Privacy Policy

Last modified: January 1, 2020

Introduction

Wenger Corporation ("Company" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the websites WWW.WENGER.COM (“Website") and our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies to information we collect:

On this Website.
In e-mail, text and other electronic messages between you and this Website.
Offline when you attend industry trade shows or social events

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time . Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

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 or on the Website without verifiable parental consent.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

by which you may be personally identified, such as name, postal address, e-mail address, telephone number or any other information the website collects that is defined as personal or personally identifiable information under an applicable law or any other identifier by which you may be contacted online or offline ("personal information");
about your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

Directly from you when you provide it to us.
Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies.

Information You Provide to Us. The information we collect on or through our Website may include:

Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, or requesting further services. We may also ask you for information when you report a problem with our Website.
Records and copies of your correspondence (including e-mail addresses), if you contact us.
Details of transactions you carry out through our Website and in the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
Your search queries on the Website.

Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

Details of your visits to our Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system and browser type.

The information we collect automatically helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

We do not collect personal Information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

Third-party Use of Cookies and Other Tracking Technologies.

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services . They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you.
To provide you with information, products or services that you request from us.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account, including expiration and renewal notices.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Website or any products or services we offer or provide though it.
To allow you to participate in interactive features on our Website.
To allow you to receive our newsletter and blogs
In any other way we may describe when you provide the information.
For any other purpose with your consent.
To provide you with communications about our products and services

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates.
To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Wenger assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Wenger about our Website users is among the assets transferred.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal information:

To comply with any court order, law or legal process, including to respond to any government or regulatory request.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Wenger, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by clicking on the following link _____________.
Promotional Offers from the Company. If you do not wish to have your e-mail address used by the Company to promote our own or third parties' products or services, you can opt-out by clicking on the following link________________..
We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Data Security

We have implemented measures reasonably designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

We reserve the right to update or revise this Privacy Policy at any time and without prior notice, by posting the revised version on this Website. The changes will be effective as of the date we post the revised version and apply to the personal information we collect after such date. Your use of the Website following any such change constitutes your consent to the terms of the revised Privacy Policy. You are responsible for periodically visiting our Website and this privacy policy to check for any changes

Special Notice to Those Who Reside Outside the United States

Our servers are located in the United States and all personal data is collected and processed by us in the United States. If you are not located in the United States your personal data will therefore be transferred to, processed, and stored in a country outside of the country where you live. By submitting your personal information to us, you are consenting to the processing of your personal information in the United States Your personal information will only be used by us for legitimate business purposes as set forth in this Privacy Policy. .

Special Notice for California Residents

The following applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, Wenger’s website has collected the following categories of personal information from its consumers within the last twelve (12) months:

A. Identifiers which may include a real name, postal address, telephone number, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.

B. Commercial information which may include records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

C. Internet or other similar network activity may include browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Personal information does not include:

· Publicly available information from government records.

· Deidentified or aggregated consumer information.

· Information excluded from the CCPA's scope.

Wenger obtains the categories of personal information listed above from the following categories of sources:

· Directly from you. For example, from forms you complete or products and services you purchase.

· Indirectly from you. For example, from observing your actions on our Website.

· From third parties who are authorized to provide us with such data

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following purposes:

· To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

· To provide, support, personalize, and develop our Website, products, and services.

· To create, maintain, customize, and secure your account with us.

· To process your requests, purchases, transactions, and payments and prevent transactional fraud.

· To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

· To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).

· To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.

· For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.

· To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

· As described to you when collecting your personal information or as otherwise set forth in the CCPA.

· To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Wenger's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Wenger about our Website users is among the assets transferred.

Wenger will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

Wenger may disclose your personal information to a third party for a business purpose related to the service or product we are providing you. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Wenger disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

· The categories of personal information we collected about you.

· The categories of sources for the personal information we collected about you.

· Our business or commercial purpose for collecting or selling that personal information.

· The categories of third parties with whom we share that personal information.

Deletion Request Rights

You have the right to request that Wenger delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

· Calling us at : 800-733-0393

· Clicking on the following link : https://www.wengercorp.com/dataprivacy

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

· Deny you goods or services.

· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

· Provide you a different level or quality of goods or services.

· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]

Changes to Our Privacy Notice

Wenger reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which Wenger collects and uses your information described below and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 800-733-0393

Website: www.wengercorp.com

Email:[email protected]

Postal Address: PO Box 448, Owatonna, MN 55060

Wenger Corporation

Attn: Data Analytics

555 Park Avenue, Owatonna, MN 55060

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

[email protected]

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