Wintellect is committed to protecting your personal information. Your privacy is important to us, and maintaining your trust and confidence is one of our highest priorities. We therefore adhere to ethical standards in the collection, use, and protection of any information you provide. We believe that you should know how information is used and collected, and we appreciate that you trust us to do so carefully and sensibly. We will ask you when we require information that personally identifies you or allows us to contact you (i.e., personal information).

This Privacy Policy sets forth our current privacy practices, and explains the information we collect when you interact with the www.Wintellect.com and www.WintellectNOW.com websites (collectively, the “Site” or “Sites”), owned and operated by Wintellect, LLC, a Tennessee Limited Liability company. All Terms apply to both Sites equally, except as may be specifically noted herein. We hope that by taking a few minutes to read this Privacy Policy, you will have a better understanding of what we do with the information you provide to us, and how we keep it private and secure. You acknowledge that by entering and accessing the Site that you understand and accept this Privacy Policy, and that you freely consent to the privacy practices described in this Privacy Policy.

This Policy is incorporated into, and is subject to, the wintellect terms of Service for the web site being accessed. Terms used but not defined in this Policy have the meaning given to them in the wintellect terms of Service.

1. General Terms for Data Protection.
Some data protection laws require companies to describe their role and responsibility when handling personal information.

When users access our Sites, view information, communicate with us, download or upload text, video, or any other resources, register for events or training, etc., we are the data controller.

When and individual registers as a user of the Site, for example via an Individual subscription, or for any other service or reason requiring user registration, Wintellect is the data controller for all personal information provided by that user and collected by the Site(s) as the user accesses and uses it.

When an individual engages with our Site(s) because their employer has signed them up or registered them, or a business account has been purchased, then:

  • the user’s employer is the data controller with respect to the user information it provides to us. Where your employer is data controller in this way, we act as a data processor under data protection laws, meaning we use the information to provide a service to your employer.
  • Wintellect is the data controller for information provided directly by the individual, or as a result of interacting with the Sites, including assessment data, profile details, titles, short bios, and other information (if and when required).

2. Privacy Policy Changes
Due to the Internet’s rapidly evolving nature and the fact that laws change, we may change this Privacy Policy from time to time, as needed. We reserve the right, in our sole discretion and at any time, to revise, update, or otherwise modify this Privacy Policy. We will post the most current version of this Privacy Policy on the Site. This will enable you to always be aware of what personally identifiable information we may collect, and how we may use that information. We encourage you to review this Privacy Policy regularly for any changes. Your continued use of the Site(s) will constitute your acceptance of any changes to this Privacy Policy.

3. Collected and User-Provided Information

3.1. Site Purpose We reserve the right to collect the information mentioned in this section to ensure that the Site is used for its intended purpose. Proprietary and confidential information will not be shared with any third-party while the Site is used for its intended purpose, except as otherwise stated in this Privacy Policy.

3.2. Registration Certain areas of the Site may require that you register for access. Registered users need a user ID and password. Before you receive a user ID and password, we require that you provide certain information. We will not collect or use that information for purposes other than the Site’s purpose, unless we obtain your prior consent. We reserve the right to add additional features or services that require that you register for additional access. Collected information will be used according to the terms of this Privacy Policy. We ask that you also review our Terms and Conditions of Use so that you have a complete understanding of all of our policies and procedures.

3.3. Accuracy of Collected Information We review our data collection, storage, and processing practices to ensure that we only collect, store, and process the information needed to provide or improve our Site and the services we provide. We take all reasonable measures to ensure that the information we process is accurate, complete, and current; however, we depend on you to update or correct your information whenever necessary. If you fail to provide or update certain information, you may lose some functionality with the Site or the services we provide.

3.4. User-Provided Information and How Long We Retain It The Site collects user-provided information when you register for one of our services. During registration, we may ask you for your name, company’s name, federal tax identification number, business profile, address, phone number, email address, diversity information, business license information, insurance policy information, and financial information. Beyond registering, we may ask you for the same, or more, information when you edit your user-provided information, purchase or sell any products through the Site, contact us about an issue, or in other instances not described in this Privacy Policy. We will provide you with the means to ensure that your personal information is correct and current. If you have completed a user profile, we will provide a way for you to access and change your profile from our Site. We retain your information while your account is active or as needed to provide you services. Thereafter, we may retain certain personal information indefinitely as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain aggregate information for research purposes and to help us develop and improve our Site and services.

3.5. Collected Information

3.5.1. Cookies We may use cookies to personalize or enhance your user experience. A cookie is a small text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. For example, if you personalize a web page, or navigate within the Site, a cookie helps the Site to recall your specific information on subsequent visits. Therefore, this simplifies the process of delivering relevant content and eases Site navigation by providing and saving your preferences and login information.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser preferences to decline cookies. If you reject cookies, you may disable some of the functionality of the Site. Should you decline to use cookies, Wintellect does not and will not ensure that the site will work properly for you, and this choice is solely your responsibility and not the responsibility of Wintellect. Please check with your browser provider for more information on removing cookies.

