1. Important Information and contact details
This version of the Privacy Notice was last updated in May 2019. By accessing www.westfountain.com (the “Website”), you agree to this Privacy Notice. WFGF reserves the right to modify this Privacy Notice at any time and to use user information for new, unanticipated uses not previously disclosed in this Privacy Notice. However, if our information practices change at some time in the future, we will post the policy changes to our Website to notify you of these changes and provide you with the ability to opt out of these new uses. Your continued use of the Website after such changes are made is considered to be your acceptance of those changes. If you are concerned about how your information is used, you should check back at our Website periodically.
This Website is not directed at children 16 years of age or younger. WFGF, therefore, will not intentionally collect information about any user under the age of 16 and our website or communications are not extended to such persons.
If you have questions or comments about this Privacy Notice or our privacy practice or any of the other terms set out in notice, please contact us via e-mail at: email@example.com or at our postal address which is:
3001 China Merchants Bank Shenzhen Branch Building
2016 Shennan Avenue
Futian Center District
If you are a data subject protected by the EU General Data Protection Regulation ((EU) 2016/679) (“GDPR”) please address your queries to the firstname.lastname@example.org.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the personal identifiers have been removed (anonymous data).
Automatic collection of information upon visiting WFGF’s Website
When you access our Website, WFGF will collect and store certain information, such as: the domain name and host from which you access the Internet, the browser software and operating system of your computer, the Internet protocol (IP) address of your computer, the pages accessed or visited on the site, the Internet address of the site from which you directly linked to WFGF’s Website, as well as your browser’s country setting. If you leave our Website via an external link to another site/domain name, we will not collect any information that you share on the external site/external domain name.
Collection of voluntary information by WFGF.
By writing (including by way of email) to WFGF or by filling out certain forms or data requests from WFGF, or otherwise voluntarily requesting or supplying information to WFGF, you are volunteering to provide such information, including but not limited to, your contact information and/or site registrations, name and address, telephone number or fax number, to us. If you e-mail us, we will collect your e-mail address and IP addresses. If you do not want to receive nonbusiness related e-mail communications from us in the future, please let us know by sending us an e-mail at email@example.com. If you supply us with your postal address online, you will only receive the information for which you provided us your address. Persons who supply us with their telephone numbers online will only receive telephone contact from us with information relating to their particular request.
We also collect, use, store and share “Aggregated Data”, which is defined as information from more that one person, such as statistical or demographic data for our or third-party use for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your use of this Website data to calculate the percentage of users accessing a specific Website feature or particular content. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice or any other privacy notice we may have sent or provided you access to at the time or soon after its collection.
We do not collect any personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, criminal convictions, criminal offenses, information about your health and genetic and biometric data, etc.)
Contact Forms - We use a session cookie in our contact forms to allow you to contact us via our Website.
Content Management System - We use persistent cookies and session cookies in our content management system to enable the Website to work effectively and to remember your preferences and settings.
LinkedIn – session cookies are used to track basic demographic information of LinkedIn visitors to our Website.
4. How we use your personal data
WFGF will only use your personal data when the laws of the jurisdiction of specific WFGF entity allow. Most commonly, we will use your personal data where WFGF has a legitimate interest in, or other legal basis for, processing your information, including where we need to comply with a legal or regulatory obligation or in relation to legal claims. We may also process your personal data where we have your consent to process your personal information and, when we rely on your consent for the processing, you may withdraw such consent at any time. Other lawful basis for us processing your data may be that such processing is necessary for the performance of a contract we have entered or at your request are entering with you. However, please note that where we have relied on more than one legal basis for processing, we may continue the processing without your consent.
The information we collect from you may be used to improve the content of our Website, to fulfill your requests for information, provide services and marketing information to you and otherwise communicate with you, and to serve the appropriate region data to you. We may also keep your personal data and use it to contact you in the future.
Data submitted on the Website will be used for the purposes specified in the relevant part of the Website and, where relevant, for other purposes for which you give your consent.
You have the right to withdraw your consent where this has been provided, or to unsubscribe to mailings lists or registrations at any time by either using the unsubscribe link within our email communications or by writing to us at firstname.lastname@example.org.
5. Disclosures of your personal data and international transfers
WFGF does not sell or license personal information to third parties. We may disclose the information collected with third-party marketing service companies which may process your data on our behalf and under our instruction. These third-party service providers include, without limitation, dotMailer, HubSpot, LinkedIn, Grove Marketing, Google Analytics, New Relic and AddThis who may assist us in maintaining our Website, analyzing our Website traffic, and in providing services and information to users of our Website. We require all third parties to respect the security of your personal data and to treat it in accordance with applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
With respect to Ad Servers: we do not partner with or have special relationships with any ad server companies.
WFGF reserves the right to disclose your information where required by law or to comply with valid legal or regulatory processes to protect WFGF rights. In addition, we may also disclose your personal data to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets, or alternatively, if we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners, or combined group, may use your personal data in the same way as set out in this Privacy Notice, otherwise you will be notified of any change by an updated privacy notice on this Website.
The information collected may also be shared globally with third parties who may be providing services to any WFGF. Those countries may not provide an adequate level of protection in relation to the processing of personal data but, in connection with the processing of personal data to which GDPR applies where required by law, we have put in place legal mechanisms designed to ensure adequate data protection.
Please contact us if you want further information on transferring your personal data.
6. Links to third-party sites
Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
7. Data security
WFGF has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. For the processing of data subject to GDPR, they will only process your personal data on our instructions and where they are subject to a duty of confidentiality, and we will also deal with personal data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so. In the EU, the relevant authority is the UK’s Information Commissioner's Office (ICO).
Despite these precautions, WFGF cannot guarantee the security of the information collected from third parties or transmitted through our Website or guarantee the security of emails. Therefore, we assume no liability for any disclosure of information collected arising from the acts of third parties or other events, acts or omissions outside of our control, including, but not limited to, interruption of service or any issues related to the use of the internet. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
8. Data retention
WFGF will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including, where applicable, for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.
Details of retention periods applied to your personal data can be requested by contacting us. For data subjects protected by GDPR we keep basic information about you for six years after you cease to use our services or hold other communication with us. This data retention schedule comes into effect January 2025. Personal information collected in relation to money laundry requirements will be kept for up to 10 years. In some circumstances, you can ask us to delete your data: see your legal rights section below for further information.
We may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under local data protection laws, you may have rights in relation to your personal data. In the processing of your personal data, certain of your rights are protected by the GDPR, and these rights will include the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you are protected by GDPR and wish to exercise any of the rights set out above, please contact us. However, there are circumstances in which those rights may not be available to you and we may not satisfy your request.
You will not have to pay a fee to access your personal data or to exercise any of the other rights, where these rights apply in our processing of your personal data. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
In addition, where granted by local law, you may also have the right to make a complaint at any time to the relevant data protection authority. We would, however, appreciate the chance to deal with your concerns before you approach any authority so please contact us in the first instance.
10. Your California privacy rights
California 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 e-mail to email@example.com or write us at:
3001 China Merchants Bank Shenzhen Branch Building
2016 Shennan Avenue
Futian Center District