WTT HOLDCO LLC WEBSITE PRIVACY POLICY
Effective Date: May 19, 2026
Last Updated: May 19, 2026
Introduction
This website privacy policy ("Privacy Policy") explains how WTT Holdco LLC ("we," "us," or "our") collects, uses, discloses, and safeguards personal information when you visit or interact with our website at www.wtt.com and any related pages that link to this Privacy Policy (collectively, the "Site"). By using the Site, you acknowledge that you have read and understand this Privacy Policy. If you do not agree, please discontinue use of the Site.
This Privacy Policy incorporates by reference our California Consumer Privacy Act Privacy Policy, our Terms and Conditions of Use, our Website Cookie Notice, our SMS/Text Messaging Policy, and our Accessibility Statement (collectively, the "Policies").
Scope
This Privacy Policy applies to personal information we collect from visitors, customers, and other users of the Site located in the United States. It does not cover information collected in an employment or contractor context, or information collected offline unless expressly stated. If we provide a separate privacy notice for certain services, products, programs, or regions, that notice will govern to the extent of any conflict.
Information We Collect
We collect information that identifies, relates to, describes, or could reasonably be linked with you or your household. The categories of personal information we may collect include contact identifiers such as name, date of birth, email address, telephone number, and postal address; commercial information such as purchase history, service interactions, and transaction details; internet or electronic network activity information such as browsing history, device and browser information, IP address, cookie identifiers, pages viewed, and referring/exit pages; geolocation data such as general location derived from IP address; payment information such as cardholder name and billing details processed by our payment processor; user-generated content such as inquiries, feedback, ratings, or reviews you submit; and inferences drawn from the information above to create a profile reflecting preferences or interests. We do not knowingly collect sensitive personal information through the Site unless specifically requested or provided by you, and we ask that you do not submit sensitive information unless necessary.
Sources of Personal Information
We collect personal information: (a) directly from you when you provide it to us; (b) automatically as you navigate through the site (this information may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies); and (c) from third parties, for example, our business partners.
Information You Provide to Us
The information we collect on or through the Site may include:
- Information that you provide by filling in forms on the Site. This includes information provided at the time of subscribing to our service or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the Site.
- Records and copies of your correspondence (including email addresses) if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through the Site and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the Site; however, all payments and order processing are handled by a third-party payment processor (i.e., Shopify®).
- Your search queries on the Site.
- Information that you provide by your participation in our contests, sweepstakes, or social media engagement.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with the Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including: (a) details of your visits to the Site, including, but not limited to, traffic data, location data, logs, and other communication data and the resources that you access and use on the Site; and (b) information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Site and to deliver a better and more personalized service, including by enabling us to: (a) estimate our audience size and usage patterns; (b) store information about your preferences, allowing us to customize the Site according to your individual interests; (c) speed up your searches; and (d) recognize you when you return to the Site.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of the Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Site.
- Flash Cookies. Certain features of the Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
- Web Beacons. Pages of the Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- Analytics. Analytics are tools we use, such as Google Analytics, to help provide us with information about traffic to and use if the Site, which Google may share with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network.
- Artificial Intelligence. We use artificial intelligence and machine learning tools to collect and analyze information about how users interact with the Site, as well as information you provide to us. These technologies help us understand user behavior, improve our services, support business operations, and inform our sales and marketing efforts, including personalizing communications and outreach.
- Mobile Application Technologies. If you access the Site through a mobile device, we may automatically collect information about your device, your phone number, and your physical location.
- Behavioral Targeting/Re-Targeting/Intelligent Advertising. We partner with a third-party ad network to either display advertising on the Site or to manage our advertising on other sites. We may also use technologies to send you follow up communications related to products you may have viewed or added to your cart but not purchased. Our ad network partner uses cookies and web beacons to collect information about your activities on this and other websites and social media platforms to provide you targeted advertising based upon your interests, available information and online activities.
