Privacy
Policy

PRIVACY NOTICE

Last updated August 05, 2020

Thank you for choosing to interact with The Wilen Group (affiliate companies including Wilen New York, LLC, Wilen Florida, and Wilen Vegas, LLC) (collectively “Wilen”, “Company”, “we”, “us”, or “our”). We are committed to protecting your (and your customer’s) personal and business information (hereafter, “Personal Information”) and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your Personal Information, please contact us at privacy@wilengroup.com.

When you visit any of our websites (the "Website"), and more generally, use any of our services (the "Services", which include the Website), we understand that you are trusting us with your Personal Information. We take your privacy very seriously. In this privacy notice, we seek to explain to you what information we collect, how we use it, and what rights you have in relation to it. Please read through it carefully. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

This privacy notice applies to all information collected through our Services (which, as described above, includes our Website), as well as any related services, sales, marketing, or events, unless explicitly superseded by written contract or other product or service specific privacy policy/notice posted or distributed by us.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

1. INFORMATION WE COLLECT

a. Wilen collects Personal, Business, and Customer information you disclose to us.

We collect Personal Information that you voluntarily provide to us when you work with Wilen including when you register on the Website, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website, or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and our Services, the choices you make, and the products and features you use. The Personal Information, provided by You, that we may collect includes, but is not limited to, names, phone numbers, email addresses, mailing addresses, job titles, usernames, passwords, contact preferences, contact or authentication data, billing addresses, and other similar information.

All Personal Information that you provide to us must (1) be true, complete, and accurate, (2) provided in accordance with all applicable law, and (3) not infringe upon the rights of others. You must notify us of any changes to such Personal Information that affects this warranty.

b. Information may be automatically collected.

Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Website or otherwise use any of the Wilen Services.

We automatically collect certain information when you visit, use, or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about where and when you use our Website, and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.  

The information we collect includes:

• Log and Usage Data. Log and usage data is defined as: service-related, diagnostic, usage, and performance information our servers and applications automatically collect when you access or use our Website or Services and which we record in log files. Depending on how you interact with us, and the security, management, and administrative needs of the website or service you are interacting with, this log data may include your IP address, device information, browser type and settings, and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error conditions and reports, and hardware settings).

• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information that includes your IP address (or the address of your proxy server, firewall or other NAT device ), device application identification numbers, location, browser type, hardware model, Internet Service Provider and/or mobile carrier (“ISP”), and operating system configuration information.
• Location Data. We collect location-based data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the capabilities, configuration, and/or settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information, or by disabling your Locations settings on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

c. Information collected from other sources.

We may collect limited data from public databases, marketing partners, and other outside sources.

In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion.

2. INFORMATION USE

We process your information for lawful purposes based on legitimate business interests, the performance of our contract with you, compliance with legal obligations, and/or your consent.

We use Personal Information collected via our Services for a variety of business purposes described below. We process your Personal Information for these purposes in furtherance of our legitimate business interests, to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• To facilitate account creation and logon processes. Use of Wilen Services, including portions of any of our Websites, may require the creation of an account for security and access purposes. Additionally, if you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allow us to collect from those third parties to facilitate account creation and logon processes for the performance of the Services or contract.
• To post testimonials. We may post testimonials on our Website that may contain Personal Information. Prior to posting a testimonial, we will obtain your consent to use your name and the consent of the testimonial. If you wish to update, or delete your testimonial, please contact us at privacy@wilengroup.com and be sure to include your name, testimonial location, and contact information.
• Request feedback. We may use your information to request feedback and to contact you about your use of our Services.

• To enable user-to-user communications. We may use your information to enable user-to-user communications with each user's consent.
• To manage user accounts. We may use your information for the purposes of managing your account(s) and ensuring it functions properly.
• To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
• To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
• To enforce our terms, conditions, and policies for business purposes, to comply with legal and regulatory requirements, or in connection with our contract.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Website or use of our Services.
  Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.
• To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
• To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us, our Website, or Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time by following instructions provided herein.
• Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

• Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
  
  
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
  
  
• Performance of a Contract: Where we have executed a contract with you, we may process your personal information to fulfill the terms of our contract.
  
  
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  
  
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

Additionally, we may need to process your data or share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company or legal entity.

• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include any parent or holding company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

We may use cookies and other tracking technologies (like web beacons and pixels) to collect and store your information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

5. GOOGLE MAPS

We may use Google Maps (or other mapping technology) for the purpose of providing relevant services.

We may use Google Maps APIs which is subject to Google's Terms of Service. You may find the Google Maps APIs Terms of Service here. To find out more about Google’s Privacy Policy, please refer to this link. We obtain and store on your device ('cache') your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document.

6. INFORMATION RETENTION

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your Personal Information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). However, no purpose in this notice will require us to keep your personal information for longer than the time in which users have an account with us.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize such information, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

7. INFORMATION SECURITY

We protect your Personal Information through a formalized system of administrative, procedural, and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any Personal Information we process and in accordance with industry standards. Additionally, we perform annual third-party audits of our information security practices. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Accordingly, we cannot promise or guarantee that hackers, cyber-criminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your Personal Information, transmission of Personal Information to and from our Website or Services is at your own risk, subject to any formalized written agreements. You should only access the Website within a secure environment.

8. WE DO NOT COLLECT INFORMATION FROM MINORS.

We do not knowingly collect data from, or market to children under 18 years of age.

We do not knowingly solicit data from, or market to children under 18 years of age. By using the Website, you represent that you are at least 18 years old, or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any information we may have collected from children under age 18, please contact us at privacy@wilengroup.com

9. YOUR PRIVACY RIGHTS

You may review, change, or terminate your account at any time.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

    ■  Log in to your account settings and update your user account.

    ■  Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our systems or files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or functions of our Website or Services. To opt-out of interest-based advertising by advertisers on our Website visit http://www.aboutads.info/choices/.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list. However, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

    ■  Access your account settings and update your preferences.

    ■  Contact us using the contact information provided.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

11. SPECIFIC PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS.

If you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).  

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, certain rights and obligations apply regarding your personal information.

Categories of Personal Information we may collect:

We have collected the following categories of Personal Information in the past twelve (12) months:

We may also collect other personal information outside of these categories in instances where you interact with us in-person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries
  
  

Our use of your personal information.

Information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by any method listed on our Websites or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

How your Information may be shared.

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

 We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.

 Wilen has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Wilen will not sell personal information in the future belonging to website visitors, users, and other consumers.

Your rights with respect to your personal data:

Right to request deletion of the data - Request to delete

You can ask for the deletion of your Personal Information. If you ask us to delete your personal information, we will respect your request and delete your Personal Information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

 Right to be informed - Request to know

Depending on the circumstances, you have a right to know:

• whether we collect and use your Personal Information;
• the categories of personal information that we collect;
• the purposes for which the collected Personal Information is used;
• whether we sell your Personal Information to third parties;
• the categories of Personal Information that we sold or disclosed for a business purpose;
• the categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and
• the business or commercial purpose for collecting or selling Personal Information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

 Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights

 We will not discriminate against you if you exercise your privacy rights.

 Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

 We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

 Other privacy rights

• You may object to the processing of your personal data
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.

To exercise these rights, you can contact us through this Website, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

12. UPDATES TO THIS NOTICE.

We will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

13. CONTACT INFO

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), by email at privacy@wilengroup.com, or by post to:

The Wilen Group 

45 Melville Park Road

Melville, NY 11747

United States

RIGHT TO REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU:

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request to privacy@wilengroup.com. We will respond to your request within 30 days.