1. Collection of Information.
1.1 Survey Information.
The Wheelhouse Group collects or contracts with 3rd parties who collects information from individuals when an individual voluntarily completes a survey, order form, or a registration page either online or offline, or by means of online or offline surveys, order forms, or registration pages operated by third parties (collectively, a "Survey"). (As used herein, "online" means using the Internet, including the Websites, and related technologies, and "offline" means by methods other than online, including in person, in the postal mail, using telephones and cell phones, and other similar means.) In the Surveys, The Wheelhouse Group or a third party (a "Third Party") may ask an individual to provide various information to The Wheelhouse Group, which may include his or her name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, employment information, personal and online interests, and such other information as may requested from time to time (together, "Survey Information"). The Wheelhouse Group or Third Party may also collect information such as what browser you are using and your Internet Protocol ("IP") address. Completing the Surveys is completely voluntary, and individuals are under no obligation to provide Survey Information to The Wheelhouse Group or Third Party, but an individual may receive incentives from The Wheelhouse Group or a Third Party in exchange for providing Survey Information to The Wheelhouse Group.
1.2 Third Party List Information.
The Wheelhouse Group collects or contracts with 3rd parties who collect information from individuals when an individual provides information to a third party, and The Wheelhouse Group subsequently purchases, licenses, or otherwise acquires the information from the third party (the "Seller"). Such purchased information may include, but is not limited to, an individual's name, email address, street address, zip code, telephone numbers (including cell phone numbers and carriers), birth date, gender, salary range, education and marital status, occupation, industry of employment, personal and online interests, and such other information as the individual may have provided to the Seller (together, "Third Party List Information"). When acquiring Third Party List Information, The Wheelhouse Group seeks contractual assurances from the Seller that the Seller has a right to transfer the Third-Party List Information to The Wheelhouse Group and that The Wheelhouse Group has a right to provide offers from advertisers to the individuals whose personal information is included on the Seller's list.
1.3 Other Information.
Other occasions when The Wheelhouse Group obtains information from individuals include (1) when an individual is making a claim for a prize or seeking to redeem an incentive offered by The Wheelhouse Group or by a third party, (2) when an individual requests assistance through The Wheelhouse Group’s customer service department, (3) when an individual voluntarily subscribes to a The Wheelhouse Group service or newsletter (together, "Other Information"), and (4) when an individual voluntarily downloads, installs, and uses The Wheelhouse Group’s desktop software application(s).
1.4 Cookies, Web beacons, and Other Information Collected Using Technology.
The Wheelhouse Group currently uses or contracts with 3rd parties who use cookie and web beacon technology to associate certain Internet-related information about an individual with information about the individual in our database. Additionally, The Wheelhouse Group may use other new and evolving sources of information in the future (together, "Technology Information").
(a) Cookies. A cookie is a small amount of data stored on the hard drive of the individual's computer that allows The Wheelhouse Group to identify the individual with his or her corresponding data that resides in The Wheelhouse Group’s database. You may read more about cookies at www.cookiecentral.com. Individuals who use the Websites need to accept cookies in order to use all of the features and functionality of the Websites.
(b) Web beacons. A web beacon is programming code that can be used to display an image on a web page (by using an <img src="x"> programming function -- see www.w3.org for more information), but can also be used to transfer an individual's unique user identification (often in the form of a cookie) to a database and associate the individual with previously acquired information about an individual in a database. This allows The Wheelhouse Group to track certain web sites an individual visits online. Web beacons are used to determine products or services an individual may be interested in, and to track online behavioral habits for marketing purposes. For example, The Wheelhouse Group might place, with the consent of a third party website, a web beacon on the third party's website where fishing products are sold. When Joe, an individual listed in The Wheelhouse Group’s database, visits the fishing website, The Wheelhouse Group receives notice by means of the web beacon that Joe visited the fishing site, and The Wheelhouse Group would then update Joe's profile with the information that Joe is interested in fishing. The Wheelhouse Group may thereafter present offers of fishing related products and services to Joe. In addition to using web beacons on web pages, The Wheelhouse Group also uses web beacons in email messages sent to individuals listed in The Wheelhouse Group’s database. If you wish more information about web beacons, you may wish to visit http://www.webopedia.com/TERM/W/Web_beacon.html.