Third-Party Use of Cookies and Other Tracking Technologies; Links to Other Websites
Some content or applications, including advertisements, on the Site are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We encourage you to be aware when you leave the Site to read the privacy policies of other sites that may collect your information to learn about their use of cookies and other technology. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see How We Use Personal Information.
The information we collect is covered by this Privacy Policy, and the information the third parties or social media platforms collect is subject to the third-party website or platform's privacy practices. The Site may contain links to other websites or services that are not owned or controlled by us, including links to social media platforms such as Facebook, Instagram, Twitter and TikTok, or may redirect you off the Site to other websites for information, other services, or to receive special offers, contests, games, sweepstakes, or for transactions or purchases. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party services you use.
How We Use Personal Information
We use personal information to provide, maintain, and improve the Site and our products and services; process transactions and fulfill orders; communicate with you about your account, purchases, support requests, and administrative matters; personalize your experience and content; conduct analytics, research, and develop new features; prevent, detect, and respond to security incidents, fraud, and illegal activities; comply with legal obligations and enforce our terms; and support our marketing and advertising, including measuring the effectiveness of campaigns. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising. We use cookies and similar technologies to operate the Site, remember your preferences, analyze Site traffic and usage, and deliver and measure advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. We may also use third-party analytics services that collect information about your use of the Site to help us understand and improve performance. For more information about our use of cookies and similar tracking technologies, please review our Website Cookie Notice, incorporated herein by reference.
- Disclosure of Your Information for Third-Party Advertising. We may share certain personal information with unaffiliated or non-agent third parties for promotional purposes. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by sending us an email stating your request to privacy@wtt.com.
- Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our own or third parties' products or services, you can opt out by sending us an email stating your request to privacy@wtt.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
- Targeted Advertising. We may share certain information such as device identifiers, hashed emails, and Site activity with advertising and analytics partners to deliver, measure, and improve ads. Some U.S. state privacy laws define "sale" or "sharing" broadly and may treat this type of data disclosure as a "sale" or "sharing for cross-context behavioral advertising." We do not exchange personal information for money; however, we may be deemed to have "sold" or "shared" personal information as those terms are defined under applicable state laws. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt out by sending us an email stating your request to privacy@wtt.com. For this opt-out to function, you must have your browser set to accept all browser cookies.
We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.
How We Disclose Personal Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this Privacy Policy: (a) to our subsidiaries, affiliates, and partners; (b) to contractors, service providers, and other third parties we use to support our business, including, without limitation, third-party payment processors; (c) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the Site users is among the assets transferred; (d) to third parties to market their products or services to you if you have consented to these disclosures; (e) to fulfill the purpose for which you provide it; (f) to select business partners so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you (i.e., we may disclose your information to our co-brand or collaborative partners when you choose to be involved in those programs, such as when you enter contests or sweepstakes that are conducted with those business partner); or (g) for any other purpose disclosed by us when you provide the information. We may also disclose your personal information: (x) to comply with any court order, law, or legal process, including to respond to any government or regulatory request; (y) to enforce or apply our Terms and Conditions of Use and other agreements, including for billing and collection purposes; or (z) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Retention
We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including, without limitation, to provide the Site and services, comply with our legal obligations, resolve disputes, and enforce our agreements. We consider the volume, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, and applicable legal requirements when determining retention periods. When no longer needed, we will delete or de-identify the information, subject to any retention required by law.
Protection of Personal Information
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
Your Privacy Rights and Choices
Depending on your state of residence, you may have the right to request access to the personal information we maintain about you, to obtain a portable copy, to correct inaccuracies, to delete personal information, and to opt out of the use or disclosure of personal information for targeted advertising, certain profiling, and "sale" as defined by applicable law. If you are a California resident, you also have the right to limit the use and disclosure of sensitive personal information where applicable, and to receive information about categories of personal information we collect, use, disclose, "sell," or "share." We will not discriminate against you for exercising your rights.
