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Iowa ICDPA

Iowa Consumer Data Protection Act (ICDPA) Notice – Wind ’n’ Sails
Iowa Privacy Rights
This section provides additional information for Iowa residents under the Iowa Consumer Data Protection Act (ICDPA). Terms used in this section have the meanings given to them under the ICDPA.
The ICDPA applies to Iowa residents acting in an individual or household context and does not apply to individuals acting in a commercial or employment context. Certain information, including deidentified data, aggregate data, and publicly available information, is not considered personal data under the ICDPA.
For privacy-related questions or requests, please contact privacy@windnsails.com or visit our Privacy Preferences page.

Personal Data We Process
Wind ’n’ Sails may process personal data in connection with your purchases, use of our website, communications with us, and interactions with our services. Depending on how you interact with us, this may include categories such as:
  • Personal Identifiers – such as your name, email address, postal address, telephone number, and online identifiers.
  • Commercial Information – such as products purchased, obtained, or considered and other purchasing or consuming histories or tendencies.
  • Internet or Electronic Activity – such as information about your interactions with our website, advertisements, and digital services.
  • Payment and Transaction Information – such as information necessary to process purchases and transactions.
  • Other Information You Provide – such as information submitted when you contact Customer Care, create an account, participate in promotions, or otherwise communicate with us.
For additional information regarding the personal data we collect, the purposes for which we use it, and the categories of third parties with whom we disclose it, please review our Privacy Policy.

Sale of Personal Data and Targeted Advertising
Sale of Personal Data
Wind ’n’ Sails does not sell personal data for monetary consideration as “sale” is defined under the ICDPA.
If our practices change and we engage in activities that constitute a sale of personal data under Iowa law, eligible Iowa consumers will be provided with the disclosures and ability to opt out required by applicable law.

Targeted Advertising
Wind ’n’ Sails may process personal data for targeted advertising, including through cookies and similar technologies used by advertising and marketing partners. Depending on your interactions with our website, this may involve information such as:
  • Personal Identifiers
  • Internet or Electronic Activity
  • Commercial Information
Although the ICDPA requires controllers engaging in targeted advertising to clearly disclose that activity, the Iowa statute's enumerated consumer opt-out right applies to the sale of personal data.
Wind ’n’ Sails nevertheless provides privacy controls through our Privacy Preferences page. Additional privacy choices may also be available under other applicable U.S. state privacy laws.

Sensitive Data
The ICDPA defines sensitive data to include certain information concerning racial or ethnic origin, religious beliefs, health diagnoses, sexual orientation, citizenship or immigration status, certain genetic or biometric data, personal data collected from a known child, and precise geolocation data.
Wind ’n’ Sails does not intentionally process sensitive data for purposes requiring an opportunity to opt out under the ICDPA.
If our practices change, we will provide the notice and choices required by applicable law.

Your ICDPA Rights
Subject to applicable exceptions and limitations, Iowa residents covered by the ICDPA may have the following rights.

Right to Confirm and Access
You have the right to request confirmation of whether Wind ’n’ Sails is processing your personal data and, if so, to access that personal data.

Right to Delete
You have the right to request deletion of personal data that you provided to us, subject to exceptions permitted by law.
We may retain information when necessary or permitted for purposes such as completing transactions, complying with legal obligations, protecting against fraud or security incidents, exercising or defending legal claims, or other purposes permitted by applicable law.

Right to Data Portability
You have the right to request a copy of personal data that you previously provided to us in a portable and, to the extent technically practicable, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means and subject to limitations under applicable law.

Right to Opt Out of the Sale of Personal Data
You have the right to opt out of the sale of your personal data as defined under the ICDPA.
Wind ’n’ Sails does not currently sell personal data for monetary consideration as defined by the ICDPA.
If our practices change, we will provide an appropriate method for exercising this right.

Right to Non-Discrimination
Wind ’n’ Sails will not discriminate against you for exercising your rights under the ICDPA, including by unlawfully:
  • Denying goods or services;
  • Charging different prices or rates for goods or services; or
  • Providing a different level or quality of goods or services.
The ICDPA permits certain differences associated with a consumer's voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club-card program and other circumstances permitted by law.

How to Exercise Your Iowa Privacy Rights
To submit a privacy request, you may:
Please identify the privacy right you wish to exercise and provide the information reasonably necessary for us to process your request.
You do not need to create a new Wind ’n’ Sails account to exercise your rights. If you already have an account, we may ask you to use it when appropriate and permitted by law.
A parent or legal guardian may exercise applicable rights on behalf of a known child.

Verification of Privacy Requests
To protect your personal data, Wind ’n’ Sails may take commercially reasonable steps to authenticate your identity and your request before fulfilling certain privacy requests.
We may compare information you provide with information maintained in our records and, when reasonably necessary, request additional information to authenticate your request.
If we cannot authenticate a request using commercially reasonable efforts, we may be unable to fulfill the request and may request additional information reasonably necessary to authenticate you and your request.

Response Timing and Fees
Wind ’n’ Sails will respond to an authenticated privacy request without undue delay and, in all cases, within 90 days after receiving the request.
When reasonably necessary because of the complexity or number of requests, we may extend the response period once by an additional 45 days. If an extension is required, we will notify you within the initial 90-day period and explain the reason for the extension.
Information provided in response to a consumer request will generally be provided free of charge up to twice annually per consumer.
If a request is manifestly unfounded, excessive, repetitive, technically unfeasible, or we reasonably believe its primary purpose is not to exercise a consumer right, we may, as permitted by law, charge a reasonable fee to cover the administrative costs of responding to the request or decline to act on it.

Appealing a Decision
If Wind ’n’ Sails declines to take action on your privacy request, we will provide the justification for our decision as required by applicable law and instructions explaining how you may appeal the decision.
You may submit an appeal through our Privacy Preferences page by selecting “Appeal a Decision”, if available, or by emailing privacy@windnsails.com and clearly identifying your request as an Iowa privacy appeal.
We will respond to your appeal in writing within 60 days after receiving it and will explain any action taken or not taken in response to the appeal.
If your appeal is denied, we will provide an online mechanism through which you may contact the Iowa Attorney General to submit a complaint.

Additional Privacy Choices
Wind ’n’ Sails provides additional privacy choices that may be available to you under other applicable U.S. state privacy laws, including choices relating to certain advertising, cookies, tracking technologies, and other data practices.
Please visit our Your Privacy Choices or Privacy Preferences page for the controls currently available to you.
Where applicable law requires Wind ’n’ Sails to recognize a legally valid browser-based opt-out preference signal, such as Global Privacy Control (GPC), we will process the signal as required by the law applicable to the consumer and the relevant processing activity.

Contact Us
For questions regarding this Iowa Privacy Notice or to exercise applicable privacy rights, please contact:
Wind ’n’ Sails
Email: privacy@windnsails.com
Privacy Requests: Privacy Preferences
Additional Information: Privacy Policy