We at Winklevoss Technologies, LLC respect your concerns about privacy. This Privacy Notice, which applies to winklevoss.com (the “Site”), describes the types of personal information we collect through the Site, how we use the information, with whom we share it and the choices available to users of the Site regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices.

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Information we obtain

The types of personal information we may obtain through the Site include:

  • contact information (such as name and email address) that you provide in regard to inquiries and possible sales or service of products and services;
  • when you apply for a job, your name, postal address, email address, telephone number and any information you provide in your cover letter or resume;
  • other personal information found in content you provide, including in communications submitted through our contact form; and
  • Data that is contained in ProVal or ProAdmin files that you send to us for support.

In addition, when you visit our site, we may collect certain information by automated means, such as cookies and/or other similar technologies. The information we collect in this manner includes IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken and dates and times of activity. A cookie is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of the Site. For more information on deleting or controlling cookies we recommend all AboutCookies.org. We use Google Analytics on our site. This service help us analyze how visitors use the site. The information collected for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by Google. To learn more about opting out of these activities, see Google Analytics Opt Out.

The providers of third-party plug-ins on the site, such as Google Maps, may use automated means to collect information regarding your use of the site and your interactions with the plug-ins. This information is subject to the privacy policies or notices of the plug-in providers and is not subject to this privacy notice. We are not responsible for these providers’ information practices.

How we use the information we obtain

We may use the information described above to:

  • communicate with you and respond to your inquiries;
  • process job applications;
  • operate, evaluate and improve our business (including developing new products and services; enhancing and improving our products and services; managing our communications; analyzing our products, services and communications; and performing accounting, auditing and other internal functions);
  • protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;
  • comply with and enforce applicable legal requirements, relevant industry standards and our policies; and
  • for our legitimate business purposes, including marketing our goods and services to you or responding to your request for support.

In addition, we may use information collected through automated means (cookies and/or similar technologies) for the purposes set forth above, including (i) customizing your visit to our site, (ii) analyzing the manner in which you interact with our site, and (iii) managing our site and other aspects of our business. We also use this information to help diagnose technical and service problems, administer our site and identify users of our site. We may use the information we obtain in other ways for which we provide specific notice at the time of collection. Neither we nor any third parties on our site obtain personal information about our visitors’ online activities, over time and across third-party websites. Our site is not designed to respond to “do not track” signals from browsers.

Information we share

We do not sell or otherwise disclose the personal information we collect about you on this site, except as described in this privacy notice. We may share personal information with service providers who perform services on our behalf based on our instructions. These service providers are not authorized by us to use or disclose the information, except as necessary to perform services on our behalf or comply with legal requirements. We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government entities, and (iii) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, to enforce our rights and policies, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, divestiture, dissolution or liquidation). Following such a transaction, you may contact the entity to which we transferred your personal data with any inquiries concerning the use of that information.

Username and password information

Our training page requires credentials. If you lose or forget your login information, you may contact us and ask us to change your password to a temporary password. You authorize us to, upon request, send your login information to your email address of record. This means that if you give someone else access to your email, they might have access to your account.

Retention

We will retain information collected through the site, including personal data that we process on behalf of a customer, for as long as your account is active or as needed to provide you services. We may also retain this information as necessary to comply with legal obligations, resolve disputes, or enforce our agreements.

Your rights and choices

We offer you certain choices in connection with the personal information we collect from you on this site. To update your preferences and consents, ask us to remove your information from our mailing lists or submit any request, please contact us as indicated in the “How to contact us” section of this Privacy Notice. Users in the European Union may have the right under certain circumstances:

  • to be provided with a copy of your personal data held by us;
  • to request the rectification or erasure of your personal data held by us;
  • to request that we cease processing your data;
  • to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
  • to request that your data be transferred to a third party.

Additional rights for users in the European Union:

  • You can also object to receiving further marketing at any time without detriment. We will inform you prior to collecting or using your personal information for any purpose not set forth in this privacy notice.
  • You can also exercise the rights listed above at any time by contacting us at privacy@winklevoss.com.
  • If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, to locate your data protection authority see Data Protection.
  • To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward.

Transfer of personal information to other countries

For the avoidance of doubt, the owner and operator of the site is Winklevoss Technologies, LLC. with headquarters located in the United States. Our servers may be located in North America or parts of the world other than the country in which you are located when using the site or you reside. We may transfer the personal information we collect about you to recipients in countries other than the country in which you originally provided it or in which we are located. These countries may not have the same data protection laws as the country in which you provided the information. When we transfer your information to recipients in other countries, we will protect that information as described in this privacy notice and will comply with applicable legal requirements.

How we protect personal information

We maintain appropriate administrative, technical and physical safeguards designed to protect the personal information you provide through the site against accidental, unlawful or unauthorized access, disclosure or use.

While we cannot ensure or guarantee that unlawful or unauthorized access, disclosure or use of your information will never occur, we use all reasonable efforts to prevent it in light of the nature of information supplied.

You should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit via the site while it is in transit over the internet and any such submission is at your own risk. If you use a shared computer or a computer in a public place, it is advisable to close your browser when you have finished your user session to help ensure others do not access your personal information.

Links to other sites

Our site may provide links to other websites and apps for your convenience and information. These websites and apps may operate independently from us. Linked sites and apps may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites or apps are not owned or controlled by us, we are not responsible for their content, any use of the websites or apps, or the privacy practices of the websites or apps.

Updates to our privacy notice

This privacy notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post the updated version on winklevoss.com/privacynotice and indicate at the top of the notice when it was most recently updated.

How to contact us

If you have any questions or comments about this privacy notice, or if you would like us to update information we have about you or your preferences, please email us at privacy@winklevoss.com. You also may write to: Privacy Officer, Winklevoss Technologies LLC, Four Greenwich Office Park, Greenwich CT 06831 U.S.A.