WIN Learning Corporate Website Privacy Policy

Effective Date: April 29, 2015

Updated: August 1, 2025

Below is the WIN Privacy Policy (the “Policy”). This Policy helps you to make informed decisions about your relationship with us, so please read it carefully.

Introduction

To provide you with this website (“Website”), WIN Learning (“WIN”, “we”, “us”, or “our”) needs to collect some information about you, and this Privacy Policy is where we describe the Personal Information we collect, what we do with it, and how you can manage and control the use of your information. By using or interacting with the Website, you are entering into a binding contract with us and consenting to the use of your information as explained in this Policy. If you don’t agree with these terms, then please don’t use the Website.

What information WIN collects about you

Your "Personal Information" is any information about you that could, alone or together with other information, personally identify you or otherwise be reasonably linked or connected with you. We may collect the following categories of Personal Information about you:

Identifiers such as your username, password, email address, and full name that we may collect if you register on the Website,
Professional information such as your title and any affiliated organization,
User generated content that may enter information into a free text field, or from multiple choice or drop-down selections while using the Website,
Internet protocol (IP) address (and related IP-address based location information),
The type of device/operating system/browser used to access our Website,
Your preferences within the Website,
Web analytics data such as your web page interactions, referring webpage/source through which you accessed our Website, or other statistical information.
We will also collect any Personal Information that you provide us through communications with us.

We collect information about you through a few different channels, including:

Information You Give Us. For example, we may ask you to tell us your‎ name, email address, demographic information (such as your occupation), company affiliation, username and password through your direct interaction with us.

Information We Get From Others. Certain features of our Website are facilitated by outside third parties. For example, if you register for an online event, you may be sent to a third party website to register, and we will obtain information from that website in order to process your registration.

Information We Collect in the Background. As further described below, we automatically collect information from cookies and similar technologies (such as cookie ID and settings) to keep you logged in, to remember your preferences, to identify you and your device and to understand what works on our Website and what doesn't work so you get the best experience.

What information WIN does not process about you

WIN does not purchase or receive your Personal Information from third-party data brokers.

Our Website is not directed to children under the age of 13, and we do not knowingly collect Personal Information from children under 13. If you are under 13 years of age, do not use our Website and do not provide any personally identifiable information to us. If we discover that a child under 13 has provided us with Personal Information, we will delete it. If you are the parent or guardian of an individual under age 13 and believe they have provided us with their Personal Information, please contact us to have it deleted.

WIN will never directly use your Personal Information to train our AI models, or those provided by our third parties.

How WIN uses your Personal Information

The following are examples of how we may use your Personal Information:

Deliver Website, products and services you request;
Anonymize and/or aggregate your Personal Information, including for use within product development, analytics, and AI training and development;
Use your Personal Information within AI enabled features to generate output at your direction;
Provide customer service, such as communicating with you and addressing issues you may be having on our Website;
Operate, maintain, monitor for errors or bugs on our Website, and improve our product, products, and services;
Communicate to you updates to our product, upcoming webinars, and information that we think may be of interest to you;
Send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity in our Website or events; or
Enforce this Policy, the Terms and Conditions of Use, and the Application Terms, including to protect the rights, property or safety of WIN, users or any other person and the copyright-protected content of the Website.

Our use of cookies and tracking

“Cookies” are small text files that websites often store on computer hard drives or mobile devices of visitors. We may use both “session cookies'' (which expire once you close your web browser) and “persistent cookies'' (which stay on your computer until you delete them). In addition, we use third-party cookies, like Google Analytics. We are selective in which third-party cookie providers we use, starting with reviewing their privacy policies like you are doing here.

When you visit our Website, essential cookies (which are necessary for our Website to function on your browser or device) will always be placed. You may be prompted to consent to or opt out of the use of all other cookies. To change your cookie settings after your first visit, or see the names of third-party cookie providers we work with, the type of information they might receive, and the service they provide you can do so by clicking the cookie icon in the lower left corner of the website.

By opting in or choosing not to opt out via our cookies banner, you are agreeing that we can place non-essential cookies on your computer or device. You have the option to not accept these non-essential cookies, but doing so may reduce the quality of your experience by blocking valuable features of the WIN Website that are available to other users, some of which are described below.