3.5.2. Log File Information We collect site-visitation data automatically and store it in log files. This information includes Internet protocol (IP) addresses, internet service provider (ISP), referring/exit pages, operating system, browser type, date/time stamp, and clickstream data. We will not link this automatically-collected data to personally identifiable information without first obtaining your permission. Each computer that connects to the Internet is assigned a unique IP address for identification purposes. This Site uses an extended log file format to capture that IP address, along with the date and time of your visit, any referral address, and the Internet browser you are using. We do not collect your email address or other personal or financial information when you use the Site, unless you provide the information.
Our log files, which do not identify individual users, are used to analyze trends, to administer the Site, to track users’ movements through the Site, and to gather demographic information about our user base as a whole. We may merge Site visitation data with anonymous demographic information for research purposes, and we may use this information in the aggregate to help us provide more relevant content and improve our services. In some limited-entry sections of the Site, with your approval, we will combine Site visitation data with your personal information in order to provide you with personalized content. If you decline permission, we will not provide you the personalized service and will not merge your personal information with Site visitation data.

3.6. User ID and Passwords
Certain uses of the Site may require a user ID and password. You agree to maintain the confidentiality of your password and are solely responsible for all activities associated with its use, whether authorized or unauthorized. You shall not share or otherwise make available your account passwords with other persons. We will never ask you for your password in an unsolicited correspondence. You should always sign out of your account and close all browser windows when you have finished using the Site. This is to ensure that others cannot access your account on the Site. Your password is hashed using a one-way algorithm and stored according to industry-accepted norms. Due to the nature of one-way hashing, Wintellect will not (and cannot) retrieve lost passwords. Your User ID and password are only used to authenticate against the Site, and are not exposed to external systems or parties.

3.7. Payment Transactions
For financial transactions involving services offered by the Site, at times we must transmit or request credit card and other financial information to complete a purchase transaction or verify your identity. We use one or more outside credit card processing companies to bill you for goods and services. Wintellect does not, and these companies do not, retain, share, store or use personally identifiable information for any other purpose.

4. Use of Information

4.1. Customer Service We reserve the right to collect the information mentioned herein to improve our customer service. Customer service includes helping you with problems you may encounter with the Site or our services, as well as improving the Sites or our services to prevent those problems. As part of our customer service efforts, we may use your contact information to notify you about updates to the Site, this Privacy Policy, the Terms and Conditions of Use, or any other event that could affect your use and enjoyment of the Site and our services.

4.2. System or Administrative Email Notifications Wintellect may occasionally e-mail system or administrative notices to you. You will not be able to choose to unsubscribe to these mailings or notifications, as they are considered an essential part of the service you have chosen. These email notifications may include, without limitation, system notifications, subscription expiry notifications, conference announcements, date or time changes for events for which you have registered, and similar notifications or announcements.

4.3. Promotional Offers We may send you promotional information on occasion. When we do this, we do not provide any information to any third-party, if involved. If you wish to take advantage of such a promotion, you may be asked to provide information to the offering party. You provide that information at your own risk. You may opt out from receiving these promotional offers by following the instructions included in any promotional offer we send.

4.4. Statistical Reports We may use the collected information to generate statistical and aggregate reports for internal use. These reports may be shown to affiliates, subsidiaries, licensees, successors, partners, and advertisers. These reports will not contain any personally identifiable information.

5. Data Retention and Security

5.1. Data Retention Upon request, Wintellect will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at info@wintellect.com. We only retain personal data collected from a user (User-Provided Data) for as long as the User’s account is active or as needed to provide you services, unless otherwise required by law. However, we will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements as follows, for example to prevent unauthorized use of promotional codes or for historical audit data needed to resolve disputes.

5.2. Security The security of your personal information is of paramount importance to us. When you enter proprietary or sensitive information (such as your credit card number and/or social security number) on our registration forms, your information is sent over an authenticated and encrypted connection using the Secure Socket Layer (SSL).

5.3. Data Storage We store your personal information only on servers with restricted access that are located in controlled facilities, and use a variety of safeguards, technology and procedures to protect your personal information from unauthorized access, use, or disclosure.

5.4. Data Destruction We will take reasonable steps to destroy personal information which is no longer needed. We will shred, erase, or otherwise modify such personal information to make it undecipherable through any means.

