Privacy Policy

Windsor Circle Privacy Policy  

Effective Date: May 21, 2018

At Windsor Circle, Inc. (“Windsor Circle,” “we,” “us,” or “our”), we respect and protect the privacy of our customers (“you,” “Customer,” or “your”), website visitors and, to the extent required under applicable law, certain third parties associated with our customers.  This “Privacy Policy” describes our practices for how your personal information is collected and used.  This Privacy Policy applies to information that we collect and maintain about you when you visit the Windsor Circle website (“Site”) or use any Windsor Circle product or service (“Services”), and from other sources. 

By visiting the Site or by purchasing or using the Services, you expressly consent to the use and disclosure of your information as described below.  If you are a Customer, this Privacy Policy is made subject to, and is a part of, our standard terms of use or other written agreement between us.

Information Collected

We primarily collect and maintain three categories of information, which categories may include both information that can be used to identify or contact an individual (“personal information”) and other non-personal information:

  1. Customer Information. You may provide, and we may collect, information when you activate, subscribe for or otherwise use the Services (“Customer Information”). Examples of Customer Information include your account information such as username and password, billing information, name, email address, mailing address, phone number, usage details of the Service, information related to support or service requests, and current geographic location and language.
  2. Target Data. We collect data stored or uploaded by you into the Services about the behavior and demographics of your customers and other third parties that consent to the receipt of marketing and other content from you, or that otherwise interact electronically with you or your website (“Target Data”). All Target Data is controlled by our Customers, who are the data controllers for such information with respect to EU data protection laws and regulations. Each Customer is responsible for obtaining the requisite consent in accordance with applicable law from its customers and third parties for us to collect and use the Target Data as necessary for the provision of the Services. Except as provided herein, we will not process Target Data for other purposes or by other means than as instructed by our Customers.
  3. Usage Information. When you access or use our Services or Site we automatically collect certain information via technologies such as cookies and web beacons (“Usage Information”), which may include data about visitors to the Site who may or may not be our customers. Examples of Usage Information include IP addresses or other device addresses or ID, browser and device type, geo-location data, and dates and time of the visit or use of the Services or Site.  We may also employ web beacons to collect information regarding your or your customer’s interaction with email messages, such as whether a message is opened or forwarded.  More information on how and why we collect Usage Information is in the “Cookies and Web Beacons” section of the Privacy Policy below.   
  4. Information from Other Sources. We may obtain Customer Information, including personal information, about you or a prospective customer from our business partners or other third parties, for the purposes of providing you with improved Services.

Although we do not actively collect such information, certain information that is provided to us by our customers may relate to or contain personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information specifying the sex life of an individual (any such information, “Sensitive Information”).  

Children’s Information

The Site and Services are not intended to be used by children under the age of sixteen (16) for residents of the European Economic Area (“EEA”) and under the age of thirteen (13) for all others, and we do not knowingly collect information from such children.  If we become aware that a child under the age of thirteen (13) (or a child from the EEA under the age of sixteen (16)) has provided us with information, we will remove it from our systems. If you believe we might have any information from or about underage children, please contact us at

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, in various ways, including the following:

  • Operations. We use Customer Information that we collect to provide, maintain, improve and develop our Services, to provide information, products, support or services that you request from us; to fulfill any other purpose for which you provide it; and to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
    • Marketing. If you have provided your contact information to us, you agree we may use such information to contact you for marketing purposes via direct mail, email, telephone, pre-recorded messages, text messages, instant messages or other communications If, however, you live in the European Union or another jurisdiction where affirmative and express consent is required, we will obtain such consent before contacting you for marketing purposes.  For all of our customers, if at any time you do not want us to use your information in this way, or to pass your details on to third parties for marketing purposes, please opt-out by following the instructions set forth below. 
    • Customer Support.   If you have a problem, comment, or request concerning the Site or the Services, we will use the contact information provided by you to respond to those problems, comments or requests.  In certain instances, our response may be provided to other Windsor Circle customers or third parties as necessary to respond to any problem, comment, or request, but any such response shall not include your personally identifiable information.
    • Target Data.   Windsor Circle may use Target Data in connection with its performance of the Services, and in accordance with the instructions provided by the applicable Customer. We may also use non-personally identifiable Target Data in aggregate and blinded formats that do not identify, reference or imply an association with, Customer or its customers, for the purposes of creating benchmarking, statistical, research and marketing analyses, surveys, reports and studies.  If you are a customer of one of our Customers and would no longer like to be contacted by one of our Customers that use our Service, please contact the Customer that you interact with directly.
    • Usage Information. We use Usage Information generally to improve the accessibility and usage of our Site and Services. We may use Usage Information to personalize the Services to you, provide customized advertising, marketing, content or information, communicate with Site visitors, monitor and analyze Site usage and access. 

