Privacy Policy

Website Privacy Policy

Last modified: May 27, 2020

Introduction.

Winston Digital Labs, LLC (“Company,” “we” or “us”) respects your privacy and is committed to protecting it through its compliance with this policy (this “Policy”). This Policy describes the types of information we may collect from you or that you may provide when you visit the website bestexerciseapps.com (the “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

• This Policy applies to information we collect:
  • On this Website.
  • In email, text, and any other electronic messages between you and this Website and/or the Company.
    
    
• It does not apply to:
  • Information collected by us offline or through any other means, including, without limitation, on any other website operated by the Company; or
  • The practices of any third party, including, without limitation, the use by third parties of any application or content (included but not limited to advertising) that may link to or be accessible from or on the Website.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with this Policy, you should not use the Website. By accessing or using the Website, you agree to this Policy. This Policy may change from time to time. Your continued use of the Website after we make changes is deemed to be acceptance of those changed. We will post any changes we make to this Policy on this page with a notice that the Policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for regularly visiting the Website and this Policy to check for any changes.

Individuals Under the Age of 18.

The Website is not intended for anyone under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from individuals under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, or provide any information about yourself to us, including, without limitation, your name, address, telephone number, or email address. If we learn we have collected or received personal information from anyone under 18, we will delete that information. If you believe we might have any information from or about an individual under 18, please email us at support@winstondigitallabs.com.

Information We Collect About Users and How We Collect It.

• We collect several types of information from and about users of the Website, including, without limitation, information:
  • By which you may be personally identified, such as name, postal address, email address, and telephone number (collectively “personal information ”);
  • That is about you but individually does not identify you; and/or About your internet connection, the equipment you use to access the Website, and usage details.
    
    
• We collect this information:
  • Directly from you when you provide it to us.
  • Automatically as you navigate through the Website. Information collected automatically may include usage details, internet protocol (“IP”) addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • From third parties, for example, our business partners.

Information You Provide to Us

• The information we collect on or through the Website may include:
  • Information that you provide by filling in forms on the Website. This includes, without limitation, information provided at the time of completing the Website’s questionnaire. We may also ask you for information when you report a problem with the Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
    
    
• Failure to provide certain information may make it difficult or impossible for you to access some of the services provided through the Website. You should ensure that any personal information submitted to us is accurate.

Information We Collect Through Automatic Data Collection Technologies

• As you navigate through and interact with the Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
  • Details of your visits to the Website, including, without limitation, traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.
    
    
• We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). At this time, we do not respond to Do Not Track browser settings or signals on the Website. The information we collect automatically is only statistical data and does not include personal information.
  
  
• 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 Website. 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 Website.
  • Flash Cookies: Certain features of the Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
  • Web Beacons: Pages of the Website 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).
  • Data Analytics: We use certain web analytics services, including third-party services such as Google Analytics, to help us understand and analyze how visitors use the Website. We may receive reports based on the use of these technologies on both an individual and aggregated basis. These analytics services, including third-party services such as Google Analytics, may also use this information to place advertisements for our products on other websites that you visit after your use of the Website. These advertisements may be based on the pages you visited during your use of the Website. You may choose to install the Google Analytics Opt-Out Browser Add-on to opt out of Google Analytics data collection.

Third-Party Use of Cookies.

Some content or applications, including advertisements, on the Website may be served by third-parties, including, without limitation, 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 the 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 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.

How We Use Your Information.

• We use information that we collect about you or that you provide to us, including any personal information:
  • To present the Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To notify you about changes to the Website or any products or services we offer or provide though it.
  • To allow you to participate in interactive features on the Website.
  • In any other way we may describe when you provide the information and/or for any other purpose with your consent.
    
    
• We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. You may opt-out of receiving communications from us and any third-parties by not submitting your information to us. You can also always opt-out by sending us an email with your request to support@winstondigitallabs.com.
  
  
• We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your 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 Policy:
  • To our subsidiaries, affiliates, representatives, and partners.
  • To contractors, service providers, and other third parties we use to support our business.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, change of ownership, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about the Website users is among the assets transferred.
  • To third parties to market their products or services to you if you have not opted out of these disclosures.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Use and other agreements.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our users, or others.

Choices About How We Use and Disclose Your Information.

• We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
  • Tracking Technologies and 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 the Website may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising: 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 not submitting your information to us. You can also always opt-out by sending us an email with your request to support@winstondigitallabs.com.
  • Promotional Offers from the Company: If you do not wish to have your contact information used by the Company to promote its own or any third parties’ products or services, you can opt-out by not submitting your information to us. You can also opt-out at any time by sending an email stating your request to support@winstondigitallabs.com. If the Company sends you a promotional email, you may forward that email to support@winstondigitallabs.com and ask to be omitted from future email distributions.
  • Targeted Advertising: 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 support@winstondigitallabs.com.
    
    
• 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.

Transfer of Information.

