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Privacy Policy

Updated on April 25, 2021

Welcome! This is Wheelhouse’s privacy policy and summarizes how we use your personal information. Make sure you read it. It’s important. “Wheelhouse”, “we”, “our” and “us” refer to Wheelhouse Enterprises, Inc.

We collect information about you when you visit or use our website www.wheelhouse.com and our related services (“Services”). We work with software vendors (our business customers) and prospective software buyers (users of our website who want to be connected with software vendors). For example, if you are a software vendor, this Privacy Policy applies when one of your employees creates an account with us or creates a listing of your software product on our Service. If you are a prospective software buyer, this Privacy Policy applies when you come to our website and request information about products offered by software vendors.

In this Privacy Policy we don’t cover the privacy or data practices of other businesses (except as required by applicable law). For example, if you would like information about how a software vendor uses your information, you should contact that software vendor directly. See “Third Parties” below for more information.

When you use Services you are accepting the practices described in this Privacy Policy. Also, when you submit your contact information to us, you agree that we can contact you using automated means at the phone number and email address provided. Consent is not a condition to receiving our Services.

CONTACTING US

You can contact us about our Privacy Policy as follows:

privacy@wheelhouse.com

Wheelhouse Enterprises, Inc.
Attention: Privacy
548 Market St #51150
San Francisco, CA 94104

COLLECTION AND USE

Prospective Software Buyers:

Categories of information we collect about you

We may collect information about you as an individual prospective software buyer or as an individual on behalf of a prospective software buyer business. For example, we may collect the following types of information about you:

  • Identifiers such as name, email address, phone number, physical address, IP address, mobile device identifiers, and cookie identifiers
  • Internet or other similar network activity such as information on your interaction with our website, browser type, referring site, and device information,
  • Location data based on your IP address,
  • Audio data when we record calls if permitted by law,
  • Professional related data about you, and
  • Inferences drawn from information we have on you to determine the kind of software products you may be interested in.
Sources of categories
  • Information you provide: We collect your personal information when you directly contact us about software products of software vendors. For example, you could fill out a form requesting to be contacted or requesting to receiving pricing information about a software vendor. Or you might ask us for access to our white papers.
  • Automatically collected information: We and our service providers may collect other information automatically such as through cookies and similar technologies, your browser or device, your mobile device identifier, your interaction with our advertisements, and your IP address.
  • Information we receive from service providers: We may also receive information about you from our suppliers because those suppliers thought you might be interested in buying software from our software vendors.
Uses of information
  • To provide the Services to you,
  • To contact you to respond to your requests,
  • To connect you with software vendors,
  • To send administrative information to you,
  • To evaluate the quality of the Services and to improve the Services,
  • To send you targeted content and communications that we believe may be of interest to you to the extent permitted by applicable law,
  • To assist software vendors in sending you targeted content or communications that they believe may be of interest to you,
  • For our service providers’ advertising purposes (e.g., Google Analytics),
  • To provide you with personalized location-based services and content through the use of your device’s physical location where permitted by law,
  • To measure and report on the success of marketing campaigns,
  • To diagnose problems and for fraud monitoring and prevention, and
  • As we believe necessary: to comply with legal process and our legal obligations, to enforce our terms and conditions and to protect our rights, privacy, safety or property, and/or that of you or others.
Legal basis for individuals in Europe

Where Wheelhouse operates as a data controller with respect to personal data of individuals in Europe, we rely on:

  • legitimate interests to process personal information to provide our Services to you and
  • your consent to process personal information.

Software Vendors:

Categories of information we collect about you

We may collect information about you as an employee or other representative of a software vendor, our business customer. For example, if you are an employee of a software vendor that lists its information on our Services, we may collect the following types of information about you:

