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WinDifferent General
Privacy Policy

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1. About this Privacy Policy

We care about your privacy. This Privacy Policy sets out the basis on which we, WinDifferent LLC, and our affiliates (hereinafter instinctively “WinDifferent” or “We”), take care about your privacy. It explains how we collect, use, process, share, disclose and store the Personal Data -as this term is defined below-, pertaining to (i) business people collected in connection with our lead generation services and/or (“Business People”) (ii) individuals in connection with its use of WinDifferent’s website (www.windifferent.com) (“Visitors”and the “Website” respectively) (collectively, Business People and Visitors are hereinafter referred to as instinctively “You” or the “User/s” altogether).


The aim of this Privacy Policy is to explain the Personal Data we collect from Users;, the purposes for which we collect it, how we use it, and how we share it. In sum, the purpose of this Privacy Policy is to explain how we protect Users’ privacy, and their rights in connection to their Personal Data.


As used in this Privacy Policy, “Personal Data” or “Personal Information” means any data provided by User’s, when accessing and logging in to our Website/s, or by any other means, as further detailed on Section 3 of this Privacy Policy.


The Personal Information collected by WinDifferent will be processed pursuant to: (i) the manner described herein and (ii) all requirements set forth by laws governing personal data applicable to the geographical area where the Users are located at (“Applicable Data Protection Laws”.)


For further clarifications on this Privacy Policy, questions or concerns, please do not hesitate to contact us (see Section 17).

2. About WinDifferent

WinDifferent LLC is a Florida limited liability company headquartered in 255 Aragon Ave, 2nd Floor, Coral Gables, FL 33134 the United States of América.


For the purpose of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), WinDifferent is the data controller of the User’s Personal Data as described in this Privacy Policy, unless expressly specified otherwise.

3. Personal Data we collect from you.

a) Categories of Personal Information and Specific Pieces of Personal Information we collect from You.


We have collected within the last twelve (12) months, and may collect in the future the following categories of Personal Information listed below from User’s, for business purposes pursuant the California Consumer Privacy Act of 2018 (“CCPA”):


  1. Identifiers and registration contact information: User’s full name, gender, birth date, country of residence, location, e-mail address, postal address, telephone number, Internet Protocol (IP) address, or other similar identifiers; User’s companies’ name, phone number, address, e-mail address, category and country where it operates and provides its products and/or services, business profile, job position, among others.
  2. Internet or other electronic network activity information: User’s device information and device identifiers, browsing type and language, browsing history, search history, and information regarding the User’s interaction with the Website.
  3. Geolocation data: User’s city, state, zip code, etc. related to the IP address.
  4. Other information.


b) Categories of Sources of collection Personal Information.

We may collect data, including Personal Data, through our interactions with User’s when they:


  • Access and register on our Website and/or our affiliates Websites;
  • Download content on our Website and/or our affiliates Websites;
  • Provide us and/or our affiliates with information via phone, email, social media, etc;
  • Subscribe to WinDifferent’s and/or WinDifferent’s Website newsletters, or other content-related material;
  • Leave comments on our Website and/or on our affiliate’s Websites.
  • During in-person meetings or at WinDifferent’s and/or WinDifferent affiliate’s events, conferences, workshops or gatherings;


Online information about User’s may also originate from the use of cookies and similar technologies (for example, pixel tags and device identifiers) on our Website and/or on our affiliate’s Websites or sites of third parties. For more information on cookies and similar technologies, please see Section 6 below.


c) Personal Information we collect from Third Parties
We work closely with various third parties and may receive Personal Data from them. We protect the Personal Data obtained from them in accordance with the practices and policies described herein, plus any additional obligations imposed by the third-party source of the Personal Data. The third-party sources may vary due to context, but may include the following:


