Privacy & Cookie Policy

Introduction

Winnow Solutions, LLC is a limited liability company organized under the laws Delaware and is located at 5101 E La Palma Ave, Suite 101, Anaheim Hills, CA 92886 ( “Winnow” or “we”, “our”, “us”).

This Privacy & Cookie Policy ("Privacy Policy”) describes the personally identifiable and other information that Winnow collects through this website at www.winnow.law and equivalent domains (the “Site”) and our use of that information. Any Personal Information provided by you as a Winnow user (“you”, “your”, “User”, “Winnow User”) will be used only as described in this Privacy Policy and if you are a California consumer, our California Privacy Statement.

Winnow may share the information it collects through this Site with its parent, Orrick Herrington & Sutcliffe LLP (“Orrick”), and affiliated companies in the United States and in the United Kingdom. Orrick is the data controller for the processing of such information for purposes of the UK Data Protection Act 2018.

Please read the following carefully to understand our practices regarding information collected through the Site and how we treat it. By visiting the Site, you are accepting and consenting to the practices described in this Privacy Policy.

California Residents

If you are a California resident, you may have additional rights under California law. For more information, please visit our California Privacy Statement.

Information We Collect

A. Personally Identifiable Information

Winnow, through the Site, automatically collects “Usage Data,” which is information on how you use Winnow, such as pages visited, links clicked, non-sensitive text entered, and mouse movements, the referring URL (e.g., search engine), browser, operating system, and IP addresses. For Winnow Users, we engage service providers to approximate your geographic region and Internet Service Provider based on your IP address using publicly available sources. Winnow collects Usage Data to better understand how Winnow is being used. We may also collect cookies from your browser. For additional detail on Winnow’s collection of Cookies, please see the next section for more information (“Additional Information on Our Use of Cookies”).

Additionally, we will collect the following categories of personally identifiable information only if you voluntarily provide us this information to subscribe to our electronic newsletters, request more information from us, request a service from us, including access to Winnow, or for other purposes:

  • Name

  • Username

  • Physical address

  • Email address

  • Telephone number

  • Other identifiers that allow us to contact you

We may add the information you voluntarily provide to us to our databases, subscriber lists, and contact lists, as well as those of our parent and affiliated companies. Please see “Contact Us; Opt-Out” below if you decide that you no longer wish to receive our or their materials. On rare occasions, though, we may email users’ important administrative information regarding the Site or services because such information may be important to your use of the Site. It may not be possible to “opt out” of receiving these types of emails in certain limited instances.

B. Non-Personally Identifiable Information

This Site may automatically collect non-personally identifiable information from you when you visit the Site. This information also is collected through cookies and may include, without limitation: your internet service provider, the type of browser and operating system that you use, and information about your Site visit, including date and time, length of stay, pages viewed, the website address, if any, from which you linked directly to the Site, the website address, if any, to which you travel from the Site, and other traffic information. Please see the next section for more information (“Additional Information on Our Use of Cookies”).

We use this non-personally identifiable information to help us improve the Site and the services we provide through it. We may do this by aggregating your non-personally identifiable information with similar information collected from other users. 

Additional Information on Our Use of Cookies

A. Overview

The Site uses cookies, which are small files sent from the Site to your browser or your computer, tablet, or mobile phone (“device”) and then stored on your device’s hard drive. A cookie records on your device information relating to your internet activity, such as whether you have visited the Site before.

We use the cookies to support Site functionality. We may also use them to collect statistical information that we analyze for insights on Site usage. We do not use cookies to collect any personally identifiable information about you.

You can use your browser’s settings to restrict or block the cookies sent by the Site. This would not prevent you from using the Site.

Cookies for Users of Winnow:

Winnow uses first-party cookies, third-party cookies, and other tracking technologies in order to:

  • Provide personalized pages for Users of Winnow,

  • Help us track email response rates, measure the success of our marketing campaigns, identify when our emails are viewed, and track whether our emails are forwarded,

  • Provide assistance in navigation and during a Winnow User’s session,

  • Troubleshoot after a Winnow User’s session,

  • Analyze your use of our products, services, or applications, and

  • Assist us with our promotional or marketing efforts.

We use the following types of cookies:

  • Strictly Necessary Cookies: These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms.

  • Performance & Functionality Cookies: These cookies are used to enhance the performance and functionality of Winnow, but are non-essential to their use. However, without these cookies, certain functionalities may become unavailable.

  • Analytics & Customization Cookies: These cookies collect information that is used either in aggregate form to help us understand how Winnow is being used or how effective our marketing campaigns are, or to help us customize Winnow and our websites and applications for you in order to enhance your experience.

In some instances, we may collect cookies from Google Analytics, a web analytics service provided by Google Inc., to understand how visitors use the Site. Cookies from Google Analytics do not gather any information that identifies you.