We use cookies, logging and tracking tools for a variety of reasons including to provide, secure, and improve our product for you. These cookies may affect your experience with our Website for example, to:

remember choices you made in prior sessions so you do not need to repeat them;
understand how you use our product in order to perform our contract with you or your employer or educational institution;
identify your device for security purposes;
develop an understanding of how our Website is being used, which pages may be working as intended, and which pages may have room for improvement;
learn your computer operating system type, browser type, and browser language, in order to understand system settings that could inform how we design our Website; or
understand which sites may have led you to our Website.

Does WIN respond to Do Not Track Signals?

WIN does respond to Do Not Track requests.

How WIN shares the information we collect about you

WIN is committed to protecting your Personal Information by limiting the sharing of your Personal Information to only those who have a legitimate need to know. We collect limited Personal Information about you.

The following are examples of how we may share your Personal Information.

Categories of recipients

Reason for sharing

Service providers

Our service providers help us provide our Website effectively; for them to provide their service, we need to share your Personal Information. Our service providers include software-as-a-service hosting companies, cloud security gateways and email delivery platforms.

Law enforcement and data protection authorities

If required to do so, we will share your Personal Information for legal, protection, and safety purposes, such as:

To comply with laws;
To respond to lawful requests and legal processes;
To protect the rights and property of WIN, our agents and customers. This includes enforcing our agreements, policies, and Terms; or
In an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.

Potential purchasers of our business

If we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets, we will be required to share your Personal Information. These deals can include any merger, acquisition, or bankruptcy transaction or proceeding.

Your Personal Information does not include aggregated or non-personally identifying information that does not identify you or cannot otherwise be reasonably linked or connected with you. We may use such aggregated, non-personally identifying information to operate, analyze, improve, and optimize our Website, or for any other legally-permitted purpose. We may also publicly display insights based on aggregated information, such as how our Website is used.

How long we store Personal Information and how you can access and control the information we collect

We retain your Personal Information for as long as your account is active or as needed to provide you the Website; that duration can vary based on the context. How long we retain your information is determined by:

how long your Personal Information is needed to provide our services and operate our business;
the type of Personal Information collected; and
whether we are subject to a legal, contractual or similar obligation to retain the Personal Information (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).

Marketing emails

You may consent to receive marketing emails and join our mailing list. You can also opt-out at any time by following the instructions in our marketing emails. Opting-out of marketing emails will not affect your receipt of non-marketing emails such as emails about your account and our business dealings with you.

How WIN secures your information

We are committed to protecting our users’ information. Your password protects your user account, so you should use a unique and strong password, limit access to your computer and browser, and sign off after having used the Website. We use industry-standard methods and technology to protect your information. Though we will take reasonable steps to protect your information, we cannot guarantee the security of your information at any time.

Our privacy policy does not apply to third party sites

Our Website contains hyperlinks and pointers to internet sites maintained by third parties. You should be aware that, once you leave our Website, we do not control, operate or endorse in any respect information, products or services provided by third parties. Many third parties have their own Privacy Policies that differ from ours. This Privacy Policy only covers our Website and does not cover any other third parties. While we make every effort to keep your information secure, we do not control the policies of other parties.

How we communicate with you about our privacy policy

WIN may change our Privacy Policy from time to time; most changes are likely to be minor. We will provide notification to registered account holders of material changes to this Privacy Policy through our Website at least 30 days prior to the change taking effect by posting a notice on our home page or sending email to the primary email address specified in your WIN account. Your continued use of the Website thereafter constitutes acceptance of the changes.

Your Privacy Rights

Information We Collect

We may collect the following categories of Personal Information from consumers, and have collected such information within the last twelve (12) months (from the date of this Privacy Policy), depending on which of our products and services were used by consumers:

Identifiers - A real name, alias, postal address, unique personal identifier, online identifier, login information for our products and services, phone numbers, IP address, email address, or other similar identifiers.

Commercial information - Information related to your interactions with our products or services, including those you have purchased, obtained, considered, or your activity and preferences while using our Website.

Internet or other similar network activity - Information about your browsing history, viewing activity, search history, interactions with our website, application, or advertisements, and the content of messages exchanged through our platforms.

Geolocation data - Data such as physical location or movements or device location, generalized location data based on your IP address (such as your general jurisdiction to determine language).

Sensory data - Audio, electronic, visual, or similar information, such as photos and videos on our products or services.

Professional or employment related information.

Non-public education information - This may include education records where provided by our educational organization customers.

Inferences drawn from your Personal Information to create a profile reflecting your preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitude.

Sharing Personal Information

We may share your Personal Information by disclosing it to a third party for a business purpose, as provided in this Privacy Policy.