  • Identifiers such as name, email address, phone number, physical address, IP address, mobile device identifiers, and cookie identifiers,
  • Internet or other similar network activity such as information on your interaction with our website, browser type, referring site, and device information,
  • Professional related data about you,
  • Information about the software that you offer, and
  • Financial information such as credit card number and billing address related to your organization so that we can process payments owed to us
Sources of categories
  • Information you provide: We collect your personal information when you directly contact us on behalf of a software vendor. For example, you could contact us to request information about our lead generation services.
  • Automatically collected information: We and our service providers may collect other information automatically such as through cookies and similar technologies, your browser or device, your mobile device identifier, your interaction with our advertisements, and your IP address.
Uses of information
  • To provide the Services to you,
  • To contact you to respond to your requests,
  • To connect you with software buyers,
  • To send administrative information to you,
  • To process payment,
  • To evaluate the quality of the Services and to improve the Services,
  • To send you targeted content and communications that we believe may be of interest to you to the extent permitted by applicable law,
  • To assist software buyers in contacting you,
  • For our service providers’ advertising purposes (e.g., Google Analytics),
  • To provide you with personalized location-based services and content through the use of your device’s physical location where permitted by law,
  • To measure and report on the success of marketing campaigns,
  • To diagnose problems and for fraud monitoring and prevention,
  • As we believe necessary: to comply with legal process and our legal obligations, to enforce our terms and conditions and to protect our rights, privacy, safety or property, and/or that of you or others.
Legal basis for individuals in Europe

Wheelhouse is a data processor with respect to personal information we collect on the representatives of software vendors (our business customers). Our business customers are the data controllers. When we process this data we rely on:

  • the instructions of the software vendor,
  • legitimate interests to process personal information to provide our Services to you, and
  • your consent to process personal information.

DISCLOSURES

Software Buyers:

We may disclose your information:

  • with software vendors who will provide you with information about their products and services,
  • with our service providers who provide services such as marketing analytics, website analytics and cloud storage services,
  • on public profile pages, social media pages and blogs and other services where you posted the information directly,
  • with a third party in the event of any reorganization, sale, joint venture, or other disposition of our business, and
  • as we believe necessary: to comply with legal process and our legal obligations, to enforce our terms and conditions and to protect our rights, privacy, safety or property, and/or that of you or others.

Software Vendors:

We may disclose your information (as a representative of a software vendor):

  • with software buyers who may be interested in your product or service,
  • with our service providers who provide services such as payment processing, marketing analytics, website analytics and cloud storage services,
  • on public profile pages, social media pages and blogs and other services where you posted the information directly,
  • with a third party in the event of any reorganization, sale, joint venture, or other disposition of our business, and
  • as we believe necessary: to comply with legal process and our legal obligations, to enforce our terms and conditions and to protect our rights, privacy, safety or property, and/or that of you or others.

We provide our service providers with only the information necessary for them to perform the services we request, and we ask service providers not to use such information for purposes other than as specified by Wheelhouse. We do not sell your personal information to third parties in the ordinary course of business.

USER RIGHTS

If you’d like to access, correct, suppress, or delete the personal information that Wheelhouse maintains about you, you can contact us at privacy@wheelhouse.com. We’ll respond to your request as soon as we can.

CALIFORNIA CONSUMER RIGHTS

The California Consumer Privacy Act (CCPA) provides certain California residents with the additional rights listed below. The CCPA temporarily exempts from these CCPA rights certain business-to-business personal information and certain personal information about Wheelhouse’s workforce.

In cases where we process your information on behalf of a software vendor, you will need to exercise your rights directly with the software vendor, unless the software vendor allows us to respond to you directly.

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you,
  • The categories of sources for the personal information we collected about you,
  • Our business or commercial purpose for collecting that personal information,
  • The categories of third parties with whom we share that personal information, and
  • The specific pieces of personal information we collected about you (which will also allow you to exercise your data portability right).

You have the right request that we provide you with access to the information above in a readily useable format that allows you to transmit (i.e., port) the information to another entity without hindrance. If you make a request under your right to request access, you will receive access to your information in a readily useable format.

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. You must contact the applicable software vendor directly to delete your information that they have in their systems.

We may deny your deletion request or not delete some of your personal information, if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We may also limit our deletion to the extent permitted by applicable law.

To exercise your rights, email us or mail us your request with the following information:

  • Full name and email address associated with your use of our Service, and
  • Your specific request (e.g., right to access, right to portability, or right to delete).

privacy@wheelhouse.com

Wheelhouse Enterprises, Inc.
Attention: Privacy
548 Market St #51150
San Francisco, CA 94104

We will attempt to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

We will not discriminate against you for exercising any of your rights under the CCPA.

California law allows our users that reside in California to ask for information about our practice of sharing their personal information with third parties for their own direct marketing purposes. Please contact us as follows:

privacy@wheelhouse.com

Wheelhouse Enterprises, Inc.
Attention: Privacy
548 Market St #51150
San Francisco, CA 94104

EUROPEAN DATA SUBJECT RIGHTS

If you are located in the European Economic Area, the United Kingdom or Switzerland, you have specific legal rights in regard to the handling of your information.