  • Data brokers from which we purchase data to complement the data we collect when allowed by Applicable Data Protection Laws;
  • Partners: (i) technical services partners that helps us without technology, and may provide us with certain data (e.g. such as mapping IP address to location data) to help us to provide our services, (ii) advertising partners, that provide us with services on our Website (analytics, marketing, etc.) providing with inferences about User’s preferences and interests to offer User’s a better service and customized offering.
  • Public web sources: we may use our search technology to scan the web and gather publicly-available information.


d) Personal Data we collect Automatically.
Our Website automatically collects certain data, through automatic data collection tools such as cookies, beacons, among others. These tools automatically collect the following information:


  • Technical information including, but not limited to, User’s browser type, operating system, device information, online identifiers including cookie data and Internet Protocol address (IP), domain name, referral URL, time zone setting, and/or time-stamp for their visit, information about their devices.
  • Usage information including, but not limited to, User’s geographic location information (such as country and/or state), date and time they visited our Website, numbers and frequency visitors to our Website, page views and search queries, clickstream behaviors, amongst others. Also, it may include details of User’s use of third-party applications in connection with Windifferent’s Website.
    To provide Users with email alerts, event registrations, and other notices concerning WinDifferent’s activities, or events and/or news that might be of interest to;
    1. To administer and improve the functionality of our Website and its technical and functional management;
    2. To analyze, develop and improve the use and performance of our Website;
    3. As necessary and appropriate to protect WinDifferent’s, User’s rights and/or property;
    4. To manage the security of our Website;
    5. To comply with applicable law and regulations to operate our business;
    6. To answer to law enforcement requests as required by applicable law, court order, or governmental regulations;
    7. As described to the User’s when collecting their Personal Information, or as otherwise as set forth by the CCPA.


We do not collect additional categories of Personal Information, nor process the collected Personal Information for a different purpose than the ones described in this Privacy Policy.


Advertising: please bear in mind that the Personal Information we collect also allows us to keep Users posted on WinDifferent’s latest announcements, updates, and upcoming events. Also, to customize the content and advertising that User’ssee in our Website, personalizing User’s experience and allowing us to deliver the type of content and service and/or product offerings they are most interested in and to send periodic emails regarding our products and/or services. In the event User’s subscribe to any services or communications offered by WinDifferent, such as advertisements or newsletters, they are entitled to unsubscribe at any time by following the instructions included in such communications. If You don’t want to be on our e-mailing list, You can opt-out anytime by sending us an e-mail to: [email protected]

4. Legal Basis for processing your Personal Data:

We rely on the following legal bases to collect and process Users’ Personal Data under Applicable Data Protection Laws, as it corresponds:


  • Consent: where User’s have provided their consent for the processing of their Personal Data for a specific purpose.
  • Performance of a Contract: where processing is necessary for the performance of a contract with User’s , or taking steps prior entering a contract with any of them.
  • Legal obligation: where we have a legal obligation to process User’s Personal Data for example when answering to a public or governmental authority, courts, or regulators, according to a legal obligation under applicable law.
  • Legitimate interest: to satisfy a legitimate interest, for example when it is not required by law, but it clearly benefits the Users.

5. Cookies

How WinDifferent Uses Cookies and Other Technologies:


Cookies are small files that a Website or its service provider transfers to User’s computer’s hard drive through their web browser (if they allow) that enables the Website’s or service provider’s systems to recognize their browser and capture and remember certain information. For instance, we use cookies to understand User’s preferences based on previous or current Website activity, which enables us to provide them with improved services. We also use cookies to help us compile aggregate data about Website traffic, and Website interaction so that we can offer better Website experiences and tools in the future.


Categories of Cookies
We classify cookies in the following categories:

Performance Cookies
These cookies collect information about the use that visitors make of our services, such as the frequency of the visits and traffic, allowing us to improve the performance of our Website. These cookies can collect anonymous information about the visits on our Website. They are used exclusively to improve the performance of our services.
Functional Cookies
These cookies allow our Website to remember certain types of information. They provide functionality and personalization. This information is also anonymous. These cookies remember the options User’s have selected to improve their experience. These Cookies allow us to adapt our services based on the provided information.
Targeting Cookies
These cookies may be set through our Website to offer User’s relevant advertisements on other Websites, based on their interests. These cookies collect information on User’s browsing habits with the purpose of adapting advertisements to their activities. In general, this information is shared with other advertisers and third parties. We may also use this information to record the number of times have seen a particular ad and avoid showing them the same ads repeatedly.

