Privacy Policy

WINNOW PRIVACY POLICY

This policy explains what information we collect when you use Winnow’s sites, services, mobile applications, products, and content (“Services”). It also has information about how we store, use, transfer, and delete that information.

NOTICE TO EUROPEAN RESIDENTS

Winnow Services are hosted in the United States and are intended for visitors located within the United States. We do not actively solicit users from outside the United States or target them with our services.

If you choose to access this site from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the service. By providing any information, including personal information, on or to the service, you consent to such transfer, storage and processing.

INFORMATION WE COLLECT & HOW WE USE IT

We collect information from your interactions with our network. Some of this information you actively tell us (such as if you enter your email address, which we use to track your account or communicate with you). Other information we collect based on actions you take while using Winnow, such as what pages you access and your interactions with our product features (like highlights, follows, and applause). This information includes records of those interactions, your Internet Protocol address, information about your device (such as device or browser type), and referral information.

WE USE THIS INFORMATION TO:
  • provide, test, improve, promote and personalize Winnow’s services
  • fight spam and other forms of abuse
  • generate aggregate, non-identifying information about how people use Winnow’s services
  • When you create your Winnow account and authenticate with a third-party service (like Twitter, Facebook or Google) we may collect, store, and periodically update information associated with that third-party account, such as your lists of friends or followers. We will never publish through your third-party account without your permission.
INFORMATION DISCLOSURE

Winnow won’t transfer information about you to third parties for the purpose of providing or facilitating third-party advertising to you. We won’t sell information about you. We do not collect data for advertising purposes and do not sell data to advertisers.

We may share your account information with third parties in some circumstances, including: (1) with your consent; (2) to a service provider or partner who agrees to treat data in compliance with this Privacy Policy; (3) with academic or non-profit researchers, provided such data is provided in an aggregated, anonymized, or pseudonymized manner; (4) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process; (5) when we have a good faith belief that doing so will help prevent imminent harm to someone.

If we are obligated (or have reason to believe we are obligated) by legal process or court order to disclose personal information we have about you, we will notify you to allow you to challenge such disclosure or seek protection for it unless we’re prohibited by law. We will object to requests for personal information that we believe are improper.

DATA STORAGE

Winnow uses third-party vendors and hosting partners, such as Amazon, for hardware, software, networking, storage, and related technology we need to run Winnow. We maintain two types of logs: server logs and event logs. By using Winnow’s services, you authorize Winnow to transfer, store, and use your information in the United States and any other country where we operate.

TRACKING & COOKIES

We use browser cookies and similar technologies to recognize you when you return to our Services. We use them in various ways, for example to log you in, remember your preferences (such as default language), evaluate email effectiveness, allow our paywall and meter to function, and personalize content and other information.

Winnow doesn’t track you across the Internet. We track only your interactions within the Winnow network (which encompasses Winnowhealth.ai and custom domains hosted by Winnow).

Some third-party services that we use to provide the Winnow Service, such as Google Analytics, may place their own cookies in your browser. This Privacy Policy covers use of cookies by Winnow only and not the use of cookies by third parties.

Winnow complies with the “Do Not Track” (“DNT”) standard recommended by the World Wide Web Consortium. For logged-out users browsing with DNT enabled, Winnow’s analytics will not receive data about you, but we will do some first-party tracking in order to customize content and provide data to third-party service providers that enable Winnow Services to work. When you use Winnow while logged-in to your account, we cannot comply with DNT.

MODIFYING OR DELETING YOUR PERSONAL INFORMATION

If you have a Winnow account, you can access, modify or export your personal information, or delete your account by request at [email protected].

To protect information from accidental or malicious destruction, we may maintain residual copies for a brief time period. But, if you delete your account, your information and content will be unrecoverable after that time. Winnow may preserve and maintain copies of your information when required to do so by law.

DATA SECURITY

We use encryption (HTTPS/TLS) to protect data transmitted to and from our site. However, no data transmission over the Internet is 100% secure, so we can’t guarantee security. You use the Service at your own risk, and you’re responsible for taking reasonable measures to secure your account.

