Last modified: June 1, 2020
Information Collection and Use; Choice and Consent
You may access, review, change, update or delete your Personal Information, request information about our collection, use and disclosure of such information, and request information on our policies and practices relating to disclosure of information to our service providers, by contacting us at
We will respond to these requests in accordance with the laws that apply to you. You can help us maintain the accuracy of your Personal Information by promptly notifying us of any changes to your information.
Your Personal Information, which we processed prior to any request for deletion, may not be deleted from our Sites’ system records but will be blocked from further processing without your permission. A request to revoke consent or block processing of your Personal Information may not apply to information collected by cookies or used internally to recognize you and/or facilitate your visits to the Sites, or to information we may keep to comply with legal requirements.
We will retain your Personal Information as long as necessary to facilitate your use of the Sites and Software.
When you use or access the Software, we collect your username, phone number, email address, and encrypted password in order to create and monitor your user profile.
For more information on our cookies, please see our Cookies Statement.
Protection of Your Information
Information Sharing and Disclosure
We also may transfer your Personal Information to third parties in the event of any merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). You will be notified in advance of any rights you may have to block or object to this transfer of your information.
We may also release your information when we believe release is appropriate to comply with the law, enforce our policies, or protect our or others’ rights, property, or safety, or to assist with any online fraud or cyber threats. Because our servers, which store your information, are located in the United States of America, your information may be available to U.S. government entities or agencies under a lawful court order in the U.S.
Third Party Sites and Links
Your California Privacy Rights; California Do Not Track Disclosures
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://www.oag.ca.gov/privacy/ccpa .
Children’s Online Privacy Protection Act Compliance
We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), as we do not knowingly collect any information from anyone under 13 years of age. Neither the Sites nor the Software are intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at:
International or Cross-Border Transfer of Your Personal Information and Your Express Agreement
You may access, review, change, update or delete your Personal Information, request information about our collection, use and disclosure of such information, and request information on our policies and practices relating to disclosure of information to our service providers, by contacting us at . We will respond to these requests in accordance with the laws that apply to you. You can help us maintain the accuracy of your Personal Information by promptly notifying us of any changes to your information.
You may contact us at:
Privacy Notice for California Residents
Revised: June 1, 2020
This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. See https://www.oag.ca.gov/privacy/ccp
Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements.
Information We Collect
Our Website collects information that identify, relate to, describe, reference, are reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
In particular, our Sites have collected the following categories of personal information from its consumers within the last twelve (12) months:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||No|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||Yes|
|G. Geolocation data.||Physical location or movements.||No|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||No|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||No|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No.|
Our Sites obtain the categories of personal information listed above from the following categories of sources:
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have not disclosed personal information for a business purpose.
Sales of Personal Information
In the preceding twelve (12) months, we have not sold personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, and Deletion Rights”), we will disclose to you:
We do not provide these access and data portability rights for B2B personal information.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see “Exercising Access, Data Portability, and Deletion Rights”), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
We do not provide these deletion rights for B2B personal information.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
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 provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include you describing your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. 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. However, if applicable, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales
We do not sell the personal information of consumers.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Sites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Sites and update the notice’s effective date. Your continued use of our Sites following the posting of changes constitutes your acceptance of such changes.
THE WENGER GROUP COOKIES POLICY
What are cookies?
As is common practice with almost all professional websites, the Sites contain cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored. However, please be aware that if you prevent these cookies from being stored, it may downgrade or “break” certain elements of the Sites’ or the Software’s functionality.
For more general information on cookies, please see www.AllAboutCookies.org.
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser “Help” for how to do this). Be aware that disabling cookies may affect the functionality of the Sites and the Software and many other websites that you visit. Disabling cookies will usually also result in disabling certain functionality and features of the Software.
The Cookies We Set
Third Party Cookies
The Sites and Software also contain cookies operated by trusted third parties. The following section details which third party cookies you might encounter through the Sites and the Software.
The Sites and Software use Google Analytics, which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the Sites and Software and ways that we can improve your experience. Google Analytics operates cookies on the Sites and Software. These cookies may track things such as how long you spend on the Sites, the Software, and the pages that you visit, which helps us understand how we can improve. To opt-out of analysis by Google Analytics, please visit http://tools.google.com/dlpage/gaoptout.
From time to time, we may test new features and make subtle changes to the way that the Sites and the Software are delivered. When we are still testing new features, cookies may be used to ensure that you receive a consistent experience while using the Sites or Software and so that we can understand which optimizations our users appreciate the most.
Since we are always looking for ways to optimize your experience when using the Software, it is important for us to understand statistics about how the Software is used, therefore, this is a category of data that these cookies will track. This is important to you as it allows us to constantly improve the user experience.
We are hopeful that this has clarified the topic of “cookies” for you. However, if you are still looking for more information, please contact us through one of our preferred contact methods.