Web Beacons
We may use web beacons are very small graphic images or objects embedded in our web page or e-mail) to collect information about User’s online actions, visits to our Website, and activity.


We use cookies to:

  • Understand and save User’s preferences for future visits.
  • Compile aggregate data about Website traffic and Website interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.


How to manage Cookies

  • In your browser
    User’s may modify or withdraw their consent for the use of Cookies at any time. If You do not want to receive Cookies anymore, You may use your web browser either to accept them or reject them. For such purposes, You must follow the instructions on your web browser. If You set your browser to reject Cookies, You may not be able to use all WinDifferent’s functions in the Website.
  • In User’s devices
    In your mobile device, your operating system (IOS) offers options for avoiding personalized advertising -both in IOS and Android- to limit the use of information with the use of apps to generate advertisements based on your interests and tastes.


Please be aware that advertisers and our partners may also use their own cookies and beacons, and unluckily we do not hold control for the information they collect. In such cases, You will need to refer to their Privacy Policies. These third parties may use the information collected to serve more relevant advertisements. To configure your cookie controls and reject advertising cookies, including third-party cookies follow the instructions on your mobile device.

6. Your Rights. How to exercise your Rights.

Under current privacy laws and regulations, User’s, are given certain rights in relation to their Personal Data. Accordingly, we are glad to offer them with security, transparency, and access control to their Personal Data as available, and with the exceptions set forth on applicable laws and regulations.

User’s have the following rights:


Under the GDPR:
If You are resident from the European Economic Area (EEA) or the UK, you have the following rights regarding your Personal Data:


  1. Right of access: you have the right to be informed and request access to the Personal Data we have collected and process about you.
  2. Right to rectification: you have the right to request the rectification of inaccurate Personal Data concerning you, which must be duly amended or updated without undue delay.
  3. Right to erasure: you have the right to request we delete your Personal Data.
  4. Right to restriction of processing: you have the right to request us to prevent from processing your Personal Data, either all or some of your Personal Data, temporarily or permanently
  5. Right to data portability: you have the right to request a copy of your Personal Data in electronic format and the right to transmit that data to another controller.
  6. Right to object: you have the right, at any time, to object to us from processing your Personal Data on grounds relating to your particular situation, and the right to object for your Personal Data to be processed for direct marketing purposes.
  7. Right not to be subject to automated decision making: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. For exercising any of the aforementioned rights, please contact us or email us at [email protected] or at the following number +1 (954) 889-7236.


Under the CCPA:
Personal Information Collected and Processed: Section 3 of this Privacy Policy describes the categories of Personal Information we collect, use and disclose, and/or have collected, used and disclosed for the preceding 12 (twelve months); the sources from which we obtain each category of Personal Information, and the purposes for which we obtain such Personal Information.


If You are resident of the state of California, USA, please be advised that You may exercise the following additional rights, under the CCPA:


A. RIGHT TO KNOW the specific pieces of information about you we collect, use, disclose or sell, or have collected, used, disclosed, or sold:

User’s have the right to KNOW the specific pieces of Personal Information we collect, use, disclose or sell, and have collected, used, disclosed or sold, covering the 12-month period preceding our receipt of their information request.


In particular, You might request for us to disclose:


  1. The specific pieces of your Personal Information we collect or have collected.
  2. The categories of Personal Information we have collect or have collected about You;
  3. The categories of sources from which we collect or have collected your Personal Information;
  4. The categories of your Personal Information that we sell, or have sold, disclose or have disclosed for a business purpose;
  5. The categories of third parties with whom we sell or have sold, disclose or have disclosed your Personal Information.
  6. The business or commercial purpose for which we have collect, sell or have collected or sold your Personal Information;


To make a verifiable consumer request for information about the Personal Information we have collected about you, please exercise your rights by contacting us or emailing us at [email protected] or at the following number +1 (954) 889-7236.


