WAVE PRIVACY POLICY

Last updated: June 15, 2023

Introduction
Worthington Armstrong Venture (“WAVE,” “we,” “us,” “our”) takes your privacy seriously. This Privacy Policy describes the ways we collect, use, and disclose the information we may collect through our website, https://worthingtonarmstrongventure.com/, and all of its subdomains or websites that link to this Privacy Policy, (collectively, the “Site”).

The Site may contain links to websites and services hosted by third parties that are not under common ownership or control with WAVE. If you choose to link to these websites or services, you agree that the privacy policies of such third parties, and not WAVE, will apply to your use of those services. If you use the website of one of WAVE's affiliated parent companies, please note that such websites may also have different privacy policies to govern the collection of information from you, and those privacy policies will be available on their websites.

By using the Site, you agree to this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Site.

This Privacy Policy contains the following sections:

  • Information We Collect and How We Collect It
  • How We Use Your Information
  • When We Disclose Your Information
  • International Users
  • Personalized Content and Your Choices
  • Your Data Rights and Choices
  • Notice to California Residents
  • Data Security
  • Data Retention
  • Privacy Policy Changes
  • Contact Us

Information We Collect and How We Collect It
As discussed further in this section, WAVE may collect the following categories of information about you depending on how you interact with the Site:
Information You Directly Provide to Us

When you use the Site, you may provide information directly to us, including:

  • Contact information, such as your name, email address, phone number, fax number, company name, your role, and physical address.
  • Business information, such as company name, company email address, company physical address, professional licenses, and other information relating to your business.
  • Registration information, including a username and password.
  • Correspondence between you and us and records of such correspondence, such as the contents of emails you send us, support inquiries, or other feedback you provide directly to us.
  • General geolocation information, such as zip code inferred based on your IP address.
  • Information you provide in product reviews and surveys;
  • Marketing preferences, such as records of your requests to opt out of marketing communications.
  • Additional information that you provide. This can include any additional information that you choose to provide us in connection with the Site.

Information Automatically Collected
Some information is collected by us automatically when you access our Site. This information includes: (1) device and usage information, which may include the type of device you are using, your operating system, your browser type, your browser language, your internet service provider, your domain name, your internet protocol (IP) address, your device and mobile ad identifiers, the website that referred you to our website, the web pages you view (including the date and time you viewed them), and the services or functionality you access or use (including the date and time of your access or use); and (2) location information (which may include general information about the location of your device based on your IP address).

We and our service providers may use a variety of technologies to collect information about your device and use of our website(s) as discussed immediately above. These technologies include cookies, web beacons, JavaScript, and entity tags. Most web browsers can be programmed to accept or reject the use of some or all of these technologies, although you must take additional steps to disable or control other technologies.

  • Cookies – Cookies are small data files that are sent from a website’s server and are stored on your device’s hard drive either for only the duration of your visit ("session cookies") or for a fixed period ("persistent cookies"). Cookies contain information that can later be read by a web server. We may use cookies to understand user preferences, navigation, and locations.
  • Web Beacons – Web beacons are small, transparent images that are embedded in web pages, applications, online ads, and emails that are sometimes called “clear gifs," “single pixel gifs", "page tags" or “web bugs." We may use web beacons to track the web pages you visit and to find out if an email has been opened and acted on.
  • Java Scripts – Java scripts are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components.
  • Entity Tags -- Entity Tags are HTTP code mechanisms that allow portions of websites to be stored or “cached" within your browser and validates these caches when the website is opened, accelerating website performance since the web server does not need to send a full response if the content has not changed.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g., Microsoft Edge, Google Chrome, Mozilla Firefox, or Apple Safari). As stated above, by blocking any or all cookies, you may not have access to certain features or offerings of the Site.

We use third parties to assist us in tracking site usage statistics and providing content- sharing services to support the Site. We do not control these third-party technologies, and their use of your information is governed by those parties' privacy policies. For more information about how to opt out of these third parties’ use of your information, please see “Personalized Content and Your Choices” below.

Information Collected from Third Parties

We may receive additional information such as demographic and statistical information from third parties and sources, such as business partners, marketers, researchers, analysts, public records, and others that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and provide more relevant experiences for you and improve our websites, analytics, and advertising.

