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WILLO 32, INC.

PRIVACY POLICY


Last modified: June 24, 2020


Willo 32, Inc. and its subsidiaries and affiliates (collectively, “Willo”, the “Company”, “us”, “we”, or “our”) respect your privacy and are committed to protecting it through our compliance with this privacy policy (this “Privacy Policy”). This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the website (https://www.willo.com/)  and/or use our mobile or desktop applications (collectively, our “Website”), as well as through email messages that we send you that link to this Privacy Policy, and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Policy also governs your use of the products and information available on our Website (together with the Website, the “Services”). “You” or “your” refers to our customers or other visitors to or users of our Services, as well as job applicants and others who contact us about employment opportunities at Willo.

This Privacy Policy is incorporated into and made part of our Terms of Use. We encourage you to review our Terms of Use, because they contain important information about your use of our Services.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services and/or providing information to us, you acknowledge that you understand and agree to this Privacy Policy.

CHANGES TO OUR PRIVACY POLICY

Since technology and privacy laws are always changing, we may update this Privacy Policy. If a significant change is made, we will be sure to post a notice in your account. If you continue to use the Services after these changes are posted, you agree to be bound by the amended Privacy Policy, which supersedes all previous versions of agreements, notices, or statements about the Privacy Policy. When we make changes, we will update the “Last modified” date above.

CHILDREN’S PRIVACY

Our Website is not directed at children under the age of 13, and we do not knowingly collect any “personal information” (as such term is defined in the U.S. Children’s Online Privacy Protection Act) from children under 13 without the verifiable consent of that child’s parent or guardian. If you are under 13, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If you are aware of a child providing his or her personal information without parental consent, please contact us at legal@willo.com . We will endeavor to delete all data we collected from a child under 13 if we discover we collected it without that child’s parental consent.

INFORMATION WE COLLECT

We get information about you in a range of ways. 

Information You Give Us. We collect your‎ name, mailing address, email address, phone number, username, password, and demographic information (such as your sex and occupation). We may also collect information you directly give us through the Services, including information that you provide by filling in forms on our Website, records and copies of your correspondence if you contact us, your responses to surveys that we may ask you to complete for research purposes, dates of transactions you carry out through our Website, and your search queries on the Website.

Information We Get From Others. We may get information about you from other sources, such as third parties who are our business partners. We may add this to information we get from the Services.

Information Automatically Collected. We automatically log information about you and your computer. For example, when visiting our Website, we log your IP address, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Website, and location data.

Cookies. We may log information using “cookies.” Cookies are small data files stored on your hard drive by a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website. This type of information is collected to make our Website more useful to you and to tailor the experience with us to meet your special interests and needs.

User Contributions. You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

INFORMATION THIRD-PARTIES MAY COLLECT

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see “Information Choices and Changes” below.

USE OF PERSONAL INFORMATION

We use your personal information as follows:

  • To operate, maintain, and improve our Website and to provide the Services. 
  • To provide you with information, products, or services that you request from us, including responding to comments and questions and to provide customer service.
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To process and deliver contest entries and rewards.
  • To send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
  • To communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
  • To link or combine user information with other personal information.
  • To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

SHARING OF PERSONAL INFORMATION

We may share personal information as follows:

  • We may share personal information with our subsidiaries and affiliates.
  • We may share personal information with your consent and for the purpose for which you provide it. For example, you may let us share personal information with others for their own marketing uses. Those uses will be subject to their privacy policies.
  • We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
  • We may share personal information for legal, protection, and safety purposes.
    • We may share information to comply with laws.
    • We may share information to respond to lawful requests and legal processes.
    • We may share information to protect the rights and property of Willo 32, Inc., our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
    • We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
  • We may share information with those who need it to do work for us. This may include contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

INFORMATION CHOICES AND CHANGES

We strive to provide you with choices regarding the personal information you provide to us. You can review and change your personal information by logging into your account on the Website (either at https://www.willo.com/ or through our mobile application. You may also send us an email at support@willo.com to request access to, correct or delete any personal information that you have provided to us. In some instances, we may be unable to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms of Use. California residents may have additional personal information rights and choices. Please see “Your California Privacy Rights” for more information.

You may also control your information by using the following mechanisms:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of our Website may then be inaccessible or not function properly.

Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data (the order form or registration form. You can also always opt-out by clicking the “unsubscribe” link in the footer of the applicable email or by sending us an email stating your request to support@willo.com.