B. RIGHT TO DELETE your Personal Information.
You also have the right to request that we delete their Personal Information, subject to certain exceptions, according to Applicable Data Protection Laws. You may exercise your right by contacting us or emailing us at [email protected] or at the following number +1 (954) 889-7236.


C. RIGHT TO RECEIVE A COPY of your Personal Information:
You have the right to request a copy of the Personal Information about you, we have collected. You may exercise your right by contacting us or emailing us at [email protected] or at the following number +1 (954) 889-7236.


You have the right not to be discriminated against by us; this is: us denying you our services or charging you a different price or rate for our services, amongst others, as a consequence of you having exercised any of your consumer rights under the CCPA.


You may exercise any of your rights under the CCPA by submitting your request for information required to be disclosed and/or deleted by contacting us or emailing us at [email protected] or at the following number +1 (954) 889-7236.


When receiving a verifiable consumer request, we will verify the person making a request is the User about whom we have collected the Personal Information. We will generally avoid requesting additional information for the User’s purpose of verification. However, if we cannot verify the identity of the User’s from the information already maintained by us, we may request certain additional information, that will be only used for the purposes of verifying the User’s identity. We will address the User’s verifiable request in an appropriate manner, pursuant to provisions set forth on the CCPA.


Provided You have a password-protected account with us, we may verify your identity, by authenticating you through that account.


Requests made through authorized agents: Please note that under the CCPA, User’s also may designate in writing or through a power of attorney an authorized agent to make the request on their behalf and exercise their privacy rights. Before accepting their agent’s request, we will take all steps necessary to verify they have duly authorized him/her to act on their behalf, for which they must provide us in writing a signed authorization or copy of a power of attorney.

7. Sharing your Personal Data. Categories of third parties with whom we share your Personal Information.

We may share User’s Personal Data globally with our affiliates, subsidiaries and group companies to carry out our activities, specified in this Privacy Policy. Also, we may share Personal Data with, or subcontract processing, with third parties located in different countries than their country.


In this regard, we may share User’s Personal Information with:

  • our affiliates: to provide our services and/or products;
  • our service providers: that help us conduct our business and support infrastructure;
  • advertising partners;
  • For business transfers: we share User’s Personal Data in those cases where we sell or negotiate to sell our business to a buyer or potential buyer. In this case, we will continue to ensure the security and confidentiality of the Personal Data, and give User’s Notice before their Personal Data is transferred to a buyer or becomes subject to a different privacy policy;
  • Others.

8. Transfer of your Personal Data to other countries

In some cases, our affiliates, subsidiaries, and/or third-party service providers are located in other countries, meaning that User’s Personal Information may be processed or stored in other countries. In certain circumstances, our affiliates, subsidiaries, and/or service providers may be required to disclose information to government authorities, regulators, courts, or law enforcement in those countries.


When User’sCompanies’ Personal Data is transferred internationally to third parties located in territories which may not offer an equivalent level of protection to privacy as that applicable within their country of residence (Personal Data collected within the European Economic Area (EEA), for example may be transferred to be processed by third countries located outside the EEA), we ensure that the transfer of the Personal Data is carried out in accordance with the terms of Applicable Data Protection Laws.


We will take all the necessary steps to verify that User’s Personal Data receives an “adequate level of protection” or substantially equal (where required by local law) level of protection. This, by requesting their express consent to the transfer pursuant to applicable law, and/or entering into Data Transfer Agreements (“DTA’s”) pursuant to applicable law, such as the Model Clauses of EU Directive 87/2010, valid as set forth by Section 47 of the GDPR, or Corporate Binding Rules as an option to the referred DTA’s, when the international transfer of Personal Data is made amongst companies of the same economic group, to countries that do not count with an adequate level of protection in accordance to the terms of applicable law.


