Winston Privacy does not remotely collect or store any record of internet activity.
We do not share customer data with third parties or engage in whitelisting agreements.
We are independently owned and are based in the US.
Read this document to understand what data we potentially have access to and how we use it.
SECTION 1 - PRIVACY PROTECTIONS
The Winston device and network are designed to encrypt your internet activity and to the greatest technical extent possible render it unusable for tracking purposes by third parties, including us. We do not (and cannot) monitor your internet activity on our network nor do we gather any usage data from your Winston device.
We do not engage in any form of logging of traffic on the distributed network we and intentionally design our systems to mangle and encrypt packets to prevent tracking of the source IP address.
Network level filtering protections are extended to all local traffic. IP cloaking protections are currently extended to HTTP/S traffic on port 80 and 443 and do not include any websites that you voluntarily choose to reveal or whitelist, nor to the third parties that those websites call in turn.
Winston's hardware device maintains a local database containing a record of the domains which have been contacted or blocked on your network over the prior 7 days. The hardware regularly analyzes this information to assess the potential for privacy risk and adjust security and network egress policies for sites with higher potential to leak private data. This data is not accessible remote and is automatically erased after 7 days. It can be manually erased by clicking the Factory Reset button found on the Advanced Settings page of the dashboard.
Winston ships with a set of default whitelists which improves security and performance for streaming, financial, gaming and web conferencing sites. These whitelisted sites may be examined and modified or disabled in the "Privacy Settings" section of the Winston administration website.
IP cloaking protections do not extend to Torrent, Onion or other file sharing protocols.
Winston does not accept paid inclusions on our whitelists.
SECTION 2 - DEVICE TELEMETRY
The Winston device will periodically report its functional status, check for software updates and download them as necessary. The minimal amount of information required to keep your device updated and operating properly (including firmware version, IP address, estimated latitude/longitude of the IP address within 11 km, bandwidth estimates, advanced settings selections, hardware metrics and other firmware-related details) will be transferred to our update service during this process. No activity data is transferred from your device.
SECTION 3 - REMOTE DIAGNOSTICS/DEBUGGING
In the event of a hardware or networking issue, our customer support team may request a diagnostics file from your device. There is no way to remotely generate this file and it may only be provided by the end user. This file contains debug output, configuration settings and a database containing recent activity, traffic measurements and privacy risk scores. No information from this file is used for any purpose other than diagnosing issues and it is deleted after analysis.
On rare occasions, it may necessary for our engineering staff to remotely debug a device in order to troubleshoot a hardware issue. In such cases, customer support will explicitly request permission and connection details and then provide instructions on how to manually configure the device to enable this. Remote debugging sessions are secured by private keys and are limited to specific Winston IP bastion hosts.SECTION 4 - WHAT DO WE DO WITH YOUR MARKETING AND SUBSCRIPTION INFORMATION?
When you purchase something from our store, as part of the buying and selling process, we collect the personal information you give us such as your name, address and email address.
When you browse our store, we also automatically receive your computer’s internet protocol (IP) address in order to provide us with information that helps us learn about your browser and operating system.
We may send you emails and/or physical mail about Winston, new products and other updates. You may opt-out of marketing at any time. Your shipping address is also used to automatically opt you out of direct mail advertising.
SECTION 5 - CONSENT
How do you get my consent?
When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only.
If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.
How do I withdraw my consent?
If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at anytime, by contacting us at email@example.com or mailing us at: Winston Privacy, Inc. 333 N. Green St #807, Chicago IL, 60607, United States
SECTION 6 - DISCLOSURE
We may disclose your personal information if we are required by law to do so or if you violate our Terms of Service. This data is limited to your contact information provided as part of your subscription, your serial number, IP address, and estimated location of the IP address within 11 km.
We do not collect nor can we remotely access any history of internet activity and cannot provide this information to anyone.
SECTION 7 - SHOPIFY
Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you.
Your data is stored through Shopify’s data storage, databases and the general Shopify application. They store your data on a secure server behind a firewall.
If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. It is encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction. After that is complete, your purchase transaction information is deleted.
All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.
PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
For more insight, you may also want to read Shopify’s Terms of Service here or Privacy Statement here.
SECTION 8 - THIRD-PARTY SERVICES
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
When you click on links on our site, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
SECTION 9 - SECURITY
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.
If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption. Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.
We encourage you to regularly delete or block all cookies, including any placed on your computer by our website. Unfortunately, these cookies are required by our hosting and payment providers, so we are forced to serve them.
Here is a list of cookies that are used by Shopify. We’ve listed them here so you can understand what they are used for and opt-out if you choose.
_session_id, unique token, sessional, Allows Shopify to store information about your session (referrer, landing page, etc).
_shopify_visit, no data held, Persistent for 30 minutes from the last visit, Used by our website provider’s internal stats tracker to record the number of visits
_shopify_uniq, no data held, expires midnight (relative to the visitor) of the next day, Counts the number of visits to a store by a single customer.
cart, unique token, persistent for 2 weeks, Stores information about the contents of your cart.
_secure_session_id, unique token, sessional
storefront_digest, unique token, indefinite If the shop has a password, this is used to determine if the current visitor has access.
SECTION 10 - AGE OF CONSENT
By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
If our store is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.
SECTION 12 - SMS/MMS MOBILE MESSAGING MARKETING PROGRAM
We respect your privacy. We will only use the information you provide through the Program to transmit your mobile messages and respond to you, if necessary. This includes, but is not limited to, sharing information with platform providers, phone companies, and other vendors who assist us in the delivery of mobile messages. WE DO NOT SELL, RENT, LOAN, TRADE, LEASE, OR OTHERWISE TRANSFER FOR PROFIT ANY PHONE NUMBERS OR CUSTOMER INFORMATION COLLECTED THROUGH THE PROGRAM TO ANY THIRD PARTY. Nonetheless, We reserve the right at all times to disclose any information as necessary to satisfy any law, regulation, or governmental request, to avoid liability, or to protect Our rights or property. When you complete forms online or otherwise provide Us information in connection with the Program, you agree to provide accurate, complete, and true information. You agree not to use a false or misleading name or a name that you are not authorized to use. If in Our sole discretion, We believe that any such information is untrue, inaccurate, or incomplete, or you have opted into the Program for an ulterior purpose, We may refuse you access to the Program and pursue any appropriate legal remedies.
California Civil Code Section 1798.83 permits Users of the Program that are California residents to request certain information regarding our disclosure of the information you provide through the Program to third parties for their direct marketing purposes. To make such a request, please contact us at the following address:
Winston Privacy, Inc.
333 N. Green St #807, Chicago IL, 60607, United States
QUESTIONS AND CONTACT INFORMATION
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact us at firstname.lastname@example.org or by mail at:
Winston Privacy, Inc.
333 N. Green St #807
Chicago IL, 60607