Exercising Your Rights
You can submit a privacy rights request by emailing us at privacy@wtt.com. We will verify your request by asking you to provide information that matches our records or by using a third-party verification service. If you use an authorized agent, we may require proof of authorization and verification of your identity. Where permitted by law, you may appeal our decision by contacting privacy@wtt.com with "Privacy Appeal" in the subject line, and we will inform you in writing of our response and the reasons for our decision.
Opt-Out of Targeted Advertising and Sale or Sharing
You can opt out of targeted advertising and the "sale" or "sharing" of personal information by emailing privacy@wtt.com, adjusting your cookie preferences, or enabling a browser-based opt-out signal such as Global Privacy Control, which we honor to the extent required by applicable law. Your opt-out will apply to the browser and device you use to submit the request. If you clear cookies or use a different browser or device, you may need to resubmit your opt-out preferences.
Children's Privacy
The Site is not directed to children under thirteen (13) years of age, and we do not knowingly collect personal information from children under thirteen (13) (or a higher age threshold where applicable). If you believe a child has provided us personal information, please contact us so we can take appropriate steps to delete such information. If we learn we have collected personal information from a child without parental consent as required by law, we will delete it.
Do Not Track
Some browsers transmit "Do Not Track" signals. We do not respond to such signals at this time. We will continue to evaluate responses as standards evolve.
Notice to Certain Residents
Persons in the European Union or European Economic Area
To the extent any European data protection laws apply, and we hold any of your "personal data" as defined in such laws (which may include some or all of your information as defined in this Privacy Policy), and we hold such personal data in our capacity as a data controller as defined under those laws, you may request that we: (a) restrict the way that we process and share your personal data; (b) transfer your personal data to a third party; (c) revoke your consent for processing of your personal data; (d) provide you with access to your personal data; (e) remove your personal data if no longer necessary for the purposes collected; (f) update your personal data so it is correct and not out of date; and/or (g) object to our processing of your personal data.
If you wish to object to the use and processing of your personal data or withdraw consent to this Privacy Policy, you can contact us at privacy@wtt.com.
The requests above will be considered and responded to in the time-period stated by applicable law. Note, certain information may be exempt from such requests. We may require additional information from you to confirm your identity in responding to such requests. You have the right to lodge a complaint with the supervisory authorities applicable to you and your situation, although we invite you to contact us with any concern as we would be happy to try and resolve it directly. Please contact us at privacy@wtt.com.
As described throughout this Privacy Policy, we believe the foregoing handling of your information, which may include your personal data, furthers our legitimate interests in commercial activities that are not overridden by the interest or fundamental rights and freedoms of the individuals at issue. Depending on what personal data we collect from you and how we collect it, we rely on various grounds for processing your personal data, including the following reasons: (a) to administer our contractual relationship, including setting up any services you may request; (b) because it is in our legitimate interest to effectively and efficiently operate our business and provide you with the services offered through the Site and other useful content and for other marketing, design, and advertising purposes; (c) to process employee data, prevent against fraud, provide technology security, and other necessary Company operational matters; (d) in order to fulfill any legal obligations, we may have to collect this information from you; and/or (e) because you have provided your consent for us to do so.
The Site is operated in the United States. Please be aware that information, including personal data, that we collect will be transferred to, stored, and processed in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. We collect and transfer to the U.S. only information, including personal data: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms. We endeavor to apply suitable safeguards to protect the privacy and security of your personal data and to use it only consistent with your relationship with us and the practices described in this Privacy Policy. We also enter into data processing agreements and model clauses with vendors whenever feasible and appropriate.
Persons in California
California residents can review the following disclosures to understand how we collect, use, disclose, sell, or share personal information as defined by the California Consumer Privacy Act, as amended by the California Privacy Rights Act. We collect the categories of personal information described in the "Information We Collect" section for the purposes listed in the "How We Use Personal Information" section. We disclose these categories to the third parties listed in the "How We Disclose Personal Information" section for business purposes such as service provision, security, debugging, and auditing, and we may "sell" or "share" identifiers and internet or network activity with advertising and analytics partners for cross-context behavioral advertising. We retain personal information as described in the "Retention" section. California residents have the rights described in the "Your Privacy Rights and Choices" and "Exercising Your Rights" sections, including the right to limit the use and disclosure of sensitive personal information where applicable. We do not knowingly sell or share personal information of consumers under sixteen (16). For further information, California residents should review our California Consumer Privacy Act Privacy Policy, incorporated herein by reference.
