Privacy Policy

Privacy Policy

Effective date January 2020

This Privacy Policy describes how Winter Properties LLC (“Company,” “we,” “us,” “our,” or “ourselves”) collects and processes your personal information, including the types of personal information we hold about you, our purposes for processing that information, the entities with which we share personal information, and your rights with respect to this information. Personal information includes information, or a combination of pieces of information that relates to or could identify you, or, in certain states, your device or household. This Privacy Policy applies to all instances in which you provide, or we otherwise collect, personal information, including through our digital platforms and any other platform that links to this Privacy Policy, such Company website(s), product review tools or services, and mobile applications (“apps”). This Privacy Policy also applies to the information that we may collect via social media platforms and our electronic communications. 

By accessing our digital platforms, registering for any of our product warranties or guarantees, or otherwise providing us with your personal information, you agree to this Privacy Policy. This includes changes that we may post here from time to time.

We collect personal information from and about you.

Information collected directly from you. We collect the information you provide to us, for example by making purchases; entering information on our digital platforms and social media accounts; registering for an account, warranty, guarantee, or portal; or posting in public forums. We may receive the following types of personal information directly from you:  

  • identifiers (e.g., name, mailing address, email address, phone number, username, password); 
  • protected characteristics (e.g., gender, age, or other classifications under applicable law);
  • family details (e.g., marital status, name of partner); 
  • financial(e.g., bank account information, bank or credit card numbers, payment information);
  • professional or employment-related information (e.g., job title, department, office address and business contact information, professional communications and correspondence); 
  • communications (e.g., responses to polls or surveys, questions, comments, or requests you send us);
  • audio, electronic, visual, thermal, olfactory, or similar information (e.g., graphics, photographs taken at our events);
  • internet or other electronic network activity information (e.g., browsing history, search history, interactions with platforms and applications);
  • geolocation data; and
  • inferences drawn from any of the information identified herein.

By providing information to us, you represent and warrant that you own or otherwise control all of the rights to the content that you provide; that the content is accurate; that use of the content you supply does not violate this Policy and will not cause injury to any person or entity. We take no responsibility and assume no liability for any content provided by you or any third party. 

Information we collect automatically or generate about you. We, our service providers, and other businesses that support our business operations, including, but not limited to, third party providers of advertising or analytics services, may use technologies like cookies and pixel tags to automatically collect information when you access our digital platforms or interact with our electronic communications. The information that we collect automatically or manually may include technical information from or about your computer, mobile device or Wi-Fi network (including SSID and password for certain apps), DHCP, the browser you use, your search history, the number of times you visit our platforms, the device you use, identifiers associated with your device, your device’s operating system, the content you view on our digital platforms, the content you view immediately before and after using our digital platforms, product preferences, and the programs and services you use with us or others. We, our service providers, and third parties (e.g., network advertising companies) may collect information about your online activities over time and across different websites when you use our digital platforms. 

Information collected from third parties. We may obtain information about you from third parties. For example, our business partners may provide us with information about you. The types of personal information we may obtain from third parties may include, without limitation, and to the extent permitted by applicable law:

  • identifiers (e.g., name, mailing address, email address, phone number, username, password); 
  • protected characteristics (e.g., gender, age, or other classifications under applicable law);
  • family details (e.g., marital status, name of partner); 
  • financial information (e.g., bank account information, bank or credit card numbers, payment information);
  • professional or employment-related information (e.g., job title, department, office address and business contact information, professional communications and correspondence); 
  • audio, electronic, visual, thermal, olfactory, or similar information (e.g., graphics, photographs taken at our events);
  • internet or other electronic network activity information (e.g., browsing history, search history, interactions with platforms and applications);
  • geolocation data; and
  • inferences drawn from any of the information identified herein.

We use personal information as disclosed and described here.

We use information to provide you with services, including on our digital platforms or in connection with our products and apps, and to respond to your requests, inquiries, comments, and questions. We also use information to send you products you may want to purchase.

We use information to troubleshoot and improve our products and services, including our digital platforms. We may use the information we collect to customize your experience with us.

We use information for marketing purposes. For example, we might use the information we collect to send you information about products, services or special offers that we believe may interest you. This might include information about upcoming contests or promotions. We may use the information we collect to deliver advertisements based on your activities on our digital platforms and third party websites and apps. For example, if you view one of our products on our website, you may receive an online ad for that product or a related product on our digital platforms or on third party websites and apps.

We use information to communicate with you about your account or our relationship. For example, we might tell you about changes to our platforms or to your accounts. Or we might reach out to you and ask you to take a customer satisfaction survey.

We may use the information we collect for analytical purposes, such as to better understand the interests and preferences of our customers, people who use our digital platforms, and people who buy our products. For example, we may use information to generate and analyze aggregate statistics about how users interact with our digital platforms.

We may combine the information we collect. For example, we might combine information you give us with information we get from a public source. We might also combine information we collect from you with information we get from third parties. When we do so, we treat the combined information as disclosed in this Privacy Policy.

We use information as permitted by law and as otherwise disclosed to you. For example, we may use the information we collect to protect the rights and property of us, you, and others; to comply with any legal or regulatory obligations; to handle legal claims or disputes; or to otherwise operate our business.

We may share personal information with third parties.

We will share information within our Company.  We may share your information with our affiliates or subsidiaries. 