Because we respect your privacy rights, we provide you with an easy way you can opt-out of our use of some types of cookies. Please see the “Contact Us; Opt-Out” section of this Policy. Please know, however, that blocking some types of cookies may impact your experience on Winnow and the services we are able to offer. Additionally, please know that in addition to using your browser settings to restrict or block this Site’s use of Google Analytics cookies, you can restrict or block their use by every website you visit. To do this, visit this Google page.

How We Respond to Do Not Track Signals

Winnow does not track its Users over time and across third-party websites and therefore does not respond to Do Not Track (DNT) signals.  However, Winnow uses a third-party service provider to assist with its marketing, and as such the third party may use information, which does not identify users, to analyze trends, administer websites, track Users' movements around websites, and to gather demographic information about Winnow’s User base as a whole. The third-party service provider does not link this automatically-collected data to personally identifiable information. However, our third-party service provider honors DNT signals. However, our third-party service provider cannot collect any other personally identifiable information from Winnow unless the User provides it directly to the service provider.

How We Use Personally Identifiable Information

We use personally identifiable information collected by this Site and may share it with our parent and affiliated companies to:

  • Fulfill subscriptions you request

  • Respond to your inquiries and comments

  • Send you information regarding events and developments that may be of interest to you

  • Administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes.

  • To add you to contact lists and databases. 

Our Disclosure of Personally Identifiable Information

If you voluntarily provide us with your personally identifiable information through this Site, we, our parent, and our affiliated companies may share that information with our respective employees, contractors, agents, and designees for the purposes described immediately above in the subsection entitled “How We Use Personally Identifiable Information.” Generally, we do not disclose personally identifiable information collected through the Site to unaffiliated third parties without your further consent. However, if you register for a webcast or other event through our Site or a page linked from it, we reserve the right to share your registration information with unaffiliated third-party co-hosts, sponsors, presenters, and their respective organizations.

 We also may disclose such information to a third party if we believe that we are required to do so: (i) by law; (ii) to comply with legal processes or governmental requests; (iii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of the Site or our network; or (iv) to protect the rights, property, or safety of any of Winnow or its parent or affiliated companies, their partners, members, and employees, users of the Site, or the public.

Winnow also reserves the right to transfer any and all information we collect from users, or that we otherwise collect in connection with the Site, including, without limitation, to unaffiliated third parties, in the event of a sale or transfer of assets or portion of our business.

Where We Store Personally Identifiable Information

The personally identifiable information that you give us or that we collect from you may be transferred, stored, or processed outside the European Economic Area. By submitting this information to us, you agree to this transfer, storing, or processing. We take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy.

Security

Winnow employs industry-standard security measures designed to protect against the loss, misuse, or alteration of personally identifiable information under our control, but no security system, or system of transmitting data over the internet, is 100% secure. For that reason, we do not guarantee the absolute security of our servers, the means by which information is transmitted between your computer and our servers, or any information provided to us or to any third party through or in connection with the Site.

Links to Other Web Sites

The Site may contain links to websites owned by third parties that may collect personally identifiable information about your online activities over time and across different websites. We are not responsible for the privacy practices of these third parties, and any information you disclose on their sites is not subject to this Privacy Policy. You should consult the privacy policies of each website you visit. A link on this Site to one owned by a third party does not constitute endorsement, approval, association, sponsorship, or affiliation with the linked site unless specifically stated.

Children Under 13

The Site is intended for a general audience and is not directed to children under 13 years of age, from whom we do not knowingly collect personally identifiable information. We ask that users younger than 13 not provide any personally identifiable information while using the Site. If you become aware that a child has provided us with personal information without parental consent, please contact us here.

Changes to Privacy Policy

We reserve the right to update, revise, or otherwise change this Privacy Policy at any time, and any changes to the Privacy Policy will be effective upon posting. Use of the Site constitutes acceptance of the currently posted Privacy Policy, and users should review this Privacy Policy regularly to ensure that they are aware of its terms. Any changes to this Privacy Policy will be reflected on this page.

This Privacy Policy is in effect and was last updated on February 22, 2021.

Access to Personally Identifiable Information

You may request a copy of the information that we hold about you by emailing privacy@winnow.law. We may charge a fee of £10 (or U.S. dollar equivalent) toward the costs we incur in providing you with the information.

Contact Us; Opt-Out

If you no longer wish to receive materials from us or our parent or affiliated companies or want your personally identifiable information removed from our or their databases, please contact us at privacy@winnow.law. If you do, please specify whether your request applies to us, certain of our parent and affiliated companies, or our entire group. Alternatively, when you receive materials from us by email, you may make use of any other “opt-out” instructions we provide to stop receiving materials from us.

If you have any questions about this Privacy Policy or our collection and use of your personally identifiable information, please contact us at privacy@winnow.law.