Persons in Virginia, Colorado, Connecticut and Utah
Residents of Virginia, Colorado, Connecticut, and Utah have rights to access, delete, obtain a portable copy of their personal information, and opt out of targeted advertising and the sale of personal data as defined by applicable law. Residents of Colorado, Connecticut, and Virginia also have rights to correct inaccuracies in their personal information, taking into account the information's nature processing purpose, and opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects. You can exercise these rights using the methods described above. If we deny your request, you may appeal as described in the "Exercising Your Rights" section. We do not process personal data for profiling in furtherance of decisions that produce legal or similarly significant effects, unless we separately notify you and obtain required consent.
Nevada Residents
Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out right may submit a request to privacy@wtt.com.
Business-to-Business and Employment Information
This Privacy Policy does not cover personal information collected in a business-to-business or employment context where a separate privacy notice may apply. If you interact with us as a job applicant, employee, contractor, or in a business capacity, please refer to the relevant privacy notice or contact us at privacy@wtt.com for more information.
Data De-Identification and Aggregation
We may de-identify or aggregate personal information so that it can no longer reasonably be used to identify you. We use and disclose such information for any purpose permitted by law.
Verification and Authorized Agents
When you submit a request, we may require sufficient information to verify your identity or authority. If you submit a request through an authorized agent, we may require the agent to provide proof of authorization and may require you to verify your identity directly with us, to the extent permitted by law.
Financial Incentives
If we offer financial incentives, loyalty programs, or price or service differences related to the collection, retention, sale, or sharing of personal information, we will provide required notices describing the material terms of the program, how to opt in, how to withdraw, and how the value of the personal information is calculated.
Accessibility
We are committed to making our privacy practices accessible to all users. If you need this Privacy Policy in an alternative format due to a disability, please contact us at privacy@wtt.com. For more information concerning the accessibility and usability of the Site please review our Accessibility Statement.
Changes to Our Privacy Policy
It is our policy to post any changes we make to this Privacy Policy on this page. If we make material changes to how we treat our users' personal information, we will notify you by posting a notice on the homepage of the Site. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting the Site and this Privacy Policy to check for any changes. Your continued use of the Site constitutes your acceptance of any updates to this Privacy Policy.
Contact Information
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:
WTT HOLDCO LLC SMS/TEXT MESSAGING POLICY
Effective Date: May 19, 2026
Last Updated: May 19, 2026
Overview
This SMS/Text Messaging Policy explains how WTT Holdco LLC communicates with individuals by text message when they voluntarily provide a mobile telephone number to us. It describes what you can expect to receive, how to control your preferences, and your rights and obligations related to our messaging programs. By providing your mobile number and opting in to receive text messages from WTT Holdco LLC, you agree to the terms of this policy.
This SMS/Text Messaging Policy incorporates by reference our Website Privacy Policy, California Consumer Privacy Act Privacy Policy, our Terms and Conditions of Use, our Website Cookie Notice, and our Accessibility Statement.
Programs Covered
This policy applies to all text message programs operated by WTT Holdco LLC, including but not limited to account notifications, transactional alerts, customer support messages, security verifications, appointment or delivery reminders, and promotional or marketing messages (collectively, the "SMS Program").
How We Obtain Your Mobile Number and Consent
We collect your mobile number directly from you when you provide it to us through our website, mobile applications, in-person forms, customer support interactions, event registrations, or other channels. If you opt in to receive texts, you consent to receiving automated or non-automated text messages from WTT Holdco LLC at the mobile number you provided. Your consent to receive marketing texts is not required as a condition of purchasing goods or services. If you provide a mobile number for another person, you represent that you are authorized to do so and to consent on their behalf.
