Privacy Policy

Last Updated: December 2021

PRIVACY POLICY

We respect your privacy.  This Privacy Policy is designed to explain how we collect, use, share, and protect the personal information you provide to us when you access our website, purchase our goods, or engage with us on social media, as well as your own rights to the information we collect. As used in this policy, terms such as “we” or “our” and “company” refer to Wheelhouse Collective LLC d/b/a WITT (“WITT”), and any current or future affiliates.

Please read this Privacy Policy carefully. We will alert you to any changes to this Policy by changing the “last updated” date at the top of this Policy.  Any changes become effective immediately upon publication on our website, and you waive specific notice of any changes to the Policy by continuing to use and access our website(s).  We encourage you to review this Privacy Policy periodically, when you use our website for any purpose or engage with us on social media. You are deemed to have accepted any changes to any revised Privacy Policy by your continued use of our website after the revised Privacy Policy is posted.

At the end of this Policy, we will ask those of you located in the State of California, or the European Economic Area (which includes all EU countries plus Iceland, Liechtenstein and Norway) to click a box indicating that you agree to this Policy. If you do not wish to click the box, then please do not use the website.

INFORMATION THAT WE COLLECT

We collect a variety of information from you when you visit our website, take our quiz, use our services, make purchases, or interact with us on social media. By accepting this Privacy Policy, you are specifically consenting to our collection of the data described below, to our use of the data, to the processing of this data, and to our sharing of the data with third party processors as needed for our legitimate business interests. The information we collect may include:

Personal Data

Personal Data is information that can be used to identify you specifically, including your name, shipping address, email address, telephone number or demographic information like your age, gender, or hometown. You consent to giving us this information by providing it to us voluntarily on our website or any mobile application. You provide some of this information when you register with or make purchases from our website.  You may also provide this information by participating in various activities associated with our site, including responding to us or contacting us with questions. Your decision to disclose this data is entirely voluntary. You are under no obligation to provide this information, but your refusal may prevent you from accessing certain benefits from our website or from making purchases.

Derivative Data

Derivative data is information that our servers automatically collect about you when you access our website, such as your IP address, browser type, the dates and times that you access our website, and the specific pages you view.  If you are using a mobile application, our servers may collect information about your device name and type, your phone number, your country of origin, and other interactions with our application.

Financial Data

Financial data is data that is related to your payment method, such as credit card or bank transfer details. We collect financial data in order to allow you to submit payment for our services. We store limited financial data. Most financial data is transferred to our payment processor, or any other third-party payment processor that we may employ, and you should review the processor’s Privacy Policy to determine how they use, disclose, and protect your financial data. 

Social Networking Data

We may access personal information from social networking sites and apps, including Facebook, Instagram, Twitter, Pinterest, or other social networking sites or apps not named specifically here, which may include your name, your social network username, location, email address, age, gender, profile picture and any other public information. If you do not want us to access this information, please go to the specific social networking site and change your privacy settings.

Mobile Device Data

If you use our website via a mobile device or app, we may collect information about your mobile device, including device ID, model and manufacturer, and location information.

Feedback and Support 

If you provide us feedback or contact us for support, we may collect your name and email address, as well as any other content that you send to us, to reply. The purpose for collection and use of this data is that we have a business need to receive and act upon your feedback or issues.

HOW WE USE YOUR INFORMATION

Your information allows us to offer you services including the use of our website, to fulfill our obligations to you, to customize your interaction with our company and our website, and to allow us to suggest other products and services we think might interest you. We generally store your data and transmit it to a third party for processing. However, to the extent we process your data, we do so to serve our legitimate business interests (such as providing you with the opportunity to purchase our goods or services and interact with our website or mobile app).