How We Use Your Information

WAVE may use the information in the following ways:

  • To provide, operate, administer, and troubleshoot the Site.
  • To communicate with you about our products and services.
  • To review customer feedback that you requested or asked WAVE to review.
  • To analyze usage patterns and performance of our Site and products.
  • To market our products and services to you.
  • To administer surveys, sweepstakes, and special promotions.
  • To personalize your experience when using the Site.
  • To conduct internal research, reporting, and data analytics.
  • To enable third parties or agents to help WAVE maintain the Site, analyze how users use the Site, or provide other administrative services to WAVE.
  • To comply with applicable laws and regulations.
  • To protect or defend WAVE’s legal rights or property.
  • To enforce the legal or contractual terms that govern your use of the Site.
  • For other disclosed purposes to which you consent.
  • As required or permitted by law.
  • As otherwise described to you at the point of collection.

We may also combine information that we collect from you with information we obtain about you from third parties. We may aggregate and/or de-identify any information collected through the Site. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes and to improve users’ experience on the Site, and may also disclose such data to any third parties.

When We Disclose Your Information

We may disclose your information to parties outside of WAVE under the following circumstances:

  • Affiliates. We may disclose your information to our affiliates and subsidiaries under common ownership and/or control, including our parent companies.
  • Product distributors and joint marketing/product partners, including companies with which we market or promote our products and services, which may include distributors, contractors, representatives, retailers, or online marketplaces and websites to provide you with a product or service you requested.
  • Service Providers. We may provide access to your information to vendors and others who perform services on our behalf under contract with us. These parties provide a variety of services to us, including, without limitation, order processing, billing, sales, marketing, advertising, market research, fulfillment, data storage, analysis and processing, and legal services.
  • Consent. If you consent, we may disclose your information publicly or to third parties, such as if you agree to provide a product or service review and have that content attributed to you.
  • Protection of WAVE and Others. We may access, preserve and disclose your information if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to: (a) comply with applicable laws and regulations or legal process; (b) enforce our legal terms, this Privacy Policy, or other contracts with you; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of WAVE, its agents and affiliates, its users and/or the public. We may also disclose information to law enforcement agencies in emergency circumstances where the disclosure of such information is consistent with the types of emergency disclosures permitted or required by law.
  • Business Transfers. We may disclose and/or transfer your information, including your contact information, in connection with a proposed or actual merger, acquisition, transfer of control, distribution or sale of all, or components, of our business or our assets.

International Users

Please be aware that we are based in the United States and the information we collect will be transferred to, processed, and stored on servers in the United States in accordance with this Privacy Policy and applicable laws. The data protection laws and regulations applicable to your information transferred to the United States may be different from the laws in your country of residence. We take appropriate steps to protect, process, and transfer your information only in accordance with this Privacy Policy and applicable law.

Personalized Content and Your Choices

Online Analytics

We may use third-party web analytics services on our Site, such as those of Google Analytics and others. These entities use the sort of technology previously described in the “Information We Collect and How We Collect It” section to help us analyze how users use the Site, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Site. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

Your Data Rights and Choices

Marketing Communications

In accordance with applicable law, WAVE may send you marketing and promotional emails. If you would like to opt out of email marketing, notify us at [email protected] or follow the unsubscribe instructions in the email. Please note that even though you may opt-out of receiving marketing-related communications from us, we may still send you important administrative and transactional messages (e.g., shipment notifications, notifications regarding updates to our legal terms).

Rights Regarding Your Information

Depending on your jurisdiction, you may have the right, in accordance with applicable data protection laws, to make requests related to your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to herein as “personal information”). Specifically, you may have the right to ask us to:

  • Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties to whom we disclose personal information.
  • Provide you access to and/or a copy of certain personal information we hold about you.
  • Correct or update personal information we hold about you.
  • Delete certain personal information we have about you.
  • Provide you with information about the financial incentives that we offer to you, if any.
  • Restrict or object to certain uses of your information.
  • Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

Please note that certain information may be exempt from such requests under applicable law. For example, we need certain information in order to provide the Site (including our products and services) to you.

If you are a California resident, please see the “Notice to California Residents” section below for more information about our privacy practices and your rights.

As provided in applicable law, you also have the right to not be discriminated against for exercising your rights. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our products and services to you. We also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify your identity, we may be unable to respond to your requests. Please note that we have not "sold" or "processed" personal information for purposes of online "targeted advertising" over the past year as such terms are defined in applicable law.

To exercise any of these rights, you can call us at 833-950-7400 or email us at [email protected] with your name and type of request you are making.

