Last update: [9/25/2023]

This Privacy Notice describes how we at Windows USA, LLC, together with our subsidiaries and affiliates (“Windows USA,” “we,” us,” or “our”), collect, use, disclose, and otherwise process your information when you interact with our websites, emails, social media accounts, and other online properties (“Online Properties); contact us; purchase our products; or otherwise engage with us through online and offline interactions. Please review this Privacy Notice carefully as it will help you make informed decisions regarding your information. 

PERSONAL INFORMATION WE COLLECT

In this Privacy Notice, we use the term “Personal Information” to refer to information that relates to you. Depending on how you interact with us, we may collect the following types of Personal Information from you or about you:

• Contact information, such as your name, postal address, email address, phone number, and other contact information.
• Commercial information, such as information about your Windows USA account, your transactions with us, and products in which you may be interested, and other information you choose to provide to us.
• Online usage information that we automatically receive about you or the devices you use to access our Online Properties, such as IP address, the type of Internet browser used to visit our websites, geolocation, the areas of our Online Properties you visited, and actions you performed on our Online Properties.
• Financing information if you apply for financing, such as your age, income, Social Security number, employer, job title, employment history, date of birth, and credit history.

HOW WE COLLECT PERSONAL INFORMATION

Depending on how you use our services, we may collect Personal Information from you in the following ways:

• Directly from you. We may collect information from you, such as when you contact us, interact with us in person, place orders, or otherwise communicate with us. 
• Through automated data collection technologies. We may collect your information using automated data collection technologies as described in the “Cookies and Other Data Collection Technologies” section below. For example, we may collect the IP address of the device you use to access our Online Properties and other browsing information, such as page requests, browser type, operating system, and average time spent on our Online Properties. 
• From third parties. We may obtain your information from third parties, such as our business partners, referral sources (friends and family), credit bureaus, individuals with whom you co-purchase our products or co-apply for financing, and service providers. We may also collect or license information about you from information aggregators or event/promotion co-sponsors. 

We may combine Personal Information that we receive from these sources for the purposes described below. 

HOW WE USE PERSONAL INFORMATION

We may use your Personal Information to: 

• Communicate with you, including to respond to your comments and questions;
• Send notices and updates regarding our products and services;
• Analyze how you interact with us, including our Online Properties;
• Process and complete your requests and transactions;
• Facilitate your financing application, if you apply for financing;
• Promote products and special offers that may interest you, including through targeted advertising;
• Maintain and improve our products and services, develop new products and services, and for other internal business purposes;
• Enhance the security of our transactions and IT systems, architectures, and networks to prevent fraud, criminal activity, or misuses of our services; 
• Comply with our legal obligation and legal processes and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties; and
• Consider and complete corporate transactions, such as selling all or a portion of our business.

Anonymized or Deidentified Information. We may anonymize or deidentify Personal Information and use and disclose the anonymized or deidentified information for any purpose permitted by law. 

HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose your Personal Information to the following categories of third parties:

• Affiliated entities: We may disclose Personal Information to our affiliates, including parent entities, subsidiaries, and other entities under common ownership.
• Service providers: We may disclose Personal Information to our service providers to assist us in meeting business operations needs and to perform certain services and functions, including providers of hosting and technology services, email communication software, payment processors, customer relationship management and customer support services, and analytics services.
• Professional advisors: We may disclose Personal Information to accountants, auditors, lawyers, financial advisors, and other professional advisors.
• Business partners: We may disclose Personal Information to business partners who may use the information for their own purposes, such as advertisers, social media platforms, providers of cookies and other data collection technologies, credit bureaus, and banks and other financing partners if you apply for financing. We are not responsible for the privacy practices of our business partners, and you should consult their privacy notices to learn about how they process Personal Information.
• Third parties involved in corporate transactions: If we are involved in a merger, acquisition, reorganization, bankruptcy, sale of all or a portion of our assets, or other corporate transaction, we may share your Personal Information with other parties involved in the transaction.
• Third parties for legal reasons: We may disclose information to government authorities and other third parties to, for example, (i) comply with legal obligations, (ii) protect and defend our rights or property or those of other parties, (iii) prevent fraud, (iv) protect the personal safety of individuals or the public, and (v) enforce our agreements and policies.