Specifically, some of the ways that we may use the information and data described above are to:

1. Create and administer your account; 
2. Deliver any products or services purchased by you to you;
3. Correspond with you; 
4. Process payments or refunds; 
5. Contact you about new offerings that we think you will be interested in;
6. Interact with you via social media;
7. Provide you with personalized quiz results; 
8. Provide a referral to a licensed therapist; 
9. Provide product recommendations; 
10. Send you a newsletter or other updates about our company or website;
11. Deliver targeted advertising; 
12. Request feedback from you; 
13. Notify you of updates to our product and service offerings; 
14. Resolve disputes and troubleshoot any problems;
15. Generate a profile that is personalized to you, so that future interactions with our website will be more personal;
16. Compile anonymous statistical data for our own use or for a third party’s use; 
17. Assist law enforcement as necessary;
18. Prevent fraudulent activity on our website or mobile app; and
19. Analyze trends to improve our website and offerings.

WHY WE DISCLOSE YOUR INFORMATION

We may share your information with third parties in certain situations. In particular, we may share your data with third party processors as needed to serve our legitimate business interests, which include administration of our website, administration of your account, entering into contracts with you, communicating with you, taking orders for goods or services, delivering our goods and services, identifying trends, protecting the security of our company and website, and marketing additional goods and services to you. The legal basis for our disclosure of your data is both your consent to this Privacy Policy and our own right to protect and promote our legitimate business interests.

The following are specific reasons why we may share your information:

Third Party Processing

We may disclose your information to third parties who assist us with various tasks, including payment processing, hosting services, email delivery, and customer service.  For more information, see the “Processing Your Information” section below.

By Law

We may share your data as required by law or to respond to legal process, including a subpoena, or as necessary to protect the rights, property, and safety of others.  This includes sharing information with other parties to prevent or address fraud and to avoid credit risks.

To Protect Our Company

We may use your information to protect our company, including to investigate and remedy any violations of our rights or policies. We may also disclose your information as reasonably necessary to acquire and maintain insurance coverage, manage risks, obtain financial or legal advice, or to exercise or defend against legal claims.

Other Third Parties

We may share information with service providers, our investors, or other third parties for business purposes. 

Sale or Bankruptcy

In the event that our company is sold, goes out of business, or enters bankruptcy, your information may be an asset that is transferred to a third-party successor.  Such a successor is not bound by our Privacy Policy and may have its own. 

Interaction with Others

If you interact with others on our website, other users may have access to some of your data, including your name, profile picture, and your history of interaction with our website, such as prior comments or posts.

Online Postings

When you post online, your posts may be viewed by others, and we may distribute your comments outside the website.

External Links

Our website may include hyperlinks to other websites not controlled by us. We suggest you exercise caution when clicking on a hyperlink. Although we use reasonable care in including a hyperlink on our own web page, we do not regularly monitor the websites of these third parties, and we are not responsible for any damage or consequences you suffer by using these hyperlinks. We are not bound by the privacy policies of any third-party website that you access by a hyperlink, nor are they bound by ours. We encourage you to read the Policies of those third-party websites before interacting with them or making purchases. They may collect different information and by different methods than we do.

Other Purposes

We may disclose your personal data as necessary to comply with any legal obligation or to protect your interests, or the vital interests of others or our company.

TRACKING TECHNOLOGIES

Cookies, Log Files, and Web Beacons

Like many other Web sites, we make use of log files. These files merely log visitors to the site – usually a standard procedure for hosting companies and a part of hosting services’ analytics. The information inside the log files includes internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date/time stamp, referring/exit pages, and possibly the number of clicks. This information is used to analyze trends, administer the site, track a user’s movement around the site, and gather demographic information. IP addresses and other such information are not linked to any information that is personally identifiable.

We also use cookies - small text files sent to us by your computer - and web beacons to store certain information. We may use cookies to authenticate your identity, to determine if you are logged onto our website, for personalization, for security, for targeted advertising, or for analysis of the performance of our website and services. We use cookies that are not specific to your account but unique enough to allow us to analyze general trends and use, and to customize your interaction with our website. Cookies may include “single-session cookies” that generally record information during only a single visit to a website and then are erased, and “persistent” cookies that are generally stored on a computer unless or until they are deleted or are set to expire.

Most browsers are set to accept cookies by default.  In addition, when you first encounter our website, you will be asked to “consent to cookies.” If you wish to disable cookies, you may do so through your individual browser options.  However, this may affect your ability to use or make purchases from our website. More detailed information about cookie management with specific web browsers can be found at the browsers’ respective websites. What Are Cookies?  By continuing to use our website and not disabling cookies on your browser, you are consenting to our use of cookies in accordance with the terms of this Policy.    

