Privacy Policy

Effective date: October 7, 2021

Last modified February 18, 2022

Wagstaff, Inc. and Wagstaff AT (“Wagstaff,” "we,” "us,” or "our") take your concerns about privacy seriously. This Privacy Policy and Notice of Information Practices (“Privacy Policy”) sets forth Wagstaff’s practices regarding the collection, use, and disclosure of information that you may provide when you use wagstaff.com and wagstaffat.com, and the translated versions of these websites (our “Websites”), any online services that we operate and that link to this Privacy Policy, and any of our offline services that reference this Privacy Policy (collectively, the “Services”).

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Services and the choices you have associated with that data. Please read the entire Privacy Policy before using the Services.

By using the Services, you agree to the collection and use of your personal information in accordance with this Policy. Unless otherwise defined in this Privacy Policy, the terms used in this Policy have the same meanings as in our Terms and Conditions, accessible from www.wagstaff.com.

Information Collection and Use

We collect several different types of information to provide and improve our Services. Some data is provided by you and some is passively collected through the Services.

Types of Data Collected

Personal Data

“Personal Data” means data about a living person who is identified or identifiable, directly or indirectly, from those data by reference to other information either in our possession or likely to come into our possession. We may ask you for some or all of the following types of information when you register with our Services, access various content or features of our Websites, or directly contact us with questions or feedback:

Contact Information, such as name, email address, postal address, telephone number and name of your company;
Demographic information, such as age information and gender;
Communications preferences;
Search queries;
Correspondence and other information that you send to us.

Usage Data

We may also collect information on how the Services are accessed and used ("Usage Data"). This Usage Data may include information such as:

Your Internet Protocol address (e.g., IP address), which is the number automatically assigned to your computer whenever you access the Internet that can sometimes be used to derive your general geographic area;
Your browser type, browser version, and operating system;
Other unique identifiers, including mobile device identification number;
Sites you visited before and after visiting the Services;
The pages of our Services that you visit, referring and exit pages and URLs, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data;
Information collected through cookies and other technologies;
Information about your interactions with email messages, such as the links clicked on and whether the messages were opened or forwarded;
Standard servicer log information.

We collect this information through browser navigational tools, cookies, pixel tags, and similar technologies.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Services and we hold certain information. Cookies are small files that a website sends to your web browser and stores on your device (computer or mobile device) to helps the website remember information about you and your preferences across multiple visits. Cookies may include an anonymous unique identifier.

You can instruct your browser to refuse all cookies, except the necessary cookies, or to indicate when a cookie is being sent. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. If you do not disable Cookies and continue to use our Services, we will infer your consent to their use. However, if you do not accept cookies, you may not be able to use some portions of our Services.

Examples of Cookies we use:

Session Cookies. A session cookie expires when you close your browser. We use Session Cookies to operate our Services.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.

Sensitive Information

Wagstaff does not knowingly solicit or collect, and you should not provide, any information regarding your medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs, or other sensitive information.

Controller

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data. Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manners in which any personal information is, or will be, processed.

Use of Data

Our legal basis to collect and process your Personal Data includes processing that is necessary for Wagstaff's legitimate business interests, including but not limited to the following examples:

To provide and maintain our Services.
To communicate with you about products or services we offer that we believe are of interest to you.
To notify you about changes to our Services.
To allow you to participate in interactive features of our Services when you choose to do so.
To maintain or administer our Services, perform business analyses, or for other internal purposes to improve the quality of our Services.
To provide customer support.
To gather analysis or valuable information so that we can improve our Services.
To monitor the usage of our Services.
To detect, prevent and address technical issues.

We may also process your information in order to comply with our legal obligations, perform a contract between us and you, establish and defend any legal claims, and in some cases our basis for processing will be because you have consented to our use of your information. We may employ other companies and individuals to perform such functions on our behalf. They have access to Personal Data needed to perform their functions, but may not use it for any other purpose.

Disclosure of Data

Wagstaff may disclose your Personal Data to our service providers and affiliates for the purposes described above. We may also disclose your Personal Data in the good faith belief that such action is necessary to:

Corporate Parents and Affiliates. We may share your information with our corporate affiliated entities for a variety of purposes, including business, operational, and marketing purposes. For more information on those entities, see www.wagstaff.com.