European Data Subject Rights
  • The right to access the personal information we process about you
  • The right to rectify personal data about you that is inaccurate or incomplete
  • The right to have your personal information erased
  • The right to restrict processing of your personal data in certain circumstances
  • The right to data portability
  • The right to object to the processing of your personal data
  • The right to lodge a complaint with a supervisory authority
  • Right to be free from automated decision making and profiling
  • Right to withdraw your consent for processing done based on your consent

To exercise these rights, contact us at:

privacy@wheelhouse.com

Wheelhouse Enterprises, Inc.
Attention: Privacy
548 Market St #51150
San Francisco, CA 94104

TRANSFER OF DATA

If you use the Services from outside of the United States, we will process your information in the United States and any other country where we operate our business or where our service providers operate. The privacy laws in the United States and those other countries may not be as protective as those where you live. By using our Services, you consent to the transfer of your information to the United States and those other countries.

If you are located in the European Economic Area, the United Kingdom or Switzerland, in order for us to transfer your personal data to the United States, we rely on and comply with the EU Standard Contractual Clauses (the “Model Clauses”) regarding the collection, use, and retention of personal information. If there is any conflict between the terms in this Privacy Policy and the Model Clauses, the Model Clauses control. To read about the Model Clauses, please visit
https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32010D0087&from=en.

If you have any complaints about our collection or use of your personal information please contact us at:

privacy@wheelhouse.com

Wheelhouse Enterprises, Inc.
Attention: Privacy
548 Market St #51150
San Francisco, CA 94104

OPTING OUT

Opting out of communications

You can opt out of receiving communications from us. If you no longer want to receive communications from us, please contact us at privacy@wheelhouse.com. For email, you can also click on the unsubscribe link in the email.

Please note that we may still need to contact you for administrative purposes relating to the Services from time to time.

Opting out of cookies

For information about your choices regarding cookies, see our Cookie Policy.

Opting out of interest-based advertising by third parties in mobile apps

To opt out of our interest-based advertising by third parties that takes place through mobile applications, please follow the instructions in your mobile device’s operating system’s opt out settings.

Opting out of cross-device targeting by third parties

Third parties may combine and use information from websites or applications on your current browser or device with information from your other browsers or devices for advertising purposes. To opt out of such practices, follow the instructions in our Cookie Policy for opting out of cookies on each of your browsers and opting out of interest-based advertising in mobile apps on each of your mobile devices above.

Please note that you will need to opt out separately on (1) each of your browsers and (2) each of your devices to ensure that information collected on a particular browser or device is not used on another browser or device.

Opting out of use of precise location

To disable the collection of precise location information from your mobile device through mobile applications, you can access your mobile device settings and choose to limit that collection.

Do Not Track headers

At this time, we do not honor browser “Do Not Track” headers and similar mechanisms.

COOKIES AND SIMILAR TECHNOLOGIES

We use cookies as part of our Services. A cookie is a small data file that we store on your computer’s or mobile device's memory. Some cookies collect information about how you use our Services, which highlights areas we can improve, including navigation. We may also use cookies to send you advertising or content that we think may be of interest to you.

For more information about how we use cookies and similar technologies and your choices, please read our Cookie Policy.

THIRD PARTIES

This Privacy Policy doesn’t cover the privacy or data practices of any third parties (except as required by applicable law), including any of our service providers or any software vendors or any third parties operating any site or service to which our Services link. If you see a third party link on our website, it doesn’t mean that we endorse that site. You should review these third parties’ own privacy policies.

SECURITY

We store personal information using procedures that we think are designed to help protect against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information that is processed by us.

USE OF SERVICES BY MINORS

Our Services are not intended for or directed to individuals under the age of 18. If you are under 18, please don’t provide personal information to us.

RETAINING YOUR INFORMATION

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer period is required or permitted by law, or if you (as an individual) request the deletion of your information. We will retain personal information of software vendors’ representatives for the period necessary to fulfill our obligations under our contract with our software vendors, unless a shorter or longer period is required or permitted.

CHANGES

We may make changes to this Privacy Policy. Please look at the date at the top of this page to see when this Privacy Policy was last updated. Where required by law, we will obtain your consent to make these changes or give you notice of these changes.