Privacy Policy

  Windrose Partners, LP (“Windrose,” “We” or “Us”) is committed to respecting the privacy rights of visitors to the websites operated by Windrose and its affiliated companies, including without limitation www.windrosetower.com and all subdomains and social media accounts (the “Sites”). Windrose has adopted the privacy policies outlined below, which serve as the basis for our use of your personal information in our business and advertiser relationships. This Privacy Policy is intended to comply with privacy laws applicable to Windrose, its affiliated companies and the operation of the Sites. This Privacy Policy, however, does not cover Windrose’s or its affiliated companies’ offline privacy practices. WHAT TYPE OF INFORMATION DOES WINDROSE COLLECT? We collect two types of information about users: “Personal Information” (such as name, email address, IP address, social media account user name or ID, phone number, and personal preferences and other account information) and “Aggregate Information” (such as information about how many users log on to the Sites on a daily basis). Personal Information is collected online when users voluntarily submit non-public personal information on the Sites by requesting information, receiving electronic notices or other similar communications. Only your IP address and/or user name would be collected automatically when you access the Sites for purposes of viewing webpages, submitting contact forms or enhancing your Site browsing via cookies and/or auditing. Aggregate Information is non-personally identifiable (or anonymous) information about you, such as pages most frequently accessed by you or search terms entered by you. Aggregate Information is used in a collective manner, and no single person can be identified by that compiled information (for example, the number of people who logged into the Sites in a particular day). Aggregate Information does not personally identify a specific user. Your Personal Information will be retained for fulfillment of the intended purposes for which such Personal Information is collected. We will establish minimum and maximum retention periods based upon the type of information collected (i.e. sensitivity), the intended purposes and as otherwise may be legally required. For example, Windrose will purge your customer data no more than two (2) years after the deactivation of your account. Personal Information shall NOT include any personal information posted or sent by or to you in any public forum (such as a comment box on a particular social media posting or tweet) on or from the Sites. Participation in these public forums requires the public release and dissemination of such information, and thus Windrose cannot commit to treating such information confidentially in the same manner that other personal information will be treated under this Privacy Policy. Participation in these features of the Sites is voluntary and thus your consent to certain terms is required before participation is allowed. HOW DOES WINDROSE SECURE MY PERSONAL INFORMATION? Windrose maintains commercially reasonable safeguards to ensure the security, integrity and privacy of the Personal Information provided by you. Such security safeguards are intended to be appropriate to the sensitivity of the Personal Information collected. To the extent that Windrose transfers any Personal Information to third parties, we will use commercially reasonable efforts to assure that such third parties to whom we may transfer any Personal Information have knowledge of our Privacy Policy and provide sufficient protection of such Personal Information. Windrose is committed to properly securing the Personal Information collected online. To help us accomplish this, we take the following steps: • We employ internal access controls to ensure that the only people who see your information are those with a need to do so to perform their official duties. • We train relevant personnel on our privacy and security measures. • We physically secure the areas where we hold hard copies of the sensitive Personal Information if collected online. • We regularly back up the information that we collect online to insure against loss. • We use technical controls to secure the information that we collect online as appropriate, including but not limited to: encryption, firewalls, and password protections. • We periodically test our security procedures to ensure personnel and technical compliance. Please note that Personal Information stored on the Sites will be collected, stored and processed in the United States of America. DOES WINDROSE USE COOKIES TO COLLECT PERSONAL INFORMATION ON THE SITE? The Sites may utilize a standard technology called a “cookie” to collect information about how the Site is used. A “cookie” is a small text file placed on your hard drive by our web page server. These cookies do not collect Personal Information, only Aggregate Information. Your browser is probably set to accept cookies. However, if you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies. If you choose to have your browser refuse cookies, it is possible that some areas of our Sites will not function properly when you view them. We do not combine Aggregate Information collected through cookies with other Personal Information to determine who you are or what your e-mail address is. The Sites can access the Aggregate Information only from a cookie sent by the Sites. We cannot access other cookies sent by other web sites or the information contained in those other web sites. Additionally, we cannot learn your email address through the use of a cookie. You must specifically submit Personal Information to Windrose. For example, in order to set up a Windrose user account, you must voluntarily submit your name and email address and, if you wish to participate in the social media elements of our Sites (such as Facebook, Twitter, Instagram, LinkedIn and YouTube), your social media user account name. We use cookies to track usage of the Sites and further customize your experience when you are visiting the Sites. By tracking usage, we can best determine what features of the Site best serve the users. Without cookies, the Sites would “forget” items that may be stored. The session information used by the Sites is deleted when your browser is closed. We may use cookies to track