WinkProgress is committed to protecting the privacy of users of The Site. The WinkProgress Network intends to give users as much control as possible over user’s personally identifiable information. This Privacy Statement applies to The Site and describes the information The WinkProgress Network collects about users and how that information may be used.
WinkProgress reserves the right to update and change this Privacy Statement from time to time. If we make material changes to its privacy practices, a prominent notice will be posted on the web page. Each time a user uses The Site, the current version of the Privacy Statement applies. Accordingly, a user should check the date of this Privacy Statement (which appears at the top) and review for any changes since the last version. If a user does not agree to the Privacy Statement, the user should not use The Site. The most current version of the Privacy Statement will always be available at http://winkprogress.com/privacy/.
Safe Harbor Framework: The WinkProgress Network complies with the United States (“US”) / European Union (“EU”) Safe Harbor framework as set forth by the US Department of Commerce regarding the collection, use, and retention of data from the EU. Individuals who wish to file a complaint or who take issue with WinkProgress’s EU Safe Harbor policies should direct such communication to The WinkProgress Network – Privacy via written communication at the contact information provided below. Filing a complaint in English will expedite the process. The WinkProgress Network will investigate and attempt to resolve complaints regarding use and disclosure of personal information in accordance with the principles contained in this Privacy Statement. For complaints that cannot be resolved between the WinkProgress Network and the complainant, the WinkProgress Network participates in the dispute resolution procedures of the panel established by the EU data protection authorities to resolve disputes pursuant to the Safe Harbor framework.
The WinkProgress Network agrees to notify users of the following privacy principles: Notice, Choice, Onward Transfer, Security, Data Integrity, Access, and Enforcement.
Notice: The WinkProgress Network provides this Privacy Statement to make users aware of WinkProgress privacy practices, and of the choices a user may make about the way the user’s information is collected and used.
Children: Users represent they are of legal age to create binding and financial obligations for any liability users may incur as a result of their use of The Site. The Site is not directed to children under the age of 13, and The WinkProgress Network will never request personally identifiable information from anyone whom it knows to be under the age of 13 without verifiable parental or guardian consent. The WinkProgress Network does not knowingly collect, or wish to obtain, personally identifiable information from children. If The WinkProgress Network becomes aware that a user is under the age of 13 and has provided personally identifiable information without prior verifiable parental or guardian consent, it will remove user’s personally identifiable information from its files and The Site.
What Information WinkProgress.Com Collects: The WinkProgress Network may collect two types of information from users of The Site: “personally identifiable information” (such as name, email address, website URL) and “aggregate information” (such as frequency of visits to Sites, IP address, Site pages most frequently accessed, browser type). Personally identifiable information is any piece of information which can potentially be used to uniquely identify, contact, or locate a user of The Site. Aggregate information is non-personally identifiable/anonymous information about users of The Site. Aggregate information is used in a collective manner and no single person can be identified by that compiled information.
On The Site, users are never asked to register or create accounts to log in. However, users are required to enter a name and email address in order to leave comments on the site, and may voluntarily provide a website URL as well. In addition, when we publish content by guest contributors, we request at minimum a contact email address and a name or pseudonym for the by-line of the content to be published. We may also request the real name of the author, although that information will be kept offline and not in a format associated with the website if the guest author requests.
The ads appearing on the Sites are delivered to visitors both by individual advertisers and through third-party advertising services such as Google AdSense and Amazon. The third party advertising technology that WinkProgress uses on The Site uses information derived from a user’s visits to the Site to target advertising within The Site. In addition, WinkProgress advertisers may use other third party advertising technology to target advertising on the Site. In the course of serving advertisements to The Site, third-party advertising platforms may place or recognize a unique cookie on a user’s browser. Information about users’ visits to The Site, such as the number of times users have viewed an ad (but not users’ names, addresses, or other personally identifiable information), are used to serve ads to visitors. As with other cookies, and consistent with The WinkProgress Network policy on cookies stated above, the user may block or delete such cookies from the user’s drive or memory.
For more information about advertising on The Site, please see our About Our Ads page.
Log Files: The WinkProgress Network web servers may automatically log aggregate information, such as a user’s IP address, domain name, browser type, date and time of access, and other log file data. This information may be used to analyze trends or administer The Site. Log files do not contain personally identifiable information.
How WinkProgress.Com Uses The Information Collected: The WinkProgress Network may use the any information that a user submits for any purposes related to WinkProgress business, including, but not limited to:
User names, identifications (“IDs”), and email addresses (as well as any additional information that a user may choose to post) may be publicly available on a Site when users voluntarily and publicly disclose personally identifiable information, such as when a user posts personally identifiable information as part of a message posted to a public forum. Users may not be able to change or remove public postings once posted. Such personally identifiable information may be used by visitors of these pages to send unsolicited messages. WinkProgress is not responsible for any consequences which may occur from the use of personally identifiable information that a user chooses to submit to public pages.
Choice / Opt Out: A user makes the decision whether to proceed with any activity that requests personally identifiable information. If a user does not provide requested information, the user may not be able to complete certain transactions.