You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law.

Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority.

Notice to California Residents

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and disclose your “personal information” as defined in the California Consumer Privacy Act (“CCPA”).

We describe the categories of information we collect, our business purposes for collecting such information, the sources and uses of such information and the entities with which we disclose such information in the “Information We Collect and How We Collect It”, “How We Use Your Information,” and “When We Disclose Your Information” sections of this Privacy Policy. We provide additional information required by the CCPA below.

Categories of Personal Information We Collect, Use, and Disclose

Throughout this Privacy Policy, we discuss in detail the types of Information we collect from and about users and discuss how we use and disclose such information. The following are the “categories” of personal information under the CCPA that we collect from California consumers and that we may, as discussed throughout this Privacy Policy, use and disclose for our business purposes:

Identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information processed by our payment processor); device identifiers (such as IP address and unique device identifiers); internet or other network or device activity (such as browsing history); general geolocation data derived from IP addresses; any user- generated content or feedback that you provide; and registration information (e.g., username and password) (which is considered “sensitive” personal information under California law).

How We Use These Categories of Personal Information

We and our service providers may use the categories of personal information we collect from and about you for the following business and commercial purposes (as those terms are defined in applicable law):

  • Our or our service providers’ operational purposes;
  • Auditing consumer interactions on the Site and with other third parties, which may include data compilers, business partners and promoters of our products (e.g., retailers, distributors, contractors, representatives or online marketplaces);
  • Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
  • Bug detection and error reporting;
  • Customizing content that we or our service providers display on the Site;
  • Providing the Site and our services (e.g., account servicing and maintenance, customer service, marketing, analytics, and communication about the Site and our services);
  • Improving our existing services and developing new services (e.g., by conducting research to develop new products or features);
  • Other uses that advance our commercial or economic interests, such as communicating with you about relevant offers; and
  • Other uses about which we notify you.

Examples of these types of uses are discussed in our main privacy policy in the “How We Use Your Information” section. We may also use the categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any user or device. We may also disclose this information to third parties for legal, compliance or security purposes, or in connection with a business transfer, as described further in “When We Disclose Your Information” above.

Additional Privacy Rights

In addition to the rights set forth in the section above on “Sale/Sharing of Personal Information,” California residents may make certain requests about their personal information under the CCPA as set forth in the section above on “Rights Regarding Your Information.”

Please note that we have not "sold" or "shared" personal information for purposes of cross-context behavioral advertising over the past year as such terms are defined in the CCPA.

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note, in the limited circumstances that we process sensitive personal information (such as usernames in combination with passwords) as defined in the CCPA, we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA. We ask that users not include sensitive information in your correspondence with or any submissions to WAVE.

If you are a California resident and would like to exercise any of your legal rights under the CCPA, you can call us at 833-950-7400 or email us at [email protected] with your name and type of request you are making.

Shine the Light

California law permits customers who are California residents to request certain information once per year regarding our disclosure of their “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Except as otherwise described herein with respect to legally required browser based opt outs, we do not recognize or respond to browser-initiated DNT signals, as there is no industry-wide framework for DNT signals. To learn more about Do Not Track, you can do so here. Please note that Do Not Track is a different mechanism that the legally-recognized browser-based opt out preference signal mentioned above.

Data Security

WAVE uses appropriate measures to safeguard the information you submitted to us through the Site or that WAVE received about you through the Site or third parties. You agree by using the Site that you understand that no transmission of information over the Internet can be guaranteed to be totally secure. If you do not want to transmit information to WAVE because WAVE cannot and does not guarantee it will be totally secure during its transmission, do not submit information through the Site, call us instead.

Data Retention

WAVE will retain your information in its computer systems as long as needed for the purposes described in this Privacy Policy. There may be laws that require WAVE to keep your information for specific time periods. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. To dispose of your information, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

Privacy Policy Changes

WAVE may change this Privacy Policy.
When WAVE changes it, WAVE will revise the Privacy Policy’s effective date. If we make a material change to the Policy, we will provide you with appropriate notice in accordance with legal requirements. By continuing to access and use the Site, you are confirming that you have read and understood the latest version of this Privacy Policy.

Contact Us

Questions, comments, and requests about this Privacy Policy or the information WAVE collects about you while you use the Site may be sent to [email protected] or mailed to Worthington Armstrong Venture, 101 Lindenwood Drive, Suite 350, Malvern, PA 19355.