banner advertisement usage. However, we cannot control what information the social media providers (such as Facebook, Twitter, Instagram, LinkedIn and YouTube) and you must look to those social media providers for their own privacy policy. When you visit the Sites, we automatically collect Aggregate Information about your visit. We can tell the type of computer, browser, and web service that you are using. We also know the date, time, and pages that you visit. Collecting this information helps us design the Sites to enhance your experience while on our Sites. We may use Aggregate Information for internal purposes, such as tracking demographic data and providing targeted content to make the Sites more useful to our visitors. The gathering of this Aggregate Information may be accomplished by the use of cookies. In particular, Windrose may collect an IP Address from all visitors to the Sites. An IP Address is a number that is automatically assigned to your computer when you use the Internet. We use IP addresses to help diagnose problems with our server, administer our Sites, analyze trends, track users’ movement on the Sites, gather broad demographic information for aggregate use in order for us to improve the Sites, and deliver customized, personalized content. IP addresses, however, are not linked to Personal Information. We do provide third parties with Aggregate Information about our users, as more fully set forth in this Privacy Policy. On those pages of the Sites not requiring your account login, you may decline to accept cookies sent by the Sites by selecting an option on your browser to reject cookies. Cookies enable our server to know that you are a registered user; therefore, our registration system requires that you accept the cookies from the Sites. Other sites linked to the Site also may send cookies; however we do not control such activities. In certain instances on our Sites, you may be asked to opt-in to the use of cookies before you will be given access. You will only be asked to opt-in upon your initial visit to those portions of the Sites only. However, if you elect to not opt-in to the use of cookies, you may not be able to access those portions of the Sites or your ability to use those Site features will be impacted. Windrose also may use a unique assigned number located with the Sites’ URL to determine the web site from which you navigated to get to the Sites. While this number may not be apparent to you, it does not contain your Personal Information. HOW DOES WINDROSE USE PERSONAL INFORMATION? Your privacy is important to us. We will use the Personal Information provided by you in accordance with good commercial practice and applicable law. If you provide us with your e-mail address (or have done so in the past), we will send notifications or e-mail offers to you in accordance with the account preferences opted by you. The default setting will select all types of email notifications offered by Windrose. Your email will be used for notifications only. Windrose does not share your public email address with others in its public forums. We may use information provided by you, for example, to provide notifications about certain features of our Sites, to measure consumer interest in our various services and to inform you about various products and services offered on the Sites (including both our own products and the products of others). These offers may be based on information provided by you in correspondence, in surveys, from information that may indicate your preferences, as well as information available from external sources. These e-mail offers will come exclusively from Windrose or its affiliated companies. All offers are carefully developed to ensure that they meet our standards. Our goal is to target offers to Site users who we believe will find them of value. The lists used to send you product and service offers are developed and managed under conditions designed to safeguard the security and privacy of your Personal Information. By providing information using the Sites, you warrant to Windrose that your Personal Information is reliable for its intended uses, accurate, complete and correct, and that you will promptly notify use if such Personal Information is no longer current or correct. DOES WINDROSE SHARE YOUR PERSONAL INFORMATION WITH OTHERS? As a general policy, Windrose does not share, sell or trade Personal information with third parties without permission from the user. However, we may provide your Personal Information to third parties directly involved in the operation, performance, support and/or maintenance of the Sites and/or each product or service offered on the Sites, including our web site designers, hosts, service providers, technical consultants, agents, brokers and business partners. Any Personal Information, however, will be used by such organizations only to perform their functions and/or to provide services in support of the Sites or as otherwise approved by you and for no other purpose. Aggregate information may at times be shared with Windrose’s business partners and other third parties. We reserve the right to assign or transfer your Personal Information to any successor in interest to our business associated with the Sites by merger, reorganization, sale of all or substantially all of our assets or equity interests or operation of law. We also may divulge Personal Information if such information is required for us to comply with any valid legal process, such as a subpoena, search warrant, statute or court order, or if we reasonably believe that you have commit unlawful acts or acts that may endanger the health or safety of another user or of the general public. DO I HAVE THE CHOICE TO OPT-IN OR OPT-OUT OF ANY USES OF MY PERSONAL INFORMATION? Windrose provides its account users with an easy means to decline receiving notifications or offers by email. We recognize the importance of providing you with the choice to “opt-out”. You can control the number of notifications sent by email by logging into your user account and changing your account preferences. If you prefer, you also can “opt-out” of receiving any email notifications by contacting our Privacy Officer at the Contact Address below. All e-mail offers sent by Windrose will inform you as to how you can “opt-out” or decline receiving further e-mail