Users who use the personally identifiable information of other users agree to use such information only for:
Using services offered through a Site; Site transaction-related purposes and not for unsolicited commercial messages; or Other purposes that the other user expressly chooses.
Users are not licensed to add other users to a Site, even users who entered into transactions with them, or to their mail lists without consent.
WinkProgress encourages users to evaluate privacy and security policies of any of The Site’s transaction partners before entering into transactions or choosing to disclose personally identifiable information.
Emails: The WinkProgress Network will not use or share the personally identifiable information provided to it online in ways unrelated to the items described above without first letting a user know and offering the user a choice. WinkProgress WILL NEVER SELL YOUR EMAIL ADDRESS to advertisers or other third-party vendors.
Comments and Author Information Display: A user’s personally identifiable information may be publicly available when it is entered for the purpose of leaving a comment, or on the author page if a user has contributed content as a guest author on the website. In most cases, information is optional and can be left blank (e.g. website URL) or, when required, remains hidden from the public (e.g. email address).
Onward Transfer: With whom may the WinkProgress Network share information?
WinkProgress will not sell, rent, or lease a user’s personally identifiable information to others. Unless WinkProgress has a user’s permission or as required by law, WinkProgress will only share the personally identifiable information a user provides online with service providers who may be used to ship products, process credit cards, provide technical support, handle order processing, or otherwise act on the behalf of WinkProgress. These third parties are prohibited from using users’ information for any other purpose, including their own marketing.
When WinkProgress uses third parties to assist in processing The Site’s user personally identifiable information, WinkProgress requests that they comply with WinkProgress privacy practices, and other appropriate confidentiality and security measures.
Please be advised that in certain instances, it may be necessary for WinkProgress to disclose a user’s personally identifiable information without a user’s permission to government officials or otherwise as required by legal obligations. WinkProgress may disclose such personally identifiable information when responding to subpoenas, court orders, or legal process, or to establish or exercise legal rights or defend against claims, including fraud or infringement investigations.
When users choose to provide WinkProgress with personally identifiable information, users consent to the transfer and storage of such information by WinkProgress servers in the United States.
In addition, WinkProgress reserves the right to share aggregate information collected from users of The Site, without prior notice, with other third parties for the any purpose, including but not limited to statistical reports about website views, ad clicks, and content popularity. As stated earlier, aggregate information is used in a collective manner and no single person can be identified by such compiled information.
Service Orders: Currently, no products or services are sold through The Site; however, we reserve the right to offer products or services in the future. To purchase services, users may be asked to be directed to a third party site, like PayPal, to pay for their purchases. If applicable, the third party site may collect payment information directly to facilitate a transaction. None of this information will be captured or stored by WinkProgress.
Links To Third-Party Websites: Links to third party web sites on The Site are provided solely as a convenience to the user. When a user uses these links, the user leaves The Site. WinkProgress has not reviewed all of these third party sites, does not control, and is not responsible for, any of the third party sites, their content or privacy practices. WinkProgress does not endorse or make any representations about the third party sites, or any information, services, or products found on the sites. If a user decides to access any of the linked sites, WinkProgress encourages the user to read their privacy statements. The user accesses such sites at user’s own risk.
Bankruptcy or Sale of Business: WinkProgress reserves the right to share or transfer personally identifiable information and aggregate information to a third party should WinkProgress ever file for bankruptcy or in the event of a sale, merger or acquisition of WinkProgress, provided such third party agrees to adhere to the terms of this Privacy Statement.
Data Integrity and Access: Should a user find inaccuracies in such user’s information, or desire to close an account or view the personally identifiable information WinkProgress may have regarding the user, the user may contact WinkProgress through the communication methods described below, or when technically feasible, directly on The Site. WinkProgress will make commercially reasonable efforts to respond to requests for access within thirty (30) days of receiving requests. WinkProgress may decline to process users’ access or update requests to their personally identifiable information if the requests require disproportionate technical effort, jeopardize the privacy of other users, or are impractical (for instance, requests concerning information residing on backup tapes).
Security: To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use of information, WinkProgress implements physical, electronic, and managerial procedures to safeguard and secure the information WinkProgress collects. WinkProgress uses encryption when collecting or transferring sensitive personally identifiable information. However, WinkProgress does not guarantee that unauthorized third parties will never defeat measures taken to prevent improper use of personally identifiable information.
Internal WinkProgress access to users’ nonpublic personally identifiable information is restricted to WinkProgress administrators and individuals on a need-to-know basis. These individuals are bound by confidentiality agreements.
Enforcement: In the event WinkProgress becomes aware that the security of The Site has been compromised or user’s personally identifiable information has been disclosed to unrelated third parties as a result of external activity, including but not limited to security attacks or fraud, WinkProgress reserves the right to take reasonable appropriate measures, including but not limited to, investigation and reporting, and notification to and cooperation with law enforcement authorities.
If WinkProgress becomes aware that a user’s personally identifiable information has been disclosed in a manner not permitted by this Privacy Statement, WinkProgress will make reasonable efforts to notify the affected user, as soon as reasonably possible and as permitted by law, of what information has been disclosed, to the extent that WinkProgress knows this information.
If a user has comments or questions about this WinkProgress privacy statement, please email: