Privacy Policy

Effective Date: October 1, 2019

Last Updated: January 1, 2023

White Wing Insurance Solutions, LLC (including our affiliated entities) (“WWIS”) has adopted this Privacy Policy which governs the collection and use of personal information collected through our corporate website, www.whitewinginsurance.com (the “Site”), personal information we receive from third party sources, such as lead generation tools, data providers or social media platforms (“Third Party Sources”), at tradeshows, conferences or conventions, and personal information we received from our customers through their use of our digital marketing platform (the “WWIS Platform”). This Privacy Policy does not apply to individuals our customers communicate or correspond with, any third-party services, third-party websites or third party platforms (such as social network platforms), or to our employees.

Our Privacy Policy explains: (1) what information we collect; (2) why we collect it; (3) how we use that information; (4) how we may share it; and (5) the choices we offer, including how to access and update information.

This Privacy Policy is organized into two sections:

The first section applies to information we collect through the Site or from Third Party Sources.
The second section applies to the information we collect through our services, the WWIS Platform.

Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Site, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Site.

Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “International Transfer” section below. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, please do not use the Site or services.

If you have any questions or comments about this Privacy Policy, please submit a request to privacy@whitewinginsurance.com.

When this Privacy Policy Applies

Our Privacy Policy applies to all of the services offered by WWIS and its affiliates, and services offered on other sites but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our services, and who may use cookies, pixel tags, and other technologies to serve and offer relevant ads.

By accessing or using the Site in any manner, you also agree to be bound by WWIS Terms of Use (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Site.

Section 1: Data Collection via the Site and Third Party Sources

By using the Site, or by interacting with us through Third Party Sources, you consent to the collection, use and disclosure of information by WWIS as specified in this Section 1.

Information We Collect

We collect information, including personal data, to provide better services to all our users. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you. Common examples of personal data include full name, email address, digital identity, such as a login name or handle, information about your device, and certain metadata.

“Sensitive Personal Data” refers to a smaller subset of personal data which is considered more sensitive to the individual, such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data, or sexual orientation. WWIS does not collect or use Sensitive Personal Data and asks that you do not provide Sensitive Personal Data to us.

We collect Personal Data in the following ways:

Information You Give to Us

In certain sections of the Site, you may choose to provide us with personal data about yourself, including your name, email, and phone number by completing forms on our websites, such as when you request information about our services or complete a profile or registration form. You may also provide us with billing information, such as a payment card number, billing address, and security code.

The Site offers interactive and social features that permit you to submit content and communicate with other users. You may provide personal data to us when you post information in these interactive and social features. Please note that your postings in these areas of the Sites may be publicly accessible or accessible to other users.

Please note that if you do not provide us with Personal Data, your ability to use certain aspects of our products and services may be limited.

Information We Obtain from Your Use of the Services

We collect certain information automatically, such as your operating system version, browser type, and internet service provider. When you use our Site, we automatically collect and store this information in service logs. This includes details of how you used our Site; Internet protocol address; and cookies that uniquely identify your browser. We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.

Cookies and Similar Technologies

We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third party advertising and analytics partners include Google, Bizible, Pardot, CallidusCloud, Salesforce, and similar partners.

The technologies we use for this automatic data collection may include:

Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser Cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our services. For more information about our use of cookies, including details on how to opt-out of certain cookies, please see our Cookie Policy.

Web Beacons. Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Site. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Site, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Site.

How We Use Information We Collect

We use the information we collect or are provided in the following ways:

To present, operate or improve the Site, including analysis of Site activity;
To provide you with services and products;
To improve our services and products;
To authorize access to our Sites and services;
To respond to technical problems;
To respond to, process and deliver your communications, requests, surveys, or contest entries;
To contact you to request feedback about your experience with our products and services or learn about your demographics, preferences or interests;
To communicate with you about new contests, promotions or rewards, upcoming events, trade shows or conferences, changes to the Site or our products or services, or other news about products and services (whether offered by WWIS or our partners);
To process job applications;
To customize or personalize your online experience, for example to pre-populate forms, or to display or provide you with relevant content, advertising or communications;
To improve our customer service;
To comply with all applicable legal requirements;
To investigate possible fraud or other violations of our Terms of Use or this Privacy Policy and/or attempts to harm our users; or
To otherwise fulfill the purpose for which the information was provided.

We use the information we collect from our Site to provide, maintain, and improve them, to develop new services, and to protect WWIS and our users.

