Last updated: December 8, 2017
Information We Collect
INFORMATION YOU PROVIDE US
We may also ask you to create login information for your WinWin account, such as a username and password. When you provide your mobile phone number, we may ask for your consent to receive text messages relating to our Services at that number. You may withdraw your consent by contacting us as indicated below or by replying with “STOP” to any text message we send you. Please note that if you withdraw your consent to receive text messages from us, you may not be able to use some of our Services. Your mobile carrier’s standard text message and data charges may apply to text messages you receive from us, and you are responsible for any fees charged by your mobile carrier if we contact you.
INFORMATION ABOUT YOUR TRANSACTIONS
We collect Personal Information about your transactions with us and others including Wells Fargo.
INFORMATION FROM THIRD PARTIES
We also collect Personal Information about you from other companies. For instance, we may receive Personal Information about you from Wells Fargo.
INFORMATION AUTOMATICALLY COLLECTED
Information that we automatically collect in connection with your access or use of our Services may include:
Device Information: We may collect Device-specific information (such as hardware model, operating system version, unique Device identifiers, and mobile network Information, including your mobile phone number). We may associate your Device identifiers or mobile phone number with your WinWin account.
Log Information: We may record or log information from your Devices, their software, and your activity accessing or using our Services. This information may include:
The Device’s Internet Protocol (“IP”) address
Identification numbers associated with your Devices
Device event information, such as crashes, system activity, and hardware settings
Date and time stamps of transactions
System configuration information
Other interactions with our Services
INFORMATION COLLECTED THROUGH COOKIES AND SIMILAR TECHNOLOGIES
The cookies we use in connection with our Services include:
Session cookies: Session cookies are temporary cookies that expire and are automatically erased whenever you close your browser window. We use session cookies to grant users access to content and to enable actions they must be logged into their WinWin account to perform.
Third-party cookies: We may permit certain third parties to place cookies through our Services to provide us with better insights into the use of our Services and user demographics and to advertise our Services to you. These third parties may collect information about your online activities over time and across different websites when you access or use our Services. For example, we utilize Google Analytics to analyze usage patterns for our Services. Google Analytics generates a cookie to capture information about your use of our Services, which Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify its cookie, but this will not be associated with any other data held by Google. We may also permit third-party service providers to place cookies for our Services, as indicated above, to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties.
Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.
How We Use Information
How We Share Information
We do not share your Personal Information with: (1) other financial companies for joint marketing purposes other than Wells Fargo for purposes of the Program; (2) affiliated companies for their everyday business purposes; or (3) any third parties so they can market to you.
Accessing Your Information
You must notify us of any change in your Personal Information by updating your account profile through our Services. Any changes will affect only future uses of your Personal Information.
Information You Share Socially
Our Services may allow you to connect and share your actions, comments, content, and information publicly or with friends. We are not responsible for maintaining the confidentiality of any information you share publicly or with friends.
Our Services may also allow you to connect with us on, share on, and use third-party websites, applications, and services. Please be mindful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those sites and services directly if you want to learn about their privacy practices.
We have, and require our third-party service providers that receive Personal Information from us to have, a comprehensive written information security program that contains administrative, technical, and physical safeguards for our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, or alteration. When account information is transmitted via our Services, it will be protected by encryption technology, such as Secure Sockets Layer (SSL).
No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your username and password for your WinWin account and do not share them with others. If we receive instructions using your WinWin account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your account or any other breach of security. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate WinWin accounts, and to remove or edit content.
Protecting Children’s Privacy
Our Services are not directed, or intended to be attractive, to children under the age of 18. We do not knowingly collect Personal Information from children under the age of 18. If you are under the age of 18, do not use our Services or submit any information to us.
Links to Third-Party Websites