Service Providers. We may share your information with service providers that perform certain functions or services on our behalf pursuant to the purposes set out in this Privacy Notice (such as to host the Site, manage databases, perform analyses, or send communications for us). For more information about our use of service providers, please see below.

Other Parties When Required By Law or as Necessary to Protect the Services. We may disclose your information to third parties in order to: protect the legal rights, safety, and security of Wagstaff, our corporate parents and affiliates, and the users of our Site; enforce our Terms of Use; prevent fraud (or for risk management purposes); and comply with or respond to law enforcement, or legal process, or a request for cooperation by a government entity, whether or not legally required.

In Connection With a Transfer of Assets. If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may transfer your information to one or more third parties as part of that transaction.
Other Parties With Your Consent. We may disclose to third parties information that does not describe or identify individual users, such as aggregate website usage data or demographic reports.
Aggregate Information. We may disclose to third parties information that does not describe or identify individual users, such as aggregate website usage data or demographic reports.

Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are using our Services from the European Economic Area (“EEA”), we will lawfully process your personal data in accordance with the European General Data Protection Regulation (“GDPR”), where applicable. Wagstaff may process your personal data because it is in our legitimate interest in conducting our business and marketing to you, because you consented to the processing (in the case of certain online data collection and marketing activities), because it is necessary for the performance of a contract with you, or because it is necessary in order for us to comply with a legal obligation. The legal basis for collecting and using your personal data described in this Privacy Policy depends on the information we collect and the specific context in which we collect it.

Your Choices and Rights under the GDPR

If you are a resident of the European Union, you have certain data protection rights, including:

The right to request access, updates or deletion of the information we have on you;
The right to object to our processing of your Personal Data;
The right to request that we restrict the processing of your personal information;
The right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format;
The right to withdraw consent your consent at any time where Wagstaff relied on your consent to process your personal information.

Wagstaff aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data. If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at privacy@wagstaff.com. To allow the processing of your request, please provide your full name, postal address, and email address to verify your identity. We will do our best to process your request without undue delay.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local Data Protection Authority in your country.

Retention of Data and Right to Erasure

We will retain your Personal Data only for as long as it is necessary for the purposes for which the data was collected and/or processed, unless a longer retention period is required by law.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we provide the Services from the United States. As a result, when you use the Services, we transfer data, including Personal Data, to the United States and process it there.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, the GDPR when applicable, and the laws of your country. No transfer of your Personal Data to an organization or country will take place unless there are adequate safeguards in place.

Data Storage and Security

We maintain reasonable security procedures to help protect against loss, misuse or unauthorized access, disclosure, alteration, or destruction of the information you provide through the Services. Wagstaff will use at least industry standard measures on our Websites to protect the loss, misuse and alteration of the information under our control. Your personal information is stored through a data management system. Your information can be accessed only by those who help manage that information and are required to keep the information confidential.

Your information will be retained only for so long as reasonably necessary for the purposes set forth in this Privacy Policy, in accordance with applicable laws. However, no data transmission over the Internet or stored on a server can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information. In the event that we believe that the security of your information may have been compromised, we will endeavor to give you appropriate notice as quickly as possible, including by email, and in accordance with applicable laws.

Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Service Providers

We may employ third party companies and individuals ("Service Providers") to provide, on our behalf, our services via our Websites, perform Website-related services or assist us in analyzing how our Websites are used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Websites.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Links to Other Sites

Our Websites may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's website. Such links do not constitute an endorsement by Wagstaff of the content or the persons or entities associated therewith. This Privacy Policy does not apply to third-party content. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any of such third party sites or services.

Children's Privacy

Wagstaff respects the privacy of children, and we are committed to complying with applicable legislation, including the US Children’s Online Privacy Protection Act (“COPPA”) and the GDPR. Our Services are not directed to anyone under the age of 18 ("Children"). We do not knowingly collect Personal Data from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us at privacy@wagstaff.com If we become aware that we have collected Personal Data from children without verification of parental consent, we will take the necessary steps to remove that information from our servers.

Changes to This Privacy Policy

At times, it may be necessary to make changes to our Privacy Policy. In that event, we will notify you of such changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Information

If you have any questions about this Privacy Policy, or want to exercise your privacy rights, please contact us at privacy@wagstaff.com.