COOKIES AND OTHER DATA COLLECTION TECHNOLOGIES

We and our third-party partners use cookies and other data collection technologies on our Online Properties. A “cookie” is a small text file that is placed on your computer or mobile device when you visit a website. Other data collection technologies we may use include “pixels,” a code that is embedded on a website or in an email; “session replay tools,” which record your interactions with websites; “embedded scripts,” which are scripts temporarily downloaded to a device from a web server; and “local storage,” which generally refers to other places on a browser or device where information can be stored. Some cookies and other data collection technologies are deleted when you end your session, while others are stored between sessions.

The data collection technologies we may use change from time to time, but we generally use them for the following purposes:

• Strictly necessary. These technologies are needed to make our Online Properties run correctly.
• Functionality. We use these technologies to help us remember you and personalize features and content for you on our Online Properties. 
• Analytics. We use these technologies to compile statistics and analytics about our users, including traffic, usage, and trend data. For example, we use Google Analytics to help us understand how users engage with our Online Properties. This information helps us improve our online services. To learn more about how Google Analytics uses your data, please visit www.google.com/policies/privacy/partners.
• Advertising. We use these cookies to place and personalize advertisements on our Online Properties and third-party websites. These cookies may track your activity over time and across properties to understand and to advertise to your interests (“interest-based advertising”). 

You may be able to disable or delete cookies using your web browser’s settings. If you do, you may not be able to access or use certain features on our Online Properties. You may also be able to opt out of certain interest-based advertising using tools provided by the Digital Advertising ("DAA") and Network Advertising Initiative ("NAI"). For more information, please visit  http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/.

Some browsers offer a “Do Not Track” feature. We do not currently respond to “Do Not Track” signals.

EMAIL MARKETING

We made send you email promoting our products and services. If you no longer wish to receive these emails, you may opt out by clicking the unsubscribe link in the email. We may continue to send you emails about products you have purchased, responding to your questions or comments, or providing legal updates after you have unsubscribed from promotional emails.

PRIVACY RIGHTS FOR TEXAS RESIDENTS

Residents of Texas may have the following rights in their Personal Information:

• Right to Know. You have the right to request confirmation of whether we process your Personal Information and to access the Personal Information.
• Right to Correct. You have the right to request correction of inaccuracies in your Personal Information. 
• Right to Delete. You have the right to request that we delete Personal Information we have obtained about you.
• Right to Data Portability. You have the right to request a copy of your Personal Information that you previously provided to us in a portable and, if feasible, readily usable format.
• Right to Opt Out. You have the right to request to opt out of (i) targeted advertising; (ii) the sale of Personal Information; and (iii) profiling to make significant decisions about you. While we do not “sell” your Personal Information for money, we engage in routine online practices with third parties that may be considered a “sale” under Texas law, including targeted advertising. We do not make significant decisions about you using profiling.

Texas residents may exercise these rights by emailing us at cs@windowsusa.com . To opt out of targeted advertising and sales of Personal Information, please use our cookie preference center - https://www.iubenda.com/privacy-policy/45064092/cookie-policy . If we deny your rights request, you may appeal our decision by contacting us at cs@windowsusa.com .

SECURITY OF PERSONAL INFORMATION

We maintain reasonable safeguards designed to protect against unauthorized access, use, and disclosure of your information in our custody and control. However, no data, on the Internet or otherwise, can be guaranteed to be 100% secure. While we strive to protect your information from unauthorized access, use, or disclosure, we cannot guarantee the security of your information.

THIRD PARTY WEBSITES

Our Online Properties may contain links to other websites not operated or controlled by us, including social media services. This Privacy Notice does not apply to those websites, and we are not responsible for the privacy practices of the parties that operate those websites. The information that you share with those sites will be governed by the specific privacy notices of those sites. Please review their privacy notices for information on their privacy practices and policies.

CHILDREN’S PRIVACY

Our websites are intended for individuals over 18 years of age. We do not target our websites to know or knowingly collect any information from children under age 18. If you believe a minor has provided us with Personal Data, please contact with us at the contact information below.

INTERNATIONAL USERS

If you use our services from outside the United States, your Personal Information may be transferred to, stored, and processed in the United States. The laws in the United States may be different than those in your country.

CHANGES TO THE PRIVACY NOTICE

We may update this Privacy Notice. When we do, we will post an updated version on this page, unless another type of notice is legally required. The effective date is provided at the top of this Privacy Notice. 

CONTACT US

Please feel free to contact us at any time if you have any questions or comments about this Privacy Notice or our privacy practices by contacting us at cs@windowsusa.com.

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