Information We Collect and Receive. For you to use our Site and Services, we need to collect and process certain types of information. Depending on your use of our Site and Services, this may include examples such as the following:

• Information you provide to us by completing forms on our website: For example, your name, contact, and address information, and any other information you may provide in the forms on the Site;
• Information you provide to us by contacting us: Any personal information you may provide to us when you email or call us, such as name, phone number, employer, and any other details you provide in your communications. Winthrop may also request your contact information for the purposes of having someone contact you for additional information, or in response to your request for information from us;
• Transaction information when you purchase Services from us: For example, if you pay for our Services with a bank account transfer or your credit card, we may use your payment information for billing and validation purposes;
• Job Applicant information: Current employer, current position, prior work history and education, resume information, qualifications for employment, and other information you provide us during the application process; and
• Information about your activity through our Site and Services, including your device information, such as your IP address, the type of device or browser you use, and your actions on the Site.

We will only use your personal information to provide you with information or Services you have requested, or for the purposes set out in this Policy. Personal information does not include aggregated information from which individual identities have been removed.

Information from Children. Winthrop does not knowingly solicit or collect any personal information from anyone under 13 years of age, and children under 13 are not permitted to register for or use our Site or Services, including by subscribing to receive information from Winthrop. Parents can contact our email address listed below to access, change, or delete the personal information that has been submitted by a child. If we become aware that a child under the age of 13 has provided us with personal information, we will delete it.

Cookies, Tracers, and Advertising. We may use cookies and similar technologies (e.g., web beacons, pixels, ad tags, and device identifiers) to recognize you and/or your device(s) on, off, and across the Site and different Services and devices. A “cookie” is a small file that is placed onto your device (e.g., computer, smartphone, or other electronic device) that stores information when you visit a website. Cookies may also enable us, our service providers, or other companies we work with to analyze your use of our Services over time to customize your experience. Clear GIFs, pixel tags, and web beacons are typically one-pixel, transparent images located on a webpage or in an email or other message. These, or similar technologies, may be used on our Sites and in some of our digital communications (such as email or other marketing messages). They may also be used when you are served advertisements or you otherwise interact with advertisements outside of our online services. These are principally used to help recognize users, assess traffic patterns, and measure site or campaign engagement.

However, you can control cookies through your browser settings and other tools. You can also opt-out from our use of cookies and similar technologies that track your behavior on the sites of others for third-party advertising. Neither the Site nor the Services respond to Do Not Track signals. Sometimes cookies are placed by us (“first-party cookies”) and sometimes they are placed by others (“third-party cookies”). The cookies that we place on your device may include:

• Essential cookies: these cookies are essential for you to be able to navigate our Site and use its features. Without these cookies, the services you have asked for could not be provided.
• Analytics cookies: these cookies collect information about how you use our Site; for example, which pages you go to most often. Much of the information collected by these cookies is aggregated and anonymous, and is only used to improve how our Site works.
• Functionality cookies: these cookies enhance your browsing experience and allow our Site to remember the choices you make (such as your username, language, last action, and search preferences) and provide enhanced, more personal features. The information collected by these cookies is anonymous and cannot track your browsing activity on other websites. Information collected by these cookies may include personal information you have disclosed.
• Marketing cookies: also known as advertising cookies, these cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement on our Site and help measure the effectiveness of the advertising campaign. This is sometimes referred to as online behavioral advertising. In some cases, our partners may use cookies to provide us with information about your interactions with their services. These cookies remember that you have visited a website, and this information is shared with other organizations such as advertisers. Those third-party cookies would be subject to the third-party service’s policies.

Use of Cookies:

Winthrop uses cookies and related technologies on our website to help us recognize your device as a repeat visitor, and enable certain website features and functionalities. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

Specifically, we use a mix of first-party cookies, third-party cookies, and other similar technologies on this website to:

• Recognize you whenever you visit this website;
• Support security and any authentication features on our website;
• Obtain information about your preferences and use of our website;
• Carry out research and statistical analysis to help improve our content, Site, and Services, and to help us better understand our clients’ needs;
• Improve the speed and performance of our website and Services; and
• Make your online experience more enjoyable and efficient.

If you turn off any cookies, please be aware that you may lose some of the functionality of this Site. For more information about cookies and how to disable them please check the following resource: http://www.allaboutcookies.org/

Winthrop may use the personal information we collect for the following purposes:

• To deliver our Services;
• To provide client service and our support services;
• To process any financial transactions you make while registering for or using our Services;
• To keep your information secure such as by detecting security incidents, and to be able to verify your identity and contact information;
• To alert you about updates, special offers, updated information, and other news and services from Winthrop;
• To ensure our Site and Services are relevant to you and your interests;
• To help us create and publish content most relevant to you; and
• To contact you in response to sign-up forms or requests such as our Newsletter sign-up form.

Winthrop does not sell or rent any of your personal information, and we do not share your personal information publicly without your consent. Winthrop also does not disclose sensitive personal information for purposes other than those permitted or required by applicable law. However, we may disclose your information to certain trusted third-parties to help us provide, improve, promote, or protect our Services. For example, we may share your information with:

• Services providers, such as data storage vendors or payment processors, or to store your personal information when necessary to support delivery of our Services and respond to your requests; and
• Other third parties to comply with legal requirements, such as in the event of applicable subpoenas and court orders; to verify or enforce our engagement terms, our other rights, or other applicable policies; to address fraud, security, or technical issues; to respond to an emergency; or otherwise to protect the rights, property, or security of our clients or third parties.