Your Rights and Choices under Applicable Privacy Laws

Depending on your location you may be afforded with specific privacy rights, such as those provided by The California Consumer Privacy Act of 2018, as amended (“CCPA”) for those in California.

Your Rights

We will not discriminate against you for exercising any of your rights under applicable Privacy Laws.

Please note that depending upon your data choices, certain products and services of ours may be limited or unavailable.

As a consumer, you may have the following rights under the applicable Privacy Laws:

Right to Know - You have the right to request that we disclose the specific pieces of Personal Information we have collected about you (the “right to know”), after we receive and validate your request. This right also includes data portability, which means you have the right to receive a copy of your Personal Information in a format required by the applicable Privacy Laws.

Right to Delete - You have the right to request that we delete your Personal Information, subject to applicable legal exceptions (the “right to delete”). After we receive and validate your request, we will delete your Personal Information, as well as direct our service providers to delete your Personal Information, unless an exception applies.

Right to Correct - You have the right to request that we correct inaccurate Personal Information that we maintain about you, subject to applicable legal exceptions. You may be able to correct certain information in your account on our products or services as well.

Right to Opt Out of Personal Information Processing for Targeted Advertising and Sales

Right to Opt Out of Personal Information Processing for Profiling - This right is generally available where profiling (automated decision making) is being used in furtherance of decisions that produce legal or similarly significant effects.

Right to Limit (or Opt Out of) or Require Consent to Process Sensitive Personal Information. You may have the right to request that we limit sensitive Personal Information use to specifically permitted purposes, or that we must obtain your prior consent or provide an opportunity to opt out in order to process your sensitive Personal Information.

If you would like to exercise any of these rights, please contact us using the details provided below in the section “Contacting WIN”. You can access and amend some of the information we keep on you through your settings.

Exercising Your Rights to Know or Delete

Only you, your Authorized Agent (as described below) or someone legally authorized to act on your behalf, such as a parent or legal guardian submitting a request for their child, may make a request to know or delete related to your Personal Information.

Depending on your location you may authorize another person or entity to submit an access or deletion request on your behalf (an “Authorized Agent”). As part of our verification process, we will require proof concerning their status as an Authorized Agent. We may also require you to directly confirm with us that you provided such person or business entity with permission to submit the request.

Any request to know or delete from you or your Authorized Agent must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information, or their Authorized Agent, parent or legal guardian, if applicable.

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.

You do not need to create an account with us to submit a request to know or delete.

De-identified Data Disclosure

WIN may use de-identified data in some instances. WIN either maintains such data without attempting to re-identify it or treats such data as Personal Information subject to applicable law.

Personal Information Sales and Sharing Opt-Out and Opt-In Rights

Sharing or Targeted Advertising - WIN may "share" (as defined under the CCPA) your Personal Information in certain cases or may use your Personal Information for Targeted Advertising (as defined under State Privacy Laws). For example, we may disclose information to advertising partners, advertising technology companies, and companies that perform advertising-related services in order to provide you with more relevant advertising tailored to your interests on the WIN products and services. This information may include identifiers such as your IP address, advertising identifiers, your email address, your internet or other electronic network information such as your interaction with an ad, and geolocation data.

Sales - WIN may disclose certain information about you for purposes that may be considered a “sale” under applicable Privacy Laws.

If you are age 16 or older, you have the right to direct us to not "sell" or "share" (as either term is defined in the CCPA) your Personal Information at any time (the “right to opt-out”). California residents we actually know are under 16 years old (and at least 13 years old) must give us affirmative authorization (the “right to opt-in”) in order for us to sell or share their Personal Information. California residents who opt-in to Personal Information sales may opt-out of future sales at any time.

Exercising your rights - To exercise the right to opt-out of the sale or sharing of your Personal Information or use for targeted advertising under the applicable Privacy Laws, you or your Authorized Agent (certain US states only) please contact us using the details provided below in the section “Contacting WIN”.

However, you may change your mind and opt back in to Personal Information sales at any time by contacting us using the details provided below in the section “Contacting WIN.”

You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request.

Other Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents (using the websites in their personal or household capacity) to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us using the details provided below in the section “Contacting WIN”.

Contacting WIN

We welcome your comments or questions about this privacy policy. You are welcome to email us at privacy@winlearning.com and you can also send mail to:

WIN Learning, Inc.,

1000 Waterford Place

Kingston, TN 37763

USA

WIN is a registered trademark of WIN Learning.