About 1 — The WindFall

WINDFALL
PRIVACY POLICY

Last Updated: October 16, 2023

Our Commitment to You

Windfall Firm, LLC. (collectively, “Windfall,” “our,” “we,” or “us”) values and respects the privacy of its customers and visitors. While operating our business and interacting with you, we collect, use, and share personal information as disclosed in this privacy policy (“Privacy Policy”).

This Privacy Policy provides you with detailed information about how Windfall, its website www.thewindfall.com (“Site”) and its subsidiaries, divisions, affiliates, brands and other companies that link to this Privacy Policy collect, use, share, and protect personal information, and describes your choices and rights available. For information on how your personal data is handled if you have joined our recruitment process, please see the applicable policy below. We encourage you to read this Privacy Policy carefully and if you have any questions to contact us using the methods listed below.

Collecting Your Information

Using Your Information

Providing Your Information

Marketing

Security of Your Information

Policy for Children

Links to Other Websites and Third Party Practices

Do Not Track Signals

Submitting Information From Outside The United States

Exercise Your Privacy Rights

Retention Period

Contact Us

We reserve the right to make changes to this Privacy Policy at any time and for any reason. Any changes will be reflected in a revised policy posted on the Site and we will alert you that there has been a change by updating the “Revised” date displayed on the Privacy Policy. If Windfall determines that such changes materially affect your privacy rights, we will provide additional notice to you.

Collecting Your Information We may collect information about you in a variety of ways but generally speaking it is done either through (1) your use of our services or (2) you visiting our websites. The types of information we may collect include, but are not limited to:

Information You Provide To Us This is personal information you choose to provide in connection with completing your account online, providing content on the Site, or other activities in which you participate on the Site, such as your name, physical address, phone number, and other contact information. It may also include inferences drawn from the Personal Information that you provide to us. For example, if you provide a female name, we may categorize you as a female. We do not collect any sensitive personal data.

Information We Collect About You Information our servers automatically collect when you make a purchase, contact us or, visit, use, or browse the Site, such as your IP address, your operating system, browser version, the address of a referring website, the pages you visit on the Site, the dates and times you visit the Site, device and usage information, such as language preferences, referring URLs, country, location, information about how and when you use our services and other technical information. If you access the Site from a mobile device, information about the type of mobile device you use.

In order to collect this information, we may use cookies, web beacons, and other tracking technology, depending on the features offered. Tracking technology is useful for gathering information such as browser type and operating system, tracking the number of visitors to the Site, and understanding how visitors use the Site. Cookies can also help us customize the Site and improve your experience. If you previously provided personally identifiable information to us, a unique identifier in the cookie may tie the information collected via the cookie to such information. Aggregate cookie and tracking information that does not directly identify you may be shared with third parties. Also, some content on the Site may be provided by third parties that may use cookies in conjunction with other tracking technologies to collect information about you when you use the Site, which enables them to provide targeted advertising to you. We do not control these third parties’ tracking technologies or how they may be used. We may display certain advertising offers on the Site or allow service providers, advertisers, ad networks, or other third parties to advertise on the Site. Additionally, we may use third party software to serve ads on the Site, implement email marketing campaigns, and manage other interactive marketing initiatives. This third party software may use cookies, web beacons, or similar tracking technology to help manage and optimize your online experience with us. Most web browsers are set to accept cookies by default. You can usually choose to set your browser to disable or reject cookies. Be aware that disabling or rejecting cookies could affect the availability and functionality of the Site or certain portions of the Site. Also, please note that we may still use information we’ve collected from cookies prior to your disabling them; however, we will not collect any further information from the disabled cookies.

Using Your Information Any information collected about you via the Site may be used to: help increase the efficiency and operation of the Site; deliver and improve our products and services; manage our business; monitor and analyze usage and trends to improve the Site and the user experience; generate a personal profile of you to make future visits to the Site more personalized; perform the functions and services you request; send you confirmations, updates, alerts, administrative messages, and otherwise facilitate your use of the Site; request feedback and contact you about your use of the Site; respond to your emails; compile anonymous statistical information and analyses, which we may use internally and/or provide to third parties; to support our customers and their interactions with you through our Services; market our services (and those of third parties) to you that we believe may be of interest to you; and deliver information to you that you request or that we think may be of interest to you, such as articles, news, or information about various promotions.

Providing Your Information We may share your information with third parties that perform services for or on our behalf this includes: (A) to perform analytics on the website and/or web form engagement, (B) when it is shared as part of a transfer of assets, (C) to perform marketing, and (D) when we are required by law to share it.