Disclosure of Your Information

We may disclose personal information that we collect or you provide as described in this privacy policy under the following circumstances:

  • Disclosures With Your Consent. We may disclose your personal information to third parties with your consent, or if we notify you that the information you provide will be shared in a particular manner and you provide such information.
  • Disclosures Required by Law.   Under certain circumstances, Customer Information and Target Data may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders or we may be required to disclose such information in order to enforce or apply our terms of use or other agreements, or to protect the rights, property, or safety of Windsor Circle, our customers, or third parties.  In such circumstances, you agree Windsor Circle may disclose such information to the extent necessary to comply with such legal order or requirement (“Disclosures Required by Law”).
  • Disclosures To Our Affiliates. We may share your information that we collect, or provide to us, with our affiliates. Windsor Circle affiliates will use such shared information in a manner consistent with their privacy policies, which shall be no less stringent than this privacy policy.
  • Disclosures To Our Partners. Where lawful to do so, and subject to your consent where required, we may provide Customer names to certain trusted business partners for marketing purposes, but will never share any Target Data with such business partners.
  • Disclosures To Service Providers. In addition to Disclosures Required by Law, we may engage subcontractors, service providers and other third parties to help us deliver, maintain, upgrade, create, or improve the Site and/or the Service, and these parties may have access to certain of your information in the course of providing such services.  Further, we may share your information with third parties in connection with our analysis of Site usage, as discussed below, under “Cookies and Web Beacons”. In the event you do not agree to any such disclosure, you may contact us as discussed below to modify or delete the information we hold.  Additionally, aside from in connection with Disclosures Required by Law, any disclosure to a third party of personal information of data subjects within the EEA will only be made if such third party satisfies the requirements of the EU-U.S. Privacy Shield (as defined below), or has entered into a written agreement with us providing that it will provide at least the level of privacy protection as is provided in the EU-U.S. Privacy Shield Framework.
  • Disclosures Due to Changes of Ownership. We may also provide your Information to a third party in connection with a merger, sale, or acquisition transaction, in which case we will require any such third party to agree to treat your personal information in accordance with this Privacy Policy.

Windsor Circle reserves the right to share any information that is not deemed personal information or is not otherwise subject to contractual restrictions.

Except as otherwise set forth herein (and, in the case of a Customer, set forth in our standard terms of use or other written agreements between us), we will not sell, rent or lease to others your Customer Information or your Target Data. 

Third Party Websites

As part of the Services, the Site may contain links to websites operated by third parties.  We are not responsible for the privacy practices or the content of any third party websites.  Customers and visitors who link to third party websites from the Site should check the privacy and security policy statements of such third party websites to understand the policies and practices of such third party websites as we are not responsible for those policies and practices.  Customers and visitors who access a linked site may be disclosing their private information to the owner of such third party websites.  Please review these policies before you submit any personal data to these websites.  It is your responsibility to keep such information private and confidential.