We will share information with service providers who perform services on our behalf, in which cases your personal information may be used for any of the purposes set forth in this policy, but only as directed by us for the purposes of performing certain services. For example, we may share your information with vendors that handle credit card processing and shipping, provide us with data management services, manage our digital platforms, or manage our communications and perform market research for us.

We may share information with third parties, such as marketing partners. For example, we might share information with a company with whom we are running a joint promotion, or with online network advertisers and similar companies to facilitate the delivery of marketing communications on our digital platforms and third-party websites and apps. Those communications may include ads regarding our or others’ products based on your interests. We may use third party analytics providers that collect information about your use of our digital platforms to help us understand how people interact with those digital platforms.

We will share information in order to comply with the law or to protect ourselves. For example, we will share your information with legal authorities when it is necessary to do so. We may also share your information in situations where we think that our rights or the rights of our users or others are at risk.

We may share information with any successor to all or part of our business. We may share your information as part of or as reasonably necessary to proceed with a transfer of business assets.

We may share information for other reasons we may describe to you. And we may share aggregate information or information that does not reasonably identify you with third parties for any reason.

The following types of personal information may be shared with these parties:

  • identifiers (e.g., name, mailing address, email address, phone number, username, password); 
  • protected characteristics (e.g., gender, age, or other classifications under applicable law);
  • family details (e.g., marital status, name of partner); 
  • financial information (e.g., bank account information, bank or credit card numbers, payment information);
  • professional or employment-related information (e.g., job title, department, office address and business contact information, professional communications and correspondence); 
  • communications (e.g., responses to polls or surveys, questions, comments, or requests you send us);
  • audio, electronic, visual, thermal, olfactory, or similar information (e.g., graphics, photographs taken at our events);
  • internet or other electronic network activity information (e.g., browsing history, search history, interactions with platforms and applications);
  • geolocation data; and
  • inferences drawn from any of the information identified herein.

Your privacy rights.

Subject to local law, you may have certain rights in relation to your personal information. Such rights may include the following rights to: access your personal information; have inaccurate information corrected; request that your personal information be deleted; limit the use or disclosure of your personal information; or request to receive your personal information in a usable electronic format that can be transmitted to a third party.  We will fulfill your data requests in accordance with applicable law. 

To exercise these rights, you may be required to provide additional information to verify your identity or otherwise as necessary to assist us in fulfilling your request. Please use the contact details below for more information or to exercise available rights please click here

Notice to California Residents:

If you are a California resident, the California Consumer Privacy Act (“CCPA”) provides you with the right to opt out of our sharing of your personal information with third parties where such sharing would be considered a “sale” under the CCPA.  The law also provides you with certain other rights with respect to your data. Although not legally required, we also extend to all US customers the ability to make these types of requests, which we consider on a case by case basis. Use this form to submit these requests.

You have certain choices about sharing, marketing, and tracking.

You can opt out of receiving our marketing emails. If you are a registered user, you can opt out of marketing emails by clicking here. You can also follow the instructions in any promotional message you get from us. Even if you opt out of getting marketing messages, we may still send you service-related announcements and transactional messages. In our mobile apps, you may be able to disable push notifications within the settings menu.

You may be able to control cookies on your device. Most web browsers give you the ability to control cookies. How you do so depends on the type of cookie. Certain browsers can be set to reject browser cookies. To control flash cookies you can go here. If you choose to block cookies, you may not be able to take advantage of all aspects of our digital platforms.  For more information about the cookies we use please see our Cookie Notice. [Insert Hyperlink to Cookie Notice]. 

In addition, you can learn about opting out of receiving interest-based ads from some or all participating companies by clicking here.

These digital platforms and children.

Our digital platforms are intended for people who are 13 years of age or older. We do not knowingly collect personally identifiable information from children under 13 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 13 has given us information, you can email us [email protected] You can also write to us at the address listed at the end of this policy. Please mark your inquiries “COPPA Information Request.”

Parents, you can learn more about how to protect children’s privacy on-line here.

We use reasonable security measures.

We use reasonable security measures to protect our systems and the personal information we hold. Please be aware that, despite our ongoing efforts, no security measure is perfect or impenetrable. Moreover, information submitted via the Internet or wireless networks is not 100% secure and we are not responsible for the security of information that you transmit over networks that we do not control. 

We keep personal information as long as it is necessary or relevant for the practices described in this Privacy Policy. We also keep information as otherwise required by law.

We process your information in the United States.

We process your information in the United States. In some cases, our service providers may transfer or store your information in a country that may not have the same legal protections as your home country. Additionally, information located outside of your home country may be subject to access by that country’s government or its agencies under lawful order.

Our digital platforms offer links to other websites and third-party services that we don’t control.

If you click on a link to a third party website, you will be taken to a website or application that we do not control such as our business partners’ websites or social media networks. Please read the privacy policies of any third party websites or applications that you visit. Your use of those websites or applications will not be governed by this Privacy Policy, and we are not responsible for those third party practices. Our platforms may also have third party content or services we do not control. This may include passive tracking tools.

Contact us if you have any questions.

If you have any questions about this Privacy Policy or if you wish to exercise any available rights with respect to your personal information, please email us at: [email protected].

You can also write us at:

Winter Properties LLC
9 West 57th Street, 46th floor
New York, NY 10019

We may update this Privacy Policy.

From time to time we may change our privacy practices and we will update this Privacy Policy accordingly. We will notify you of any material changes to this Privacy Policy as required by law. We will also post an updated copy on our website. Please check our website periodically for updates.