Promotional Offers from the Company. If you do not wish to have your email address and/or contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the order form or registration form. You can also always opt-out by clicking the “unsubscribe” link in the footer of the applicable email or by sending us an email stating your request to support@willo.com. If we have sent you a promotional email, you may also send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by updating the advertisement settings in accordance with instructions provided by the appropriate third-party platform (e.g., Google and Facebook). For this opt-out to function, you may need to have your browser set to accept browser cookies.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website.

California residents may have additional personal information rights and choices. Please see “Your California Privacy Rights” for more information.

DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our private, encrypted servers. Any payment transactions, which are processed by Stripe, are encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

YOUR CALIFORNIA PRIVACY RIGHTS

Additional Disclosures Related to Collection, Use, and Disclosure of Personal Information

If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to disclose the following information with respect to our collection, use and disclosure of personal information. 

  • Categories of Personal Information Collected: In the preceding 12 months, we have collected the following categories of personal information: identifiers, personal information categories listed in the California Customer Records statutes, protected classification characteristics under California or federal law, commercial information, internet or other similar network activity, sensory data, and inferences drawn about your preferences. For examples of the personal information we collect, please see “Information We Collect” above.
  • Business or Commercial Purpose for Collecting and Using Personal Information: We collect personal information for the business purposes described in “Use of Personal Information” above.
  • Categories of Sources of Personal Information: We collect personal information directly from you, automatically, and from other sources, each of which is more particularly described in “Information We Collect” above.
  • Categories of Personal Information Disclosed: In the preceding 12 months, we have disclosed the following categories of personal information for business or commercial purposes: identifiers, personal information categories listed in the California Customer Records statute, protected classification characteristic, and commercial information.
  • Categories of Third Parties with whom we share Personal Information: We may share your personal information with the third parties as described in “Sharing Information” above.

Sale of Personal Information: Willo does not sell your personal information.

Your Consumer Rights

California consumers have the right to request access to their personal information, additional details about our information practices and deletion of their personal information (subject to certain exceptions). We describe how California consumers can exercise their rights under the CCPA below. Please note that you may designate an authorized agent to exercise these rights on your behalf by providing written materials demonstrating that you have granted the authorized agent power of attorney. Please note that if an authorized agent submits a request on your behalf, we may need to contact you to verify your identity and protect the security of your personal information. 

  • Right to Know: You may request access to the specific pieces of personal information we have collected about you in the prior 12 months. You may also request additional details about our information practices, including the categories of personal information we have collected about you, the sources of such collection, the categories of personal information we share for a business or commercial purpose, the categories of third parties with whom we share your personal information, and the specific pieces of personal information we collected about you (also called a data portability request). We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security.
  • Deletion: You may request that we delete the personal information we have collected about you. Please note that we may retain certain information as required or permitted by applicable law, and we may deny your deletion request if retaining the personal information is necessary for us or our service providers under one of the nine statutory exceptions listed in Cal. Civ. Code § 1798.105, as amended by AB 1146. We are required by law to verify your identity prior to deleting your information in order to protect your privacy and security.  If you request to delete your personal information, certain of our products and services may no longer be available to you.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us in writing at Willo 32, Inc., 12 E 33rd St 10th Fl, New York, New York 10016 or by sending an email to legal@willo.com. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Shine the Light Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law, Civil Code Section § 1798.83) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; and/or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

USERS LOCATED OUTSIDE THE UNITED STATES

The Services and the products we sell through our Services are intended for individuals located in the United States, and your use of our Services and products is governed by United States law. We are not targeting or marketing to international users. If you are using the Services or our products from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Services or our products, you consent to your information being transferred to our servers, databases, and facilities, and to the servers, databases, and facilities of those third parties with whom we share information as described in this Privacy Policy. We will only process your information when we have a legal basis to do so. When we do process your information, we will do so with your consent, or because the processing is necessary for the performance of the Services or to provide products to you, to comply with our legal obligations, to pursue our legitimate interests, or to establish or defend a legal claim, and as further set forth in this Privacy Policy.


CONTACT INFORMATION. We welcome your comments or questions about this Privacy Policy. You may contact us by email to legal@willo.com. You may also contact us at our address:

Willo 32, Inc.

12 E 33rd St 10th Fl

New York, New York 10016

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