We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our services. For example, by saving your language preferences, we’ll be able to have our services appear in the language you prefer. We may use your personal information to see which web pages you visit at our Site, which web site you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

How We Share Information

We may share your information as follows:

We do not share personal information with companies, organizations and individuals outside of WWIS unless one of the following circumstances applies:

With your consent. We will share personal data with companies, organizations or individuals outside of WWIS when we have your consent to do so.
For external processing. We provide personal information to our affiliates or other trusted businesses or partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. These third parties include payment processors, such as financial institutions and their vendors and contractors that process transactions, email service providers to send out emails on our behalf, a career management platform to collect resumes, print providers for communications with prospects and customers, or a chat widget that allows us to communicate with you, and similar providers. It is our policy to only share Personal Data with contractors, service providers, and other third parties who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. Under certain circumstances, you may avoid having us share your information with our business partners and vendors by not granting us permission to share your information. Not granting us permission to share your information with our business partners or vendors may limit your access to their services through the Site. We do not share personal information with third parties for their own marketing purposes.
For Legal Reasons. We will share Personal Data with companies, organizations, or individuals outside of WWIS if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process, or enforceable governmental request.
- enforce applicable Terms of Use, including investigation of potential violations.
- detect, prevent, or otherwise address fraud, security, or technical issues.
- protect against harm to the rights, property, or safety of WWIS, our users or the public as required or permitted by law.

We attempt to notify users about legal demands for their personal data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague, or lack proper authority, but we do not promise to challenge every demand.

Business Transfers. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Data about our users is often a transferred business asset. In the event that WWIS itself or substantially all of our assets are acquired, Personal Data about our users may be one of the transferred assets.
Aggregate Site Use Information. We may share aggregated and anonymized/pseudonymized Personal Data with third parties in order to promote or describe the use of the Site, for research, marketing, advertising, or similar purposes.

We may use other third-party service providers such as an email service provider to send out emails on our behalf, a career management platform to collect resumes, or a chat widget that allows us to communicate with you. We may share your information with these service providers, and others, as necessary for them to perform their functions. These third-party providers are required to keep your information confidential in our agreements with the providers, with limited exceptions.

We do not sell, rent, or lease the information we collect to third parties.

Your Failure to Provide Personal Data

Your provision of Personal Data is required in order to use certain parts of our services and our products. If you fail to provide such Personal Data, you may not be able to access and use our services and/or our products, or parts of our services and/or our products.

Our Retention of Your Personal Data

We may retain your Personal Data for a period of time consistent with the original purpose for the collection. For example, we keep your Personal Data for no longer than reasonably necessary for your use of our products and services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements, maintain security, prevent fraud and abuse, enforce our Terms of Use, or fulfill your request to “unsubscribe” from further messages from us.

Third-Party Service Providers, Websites and Widgets

The Site may contain links to webpages or content sponsored or provided by third parties. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the user to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. Third-party websites and services may have their own privacy policies, which the user will be subject to upon linking to the third party’s website. These sites and services may use their own cookies or data tracking technologies to collect data or information from you. Voila Media does not share the information that you provide us with these third parties; however, these third parties may obtain information about you if you click on a third party link.

Please note that certain widgets, like the Facebook “like” or “share” buttons, on the Site may collect information about you, such as your IP address, automatically through cookies, and may combine information about your use of our Site with information they collect in other areas. WWIS has no control over the practices of these widgets and is not responsible for their privacy practices. Please visit the privacy policies of each of these third parties to learn more about how they collect and use your information.

Security

We maintain administrative, technical, and physical safeguards designed to protect user’s Personal Data and information and follow generally accepted industry standards to protect the personally identifiable information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is one hundred percent secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Children

The Site is not intended for use by children. We do not intentionally gather Personal Data about visitors who are under the age of 16. If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 16 in the applicable jurisdiction, please contact us at privacy@whitewinginsurance.com. If we learn that we have inadvertently collected the personal information of a child under 16, or equivalent minimum age depending on the jurisdiction, we will take steps to delete the information as soon as possible.

Notice, Access, and Choice

Whenever you use our services, we aim to provide you with choices about how we use your Personal Data. We also aim to provide you with access to your Personal Data. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes.

Where provided under applicable law, you may request a copy of the Personal Data about you that we hold, and you may ask about all recipients of the information, the purpose of the processing, request the correction of incorrect information and request the blocking and deletion of such information by contacting us by emailing us at privacy@whitewinginsurance.com. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.

You may have the right, where provided under applicable law, to ask us not to process your Personal Data. You may have the right, where provided under applicable law, to ask us not to process your Personal Data for direct marketing purposes. You can exercise these rights at any time by contacting us at privacy@whitewinginsurance.com.

Changing or Deleting Your Information

You may update or correct information about yourself by emailing us at privacy@whitewinginsurance.com. If you completely delete all account information, then your account may become deactivated. We may retain an archived copy of your records as required by law, comply with our legal obligations, resolve disputes, enforce our agreements, or for other legitimate business purposes.

We may contact you to request that you update your Personal Data on a regular basis to ensure its integrity for the purposes of ongoing data management.

Our Opt-in/Opt-out Policy

By providing an email address on the WWIS Site, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any service-related notices, or to provide you with information about our events, invitations, or related educational information.

For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a user to submit or receive information, as the case may be.

We currently provide the following opt-out opportunities:

At any time, you can follow a link provided in offers, newsletters, or other email messages (except for e-commerce confirmation or service notice emails) received from us to unsubscribe from the service.
At any time, you can contact us through privacy@whitewinginsurance.com or the address or telephone number provided below to unsubscribe from the service and opt-out of our right per your consent under the terms of this Privacy Policy to share your Personal Data.

Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change in this Privacy Policy, or to provide you with any service-related notices.

International Transfer

WWIS markets its products and services to the United States and Canada customers and is intended for the United States and Canada markets. Specifically, the information and Personal Data that we collect from you may be transferred to and stored at, a destination outside the European Economic Area (“EEA”), including the United States and any other country where we operate. By submitting your information and Personal Data and using the Site, you agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy. We have put in place commercially reasonable technical and organizational procedures to safeguard the information and Personal Data we collect on the Site.

Direct Marketing and “Do Not Track” Signals

WWIS does not track its users over time and across third-party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons, and similar technologies, to allow you to opt-out of data collection through those technologies.

California residents are entitled to contact us to request information about whether we have disclosed Personal Data to third parties for the third parties’ direct marketing purposes. We do not disclose Personal Data to third parties for the third parties’ direct marketing purposes. California users may request further information about our compliance with this law by e-mailing us at the address listed in the “How to Contact Us” section.

Section 2: The WWIS Platform

WWIS customers (“Clients”) engage us to provide digital marketing services. The WWIS Platform is the platform our Clients use to manage their website and other digital marketing tools. Client Information, Information about our Client’s Contacts, and Archival Information (each defined below) are governed by this Privacy Policy, the WWIS Terms of Service, and any other services agreements between Voila Media and the applicable Client. The WWIS Platform collects the following information:

Client Information. We collect information about individuals within our Client’s organization (“Client Information”). Client Information may include information related to the Client’s account, name, work e-mail address, work phone number, job title, or similar kinds of information. We use Client Information to support the Client account, maintain our business relationship with the Client, respond to Client inquiries, or perform accounting functions. Clients may update Personal Data and password by logging into the WWIS Platform and updating their account. Clients may contact WWIS support in order to delete their Personal Data. In some cases, we may not be able to delete Client Information, and in such cases we will tell you why.
Information about our Client’s Contacts. We collect information about any contacts that may be uploaded into the WWIS Platform (“Information about our Client’s Contacts”). Information about our Client’s Contacts may include name, e-mail address, phone number, job title, birthday, anniversaries, or similar kinds of information. We use Information about our Client’s Contacts for the purposes of marketing to such contacts. Clients may update or delete Information about their contacts in the WWIS Platform. Clients may also contact WWIS support in order to update and delete such information. In some cases, we may not be able to delete such information, and in such cases we will tell you why.
Archival Information. We collect communications information for archival purposes on behalf of, and as directed by, our Clients. This information may include emails, texts, websites, social media messages or posts, and other forms of data or electronic communications (“Archival Information”). Archival Information includes data about our Clients and the third parties they correspond with. We do not control or monitor the information our Clients collect and store through our services, or their privacy practices or policies. It is our Client’s obligation to obtain all necessary consents and to comply with all applicable laws with respect to the Client’s communications and use of our services. Our Client’s privacy policies or practices apply to Archival Information, the purposes for which the Client collects Archival Information, how the Client may use Archival Information and what choices the individual may have with respect to Archival Information. Individuals must contact the applicable Client in order to correct, amend, or delete their information, or to opt-out of any collection, uses, or disclosure of their information by our Client.
Automatically Collected Information. We collect information automatically about how our Clients use our services (“Automatically Collected Information”). We do this via data collection technologies such as cookies, web beacons, gifs, or other tracking technologies. We collect this information in order to monitor, support, and improve our services or to provide Clients with certain customized features. We may use Automatically Collected Information to tell us how our Clients use our services, to improve our services or develop new products, services or features. We may combine this information with other information we collect.

We treat Client Information, Information about our Client’s Contacts, Archival Information and Automatically Collected Information as the confidential and proprietary information of our Clients, subject to the terms of the WWIS Terms of Service and any other service agreement between WWIS and the Client. We do not share Client Information, Information about our Client’s Contacts, Archival Information or Automatically Collected Information with third parties unless directed to do so by our Client, as may be necessary to provide services to the Client, to our advisors, channel partners, affiliates, representatives, agents, service providers, in connection with a business transaction (such as a merger or sale), as allowed under the terms of our agreement with our Client, or in response to a court order, subpoena, warrant or to comply with a legal requirement or to cooperate with an investigation. We may disclose Client Information, Information about our Client’s Contacts, Archival Information or Automatically Collected Information for the aforementioned reasons, or in order to protect our rights or the rights of our affiliates, clients, channel partners or service providers.

We will retain client information we process on behalf of our Clients for as long as needed to provide services to our Client, or for the period of time requested by a particular Client.

Changes to this Privacy Policy

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or products, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

Revisions:

October 1, 2019
January 1, 2023

How to Contact Us

If you have any specific questions about this Privacy Policy, you can contact us via email or writing to us at the address below:

Send e-mail to: privacy@whitewinginsurance.com

Send mail to our address:

White Wing Insurance Solutions, LLC | 8549 Wilshire Blv., Beverly Hills, CA 90211

Attn: Privacy Department