BUSINESS TRANSFERS

If we are involved in a merger, acquisition, bankruptcy, reorganization or sale of assets such that your information would be transferred or become subject to a different privacy policy, we’ll notify you in advance so you can opt out of any such new policy by deleting your account before transfer.

Email from Winnow

If you have an account, we may send you emails about your account, service changes or new policies. You can’t opt out of this type of “transactional” email (unless you delete your account). But, you can opt out of non-administrative emails such as digests, newsletters, and activity notifications through your account’s “Settings” page

When your interact with an email sent from Winnow (such as opening an email or clicking on a particular link in an email), we may receive information about that interaction. We won’t email you to ask for your password or other account information. If you receive such an email, please send it to us so we can investigate.

Changes to this Policy

Winnow may periodically update this Policy. We’ll notify you about significant changes to it by either posting a message to your account or emailing you at the email address listed in your account. The most current version of the policy will always be on this webpage.

QUESTIONS

We welcome feedback about this policy at [email protected]. If you wish to request a copy of the personal information we have about you or ask us to delete such information, you may do so through your account or by emailing us at [email protected]

PUBLIC NATURE OF PERSONAL DATA

If you post personal data or respond to something on the site in a public manner that reveals personal data, such posts or responses will be collected and treated as public instead of personal data. If you do not agree to such public treatment, do not use these features or act in a way that the public. discloses personal information.

CATEGORIES OF PERSONAL DATA COLLECTED

We collect the following personal data in relation to our registered users:

Logged out users

  • Reading history
  • IP address
  • Browser information
  • DNT status

Logged in users:

  • Username
  • Display name
  • Actual name
  • Email address (non-public)
  • Session activity (security)
  • IP address
  • Browser information
  • Reading history (on SwitchPoint Ventures network only)

Members generally:

  • Billing information and history and related financial/payment information (e.g., credit card or bank information)
CATEGORIES OF RECIPIENTS

Winnow shares minimal personal data with third-party processors in order to provide the Services. These processors offer at least the same level of data protection as that set out in this statement. This includes the following categories of recipients:

  • Hosting, Storage, & Other Infrastructure
  • Security
  • Analytics
  • Communication & Support
  • Payment Processors
  • Cross-border Transfers

Winnow is hosted in the United States. By using WinnowServices, you authorize Winnow to transfer, store, and use your information in the United States and any other country where we operate. Where your data is disclosed to our processors, it is subject by contract to at least the same level of data protection as that set out in this statement.

CHILDREN UNDER THE AGE OF 13

Our website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to us or the website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this website or on or through any of its features or register on the Website, make any purchases through the website, use any of the 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 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 [email protected]

YOUR CALIFORNIA PRIVACY RIGHTS

California Civil Code Section § 1798.83 permits California residents to request certain information regarding a business’s disclosure of customer information to third parties for that third party’s direct marketing purposes. For such requests, we have designated the following mailing address and electronic mail address to which you may deliver such requests:

Attn: California Information Privacy Issue
Winnow Health
3817 Bedford Avenue
Suite 220
Nashville, TN 37215
[email protected]

If you are a California resident and have an established business relationship with us, then you can request a notice disclosing the categories of personal information that (within the one year preceding your request) we have shared with third parties who we know have used the personal information for their direct marketing purposes within that year. You may also request those third parties’ names and addresses (and other information sufficient to give you a reasonable indication of the nature of the third party’s business, if the third party’s name alone does not reasonably make that determinable to you). You may request these types of information once a year. Please allow 30 days for a response.

If you are a California resident under 18 years old and a registered user, then you can request that we remove content or information that you have posted to our website or other online services. Note that fulfillment of the request may not ensure complete or comprehensive removal (e.g., if the content or information has been reposted by another user). To request removal of content or information, please contact us at the contact addresses designated above. Please allow 30 days for a response.