In any event, we will apply appropriate technical and organizational safety measures to the transfer of Personal Data, so as to ensure that data importers comply with the Applicable Personal Data Laws and use the Personal Data for the sole purposes for which the Personal Data is transferred.

9. Links to Third Party Websites

We may display advertisements from third parties and other content in our Website that may link you to third parties’ Websites. We cannot control nor hold responsible for such content and third party’s privacy policies. If you click and access a third-party advertisement or link, please understand that you are leaving WinDifferent, and any Personal Data you provided will not be covered by this Privacy Policy.


Please refer to the third-party Privacy Policies to find out how they collect and process your Personal Data.

10. Data retention and deletion

We will keep User’s Personal Data as long as necessary to fulfill the purposes described herein.


Upon Users’ request, we will delete their Personal Data, unless we are allowed or required to keep certain Personal Data, for example to fulfill a legal obligation or to resolve a dispute, etc.

11. Keeping Your Personal Data Safe

We are firmly committed to the security of Users’ Personal Data. We will make our best efforts to protect your Personal Data, by implementing adequate technical, physical, administrative, and organizational measures, in order to guarantee the security of Users’ Personal Information.


However, please be advised that no system is ever a completely secured system, Users’ can always decide not to use our products and/or services.


We also encourage Users’ to take all possible measures to secure their Personal Data by using a safe strong password, never sharing their password with others, logging out of the account immediately after having used the account, amongst others.

12. Data Breaches

Despite our best efforts to guarantee the maximum possible level of security of Users’ information by adopting technical and organizational measures to contribute to the security of their data, provided we suffer a data breach, we will take all necessary measures to reduce its effects.


In accordance with the terms of Applicable Data Protection Laws accordingly, without undue delay and, where feasible, after having become aware of it, we will notify the Personal Data breach to the supervisory authority and/or to the Users’ as appropriate under the terms of Applicable Data Protection Laws.

13. Sale of Personal Information/Right to Opt-out of the sale of your Personal Information

The CCPA gives California residents the right to opt-out from the sale of Personal Information. We do not sell information that directly identifies Users’. We do not exchange information about Users to third parties in exchange for money or other consideration. We share information with third parties who work with us, as explained in previous sections, for the purposes described herein.


However, due to the broad definition of “sale” of Personal Information under CCPA, including the provision of Personal Information to another business or third party for monetary and other valuable consideration, shall User’s prefer for us not to sell their Personal Information, please opt-out of the future sale of your Personal Information by emailing us at [email protected] or at the following number +1 (954) 889-7236.

14. Children

Services rendered by WinDifferent shall only be available for persons with legal capacity to enter into contracts under applicable laws. Thus, should you not meet this requirement, you shall not provide us with your Personal Data.


Our services are not directed to children under the age of 13 years, or from ages 13 to 16, or equivalent minimum age in the relevant jurisdiction. If you are under the age limit of 13 years, or from 13 to 16 years old, please do not use our services and do not provide us with any Personal Data or information.


We will not collect, process nor sell the Personal Information of users under 13 years of age, or from 13 to 16 years, if we have actual knowledge that the user is less than those years of age.

15. Where do we store your Personal Information

All Personal Data provided to WinDifferent shall be safely stored. WinDifferent shall storeUser’s Personal Data inAmazon Web Services servers.

16. Updates to this Privacy Policy

We may make changes to this Privacy Policy periodically. We shall give notice of anychanges to User’s through the usual means of communication, such as the email. Notwithstanding the aforementioned, User’s undertake the obligation to regularly accessthis Privacy Policy and search for any amendments hereto.

17. How to contact us

Should User’s have any privacy-related queries or comments, or regarding this Privacy Policy they shall contact us at: [email protected] Last updated: December 1st, 2021

[email protected]
255 Aragon Ave. 2nd Floor, Coral Gables, FL, 33134
Privacy Policy
WinDifferent 2023. All rights reserved.
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