offers. However, with respect to any Personal Information that is sensitive in nature, we will require you to “opt-in” to having such Personal Information used or shared by Windrose. Windrose has made available the social media or other public forums on or from the Sites so that you may have an opportunity to interact with other Site visitors in order to share knowledge and news or participate in social media activities. Since participation in such forums is voluntary, you control what Personal Information may be disclosed to others. In order to avoid your email address or other Personal Information from being gathered and used by others for unsolicited, inappropriate or harmful purposes, Windrose advises that you should be cautious about posting your email address or phone number or other personal information in any public forums. In addition, access to Personal Information contained in your account is protected by use of a password so keep your password private and secure. CAN I MAKE CORRECTIONS TO PERSONAL INFORMATION COLLECTED ONLINE? Additionally, you may request to view the Personal Information collected about you through your use of the Sites operated by Windrose by accessing your user account on the Sites. If you prefer, you can send an e-mail to our Privacy Officer at the Contact Address below. If you send your request by email, we will send such Personal Information (or a summary thereof) for review to the email address on file for the account name in our database only. If at any time you wish to change, correct or update your Personal Information, or have it removed from our database, you may do so by accessing your user account on the Sites. You also may submit a change request to our Privacy Officer by sending an email to the Contact Address below. WHO CAN I CONTACT AT WINDROSE IF I HAVE QUESTIONS ABOUT THIS PRIVACY POLICY OR ANY CHALLENGES AS TO COMPLIANCE? We have designated our Privacy Officer, who can be contacted at the following address (“Contact Address”): By Mail: 7800 N. Dallas Parkway, Suite 156, Plano, TX, 75024 By Telephone: 469-900-9333 By Email: webmaster@windrosetower.com Our Privacy Officer is accountable for Windrose’s compliance with this Privacy Policy. If you have any challenge concerning our compliance with this Privacy Policy or if you have any questions about Windrose’s purposes for the collection and retention of your Personal Information, then please contact our Privacy Officer at the Contact Address and provide a description of your concerns sufficient in detail to permit the Privacy Officer to investigate your concerns and contact you. It is our intent to make available to you through the Privacy Officer specific information about this Privacy Policy and our management of your Personal Information as may be required by applicable law. Windrose uses a self-assessment approach to ensure compliance with this Privacy Policy and periodically verifies that this Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implement and accessible and in conformity with applicable laws. We encourage you to raise any concerns using the contact information provided above; however if a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using JAMS as a third party resolution provider. For more information on JAMS, please visit their website at http://www.jamsadr.com. DOES WINDROSE COLLECT PERSONAL INFORMATION FROM CHILDREN? Windrose does not knowingly solicit data from children or knowingly market to children. Windrose is concerned about the safety of children and their use of the Internet. Therefore, in accordance with the U.S. Children’s Online Privacy Protection Act of 1998, we do not knowingly request or solicit personally identifiable information from anyone under the age of 13 without prior verifiable parental consent. In the event that we receive actual knowledge that we have collected such Personal Information without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is reasonably practical. WHAT ABOUT PRIVACY ON INTERNET SITES LINKED TO THE SITES? You should be aware that other Internet sites to which you hyperlink from the Sites may contain privacy statements that differ from our Privacy Policy. Windrose encourages you to read and understand such privacy policies and terms of use of any linked sites accessed by you. If you decide to access such linked sites and/or provide any personal information to such linked sites, you do so entirely at your own risk. Windrose is not responsible for such provisions, and expressly disclaims any and all liability related to such provisions. WHAT ELSE SHOULD I KNOW ABOUT WINDROSE’S PRIVACY POLICY? No transmission of data over the Internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Windrose to intercept or access transmissions or private communications unlawfully. If you choose to visit the Sites, your visit and any dispute over privacy is subject to this Privacy Policy, including but not limited to limitations of damages and application of the law of the State of Texas and the laws, regulations, ordinances and treaties of the United States of America. This Site is designed to target individuals who are citizens or residents of the United States of America. WHAT IS THE EFFECTIVE DATE OF THIS PRIVACY POLICY AND HOW CAN CHANGES BE MADE? This Privacy Policy was last modified on [May 19, 2016]. This Privacy Policy has been adopted with the recognition that Internet technologies are rapidly evolving, and that underlying business models are still not established. Accordingly, these policies are subject to change at any time and Windrose expressly reserves the right to modify the terms of this Privacy Policy at any time and in our reasonable discretion, by posting a change notice to the home page of the Sites. Your continued use of the Sites following our posting of a change notice will constitute binding acceptance of this Privacy Policy and all changes thereto. WHAT CONSTITUTES MY ACCEPTANCE OF THIS PRIVACY POLICY? By using the Sites, you expressly consent to the use and disclosure of information as described in this Privacy Policy. Your continued use of the Sites after the effective date of any modification to the Privacy Policy will be deemed to be your agreement to the changed terms. You agree to review the Privacy Policy each time you use the Sites so that you are aware of such modifications.