Winfosoft Privacy Policy

HOW TO SUBMIT A PRIVACY REQUEST

If you would like to exercise any of the rights in the preceding section (“Privacy Request”), please contact us. We will not discriminate against you for exercising your rights under privacy laws. Further information on the steps needed to complete your Privacy Request are detailed below.

Step 1: Verifying your Request.

Before we can fulfill your Privacy Request, we need to verify your identity or your authority to make the request (if you are submitting a Privacy Request as an agent) and confirm that the personal information you are requesting belongs to you.

For most requests, we will ask you to provide information that matches at least two pieces of personal information we store about you before responding to your Privacy Request. If you would like to request specific pieces of personal information that we have collected, you will need to match at least three pieces of information we store about you, and you must provide a signed declaration under penalty of perjury that you are the individual whose personal information you are requesting. If you have a password-protected account with us, we may use our existing authentication procedures to verify your identity, however, you are not required to have an account with us to make a Privacy Request. 

We may refuse any request if we are unable to verify the identity of the person making the request or if we cannot authenticate the legitimacy of the request using commercially reasonable efforts. Under such circumstances, we may follow up with you for additional information as reasonably necessary to authenticate your request. We will only use personal information provided in a verifiable Privacy Request to verify the requestor’s identity or authority to make the Privacy Request.

Authorized Agents

You may grant an authorized agent written permission to submit Privacy Requests, but we may deny requests from an authorized agent if we are unable to verify your identity directly as the subject of the personal information at issue. To verify a Privacy Request from an authorized agent, we may require proof that you gave the authorized agent signed permission to submit the Privacy Request, such as by requiring you to directly confirm with us that you provided permission for the authorized agent to submit your Privacy Request, and/or we may ask you to verify your identity directly with us.

Step 2: Responding to your Privacy Request.

After verifying your identity, we will respond to your request by either fulfilling your Privacy Request or explaining why we are denying your Privacy Request. The timeframe in which we respond will vary based on the applicable law where you reside. If we deny your Privacy Request, you may have the option under applicable law to appeal this decision by contacting us. If you are concerned with the result of your appeal, you may have the right to contact your State Attorney General or other applicable data protection authority.

Deletion Requests

Please note that for deletion requests, any removal of content by us does not ensure or guarantee complete or comprehensive removal in all places. The content may have been shared or reposted by other parties who act outside of any business relationship with us or who may not cooperate with our request for them to delete your personal information, or federal or state law may require maintenance of the content or information. We will do our best to accommodate your Privacy Request, but we cannot guarantee we can remove all personal information from the specified uses. Therefore, please be as specific as possible in your Privacy Request. If the Privacy Request relates to information that we need to provide Services to you, you may not be able to use the Services properly moving forward. We reserve the right to maintain proper business records as required by law, or for otherwise legitimate business purposes to the extent permitted by law, even if such records contain your personal information.

DATA RETENTION

We retain personal information as needed to provide the Services or for other legitimate purposes such as ensuring security of our data and systems, complying with our legal obligations, complying with tax, audit, or other books and record policies, resolving disputes, conducting internal investigations, and enforcing our agreements or other legal rights. Due to the different purposes for retaining your personal information, the actual retention timeframes may vary depending on the type of personal information we collect from you and the purposes for which we use your personal information. Our retention policy is generally informed by the following factors:

• Is this information necessary to provide the Services?
• If consent was obtained, what timeframes were indicated in the consent?
• What statutory, contractual or other legal obligations do we have to retain this information?

If we determine that your personal information is no longer needed for the purposes described above, it will be deleted or anonymized so that it can no longer be attributed to you. Our retention times will be consistent with applicable law. Please note that residual copies of your personal information may be removed from backup systems subject to our backup data retention schedule.

DATA SECURITY

We have implemented technical and organizational measures reasonably designed to address the risk of loss, misuse, alteration, or unauthorized disclosure of personal information under our control. We limit access to your personal information to those employees, agents, contractors, and third parties who have a need to know such information to provide the Services and/or to instances where disclosure is necessary, such as in response to a threat to you, Winfosoft, or others, or as otherwise required or permitted by applicable law. We require that third parties only process your personal information to provide services for or on our behalf, and implement security measures to keep your information confidential and secure.

While we have employed security technologies and procedures to assist in safeguarding your personal information, no system or network can be guaranteed to be 100% secure, and we cannot guarantee that the information you send over the internet is fully secure. You should exercise discretion in what information you disclose and/or transmit on or through our Services. The transmitted information may be intercepted by others before it reaches us. Please note that e-mail communications are typically not encrypted and should not be considered secure. If you are concerned about sending information to us over the internet, please send the information by mail or call us to make other arrangements. We are not responsible for the security of information transmitted online. Likewise, when you click on Third Party links from our Site, we cannot control the security measures used on such Third Party sites or applications. If you have an account with us, you are responsible for maintaining the secrecy of your log in credentials and account information, and for controlling access to your email account and any electronic communications from us.                      

POLICY CHANGES

We reserve the right to change this Policy at any time. Since this Policy may change as we modify or expand our Services or to comply with changes in applicable laws, we suggest you check back from time to time to stay informed of such changes. Our Policy’s “Last Updated” or effective date will always be set forth at the beginning of the Policy. Any changes will be immediately incorporated into this Policy and will be prospective only. We will not make any changes that have retroactive effect unless legally required to do so. Your continued use of the Services after any changes are made to this Policy constitutes your acceptance of the changes. If any changes are unacceptable to you, you should cease all use of the Services. We will not collect new types of personal information, or use personal information for any unexpected purposes beyond what is disclosed in this Policy without using commercially reasonable efforts to provide you with notice and, to the extent required under law, obtaining your consent prior to the new collection and/or use of that personal information. We also will post the revised Policy here with a new “Last Updated” date.