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By accessing or using www.wolffand.co (referred to as the “Site”) you agree to comply with and be bound by WOLFF AND COMPANY LLC’S (“WOLFF&CO”) Terms of Service (“Terms of Service”), Privacy Policy ("Privacy Policy"), and Code of Conduct (“Code of Conduct”). Please read these carefully.

If you do not agree to the Terms of Service, Code of Conduct and the Privacy Policy, you must immediately terminate use of the Site.

  1. Introduction This Privacy Policy explains how WOLFF&CO collects, uses, shares and safeguards Personal Data and Non-Personal Data on www.wolffand.co, WOLFF&CO profiles on social media sites and any other digital services and platforms officially operated or used by WOLFF&CO from time to time (“Sites”), as well as by phone or by paper.

  2. Changes to the Privacy Policy As WOLFF&CO’s products and services change from time to time, this Privacy Policy is expected to change as well. We reserve the right to amend the Privacy Policy at any time, for any reason. The date of the last revision to the Privacy Policy will be indicated by the "Effective Date" at the bottom of this page.

  3. Types of Data We Collect

    1. Personal Data We collect information (whether online, by phone, or by paper) that enables WOLFF&CO to identify or contact you (“Personal Data”) and to carry out its business purposes.  WOLFF&CO Sites collect this information for a variety of business reasons, including but not limited to registering for an WOLFF&CO event or program, purchasing WOLFF&CO products or services, or otherwise interacting with WOLFF&CO.

    The types of Personal Data we collect include, but are not limited to: 1. General data (e.g., names, home and business addresses, email addresses, Internet protocol addresses and mobile/landline business/personal telephone numbers that are provided by our customers) 2. Financial information (e.g., credit and debit card numbers, credit reports, passwords and PIN numbers) for sales or employment purposes 3. WOLFF&CO also receives Personal Data from third parties for WOLFF&CO’s use in marketing to potential new members. 2. Non-Personal Data We collect information (whether online, by phone, or by paper) that does not directly identify you as you interact with our Sites (“Non-Personal Data”). The types of Non-Personal Data we collect includes, but is not limited to: 1. Site usage (e.g., browsing history, search terms, number of clicks, referring/exit pages, date/time stamp, time on Site) 2. Products and services viewed, including advertisements for such products and services 3. Computer type, operating system and platform type 4. Internet service provider 5. Your industry and business (e.g., company size and location, job functions and seniority levels)

  4. How We Use Your Data In addition to the uses described above, we use your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to the below:

    1. Personal Data We use Personal Data to (1) Identify you when you visit our Sites; (2) Provide service communications such as bill reminders, order confirmations, and customer service messages; (3) Provide products, information and services you request or that we think you may be interested in; (4) Respond to your emails or online requests for products, services, or information; (5) Deliver and process surveys; (6) Personalize and improve the usability of the Sites (7) Fulfill and/or deliver WOLFF&CO’s products and services; and (8)Tailor content, advertising and marketing to you.
    2. Non-Personal Data We use Non-Personal Data to improve the usability of our Sites and for other business reasons. We or other third-party companies also use the Non-Personal Data to provide advertisements and targeted advertisements to you (ads based on the Non-Personal Data). We do not provide Personal Data to third parties with whom we share your Non-Personal Data. Please note that, when you select an advertising link or other link that takes you to sites not operated by WOLFF&CO, you may be subject to the privacy policies of these third-party sites.
  5. How We Share Your Data We share your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to the below:

    1. Share data with third parties to fulfill service requests and to perform business functions (e.g. WOLFF&CO contracts with third parties to provide services on our behalf such as data hosting services; packaging, mailing and delivering services; customer support and consulting services; and event registration services)
    2. Share data with third parties as required by law or to protect WOLFF&CO in the good-faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process served on WOLFF&CO; (b) protect and defend the WOLFF&CO’s rights or property; or (c) protect the personal safety of WOLFF&CO personnel or members of the public in appropriate circumstances.
    3. Share data with third parties if WOLFF&CO and/or its assets (or a portion of its assets) are sold, assigned, transferred, or merged, or if the WOLFF&CO undergoes some other change including a change to its corporate form as part of a bankruptcy proceeding or otherwise; information may be transferred as part of that transaction or change.
    4. Share data with third parties to offer you products and services that may be of interest to you professionally or personally (e.g. business software solutions or member product discounts). Users can request their information to be removed from such lists by contacting us, as set forth in the “Contact Information” section below.
    5. Share data with third parties under other unanticipated situations, but only with your consent.
    6. Share your email address, but only as permitted by the WOLFF&CO Email Policy, as follows: Your email address will be used only by WOLFF&CO, its entities, and WOLFF&CO’s vendors performing services or offering products on WOLFF&CO’s behalf.
  6. How You Can Manage the Processing of Your Data For California residents, please consult the “California Privacy Rights” section for additional considerations. Our processing of your data is based upon your consent, contract performance (e.g. your purchase of products or services), legitimate business interest (e.g. direct marketing of goods and services), or compliance with law.  You have the right to object to our processing of your data or to restrict our processing of your data. In addition, if you have consented to the processing of your Personal Data, you have the right to withdraw your consent at any time.