In addition, we may use third-party software to post advertisements on our website or mobile app to oversee marketing or email campaigns or manage other company initiatives. These third party softwares may use cookies or similar tracking technology. We have no control over these third parties or their use of cookies. For more information on opting out of interest-based ads, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

WEBSITE ANALYTICS

We may partner with third party analytic companies. The analytic companies may also use cookies or other tracking technologies to analyze visitors’ use of our website to determine the popularity of the content, and better understand online activity. We do not transfer personal information to these third-party vendors. However, in order to access our website, you must consent to the collection and use of your information by these third party analytic companies. You should review their Privacy Policies and contact them directly if you have questions. If you do not want any information to be collected and used by tracking technologies, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

PROCESSING YOUR INFORMATION

For the most part, we do not process your information in-house, but give it to third-party processors for processing. They process your payment and remit the funds to us. So, in many instances, it will be necessary for us to transmit your information to a third-party processor, as we do not have the capability to perform these functions. More detail on third-party processing is detailed below.

However, we may, from time to time, process your data internally. The legal basis for this processing is both your consent to the processing, and our need to conduct our legitimate business interests.  Our purposes in processing this information, if we do, is to administer, maintain, and improve our website and offerings, to enter into contracts with you, to fulfill the terms of those contracts, to keep records of our transactions and interactions, to be able to provide you with goods and services, to comply with our legal obligations, to obtain professional advice, and to protect the rights and interests of our company, our customers (including you), and any third parties.  For example, we may process the following data:

1. Data associated with your account, such as your name, address, email address and payment information.
2. Data about your usage of our website, such as your IP address, geographical information, and how long you accessed our website and what you viewed.  
3. Data related to your personal profile, such as your name, address, profile picture, interests or employment details.
4. Data that you provide us in the course of using our services.
5. Data that you post on our website, such as comments or responses.
6. Data that you submit to us when you make an inquiry regarding our website or offerings.
7. Data related to your transactions with us, including your purchase of our goods or services. This information may include contact details and payment information.
8. Data that you provide to us when you subscribe to our emails or newsletters, including your email address and contact information.
9. Data that you submit to us via correspondence, such as when you email us with questions.
10. Any other data identified in this Policy, for the purpose of complying with our legal obligations, or to protect the vital interests of you or any other natural person.

 

INTERNATIONAL DATA

Our website is hosted by servers located in the U.S.  Therefore, if you reside outside the United States, some of your data will be transferred internationally to those servers. Transfers will be protected by appropriate safeguards.  

DATA RETENTION

We retain personal data as long as it is needed to conduct our legitimate business purposes or to comply with our legal obligations, or until you ask us to delete your data. For example, we will retain certain personal information indefinitely for the purposes of maintaining your account, unless and until you delete your account.  Data that we gather for a specific and particular purpose, such as analyzing trends, will not be kept for longer than is necessary for that particular purpose. Data that is no longer needed by us for any of the purposes listed above will be permanently deleted.

You may request that we delete your data at any time.  However, note that we cannot control the retention policies of third parties.   If you wish to have any third parties, including those to whom we’ve transmitted your data, delete that data, you will need to contact those third parties directly.  You may request from us a list of all third parties to whom we have transmitted your data.

SECURITY OF YOUR INFORMATION

We take all reasonable steps to protect your personal data and keep your information secure.  We use recognized online secure payment systems and implement generally accepted standards of security to protect against personal data loss or misuse.  However, no security measure is foolproof, and no method of data transmission can be guaranteed against interception or misuse. We cannot guarantee complete security of any information you transmit to us nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the internet.

By consent to this Privacy Policy, you acknowledge that your personal data may be available, via the internet, around the world. We cannot prevent the use or misuse of your data by other parties.

We will notify you promptly of any known breach of our security systems or your data which might expose you to serious risk.

CHILDREN

This website or mobile app is not designed for use by children under age 18, and we do not knowingly solicit personal data from anyone under age 18. If you are under age 18, do not access or use our website or related products or services. If you become aware that we have collected data of anyone under the age of 18, please contact us so that we may delete that data.