Types and Frequency of Messages
The specific content and frequency of messages will vary by program. Transactional and service-related texts are sent as needed to provide the requested service (for example, order updates, account alerts, or support communications). Marketing or promotional texts are sent periodically. Message frequency may vary and may increase in response to your interactions with us.
Costs and Charges
Message and data rates may apply to each text message sent or received in connection with our SMS Program, as provided in your mobile telephone service plan. Please contact your mobile carrier for pricing plans and details.
How to Opt Out
You may opt out of the SMS Program at any time. To stop receiving text messages from a specific program, reply STOP to any message you receive from that program. After you send STOP, we may send a one-time confirmatory text message to verify your opt-out. You can also manage your messaging preferences by contacting us using the information in the "Contact Us" section below. Please note that opting out of marketing texts will not affect our ability to send you transactional or service-related texts that are necessary to fulfill your requests or manage your account, unless you separately opt out of those communications where available.
Help and Support
If you need assistance with our SMS Program, reply HELP to any message or contact us using the information in the "Contact Us" section below. We will provide information on how to opt out and obtain further support.
Eligibility and Mobile Carriers
The SMS Program is intended for individuals in the United States who are the authorized users of the mobile number provided. Supported carriers may vary and are subject to change. Delivery of messages is subject to effective transmission by your mobile carrier and is not guaranteed. Carriers are not liable for delayed or undelivered messages.
Your Responsibilities
You agree to provide an accurate mobile number that you own or control and to promptly notify us if you change or deactivate that number. If you port or deactivate your number, you should opt out before the change to avoid messages being sent to the new owner of the number.
Privacy
We handle personal information, including mobile numbers and message content where applicable, in accordance with our Website Privacy Policy. Please review our Website Privacy Policy for details about what information we collect, how we use it, and your choices. By participating in the SMS Program, you acknowledge that messaging may be performed through third-party service providers acting on our behalf. Do not include confidential, sensitive, or payment information in text messages.
Security and Sensitive Content
We will never ask you to share passwords, full payment card numbers, Social Security numbers, or other sensitive personal information by text. If you receive a suspicious message that appears to be from WTT Holdco LLC, please contact us using the information in the "Contact Us" section and do not respond to the message.
Program Changes and Termination
We may modify or suspend the SMS Program or this policy at any time. Changes will be effective when posted or communicated, and your continued participation constitutes acceptance of the changes. We may terminate your participation at any time with or without notice, including in cases of suspected misuse or violation of this policy.
Dispute Resolution and Governing Terms
Your participation in the SMS Program is also subject to our Terms and Conditions of Use, or other applicable customer agreements. Any disputes arising from or related to the SMS Program will be handled in accordance with those governing terms, including any applicable disclaimers, limitations of liability, and dispute resolution provisions.
Contact Us
If you have questions, need help, or wish to update your messaging preferences, please contact WTT Holdco LLC at: privacy@wtt.com.
California and Other State Notices
California and other state residents may have additional rights regarding their personal information, which are described in our California Consumer Privacy Act Privacy Policy. We will honor applicable state and federal requirements related to text messaging and privacy.
Acknowledgment
By providing your mobile number to WTT Holdco LLC and opting in to receive text messages, you acknowledge that you have read and agree to this SMS/Text Messaging Policy.
WTT HOLDCO LLC
CALIFORNIA CONSUMER PRIVACY ACT PRIVACY POLICY
Effective Date: May 19, 2026
Last Updated: May 19, 2026
This California Consumer Privacy Act Privacy Policy ("Privacy Policy") explains how WTT Holdco LLC ("we," "us," or "our") collects, uses, discloses, "shares," and "sells" personal information of California residents, and describes the rights California residents have under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the "CCPA"). This Privacy Policy applies to personal information we collect online and offline, including through our websites, mobile applications, products, services, and in-person interactions. Capitalized terms used in this Privacy Policy have the meanings assigned to them in the CCPA.