International Transfers

From time to time, personal information from data subjects in the EEA that we collect may be transferred or accessed by entities who may be based outside of the EEA. We may also allow our service providers or assistance providers, who may be located outside the EEA, access to your personal data. We may also make other disclosures of your personal data overseas, for example, if we receive a legal or regulatory request from a foreign law enforcement body.  We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests.  For example, transfers to our service providers and other third parties will always be protected by contractual commitments, further assurances where appropriate, such as the European Commission's approved Standard Contractual Clauses, or certification schemes such as the EU - U.S. Privacy Shield for the protection of personal data transferred from within the EU to the United States of America.  

Data Retention

Windsor Circle will not retain your personal information longer than is necessary to fulfill the purposes for which it was collected unless a longer retention period is required or permitted by law. 

Choice and Access - Control, E-mail and Opt-Out

You may request access to and correction of, amendment to, or deletion of any information provided to us at any time by contacting us at You may also request your information by mail addressed to Windsor Circle, 212 W Main St, Suite 400, Durham, NC 27701.  We will respond to any written requests within thirty days. 

You may always decline to share certain personal information with us, in which case we may not be able to provide to you some of the features and functionality of the Services.

If you received one or more e-mails from us, it means one of two things: (i) your e-mail address is on our list of customers, free trial users or prospective customers; or (ii) you have provided us your e-mail address so that we could contact you.  If you believe you received an email from us in error, please contact us immediately at

We provide you with the opportunity to opt-out of receiving certain communications from us at any point in time.  If you wish to cease receiving e-mails and other communications from us, you can opt-out of by contacting us at

In the event we become aware that we have collected Sensitive Information, we will obtain your consent prior to revealing such Sensitive Information to any unauthorized third party or to using it for purposes other than those for which it was originally collected.

In addition to the above rights of access, correction, amendment or deletion, if you live in the EU, you may, subject to applicable law, have some or all of the following rights with respect to your personal information:

  • to restrict processing of your personal data under certain circumstances
  • to transmit your data (as provided by you, directly or otherwise collected by us by virtue of your use of the Services) in machine-readable format to you or to a third party when we justify our processing on the basis of your consent or the performance of a contract with you;
  • to withdraw your consent to our processing of your personal data (where that processing is based on your consent);
  • to obtain, or see a copy of the appropriate safeguards under which your personal data is transferred to a third country or international organization;
  • to object, at any time, to the processing of your personal information, on legitimate grounds, except if otherwise permitted by applicable law;
  • to erase your personal data (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed); and
  • to file a complaint with your local supervisory authority for data protection.

If you are seeking to exercise any of the foregoing rights, please contact us at

Please note that Windsor Circle has no direct relationship with our Customer’s customers or other third parties whose personal information we may process as Target Data on behalf of a Customer. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, or has other inquiries with respect to their personal information should direct his or her query to the Customer they deal with directly. 

Your California Privacy Rights  

California Civil Code Section § 1798.83 permits users of our Site or Services that are California residents to request certain information, including the categories of personal information disclosed to third parties for their marketing purposes and the names and addresses of those third parties, regarding our disclosure of personal information to third parties for their direct marketing purposes. If you are California resident and would like to make such a request, please submit your request via email to  

Some Internet browsers include the ability to transmit "Do Not Track" signals.  We do not currently process or respond to “Do Not Track” signals.  To learn more about "Do Not Track", please visit “All About Do Not Track."

Security of the Information Collected

We use technical, administrative, and physical security measures to protect against the loss, misuse, alteration, disclosure, and unauthorized access of data used by our system, and to ensure that all data used by our system is reliable for its intended use, and is accurate, complete, and current.  Also, we provide each customer with a unique user name and password that must be entered each time a customer logs into its account.  No data transmissions over the Internet, however, are guaranteed to be completely secure. While we strive to protect your data from unauthorized use or disclosure, Windsor Circle does not warrant or guarantee the security of the data that you provide to us; any transmission of data is at your own risk. 

Cookies and Web Beacons

Cookies are files that web browsers place on a computer’s hard drive to tell site owners whether an individual has interacted with the website previously.  Windsor Circle uses cookies to recognize repeat visits by users of the Site and to collect information about our Customers’ interactions with the Services. The use of cookies enables us to make your experience with the Site and Services easier and more meaningful.