Whenever we share data with third-party services, we require that they use your information only for the purposes we’ve authorized, and that they protect your personal information to at least the same standards we do. Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us.

We may share anonymous or aggregated information (such that it does not identify any individual customer, directly or indirectly) with third parties to help deliver products, services, and content that are tailored to the users of our online services and for other purposes.

In the past year, we have needed to disclose personal identifiers (such as names, phone numbers, postal addresses and email addresses) to our service providers so that we can deliver our products and services. We have also shared certain limited information about Internet and website usage with our service providers and partners in order to provide updates about relevant products and services, and to maintain the security of information.

We take the security of your personal information seriously, and follow industry-standard practices to protect the data we collect and process. Winthrop has therefore put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the personal information that Winthrop collects. Access to personal information will be restricted to our authorized personnel who require the information in order to perform their duties properly. In addition, access will be limited to only that information that is strictly necessary for the performance of those duties.

Remember, the safety and security of your information also depends on you. No method of transmission over the internet or electronic storage is completely secure, so Winthrop cannot guarantee its absolute security. We recommend that you do not use unsecure channels to communicate confidential information to us.

We try to keep email communications to a minimum, and give you the ability to opt-out of any marketing communications we may send. You can always opt-out of receiving marketing emails or mobile device notifications from Winthrop (other than certain required communications, such as messages confirming transactions with our firm, and notifying you of any privacy policy updates, and the like), by sending us an email at [email protected] stating your request. If we have sent you a promotional email or mobile device notification, you may send us a return email or mobile device communication asking to be omitted from future optional notices.

We will hold your personal information on our systems for as long as is necessary to perform the relevant processing activity for that information, or as long as is set out in any relevant contract you hold with us. The relevant retention period is determined on a case-by-case basis because it depends on things like the nature of the data, why it is collected, why it is processed, and any relevant legal or operational retention needs. We may also be required to hold some types of information to fulfill legal purposes. We review our retention periods for personal information on a regular basis. When the relevant processing activity has been completed, we may destroy your data, or alternatively anonymize the data, such that the data is not personally identifiable, either directly or indirectly.

Users or website visitors residing in certain states, countries or regions with enhanced data protection laws may be afforded certain additional rights regarding their personal information. Except where an exception or exemption applies, the rights may include those set out below.

• The right to request access to the information we have collected about you, as well as the right to review our data collection and sharing practices related to you. U.S. State laws may give you the right to request that we disclose the personal information we have collected about you over the past 12 months, which we only provide after we receive and validate your request.
• The right to request deletion of your personal information that we hold about you. You have the right to request erasure of your personal information, subject to certain exceptions, such as when we have a legal obligation to retain the data in question. After we receive and validate your request, we will correct or delete your personal information, unless an exception applies.
• The right to request a digital copy of the personal information that we hold about you that we collect pursuant to this Policy.
• The right not to be discriminated against due to your exercise of any of the preceding rights. Unless an exception applies, this includes our promise not to: deny you goods or services; charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
• The right to object to or restrict processing. You have the right to object to or opt out of the processing of your personal data under certain circumstances. You also have the right to request that we restrict processing some types of personal data under certain circumstances.
• The right to withdraw consent.

While these rights are not globally applicable, all of our customers are entitled to request access to the personal information that we hold about them. To ensure that your personal information is accurate and complete, please contact us through the email address below regarding any errors or updates affecting the personal information that we may hold.

You may make a request by emailing us at [email protected] to make one of the above requests. You may also designate an authorized agent to exercise certain privacy rights on their behalf, and should make any such request by contacting the above email address. To protect your privacy and security, Winthrop may take reasonable steps to verify your identity before granting access to, correcting, or deleting data. We will generally respond to your request for information within 45 days, unless, for reasons beyond our control, a longer response time is necessary, in which case, you will be advised accordingly. Please note that we may retain certain information as required by law or as necessary for our legitimate business purposes.

You have the right to appeal our refusal to take action on a request relating to the above rights. Appeals can be initiated by email to [email protected] and marking your request as an “Appeal.” We will resolve your appeal within the time frames established by applicable law. If your appeal is denied, we will explain why. If you continue to dispute our decision or would like to file a complaint regarding our handling of your personal information, you may contact the regulator in your jurisdiction that handles privacy complaints, such as your state Attorney General.

If you have questions or comments about this Privacy Policy, or if you are not completely satisfied with this Privacy Policy or its application by us, we invite you to convey your concerns or suggestions to us at [email protected]. If you have an applicable disability, you may also contact us at the above email address to request access to this Privacy Policy in an alternative format. We will reply as quickly as possible and inform you of the steps, if any, that have been or will be taken in order to address your concern or implement the suggestion.

Winthrop strives to satisfy our customers’ and visitors’ privacy concerns. However, if you have contacted Winthrop and have further questions about how to protect yourself, or if you have any concerns about how Winthrop handles or processes your personal information, you may contact the data protection authority for your area, such as your state attorney general.