Scope and Relationship to Other Notices
This Privacy Policy is intended to supplement our general privacy statements and notices, including, but not limited to our Website Privacy Policy, our Terms and Conditions of Use, our Website Cookie Notice, our SMS/Text Messaging Policy, and our Accessibility Statement (collectively, "Policies"), which are incorporated herein by reference, and any product or service-specific disclosures provided at or before the point of collection. If another notice provided at collection conflicts with this Privacy Policy, that specific notice will control to the extent of the conflict.
Notice at Collection
We collect personal information directly from you, automatically from your devices and interactions with our services, and from third parties such as business partners, data providers, advertising networks, and publicly available sources. We collect the categories of personal information described below. We collect this personal information for the business and commercial purposes described in the "How We Use Personal Information" section. We retain personal information as described in the "Data Retention" section. Providing personal information may be required to enter into or perform a contract, fulfill your requests, or comply with law. If you do not provide personal information when requested, we may not be able to provide certain services.
Categories of Personal Information We Collect
We collect the following categories of personal information as defined by the CCPA: identifiers such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and similar identifiers; customer records information such as billing address, payment card details (processed by our payment processors), and other financial information; characteristics of protected classifications under California or federal law, where you choose to provide them, such as age and gender; commercial information such as products or services purchased, obtained, or considered, and purchase histories or tendencies; internet or other electronic network activity information such as browsing history, search history, and information regarding your interactions with our websites, applications, emails, and advertisements; geolocation data such as imprecise and, where enabled by you, precise location information from your device; audio, electronic, visual, or similar information such as recorded customer support calls or voicemails; professional or employment-related information such as job title, employer, and business contact details; education information, where applicable, such as school or degree, if you choose to provide it; inferences drawn from any of the information identified to create a profile about a consumer reflecting preferences, characteristics, and predispositions; and sensitive personal information as defined by the CCPA, which may include account log-in credentials, precise geolocation, financial account information with associated security codes, contents of messages not directed to us but processed through our services where applicable, and demographic data revealing race or ethnicity if voluntarily provided in designated contexts. We do not collect sensitive personal information for the purpose of inferring characteristics about you.
In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
A. Identifiers. Collected: YES. Examples: a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Collected: YES. Examples: a name, signature, Social Security number, date of birth, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law. Collected: YES. Examples: age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information. Collected: YES. Examples: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information. Collected: NO. Examples: genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity. Collected: YES. Examples: browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
G. Geolocation data. Collected: YES. Examples: physical location or movements.
H. Sensory data. Collected: NO. Examples: audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information. Collected: NO. Examples: current or past job history or performance evaluations; job categories.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Collected: NO. Examples: education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information. Collected: YES. Examples: profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Sources of Personal Information
We collect personal information directly from you when you create an account, make a purchase, contact customer support, participate in surveys, or otherwise interact with us. We collect personal information automatically through cookies, pixels, software development kits, artificial intelligence enabled tools, and similar technologies when you use our websites and applications. We also receive personal information from third parties including business partners, payment processors, analytics providers, advertising networks, social networks, data brokers, and from publicly available sources. For more information about our use of cookies and similar tracking technologies, please review our Website Cookie Notice, incorporated herein by reference.
How We Use Personal Information
We use personal information for the following business and commercial purposes: providing, operating, and maintaining our products and services; processing transactions and payments; verifying your identity and preventing fraud, security incidents, and other malicious, deceptive, or illegal activity; debugging to identify and repair errors that impair functionality; performing services on our behalf, including customer service, order fulfillment, account servicing, and similar activities; conducting internal research and development, including to improve, upgrade, or enhance our services; engaging in short-term, transient use such as contextual advertising; undertaking activities to verify or maintain the quality or safety of a service and to improve, upgrade, or enhance it; personalizing and optimizing your experience, including content and recommendations; marketing and advertising, including cross-context behavioral advertising and audience measurement; complying with legal obligations and enforcing our Policies; and supporting corporate transactions such as mergers, acquisitions, or asset transfers. We use artificial intelligence and machine learning tools to collect and analyze information about how users interact with the Site, as well as information you provide to us. These technologies help us understand user behavior, improve our services, support business operations, and inform our sales and marketing efforts, including personalizing communications and outreach.