YOUR RIGHTS

You have certain rights with respect to your personal data, as outlined below. Note that we may charge you a reasonable fee for actions that you ask us to take with respect to your data, unless otherwise set forth in this Policy.  In addition, we reserve the right to request that you provide us with evidence of your identity before we take any action with respect to the exercise of your data rights. Further, your rights may be restricted or nullified to the extent they conflict with our compelling business interests, the public interest, or the law.

Update Account Information

You have the right to update or change any information you have provided to us. To update or delete your information, please contact us at connect@heywitt.com.

Confirm Personal Data and Its Use

You have the right to request that we confirm what data we hold about you, and for what purposes. You also have the right to confirmation of whether we process your data or deliver your data to third party processors, and for what purposes. We will supply you with copies of your personal data unless doing so would affect the rights and freedoms of others.  

Change Consent

You have the right to change your consent to our use of your information.  In such cases, we may require you to delete your account with us, as described above, and you may not have full access to our website.

Request a Copy of Data

You have the right to request a digital copy of the data that we hold about you. Your first request for a copy of your personal data will be provided free of charge; subsequent requests will incur a reasonable fee.

Transfer Your Data

You have the right to request that we gather and transfer your data to another controller, in a commonly used and machine-readable format, unless doing so would cause us an undue burden.

Delete All Data

You have the right to request that we delete all data that we hold about you, and we must delete such data without undue delay. There are exceptions to this right, such as when keeping your data is required by law, is necessary to exercise the right of freedom of expression and information, is required for compliance with a legal obligation, is necessary for a compelling business interest, or is necessary for the exercise or defense of legal claims. Such a request may result in a termination of your account with us and you may have limited or no use of our website.

Emails and Communications

You may opt out of receiving future email correspondence from us by contacting us at this email address: connect@heywitt.com

Processing

You may, in some circumstances, restrict the processing of your data, such as when you contest the accuracy of your data or when you have objected to processing, pending the verification of that objection. When processing has been restricted, we will continue to store your data but will not pass it on to third party processors without your consent, except as necessary to comply with legal obligations or protect your rights or those of others or our company.  In addition, you may opt out of any processing of your data altogether. Note however that doing so may result in the termination of your account and loss of access to our website.

Complaints

You have the right to complain to a supervising authority if you believe we are misusing your data or have violated any of your rights under this Privacy Policy or applicable law.

CALIFORNIA PRIVACY RIGHTS

As of January 1, 2020, the State of California enacted its own unique regulations (the California Consumer Privacy Act or “CCPA”) that apply to a certain definition of businesses and specifically to California residents working with those businesses and/or accessing websites. If you are a resident of the State of California, we will comply with the CCPA to the extent that it applies to us and to you.

Newsletter Privacy

We offer the opportunity for you to volunteer certain information to us that is used for email and marketing purposes. This information includes, but is not limited to, your name and email. This data is collected and held in ___________.

You will have an opportunity to unsubscribe from any future communications via email, but we reserve the right to maintain a database of past email subscribers. We reserve the right to use this information as reasonably necessary in our business and as provided by law. Your information will be shared with reasonably necessary parties for the ordinary course of conducting our business. We do not ever sell your information to third parties.

Severability

If any part of this Privacy Policy is deemed unlawful and/or unenforceable, all other provisions contained herein will remain in full force and effect.

Applicable Law; Dispute Resolution; Venue

The laws of the State of Minnesota, USA will govern this Privacy Policy, and will govern any dispute, controversy or claim relating in any way to the Privacy Policy without regard to any conflict of laws. If any dispute, controversy or claim arises between you and us, you agree to submit the matter for mediation before a mutually agreed upon mediator in Hennepin County, Minnesota. If mediation does not result in agreement, the parties agree to courts in Hennepin County, Minnesota, as the sole venue for any litigation regarding this Policy, including the rights and obligations of any party to this Policy.

For users who are residents of California or the forgoing EU Countries listed at the outset of this Policy: I consent to this Privacy Policy (check box).

If you require any more information or have any questions about our Privacy Policy, please feel free to contact us by email at connect@heywitt.com.