This Privacy Policy explains how WMT Digital LLC (“WMT,” “we,” “our,” or “us”) collects, uses, and discloses information about you when you access or use our WMT website located at https://wmt.digital or one of the platforms we support of our partners and related services, including smart calendar platform (collectively, the “Site”). We take your privacy seriously.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Site or otherwise interact with us to stay informed about our information practices and the choices available to you.
A. COLLECTION OF INFORMATION
1. INFORMATION YOU PROVIDE TO US
We collect information you provide directly to us. For example, we collect information when you sign up to receive updates, request information, fill out a form, communicate with us via third party social media sites, request support, send us an e-mail, or otherwise communicate with us. The types of information we may collect include your name, contact information (such as email address, postal address, and phone number), credit card and other payment information (although payment information may be collected directly by a third-party processor), and any other information you choose to provide. We collect this information to help better provide you services.
2. AUTOMATICALLY COLLECTED INFORMATION
When you access or use our Site, we may automatically collect non-identifying and/or anonymized information about you, including your log and usage information, device information, and location information.
Information Collected by Cookies and Other Tracking Technologies
We (and our service providers) use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Site and your experience, see which areas and features of our Site are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Site or emails and help deliver cookies, count visits, and understand our customers to provide better services. For more information about cookies and how to disable them, see Your Choices below.
B. USES OF INFORMATION
We may use the information we collect to:
• Provide, maintain, and improve our Site;
• Provide and deliver the information you request;
• Send you technical notices, updates, security alerts, and support and administrative messages and provide technical support;
• Respond to your e-mails, submissions, comments, questions and requests;
• Communicate with you about our services, such as sending you information to keep you informed about various news and information we think will be of interest to you (see Your Choices below for information about how to opt out of these communications at any time);
• Create and maintain a customer relationship management system, member directories, and invitation lists for WMT events;
• Anonymize and aggregate information for analytics and reporting;
• Monitor and analyze trends, usage, and activities in connection with our Site;
• Personalize the Site and provide advertisements, content, or features based on your preferences, and interests;
• Detect, investigate and prevent fraudulent transactions and other illegal activities; and
• Carry out any other purpose described to you at the time the information was collected.
C. SHARING OF INFORMATION
We may share information about you as follows or as otherwise described in this Privacy Policy:
• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
• To affiliates and other entities within WMT’s group of companies, other WMT customers, and service providers;
• To third parties when you use a third party feature in our Services;
• 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 WMT’s assets;
• When we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests, claims or legal authorities, including responding to lawful subpoenas, warrants, or court orders;
• If we believe your actions are inconsistent with the spirit or language of our policies, or to protect the rights, property, and safety of our staff or others;
• For any other purpose disclosed by us when you provide your Personal Information; or
• With your consent or at your direction.
D. DATA RETENTION
We store the information we collect on you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory or other compliance obligations. For any questions, comments, or requests, please see Section O to Contact Us.
E. LINKS TO OTHER WEBSITES
The Site may contain links to other websites. Any personal information you provide on such linked pages is provided directly to that third party and is subject to that third party’s privacy policy, and not this privacy policy. We encourage you to learn about their privacy and security practices and policies before providing them with personal information.
F. SOCIAL SHARING FEATURES
The Site may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Site with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on your privacy settings for the relevant social media site. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
G. ADVERTISING AND ANALYTICS SERVICES PROVIDED BY OTHERS
We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Site and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used to, among other things, analyze and track data, deliver advertising and content targeted to your interests on our Site, and better understand your online activity.
For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. You can also change your browser settings to block cookies, although doing so may disable some features of our Site. Additional, you may use the links below to opt-out where available:
https://optout.aboutads.info/?c=2&lang=EN
https://thenai.org/opt-out
H. TRANSFER OF INFORMATION TO THE U.S.
We are based in the United States and process and store information in the United States. It is possible that non-U.S. residents may access and use the Site. If you are located outside the United States, we and our service providers may transfer your information to, or store or access to your information in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. By providing personal information, you consent to the transfer of your personal information to the United States and the use of your personal information, in accordance with this Privacy Policy. If we collect personal information from European Union residents, we strive to do so in a manner in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (the “GDPR”), which includes acknowledgment of European Union residents’ rights, including the following:
• to withdraw your consent to the processing of personal information about you to which you have previously given consent;
• to object to processing of personal information about you for the purpose of direct marketing; and
• to have incorrect personal information about you corrected.
European Union residents also have the right to obtain a copy of the personal information we have about you, although we reserve the right to charge a fee for this.
I. YOUR CHOICES
1. PROMOTIONAL COMMUNICATION
We may send promotional e-mails or text messages. You may opt out of receiving promotional emails or text messages from us by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional emails, such as those about your use of the Site.
2. UPDATING INFORMATION
You may update and correct certain information you provide to us by emailing us at [email protected]. If you wish to delete information we have collected from you, please email us at [email protected], but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for as long as necessary for our business purposes.
J. COOKIES
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Site.
K. MOBILE PUSH NOTIFICATIONS/ALERTS
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.