Analytics We may allow selected service providers or processors, to use tracking technology on the Site, which will enable them to collect information about how you use the Site over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

Transfer of Assets If we reorganize or otherwise transfer some or all of the Site or our assets to another organization (such as in the course of a merger, dissolution, or liquidation), your information may be shared with the transferee; however, we will ask the transferee to honor commitments we made in this Privacy Policy.

Marketing In order to support tailored services, advertisements, offers, or content that you may find interesting when you browse the internet, Windfall may share the personal information that you provide to us or that we collect about you with our trusted third party partners that support our online advertising.

Required By Law We may share your information as permitted or required by any applicable law in response to a subpoena or other legal process or as we deem necessary to investigate or remedy any actual or potential violation of our policies or to protect the rights, property, and safety of Windfall or others, as we deem appropriate.

Security of Your Information While we take reasonable steps to protect any personally identifiable information you choose to provide via the Site from unauthorized access, please be aware that, despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online can potentially be intercepted and used by unauthorized parties, so please keep this in mind when disclosing any personal or personally identifiable information via the Site. To help ensure security via the Internet, we recommend you keep your browser up to date with automatic security updates enabled.

Policy for Children We do not use the Site to solicit information from or market to children under the age of 18. By using the Site, you represent that you are at least 18 years of age. We encourage parents and legal guardians to monitor their children’s internet usage and to instruct their children never to provide personal information through the Site or any other website without parental consent. If you believe a child has provided personal information to us via the Site, please contact us and we will use reasonable efforts to locate and delete the information.

Links to Other Websites and Third Party Practices This Site may contain links to third party websites. It is our intent to provide links only to other quality websites. However, we have no control over these linked websites or, for that matter, any third parties. Any information collected by websites, other than the Site, is not covered by this Privacy Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites that may be linked to or from the Site. We encourage you to read the provisions of privacy policies on other websites before providing them with your personal information.

Do Not Track Signals Do Not Track (“DNT”) is a privacy preference that users can set to have their Internet browser automatically send a signal to our online and mobile resources to request we not track browsing activity across different sites. There is, however, currently no universal standard for sending and receiving DNT signals. As such, we cannot promise that we respond to all DNT signals, but do recognize and respond when required by applicable privacy laws, such as when HTTP header fields or Java objects are used.

Submitting Information From Outside The United States. We control and operate the online and mobile resources from within the United States of America (the “U.S.”). Information collected through the Website and Services may be stored and processed in the United States or any other country in which our vendors or we maintain facilities. Although we do not actively block or monitor visitors from other countries, the Website is directed only at visitors from the U.S. As such, this Privacy Policy is consistent with U.S. law and practice and is not adapted to other laws (including European data security and privacy laws). Windfall will apply the applicable laws of the U.S., including as embodied in this Privacy Policy in place of data protections under your home country's law. That is, you freely and unambiguously acknowledge that this Privacy Policy, not your home country's laws, controls how we will collect, store, process, and transfer your personal information. Similarly, the English language version of this Privacy Policy is the controlling version regardless of any translation you may attempt.

Exercise Your Privacy Rights Windfall takes privacy seriously. Where applicable, data subjects have certain rights which they can request for Windfall to fulfill. These requests can be made by either the data subject or an authorized agent. These rights include:

The Right to Know. You have the right to request that Windfall disclose the personal data that Windfall has collected about you;
The Right to Amend. You have the right to correct any information that Windfall stores about you; and
The Right to Delete. You have the right to request that Windfall delete information that it maintains about you, subject to certain exceptions.

In order to exercise any of the rights detailed above, you may email us here: info@windfall.com. We will use your email as proof of verification unless otherwise prohibited. Exercising your rights under this section will not result in any discrimination by Windfall. We will treat you the same as any other user. If you disagree or dispute a decision that has been made on the scope or application of the rights described in this clause, you may appeal this decision by contacting info@windfall.com.

Retention Period Windfall shall only store personal information for as long as it is required. This is determined by considering the purposes for which it was obtained in accordance with applicable laws. Our retention period is based on (1) the nature of our relationship with the data subject and (2) any legal obligations we are bound to fulfill.

Contact Us If you have questions or comments about this Privacy Policy, please send us an email at info@windfall.com.

WINDFALL
CANDIDATE PRIVACY POLICY

Last Updated: October 2023

The purpose of this privacy policy (“Privacy Policy”) is to inform you about how your personal data is processed by Windfall Firm, LLC. (“Windfall”, “we”, “us”, “our”), when you apply for employment or are under engagement with us. You must review and ensure you agree with what is described in this notice prior to submitting data to us.

