Protecting your privacy is important to Wellspring Worldwide Inc. This Policy explains how Wellspring collects, uses and discloses the personal and non-personal information you may provide while using the Wellspring website at www.wellspring.com (the “Website”).
This Policy applies only to the personal information you provide to Wellspring through the Website.
2. Your Consent
By being a User of the Website, you consent to the collection, use, and disclosure of your personal information in accordance with this Policy. If you do not consent to the collection, use, and disclosure of your personal information in accordance with this Policy, you may not use the Website.
3. Information Collected
(a) Personal Information: During your use of the Website, you may be asked to voluntarily provide personal information (such as your name, email address, affiliated organizations). If you choose not to provide certain requested personal information, you will not be able to access or use certain services of the Website.
(b) Non-Personal Information: The Website automatically collects certain non-personal information regarding all Website Users, such as the date and time they access the Website, the Internet address of the website from which they linked directly to the Website, the browser they are using, and the Website pages read and the content accessed or downloaded. This non-personal information is used for system administration purposes and to improve the Website. Non-personal information of Users may be disclosed to other persons and permanently archived for future use. If non-personal information is combined with personal information referenced above, then the non-personal information for a User will be treated as personal information.
(c) Cookies: The Website may use “cookies”, a technology that installs a small amount of information on a Website user’s computer to permit the Website to recognize future visits using that computer. Cookies enhance the convenience and use of the Website. For example, the information provided through cookies may be used to recognize you as a previous user of the Website (so you do not have to enter your personal information every time), offer personalized information for your use, and otherwise facilitate your experience using the Website. You may choose to decline cookies if your browser permits, but doing so may affect your ability to access or use certain features of the Website.
(d) Advertisement Cookies: Advertisements may be displayed on the Website and may contain cookies or other technologies. Third party advertising companies may provide those advertisements and Wellspring has no control over, and no responsibility or liability for, the cookies or other technologies used in the advertisements or for the use and disclosure of information collected through advertisement cookies or other technologies.
4. Use of Personal Information
(b) Emails from Wellspring: If you contact Wellspring by email or otherwise indicate that you would like to receive email from Wellspring, Wellspring may send to you email or other communications containing information Wellspring believes may interest you. At any time, you may ask Wellspring to stop sending you email and other information by sending your request to [email protected] the email address noted below. From time to time Wellspring may also send to you email containing important information regarding the Website services, which you may not opt out of receiving.
5. Disclosure of Your Personal Information
Wellspring may disclose your personal information in the following circumstances and as otherwise permitted by applicable law:
(a) Disclosure to Organizations: If you use the Website on behalf of another person or organization, such as your employer and you identify your organization (an “Organization”) when you either register as a Wellspring User, or through other Wellspring Services, Wellspring may provide your personal information to your Organization if requested by an asserted authority to obtain the information from that organization. Wellspring has no control over, and no responsibility or liability for, the use of your personal information by Organization, and that use is not subject to this Policy. If you do not wish your personal information to be disclosed to an Organization, you should not reference that Organization in your registration, authorization for purchases, Wellspring Group, or for other Wellspring Services that would include this information.
(b) Disclosure to Affiliates, Agents, Suppliers and Service Providers: Wellspring may provide your personal information to its affiliates, agents, suppliers and service providers for use in connection with matters relating to your use of the Website or the provision of services to you. If at any time you do not wish your personal information to be disclosed to certain affiliates, agents, suppliers, service providers, or any other persons, you may send your request to Wellspring’s Privacy Officer at the email address noted below; however, this may affect your ability to use the Website and you may not alter records relating to previous transactions or, if you are acting as an agent, prevent an associated Organization from obtaining appropriate information.