  7. California Privacy Rights In addition to the rights as explained in this Privacy Policy, under California’s "Shine the Light" law, California residents who provide personal information (as defined in the statute) to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the personal information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year (e.g. requests made in the current year will receive information about the prior year). To obtain this information please write to us at: 17818 NW Solano Ct, Portland, OR 97229. Please include your full name and address.

  8. Canada Anti-Spam Law WOLFF&CO complies with the Canada Anti-Spam Law. WOLFF&CO users who provide us a Canadian mailing address will not receive unauthorized Commercial Electronic Messages (as defined under the Canada Anti-Spam Law) unless these individuals have “opted-in” to receive Commercial Electronic Messages.

  9. Children We do not knowingly collect Personal Data from, or market to, children under the age of 13.

  10. How We Protect Personal Data WOLFF&CO implements commercially reasonable security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. Unfortunately, no data transmission over the Internet or electronic storage is fully secure. Accordingly, and despite our reasonable efforts to protect your Personal Data from unauthorized access, use, or disclosure, WOLFF&CO cannot guarantee or warrant the security of the Personal Data you transmit to us, or to or from our online Sites. If you have questions about this Privacy Policy, please contact us.

  11. Linking to Other Internet Sites You should be aware that other Internet sites that are linked from the Sites or from an WOLFF&CO email message may contain privacy provisions that differ from the provisions of this Privacy Policy. To ensure your privacy is protected, we recommend that you review the privacy statements of these other linked sites, applications, or other digital platforms.

  12. How You Can Access, Change and Delete Your Personal Data We rely on you to update and correct your Personal Data.  If you are a user of our Sites, subscriber to WOLFF&CO publications, or purchaser of WOLFF&CO products and services, you can update and correct your information by contacting us using the information in the “Contact Information” section below. Typically, we retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. This may include retaining your Personal Data indefinitely in order to provide you with future marketing opportunities and other purposes, as well as to comply with our legal obligations, resolve disputes, or enforce any of our agreements.  Please note that you can request, at any time, that we delete your Personal Data. We can decide to delete your Personal Data if we believe that the data is incomplete, inaccurate, or that our continued use and storage are contrary to our obligations to other users, individuals, or third parties.  When we delete your Personal Data, it will be removed from our active databases or anonymized so that the data is no longer identified with you, but the data may remain in our archives if WOLFF&CO determines that it is not practical or possible to delete it.

  13. Cookies and Other Web Devices Our website sends cookies (e.g. pieces of code or text placed on your computer by us or third-parties when you browse our Sites) to your web browser (if your browser’s preferences allow it) to collect data when you browse our Sites. Cookie settings can be controlled in your Internet browser to automatically reject some forms of cookies.  If you view our website without changing your cookie settings, you are indicating your consent to receive all cookies from our Sites.  If you do not allow cookies, some features and functionality of our Sites may not operate as expected. In addition to cookies, we place technological tools (and allow certain third parties to place technological tools) such as tags and beacons (e.g. code scripts that are primarily used to track visitors’ activities on our Sites by web analytics software), Internet Protocol (IP) addresses, and other tools, to collect your data for the purposes listed in this Privacy Policy.

  14. Transmission of Data to Other Countries Your Personal Data is processed in the United States, where privacy laws may be less stringent than the laws in your country and where the government, courts, or law enforcement may be able to access your data.  By submitting your Personal Data to us, you agree to the transfer, storage and processing of your Personal Data in the United States.

  15. Breach Notification In the event we determine the occurrence of a data security incident, we will notify you by email, US mail, telephone, or other means as permitted by law.

  16. Contact Information If you have questions, comments, or complaints concerning our privacy practices or if you wish to change, access, or remove your Personal Data, please contact us as indicated below.  We will attempt, where practical, to respond to your requests and to provide you with additional privacy related information.

Wolff and Company LLC 17818 NW Solano CT Portland, OR 97229

[email protected]

Effective Date: February 10, 2019