What Information Do We Collect?

Why Do We Process Your Personal Data?

Your Right to Withdraw.

Who Has Access To Your Personal Data?

Exercise Your Privacy Rights.

Retention Period

Although this notice may be translated into other languages for convenience, this English language version is the controlling version.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. Any changes will be reflected in a revised policy posted and we will alert you that there has been a change by updating the “Revised” date displayed on the Privacy Policy. If Windfall determines that such changes materially affect your privacy rights, we will provide additional notice to you.

What Information Do We Collect?

We may collect information about you in a variety of ways but generally speaking it is done through your job application. The types of information we may collect include, but are not limited to:

Information You Provide To Us. If you apply for employment or are under an engagement either directly with Windfall or through a partner, we may collect some or all of the following information about you:

Your name, address, and contact details, including email address and telephone number;
Your qualifications, skills, experience, and employment history;
Details about your current or expected future compensation / consultancy fee;
Information about your nationality, residency, or entitlement to work in the relevant jurisdiction. This may include your social security number. ; and
Any other information that you voluntarily provide to us.

Information We Collect About You. If you apply via an online portal or similar means, we also may collect your IP address.

Additional Information. Sometimes we will collect personal data about you from third parties. For example, we might:

Obtain professional references from a former employer or other relevant reference that you identify to us;
Obtain additional information obtained from social media websites like LinkedIn such as profile photos and additional experience;
Conduct watch list checks (to ensure candidates are not identified as restricted, sanctioned, or prohibited individuals and thus prohibited from certain activities or industries); and
Engage a background check provider to undertake an employment, credit, and/or criminal background check.

Why Do We Process Your Personal Data? The provision of personal data by you is necessary in order for us to (a) fulfil our legal obligations (e.g., verify your eligibility to work in the applicable location), and (b) process your application and consider you for a position with us including by conducting interviews, collecting references, and undertaking certain types background checks all to make the most appropriate recruitment decisions for our business. Except as specifically identified below, the lawful basis for our processing is compliance with our legal obligations and protecting our legitimate interests.

Processing data from applicants allows us to:

Review and manage candidate applications and supporting materials;
Administer and manage offers and communications with candidates;
Meet our obligations with respect to any recruiting agencies that are acting on your behalf; and
Administer, manage, and improve our recruiting operations.

When we perform background checks related to credit history, we are required to provide applicants from certain jurisdictions with additional notices and disclosures and, in some cases, an opportunity to consent. If those requirements apply, you will receive links to those notices and disclosures, and a mechanism for providing or declining to provide such consent, at the email address you provided to us.

Similarly, when we perform background checks involving criminal record data (as in the case of roles that require a high degree of trust and integrity, and/or where we are required to undertake such checks to assist our clients in complying with their regulatory obligations) or where we collect any personal data that may be considered sensitive personal data in the applicable jurisdiction, we are required to obtain the consent of, and provide special notices to, applicants from certain jurisdictions. If those requirements apply, you will receive links to those notices and a mechanism for providing or declining to provide such consent at the email address you provided to us.

Your Right to Withdraw. In any case where we may indicate that the lawful basis on which we have collected and processed your personal data is your consent, you can withdraw your consent at any time by contacting us using the contact information above. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent. For the avoidance of doubt, it is not a condition of any prospective contract with us that you agree to any request for consent to process personal data. If you fail to provide certain information when requested, however, please note that we may not be able to continue with your application or conclude any agreement with you or we may be prevented from complying with our legal obligations.

Who Has Access To Your Personal Data? In connection with the purposes described above, we may disclose your personal data to:

Our subsidiaries, service providers (e.g., providers of IT services and background check agencies), and advisors;
Fraud prevention agencies and law enforcement agencies;
Courts, governmental and non-governmental regulators, and ombudsmen;
Any third party that acquires, or is interested in acquiring or securitizing, all or part of our assets, shares, partnership interests, and/or membership interests, or that succeeds us in carrying on all or a part of our businesses, whether by merger, acquisition, reorganization, or otherwise; or
As required or permitted by law, including to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or we have a legitimate interest in making a disclosure, such as where necessary to protect our rights and property.

The Right to Know. You have the right to request that Windfall disclose the personal data that Windfall has collected about you;
The Right to Amend. You have the right to correct any information that Windfall stores about you; and
The Right to Delete. You have the right to request that Windfall delete information that it maintains about you, subject to certain exceptions.

Contact Us If you have questions or comments about this Privacy Policy, please send us an email at info@windfall.com.