The Website and information provided on or through the Website may be stored and processed in the United States, and is intended only for users located in the United States. If you are located in the European Union or elsewhere outside of the United States, please do not use the Website or provide any information to us or otherwise through the Website. Please be aware that information we collect will be transferred to and processed in the United States. By using the Website or providing us with any information, you acknowledge any related transfer and the processing of information in the United States.

Accessing and Correcting Your Information.

You may send us an email at support@winstondigitallabs.com to request to access, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Proper access and use of information provided on the Website is governed by our Terms of Use.

For Nevada Residents.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated email address: support@winstondigitallabs.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

For California Residents.

Persons with disabilities may obtain this notice in alternative format upon request by contacting us at support@winstondigitallabs.com.

Shine the Light

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@winstondigitallabs.com.

Do Not Track Disclosures

California Business & Professions Code Section 22575(b)(5) (as amended effective January 1, 2014) provides that California residents are entitled to know how the Website responds to “Do Not Track” browser settings. Some browsers have incorporated “Do Not Track” features. When turned on, most of these features send a signal or preference to the websites you visit, which indicate that you do not wish to be tracked. For information about Do Not Track, please visit www.allaboutdnt.org. We do not respond to Do Not Track browser settings or signals on the Website. The information we collect automatically is only statistical data and does not include personal information.

Privacy Rights and Additional Disclosures for California and Other State Residents

• If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. The information contained in this section of the Policy applies solely to Website users who meet the definition of the term “consumer” as defined under the California Consumer Privacy Act, as amended, and the regulations adopted by the California Attorney General pursuant thereto (collectively, the “CCPA”) and to other individuals entitled to analogous rights and disclosures under applicable state law. Terms, and correlative terms, defined in the CCPA contained in this section are intended to have the same meaning and effect as set forth in the CCPA. In particular, the Website has collected the following categories of personal information from its consumers within the last twelve (12) months (Please note that while a category may be marked that does not necessarily mean that we have information in that category about you):

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, address, telephone number, education, employment, employment history. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), veteran or military status, citizenship, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	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, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
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)).	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.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

• The Website obtains the categories of personal information listed above from the following categories of sources:
  • Directly from you. For example, from forms you complete.
  • Indirectly from you. For example, from observing your actions on the Website.

Disclosures of Personal Information for a Business Purpose

• In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:
  • Category A: Identifiers.
  • Category B: California Customer Records personal information categories.
  • Category C: Protected classification characteristics under California or federal law.
  • Category F: Internet or other similar network activity.
  • Category G: Geolocation data.
  • Category I: Professional or employment-related information.
    
    
• We disclose your personal information for a business purpose to the following categories of third parties:
  • Contractors, service providers, representatives, and other third parties we use to support our business.
  • Our affiliates and partners.
  • Advertisers, advertising networks, internet service providers, data analytics providers, government entities, operation systems and platforms, social networks and consumer data resellers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

Sales of Personal Information

• In the preceding twelve (12) months, Company has sold the following categories of personal information:
  • Category A: Identifiers.
  • Category B: California Customer Records personal information categories.
  • Category C: Protected classification characteristics under California or federal law.
  • Category F: Internet or other similar network activity.
  • Category G: Geolocation data.
  • Category I: Professional or employment-related information.
    
    
• We sell your personal information to the following categories of third parties:
  • Business partners.
  • Data aggregators.
  • Advertisers.
  • Advertising networks
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

• 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 or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a “data portability request”).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• We do not provide these access and data portability rights for B2B personal information.

Deletion Request Rights

• 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. We may deny your deletion request 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 do not provide these deletion rights for B2B personal information.

Exercising Access, Data Portability, and Deletion Rights

• To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:
  • emailing us at support@winstondigitallabs.com; or
  • clicking here and checking the appropriate box(es).
    
    
• Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. We may require that you and the authorized representative complete affidavits in order to verify the identity of the authorized representative and confirm that you have authorized such person to act on your behalf. Parents of minor children may be required to submit the child’s birth certificate, in lieu of an affidavit, in order to make requests on the child’s behalf.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
    
    
• We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

• We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
  
  
• We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

• If you are 18 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 18 years of age. Consumers who do not opt-out of personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:

• Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us at support@winstondigitallabs.com.
  
  
• We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

• We will not discriminate against you for exercising any of your CCPA rights. This means, unless permitted by the CCPA, we will not:
  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services; or
  • Suggest that you may receive a different price or rate for goods or services, or a different level or quality of goods or services.
• We do not offer a financial incentive related to the collection, retention, or sale of personal information.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. 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 Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any security measures contained on the Website.

Changes to the Policy

It is our policy to post any changes we make to the Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the Policy was last revised is identified at the top of the page. You are responsible for regularly visiting the Website and this Policy to check for any changes.

Contact Information

If you have any questions or comments about this notice, the ways in which the Company collects and uses your information described in this Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by email at support@winstondigitallabs.com.