(c) New Technology. The use of technology on the Internet, including cookies and web beacons, is rapidly evolving, as is The Wheelhouse Group’s s use of new and evolving technology. As a result, The Wheelhouse Group strongly encourages individuals to revisit this policy for any updates regarding its use of technology.
1.5 Outside Information.
The Wheelhouse Group may receive information about individuals from third parties or from other sources of information outside of The Wheelhouse Group including information located in public databases ("Outside Information").
1.6 Individual Information.
As used herein, Individual Information means Survey Information, Third Party List Information, Other Information, Technology Information, and Outside Information, and any other information The Wheelhouse Group gathers or receives about individuals.
1.7 No Information Collected from Children.
The Wheelhouse Group will never knowingly collect any personal information from or about children under the age of 13. If The Wheelhouse Group obtains actual knowledge that it has collected personal information about a child under the age of 13, that information will be immediately deleted from our database. Because it does not collect such information, The Wheelhouse Group has no such information to use or to disclose to third parties. The Wheelhouse Group has designed this policy in order to comply with the Children's Online Privacy Protection Act ("COPPA").
1.8 Credit Card Information.
The Wheelhouse Group may in certain cases collect credit card numbers and related information, such as the expiration date of the card ("Credit Card Information") when an individual places an order from The Wheelhouse Group. When the Credit Card Information is submitted to The Wheelhouse Group, such information is encrypted and is protected with SSL encryption software. The Wheelhouse Group will use the Credit Card Information for purposes processing and completing the purchase transaction, and the Credit Card Information will be disclosed to third parties only as necessary to complete the purchase transaction.
1.9 Information Collected by The Wheelhouse Group’s Desktop Software.
The Wheelhouse Group’s desktop software (including NewtonKnows) and related services may routinely collect the following information about individuals: (1) error logs, (2) keywords used by the individuals in web searches, and (3) information about the sites the individuals visit. Error log information will be used by The Wheelhouse Group to improve the performance of the desktop software. Other information regarding individuals may be used for any purpose permitted by law, including targeting relevant advertising to individuals.
2. Use of Individual Information.
2.1 Discretion to Use Information.
THE WHEELHOUSE GROUP MAY USE INDIVIDUAL INFORMATION FOR ANY LEGALLY PERMISSIBLE PURPOSE AT THE WHEELHOUSE GROUP’S SOLE DISCRETION. The following paragraphs in Section 2 describe how The Wheelhouse Group currently uses Individual Information, but The Wheelhouse Group may change or broaden its use at any time. As noted below, The Wheelhouse Group may update this policy from time to time. The Wheelhouse Group may use Individual Information to provide promotional offers to individuals by means of email advertising, telephone marketing, direct mail marketing, online banner advertising, and package stuffers, among other possible uses.
2.2 Email.
The Wheelhouse Group uses Individual Information to provide promotional offers by email to individuals. The Wheelhouse Group may maintain separate email lists for different purposes. If email recipients wish to end their email subscription from a particular list, they need to follow the instructions at the end of each email message to unsubscribe from the particular list. To unsubscribe from all The Wheelhouse Group email lists, a person must visit and follow the instructions provided at end of each email message.
2.2 (a) Content of Email Messages.
In certain commercial email messages sent by The Wheelhouse Group, an advertiser's name will appear in the "From:" line but hitting the "Reply" button will cause a reply email to be sent to The Wheelhouse Group. The "Subject:" line of The Wheelhouse Group email messages will usually contain a line provided from the advertiser to The Wheelhouse Group. The subject line will not usually contain phrases such as "ADV:" or "ADVERTISEMENT". The Wheelhouse Group’s commercial email messages will contain information how an individual may unsubscribe from that particular list.
2.2 (b) Solicited Email.
The Wheelhouse Group only sends email to individuals who have agreed on the Websites to receive email from The Wheelhouse Group or to individuals who have agreed on third party websites to receive email from third parties such as The Wheelhouse Group. The Wheelhouse Group does not send unsolicited email messages. As a result, statutes requiring certain formatting for unsolicited email are not applicable to The Wheelhouse Group’s email messages.