There are two types of cookies: session-based cookies and persistent-based cookies.  Session cookies exist only during an online session.  They disappear from your computer when you close your browser software or turn off your computer.  Persistent cookies remain on your computer after you have closed your browser or turned off your computer.  They include such information as a unique identifier for your browser.  Standing alone, cookies do not contain personal data, and therefore do not identify you personally; they merely recognize your browser.  Unless you choose to identify yourself to Windsor Circle, either by responding to a promotional offer, using the Services, or registering for a free trial, you will remain anonymous to Windsor Circle.

From time to time, we may ourselves or may engage third parties to track and analyze non-personally identifiable usage and volume statistical information from visitors to the Site to help us administer the Site and improve its quality.  Such third parties may use cookies to help track visitor behavior, including visitor responsiveness to online advertisements.  Such cookies will not be used to associate individual Site visitors with any personal data.  All data collected by such third parties on our behalf is used only to provide us with information on Site usage and will not be shared with any other third parties, and any such third party either satisfies the requirements of the EU-U.S. Privacy Shield or have entered into a written agreement with us providing that it will provide at least the level of privacy protection as required by the EU-U.S. Privacy Shield Framework.

The cookies we use do not transmit personally identifiable information to us or to our service providers. You have the choice to opt-out of receiving cookies from both Windsor Circle and third parties which will prevent Windsor Circle and third parties from tracking information about the online advertisements that you visit.  Please note that you still will have the ability to view our online advertisements even if you opt-out of receiving cookies OR if you choose to disable cookies, you may still use the Site; however, you may have limited access to some areas within the Site.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies; however, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our Site. 

Pages of our the Site and 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 email and for other related  statistics (for example, recording the popularity of certain delivered content and offers).  Our web beacons may collect some contact information (e.g., the email address associated with an email message that contains a web beacon)

Google Analytics 

We also use a third-party service, Google Analytics, a web analytics service which uses cookies to measure, analyze and report on access to and usage of our Site.  The information generated by the Google Analytics cookie about visitors to the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States.  Google Analytics does not identify individual users or associate your IP address with any other data held by Google.   In addition, our Site uses third-party cookies (DoubleClick cookies) provided by the Google Analytics service for a specific feature called Google Analytics Demographics and Interest Reporting. This feature gives us insight into behavior information relating to visitor age, gender and interests on an anonymous and aggregate level. This will help us to understand browsing behavior to give you a better experience while visiting our Site and to help use refine our marketing message and to better serve our user base.  If you would like to opt-out of Google Analytics you can download and install the add-on for your web browser at:   

EU-U.S. Privacy Shield Windsor Circle complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Economic Area countries.  Windsor Circle has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification page, please visit

Windsor Circle’s accountability for personal data that it receives under the EU-U.S. Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, Windsor Circle remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Windsor Circle proves that it is not responsible for the event giving rise to the damage. 

We conduct periodic internal reviews, and provide employee training, to ensure our compliance with this Privacy Policy.  Any questions regarding this Privacy Policy, our use of your information, or the Privacy Shield should be directed to Windsor Circle, at

In compliance with the EU-US Privacy Shield Principles, Windsor Circle commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union individuals with inquiries or complaints regarding this privacy policy should first contact us at  If we do not resolve your complaint, you may submit it free of charge to JAMS, an alternative dispute resolution provider based in the United States that we have designated to address complaints.  Please visit the JAMS website at for more information.  During a dispute, Windsor Circle is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. Under certain conditions specified by the Privacy Shield Principles, you may also be able to invoke binding arbitration to resolve your complaint.

Privacy Policy Changes

This Privacy Policy may be amended from time to time, consistent with the requirements of the EU-U.S. Privacy Shield Framework.  Any changes to this Privacy Policy will be posted here, so please check this page regularly and make sure to check the effective date of the policy as set forth above. If you have any questions or concerns about the changes, please contact us at