6. Third-Party Access to Information
Information provided by the User will not be shared with any third-party, other than our mutual customers, except in special cases or as provided herein. From time to time, Wintellect may share your contact information with our sponsors and trade agreement partners. You hereby consent to Wintellect’s sharing or disclosure of such information with or to said third parties, subject to the understanding that we will not disclose your payment or credit card information except as specifically described in Paragraph 3.7 above, or other sensitive information except as otherwise provided herein.
In addition to the foregoing, we may disclose, or give access to, your information to an appropriate third-party when we believe in good faith that third-party access is necessary to ensure that we comply with applicable law, and/or that we otherwise properly maintain, service, and improve our products and services.
We may employ other companies to perform functions on our behalf, including sending mail, removing redundant information, analyzing data, and providing market consultations. These other companies will have limited access to personal information needed to perform their specific function. We make sure that these companies use this information only for their specific function. Wintellect will never sell your information to any third party without your permission.

6.1. Google Analytics We use Google Analytics to measure and evaluate access to and traffic on the Site and create user navigation reports for our Site administrators. Google operates independently from us and has its own privacy policy, which we strongly suggest you review. Google may use the information collected through Google Analytics to evaluate Users’ and Visitors’ activity on our Site. For more information, see Google Analytics Privacy and Data Sharing.
We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.

7. User Access and Control of Personal Data

7.1. Access, Editing, and Deletion We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. You may update, correct, or delete Account information and preferences at any time by accessing your Account/Profile settings page on the Service, or by contacting Wintellect. Please note that while any changes you make will be reflected in our user databases within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some of the features and functionality of the Service. At any time, you may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law. We will make every effort to accommodate your request, as long as it does not conflict with other applicable laws or the needed requirements of the Service. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact Wintellect at info@wintellect.com.

7.2. Navigation Information You may opt out from the collection of navigation information about your visit to the Site by Google Analytics by using the Google Analytics Opt-out feature.

7.3. Opting Out from Promotional and System/Administrative Communications If you receive Promotional emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “How to Contact Us” section. Please be aware that if you opt-out of receiving Promotional emails from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving Promotional messages from us, you may continue to receive Administrative or System messages from us regarding the Service, as they are considered an essential part of the Service.

8. Disclaimer Regarding Third Party Websites
The Site may contain links to other websites. Merchants and other third parties linked to the Site may have separate privacy and data collection practices. We accept no responsibility and have no liability for such independent policies. References on this Site to any names, marks, products, or services of third parties or links to third-party websites are provided solely as a convenience to you, or as a source of revenue to us, and do not in any way constitute or imply that we endorse, sponsor, or recommend the third-party and its information, product, or service. We are not responsible for the content or accuracy of material on third-party websites, and therefore we disclaim all responsibility for the content of such third-party websites. If you decide to link to any such third-party website, you do so entirely at your own risk. It is your responsibility to determine when you have left our Site.

9. Warranties and Limitation of Liability
We cannot ensure or warrant the full security of any information mentioned in this Privacy Policy.
We will disclose any breach of the security of the system to those who require such disclosure under consumer protection laws. Any disclosure shall be made in the most expedient time possible and without unreasonable delay, consistent with the legitimate needs of law enforcement. We may delay a notice if a law enforcement agency determines that the notice would impede a criminal investigation. All provisions governing warranties and liabilities within the Terms and Conditions of Use are incorporated herein by reference and shall be the same warranties and liabilities for this Privacy Policy, notwithstanding anything herein to the contrary.

10. Anti-Spam Policy
We are committed to providing users of the Site with the choice to receive or not receive promotional e-mails from Wintellect.com and WintellectNOW.com. We strive to comply with the CAN-SPAM Act. We only send promotional e-mails to users, subscribers and affiliates with current or previous relationships with Wintellect, and we offer promotional e-mail recipients the opportunity to opt-out of further communications in every promotional e-mail that we send. If you would like to opt-out of receiving further promotional communications, please follow the directions in the e-mail received or contact us as provided below. Please note, however, that we typically do not include opt-out information in system or administrative e-mails (for example, e-mails concerning an order or registration status, expiry notifications, etc.), as they are considered an essential part of the service you have chosen.

11. Law Enforcement, Legal Process, and Compliance
We may disclose Personal Data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We also reserve the right to disclose Personal Data or other information that we believe, in good faith, is appropriate or necessary to
(i) take precautions against liability,
(ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity,
(iii) investigate and defend ourselves against any third-party claims or allegations,
(iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, or
(v) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.

12. Change of Ownership
Information about Users and Visitors, including Personal Data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets and only if the recipient of the User or Visitor Data commits to a Privacy Policy that has terms substantially consistent with this Privacy Policy.

13. Children’s Privacy
Protecting the privacy of young children is especially important. For that reason, Wintellect does not knowingly collect or solicit personal information from anyone under the age of 13. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at info@wintellect.com.

14. How to Contact Us
If you have any questions about this Privacy Policy, please feel free to contact us at one of the following:
Email: info@wintellect.com
Phone: 865-966-5528
Physical Mail: 980 Hammond Drive, Suite 660, Atlanta, GA 30328 U.S.A.

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