2.3 Targeted Advertising.
The Wheelhouse Group uses Individual Information to target advertising to an individual. When an individual is using the Internet, The Wheelhouse Group uses Technology Information (see also Section 2.5 below) to associate an individual with that person's Individual Information, and The Wheelhouse Group attempts to show advertising for products and services in which the person has expressed an interest in the Surveys, indicated an interest by means of Technology Information, and otherwise. The Wheelhouse Group may, at its discretion, target advertising by using email, direct mail, telephones, cell phones, and other means of communication to provide promotional offers.
2.4 Direct Mail and Telemarketing.
The Wheelhouse Group uses Individual Information to advertise, directly or indirectly, to individuals using direct mail marketing or telemarketing using telephones and cell phones.
2.5 Use of Technology Information.
The Wheelhouse Group uses Technology Information
(1) to match a person's Survey Information and Third-Party List Information to other categories of Individual Information to make and improve profiles of individuals, (2) to track a person's online browsing habits on the Internet, (3) to determine which areas of The Wheelhouse Group’s web sites are most frequently visited. This information helps The Wheelhouse Group to better understand the online habits of individuals so that The Wheelhouse Group can target advertising and promotions to them.
2.6 Profiles of Individuals.
The Wheelhouse Group uses Individual Information to make a profile of an individual. A profile can be created by combining Survey Information and Third-Party List Information with other sources of Individual Information such as information obtained from public databases.
2.7 Storage of Individual Information.
The Wheelhouse Group stores the Individual Information in a database on The Wheelhouse Group servers. Our servers are housed in a SOC2 compliant facility that has both physical (such as keycard access) security and digital security measures (such as a firewall) in place to protect against the loss, misuse, and alteration of the information under The Wheelhouse Group’s control. Notwithstanding such measures, The Wheelhouse Group cannot guarantee that its security measures will prevent The Wheelhouse Group computers from being illegally accessed, and the Individual Information on them stolen or altered.
2.8 Email Notification of Privacy Policy Changes.
Individuals who have their information stored in a The Wheelhouse Group servers are eligible to receive notification emails from The Wheelhouse Group when there are material changes in the terms of this Privacy Policy.
3. Dissemination of Individual Information.
3.1 Sale or Transfer to Third Parties.
THE WHEELHOUSE GROUP MAY SELL OR TRANSFER INDIVIDUAL INFORMATION TO THIRD PARTIES FOR ANY PURPOSE AT THE WHEELHOUSE GROUP’S S SOLE DISCRETION.
3.2 Order Fulfillment.
The Wheelhouse Group will transfer Individual Information to third parties when necessary to provide a product or service that a person orders from such third party while using The Wheelhouse Group web sites or when responding to offers provided by The Wheelhouse Group.
3.3 Legal Process.
The Wheelhouse Group may disclose Individual Information to respond to subpoenas, court orders, and other legal process.
3.4 Summary Data.
The Wheelhouse Group may sell or transfer non-individualized information, such as summary or aggregated anonymous information about all persons or sub-groups of persons.
4. Privacy Practices of Third Parties.
4.1 Advertiser cookies and web beacons.
Advertising agencies, advertising networks, and other companies (together, "Advertisers") who place advertisements on the Websites and on the Internet generally may use their own cookies, web beacons, and other technology to collect information about individuals. The Wheelhouse Group does not control Advertisers' use of such technology and The Wheelhouse Group has no responsibility for the use of such technology to gather information about individuals.
4.2 Links.
The Websites and email messages sometimes contain hypertext links to the web sites of third parties. The Wheelhouse Group is not responsible for the privacy practices or the content of such other web sites.
4.3 Affiliated Companies.
The Wheelhouse Group may disclose, transfer, and sell Individual Information to entities affiliated with The Wheelhouse Group at The Wheelhouse Group’s discretion.
5. Unsubscribe Procedure.
If you wish to discontinue receiving email messages from The Wheelhouse Group, you have several options:
(a) Unsubscribe from one email list. To unsubscribe from a particular list, either (1) visit our unsubscribe location, or (2) follow the instructions in each promotional email message sent by The Wheelhouse Group.
(b) Unsubscribe from all The Wheelhouse Group email lists : (1) write to The Wheelhouse Group, LLC 118 Victoria St, Suite 205. Greer, SC 29651 or (2) email admin@thewheelhousegroup.net and request to be removed from our lists and include the email address to be removed.