L. YOUR CALIFORNIA PRIVACY RIGHTS
Under the California Consumer Privacy Act of 2018 (“CCPA”) and Cal. Civil Code § 1798.83, California residents have certain rights to know what information we collect, how we use that information, and rights and choices concerning that information. This Section L of the Privacy Policy applies solely to visitors, users, and others who reside in the State of California. This Section only applies to the WMT E-Commerce Platform.
1. INFORMATION WE COLLECT (E-Commerce Platforms Only)
We collect 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”). We have collected the following categories (as listed in Cal. Civ. Code § 1798.140(o)(1)) of personal information from consumers within the last twelve (12) months: A. Identifiers (e.g., email addresses), B. Personal information categories in Cal. Civ. Code § 1798.80(e) (e.g., names, credit card information, addresses), D. Commercial information (e.g., records and consuming histories), F. Internet information (e.g., information regarding a consumer’s interaction with a website), G. Geolocation data, I. Professional or employment-related information, and K. Inferences drawn from other Personal Information (e.g., profile reflecting your preferences, characteristics, and behavior.)
Personal Information does not include publicly available information from government records, de-identified or aggregated consumer information, and information excluded from the CCPA’s scope (such as information covered by the Health Insurance Portability and Accountability Act of 1996, the California Confidentiality of Medical Information Act, the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, the Driver’s Privacy Protection Act of 1994, etc.). We obtain the categories of personal information listed above from the following categories (as listed in Cal. Civ. Code § 1798.140(o)(1)) of sources:
Personal Information Sources
Identifiers Directly and indirectly from you, service providers.
Personal Information categories in Cal. Civ. Code §1798.80(e) Directly and indirectly from you, service providers.
Commercial Information Directly and indirectly from you, service providers.
Internet or other electronic network activity information Indirectly from you, service providers.
Geolocation Data Indirectly from you.
Professional or Employment-related information Directly from you.
Inferences Indirectly from you, service providers.
Please see Section B, Uses of Personal Information, for more information on how the information is used.
2. SHARING PERSONAL INFORMATION (E-Commerce Platforms Only)
We may disclose your personal information to a third party for a business purpose. 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.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose to the following third parties:
Category Type of Information Third Parties
Category A: Identifiers. Service providers, operating systems and platforms, social networks, other WMT customers.
Category B: Personal Information categories in Cal. Civ. Code § 1798.80(e) Service providers, other WMT customers.
Category D: Commercial Information Service providers
Category F: Internet Information Service providers
Category G: Geolocation Data Service providers
Category I: Employment or Professional-related Information Service providers
Category K: Inferences Service providers
In the preceding twelve (12) months, we have not sold any personal information of anyone (including California residents) to any third parties. Even though we do not sell personal information, if you are a California resident, you still may submit a verified request to opt out of the sales and/or disclosure and we will record your instructions and incorporate them in the future if our policy changes. If you are a California resident and would like to opt out of the sale or disclosure of your personal information, please contact us using the contact information at the bottom of this notice.
3. 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.
Right to Know
You have the right to request that we 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, 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.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
o sales, identifying the personal information categories that each category of recipient purchased; and
o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain restrictions. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
1. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
2. Debug products to identify and repair errors that impair existing intended functionality.
3. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
4. Comply with a legal obligation.
5. Make other internal and lawful uses of that information.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
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.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 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. 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. You may be required to provide additional information to verify your identity and request before further action is taken.
4. ADDITIONAL INFORMATION
We will not discriminate against you for exercising any of your CCPA rights. We reserve the right to amend this Section L concerning your California Privacy Rights at our discretion and at any time. When we make changes to this privacy notice, we will notify you through a notice on our website homepage. For any questions, comments, or requests, please see Section O to Contact Us.
M. YOUR NEVADA PRIVACY RIGHTS
This Section M applies solely to Nevada residents. Under Nevada law (NRS § 603A.300), Nevada residents can opt out of the sale of certain types of personal information. If you are a Nevada resident, you may submit a verified request to opt out of sales and we will record your instructions and incorporate them in the future. Opt-out requests may be sent using the contact information at the bottom of this notice.
We reserve the right to amend this Section M concerning your Nevada Privacy Rights at our discretion and at any time.
N. CHILDREN
The Site is not directed at children and we do not knowingly collect personal information directly from children (including information concerning a child or that child’s parents or guardians, any screen or user name that functions as online contact information for a child, any photograph, video, or audio file containing a child’s image or voice) directly from users under the age of thirteen (13) or from other web sites or services directed at children. Consistent with the Federal Children’s Online Privacy Protection Act of 1988 (“COPPA”), we will not knowingly request or collect personal information from any child under the age of thirteen (13) in the United States without obtaining the required consent from the appropriate parent or guardian. Children may access and browse the Site without disclosing any personal information. We will apply material changes to this Privacy Policy to conform with applicable law, including any applicable provisions of COPPA that require parental consent. Please visit www.ftc.gov/privacy/privacyinitiatives/childrens.html for information from the Federal Trade Commission about protecting children’s privacy online. If you have any reservations, questions or concerns about your child’s access to the Site or how information that your child provides is used by us, please contact us.
O. CONTACT US
If you have any questions or comments about our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us or, if applicable, submit a verifiable consumer request to us, by either:
• Calling us at 305-200-8720;
• Emailing us at [email protected]; or
• Sending correspondence to: 328 Crandon Blvd. STE 119-358, Key Biscayne, FL 33149