(c) Disclosure to Other Users: Wellspring may provide your personal information to the Users from whom you have requested information, requested to join a Group, or licensed or downloaded Content through the Website. Wellspring requests in the Acceptable Use Policy that Users and Group Members to agree to use and disclose your personal information only for the following purposes: to contact and correspond with you, to distribute and deliver technologies and materials to you and provide related services to you, to administer agreements with you, and as otherwise permitted by applicable law. Wellspring has no control over, and no responsibility or liability for, Users use or disclosure of your Personal Information, and that use and disclosure is not subject to this Policy.
(d) Disclosure in Business Transfers: Wellspring may be involved in the sale or transfer of some or all of its businesses. As part of a sale or transfer, Wellspring may disclose your personal information to the acquiring organization, but will request the acquiring organization to agree to protect the privacy of your personal information in a manner that is consistent with this Policy.
(e) Disclosure for Law Enforcement Purposes: Wellspring may disclose your personal information to a government institution or agency that has asserted authority to obtain the information, or where Wellspring believes in good faith that the information could be useful in the investigation of potentially unlawful activity or in the prevention of harm to persons or property (including Wellspring), or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information, or to its legal counsel. Wellspring has no control over, and no responsibility or liability for, those persons’ use and disclosure of your personal information, and that use and disclosure is not subject to this Policy.
(f) Depersonalized Information: Wellspring may use your personal information to create non-personal information regarding the general statistics on the use of the Website. Wellspring may then disclose that non-personal information to other persons and permanently retain that non-personal information for future use.
(g) Business Contact Information: To the extent permitted by law, the provisions of this Policy concerning “personal information” do not apply to information (such as your personal name, position or title, business address, business telephone number, business fax number and business email address) that indicates you acted for an Organization and are the contact for those principals.
6. Security and Access
(a) Securing Your Information: Wellspring employs reasonable security safeguards appropriate to the sensitivity of the personal information in its possession or under its control in order to protect that information from unauthorized access, collection, use, disclosure, modification or similar risks. Nevertheless, security risks cannot be eliminated and Wellspring does not guarantee that your personal information will not be used or disclosed in ways not otherwise described in this Policy.
(b) Accessing Your Personal Information: You may request access to your personal information and information about Wellspring’s collection, use and disclosure of that information by sending your request to Wellspring’s Privacy Officer at one of the addresses noted below. Subject to certain exceptions and limitations prescribed (or allowed) by applicable law or this Policy, you will be given reasonable access (direct or indirect at our option) to your personal information, and will be entitled to challenge the accuracy and completeness of the information and to have it amended if and as appropriate (e.g., you may not alter information relied on in previous transactions). You can help Wellspring maintain the accuracy of your information by notifying Wellspring of any changes to your personal information.
7. Other Matters
(a) Other Websites: The Website may contain links to other websites or Internet resources. When you click on one of those links you are contacting another website. Wellspring has no control over, and no responsibility or liability for, other websites or their collection, use and disclosure of your personal information.
(b) Former users: If you cease using the Website, or your permission to use the Website is terminated, Wellspring may continue to use and disclose your personal information in accordance with this Policy as amended from time to time.
(d) Policy Changes: To accommodate changes in the Website, changing technology, and legal developments, this Policy may be changed from time to time in Wellspring’s discretion and without any prior notice or liability to you or any other person. The collection, use, and disclosure of your personal information will be governed by the version of this Policy in effect at that time. New versions of the Policy will be posted on the Website and will be available upon request from Wellspring. Your continued use of the Website subsequent to any changes to this Policy will signify your consent to the collection, use, and disclosure of your personal information in accordance with the changed Policy. Accordingly, when you use the Website you should check the date of this Policy and review any changes since the last version. You should also bookmark this page and periodically review this Policy to ensure that you are familiar with the most current version.
(e) Contacting Wellspring’s Privacy Officer: Wellspring’s Privacy Officer may be contacted by the following methods: (a) by telephone – 312-643-5100; (b) by email – [email protected]; or (c) by postal mail to “Privacy Officer”, Wellspring Worldwide, Inc. 350 N. LaSalle Street 12th Floor, Chicago, IL 60654.