through links from within our various services.  These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you.

In addition to the above, we may use the information we collect to:

  • Provide, maintain, protect, and improve our services (including advertising services, if any) and develop new services; and
  • Protect the rights or property of The WIN or our users.

If we use this information in a manner different from the purpose for which it was collected, then we will ask for your consent prior to such use.  The WIN processes personal information on our servers in the United States of America.  It is possible that some of The WIN’s providers, vendors, or affiliates process personal information outside your own country.  The WIN has no control over such processing.

Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent.  However, some of our website’s features and services may not function properly if your cookies are disabled.

Information sharing
The WIN only shares personal information with other companies or individuals outside of The WIN in the following limited circumstances:

  • We have your consent.  We require opt-in consent for the sharing of any sensitive personal information.  Note that making a purchase and you providing the confidential personal and financial information necessary to complete the transaction is considered opting-in for use to share the information with our vendors so that we may complete the transaction.
  • We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf.  We require that these parties agree to process such information based on our instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures.
  • We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of The WIN, its users, or the public as required or permitted by law.

If The WIN becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will ensure the confidentiality of any personal information involved in such transactions and provide notice on our website before personal information is transferred and becomes subject to a different privacy policy.

Information security
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data.  These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data.

HOWEVER, computer and internet technology is a rapidly changing industry, and the equipment and software necessary to deliver services online is by its very nature extremely complex.  Additionally, some individuals and organizations actively seek to illegally enter computer systems and steal confidential information.  The software and hardware may contain unknown or poorly announced vulnerabilities that may allow such thefts to occur despite our security efforts.  THEREFORE, you are advised to provide your information at your own risk with the understanding that The WIN is not liable for the results of these vulnerabilities.

We restrict access to personal information to The WIN employees, contractors, and agents who need to know that information in order to process it on our behalf.  These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Accessing and updating personal information
When you use The WIN services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes.  We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required.  In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.  Because of the way we maintain certain services, after you delete your information, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems.

The WIN complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland.  The WIN adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.

The WIN regularly reviews its compliance with this Privacy Policy.  When we receive formal written complaints, it is The WIN’s policy to contact the complaining user regarding his or her concerns.  We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between The WIN and an individual.

Changes to this Privacy Policy
Please note that this Privacy Policy may change from time to time.  We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes, provided you have given The WIN your email address).