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Connecticut CTDPA

Connecticut Data Privacy Act (CTDPA) Notice
Connecticut Privacy Rights
This section supplements the Wind ’n’ Sails Privacy Policy and provides additional information for Connecticut residents under the Connecticut Data Privacy Act (“CTDPA”).
The terms used in this section have the meanings given to them under the CTDPA. Certain information, including deidentified data and publicly available information, may fall outside the scope of the CTDPA as provided by applicable law.
For privacy-related questions, please contact us at privacy@windnsails.com.

Your Connecticut Privacy Rights
Subject to applicable exceptions and limitations, Connecticut residents may have the right to:
  • Confirm and Access — Confirm whether Wind ’n’ Sails is processing your personal data and access personal data we process about you, including certain inferences derived from your personal data and information concerning certain profiling, where applicable.
  • Correct — Correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes for which it is processed.
  • Delete — Request deletion of personal data provided by or obtained about you.
  • Data Portability — Obtain a copy of certain personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance.
  • Opt Out — Opt out of the processing of personal data for targeted advertising, the sale of personal data, or certain profiling involving automated decisions that produce legal or similarly significant effects concerning you.
  • Information About Certain Sales — Where applicable, obtain information concerning third parties to which your personal data has been sold, as provided by the CTDPA.
Wind ’n’ Sails will not discriminate against you for exercising rights provided by the CTDPA.

Targeted Advertising
Wind ’n’ Sails may process personal data for targeted advertising, as that term is defined under the CTDPA.
Depending on how you interact with us, this may involve categories of personal data such as:
  • Personal identifiers and online identifiers;
  • Internet or other electronic network activity; and
  • Commercial information, including information concerning your interactions with our products or services.
You have the right to opt out of the processing of your personal data for targeted advertising.
To exercise this right, please visit Your Privacy Choices / Privacy Preferences.

Sale of Personal Data
Wind ’n’ Sails does not sell personal data for monetary consideration.
To the extent any disclosure of personal data is considered a “sale” under the broader definition provided by the CTDPA, Connecticut residents may exercise their applicable right to opt out through Your Privacy Choices / Privacy Preferences.

Profiling
Wind ’n’ Sails does not currently engage in profiling in furtherance of automated decisions that produce legal or similarly significant effects concerning consumers.
If our practices change, we will update our privacy disclosures and provide the rights required by applicable law.

Universal Opt-Out Preference Signals
Wind ’n’ Sails recognizes qualifying universal opt-out preference signals, such as the Global Privacy Control (“GPC”), as required by the CTDPA.
When we receive a legally valid opt-out preference signal that enables us to determine that the request applies under Connecticut law, we will process the signal as a request to opt out of applicable targeted advertising and sales of personal data.
Because these signals are generally associated with a particular browser or device, you may need to enable the signal separately on each browser or device you use.
Where we are able to associate an authenticated consumer account with the browser or device sending the signal, we will apply the request as required by applicable law.

Authorized Agents
You may designate an authorized agent to exercise certain opt-out rights on your behalf, as permitted by the CTDPA.
We may take reasonable steps permitted by law to verify the authority of an authorized agent before processing the request.
A qualifying universal opt-out preference signal may also communicate an opt-out request as provided by the CTDPA.

Exercising Your Rights
You may submit a request to exercise your Connecticut privacy rights through:
We may request information reasonably necessary to authenticate your identity and your request. We will use personal data provided in connection with a privacy request only as reasonably necessary to authenticate and process the request or as otherwise permitted by law.
You are not required to create a new Wind ’n’ Sails account to exercise your privacy rights.
For requests that do not require authentication under applicable law, including certain opt-out requests, we will process the request in accordance with the CTDPA.
If we cannot authenticate a request when authentication is required, we may request additional information reasonably necessary to authenticate the request.

Response Timing and Fees
Wind ’n’ Sails will respond to a verified privacy request without undue delay and generally within 45 days after receiving the request.
When reasonably necessary, we may extend the response period by an additional 45 days, taking into account the complexity and number of requests. If an extension is necessary, we will notify you within the initial 45-day response period and explain the reason for the extension.
Information provided in response to a consumer request will generally be provided free of charge once during any 12-month period.
If a request is manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee to cover the administrative costs of complying with the request or decline to act on the request, as permitted by law.

Appeals
If we decline to take action on your privacy request, we will provide information explaining our decision and instructions for appealing it.
You may submit an appeal through Your Privacy Choices / Privacy Preferences or by contacting privacy@windnsails.com and identifying your request as a Privacy Appeal.
We will respond to an appeal in writing within the period required by the CTDPA, generally within 60 days after receiving the appeal, and will explain any action taken or not taken in response to the appeal.
If your appeal is denied, we will provide information about how you may contact the Connecticut Office of the Attorney General to submit a complaint.

Data Retention and Legal Exceptions
Your privacy rights are subject to exceptions and limitations provided by applicable law.
For example, Wind ’n’ Sails may retain or otherwise process personal data when reasonably necessary and permitted by law to:
  • Complete transactions or provide products or services you requested;
  • Maintain the security and integrity of our services;
  • Detect, investigate, or prevent fraud, security incidents, or unlawful activity;
  • Comply with legal obligations;
  • Establish, exercise, or defend legal claims; or
  • Perform other activities permitted under applicable law.
Where deletion is required, we will process the request in accordance with the CTDPA and our applicable legal obligations.

Contact Us
For questions regarding this Connecticut Privacy Notice or our privacy practices, or to exercise your applicable privacy rights, please visit Your Privacy Choices / Privacy Preferences or contact:
Wind ’n’ Sails
Email: privacy@windnsails.com
Please also review our Privacy Policy for additional information about how Wind ’n’ Sails collects, uses, discloses, retains, and protects personal information.