Sharing Personal Information
We disclose personal information to service providers and contractors who process personal information on our behalf for business purposes such as hosting, payment processing, data analytics, marketing support, customer service, and security. We also disclose personal information to business partners with whom we offer jointly branded services or engage in co-marketing activities. We may disclose personal information to third parties in connection with corporate transactions, such as mergers, acquisitions, divestitures, or asset sales. We disclose personal information as necessary to comply with law, legal process, or government requests; to enforce our Policies; to protect our rights, privacy, safety, or property, and that of you or others; and to detect, prevent, or address security, fraud, or technical issues. We may disclose personal information to other entities with your direction or consent. In the preceding twelve (12) months, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.
Under the CCPA, "sell" means disclosing personal information to a third party for monetary or other valuable consideration, and "share" means disclosing personal information to a third party for cross-context behavioral advertising. We may "sell" or "share" identifiers, Internet or electronic network activity information, commercial information, geolocation data, and inferences for advertising and marketing purposes. We do not knowingly sell or share personal information of consumers under sixteen (16) years of age. In the preceding twelve (12) months, we have not sold personal information. You may opt out of the "sale" or "sharing" of your personal information at any time as described in the "Your California Privacy Rights" section.
A: Identifiers. Recipients / Business Purpose Disclosures: promotional activities, communications, third-party service providers. Sales: NONE.
B: California Customer Records personal information categories. Recipients / Business Purpose Disclosures: promotional activities, communications, third-party service providers. Sales: NONE.
C: Protected classification characteristics under California or federal law. Recipients / Business Purpose Disclosures: promotional activities, communications, third-party service providers. Sales: NONE.
D: Commercial information. Recipients / Business Purpose Disclosures: promotional activities, communications, third-party service providers. Sales: NONE.
E: Biometric information. Recipients / Business Purpose Disclosures: NONE. Sales: NONE.
F: Internet or other similar network activity. Recipients / Business Purpose Disclosures: promotional activities, communications, third-party service providers. Sales: NONE.
G: Geolocation data. Recipients / Business Purpose Disclosures: promotional activities, communications, third-party service providers. Sales: NONE.
H: Sensory data. Recipients / Business Purpose Disclosures: NONE. Sales: NONE.
I: Professional or employment-related information. Recipients / Business Purpose Disclosures: promotional activities, communications, third-party service providers. Sales: NONE.
J: Non-public education information. Recipients / Business Purpose Disclosures: NONE. Sales: NONE.
K: Inferences drawn from other personal information. Recipients / Business Purpose Disclosures: promotional activities, communications, third-party service providers. Sales: NONE.
Use and Disclosure of Sensitive Personal Information
We use and disclose sensitive personal information only for purposes that are reasonably necessary and proportionate to provide the services you request, to prevent fraud and ensure the security and integrity of our systems, to verify or maintain the quality or safety of our services, to perform services on behalf of the business, or for other purposes permitted by the CCPA regulations. We do not use or disclose sensitive personal information to infer characteristics about you. You may request to limit certain uses or disclosures of sensitive personal information as described below if our practices extend beyond these permitted purposes.
Data Retention
We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, to satisfy legal, regulatory, tax, accounting, or reporting requirements, to resolve disputes, and to enforce our agreements. We determine the appropriate retention period based on the nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and applicable legal requirements. When we no longer need personal information for these purposes, we will delete, de-identify, or aggregate it in accordance with our retention policies and applicable law.
Your California Privacy Rights
California residents have the following rights under the CCPA, subject to certain exceptions and verification requirements. You have the right to know and access the categories and specific pieces of personal information we have collected about you, the categories of sources from which the personal information is collected, our business or commercial purposes for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the categories of personal information we have sold, shared, or disclosed for a business purpose. You have the right to request deletion of personal information we collected from you, subject to certain exceptions. You have the right to correct inaccurate personal information that we maintain about you. You have the right to opt out of the sale or sharing of your personal information. You have the right to limit the use and disclosure of your sensitive personal information to the permitted purposes described above if we use or disclose sensitive personal information beyond those purposes. You have the right not to receive discriminatory treatment for exercising your CCPA rights.
How to Exercise Your Rights
You may submit requests to know, access, delete, or correct your personal information by contacting us at privacy@wtt.com. To opt out of the sale or sharing of personal information, you may contact us at privacy@wtt.com, or enable a browser-based opt-out preference signal, such as the Global Privacy Control, which we honor in a frictionless manner where detected and applicable. To submit a request to limit the use and disclosure of sensitive personal information, you may contact us at privacy@wtt.com.
Verification, Authorized Agents, and Appeals
We will take steps to verify your identity to a reasonable degree of certainty before processing your request, which may include matching information you provide with information we maintain, requiring you to log in to your account, or using a third-party identity verification service. If you use an authorized agent to submit a request, we may require the agent to provide written authorization signed by you or a valid power of attorney, and we may require you to verify your identity directly with us. If we deny your request in whole or in part, we will explain the reasons for the denial. If you disagree with our decision, you may contact us at privacy@wtt.com and we will review your appeal consistent with applicable law.
Children's Privacy
Our services are not directed to children under sixteen (16), and we do not knowingly collect, sell, or share personal information of consumers under sixteen (16) years of age. If we learn that we have collected personal information from a child under sixteen (16), we will delete it as required by law.
California Notice of Financial Incentive
We may offer programs, benefits, or other promotions that may be considered a "financial incentive" under the CCPA, such as discounts or rewards in exchange for personal information like your email address. Participation is voluntary. When you sign up, we will present program terms, including a description of the material terms, the categories of personal information involved, how the value of the incentive is reasonably related to the value of your data, and how to opt in. You may withdraw at any time by following the instructions provided or contacting us at privacy@wtt.com. We will not discriminate against you for opting out.
De-Identified and Aggregated Information
We may use de-identified and aggregated information for research, development, analytics, and other lawful purposes. When we de-identify personal information, we take reasonable measures to ensure the information cannot be associated with you, commit to maintain and use the information in de-identified form, and do not attempt to re-identify it except to test our de-identification processes.
Information Security
We implement reasonable and appropriate technical, administrative, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, and destruction. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.
International Data Transfers
If you access our services from outside the United States, you acknowledge that your personal information may be transferred to, stored, and processed in the United States and other countries where we or our service providers maintain operations, which may have data protection laws that are different from those of your jurisdiction.
Changes to This Privacy Policy
We may revise this Privacy Policy from time to time. The "Last Updated" date at the top of this Privacy Policy indicates when it was last revised. Any changes will take effect when we post the revised Privacy Policy, unless a different effective date is stated. Your continued use of our services after changes have been posted indicates your acceptance of the revised Privacy Policy.
Contact Us
If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@wtt.com.
California-Specific Disclosures for the Past Twelve (12) Months
For transparency, in the past twelve (12) months, we collected the categories of personal information described in the "Categories of Personal Information We Collect" section. We disclosed categories such as identifiers, commercial information, internet or electronic network activity, geolocation, and inferences to service providers and contractors for business purposes. We may have "sold" or "shared" identifiers, internet or electronic network activity, commercial information, geolocation, and inferences with advertising and analytics partners for cross-context behavioral advertising. We did not knowingly sell or share the personal information of consumers under sixteen (16) years of age. We used and disclosed sensitive personal information only for permitted purposes and did not process sensitive personal information to infer characteristics.
Metrics and Reporting
If required by law or regulation based on our annual processing volume, we will publish required metrics related to consumer requests and our responses. Where applicable, we will make such metrics available through our website or upon request.