Privacy Policy
Last Modified: June 17, 2026
This Privacy Policy (“Policy”) describes the categories of personal data that Sappington Co., doing business as Winscale (“Winscale,” “we,” or “us”), collects when you visit the website, https://winscale.ai/ (the “Website”), use the services made available by Winscale via the Website (including Winscale’s AI-powered B2B website provided via the Website), or otherwise interact with Winscale (collectively, the “Services”), our practices for collecting, using, disclosing, retaining, and protecting your personal data, and your rights to ensure proper management of this information. Please note, however, that if we have entered into a written agreement with you regarding the processing of personal data, then that agreement will govern and control over the terms and conditions of this Policy.
Terms used in this Policy may have different but substantially analogous terms in different jurisdictions and are intended to apply across jurisdictions except where expressly limited.
By accessing and using the Services you acknowledge that you have read and understand the contents of this Policy. Accordingly, if you do not agree to the terms of this Policy, do not use the Website or Services.
Updates and Modifications
Updates to this Policy may be made from time to time to comply with changing regulations or internal data privacy procedures. In the event of an update, the revised policy statement will be posted at: https://winscale.ai/privacy.
About Us and How to Reach Our Privacy Team
If you have a question or concern about this Policy, please contact us at:
Address:
Attn: Tim Goggin
255 South King
Street, Suite 800
Seattle, WA 98104
Phone:
206-448-2800
Email:
tim.goggin@winscale.ai
Privacy of Children and Minors
Our Website is not intended for children under 13 years of age or for minors under the age of 16. No one under the age of 16 may provide any information to or on the Website or when accessing or using any Services. We do not knowingly collect personal data from children or minors under the age of 16. If you are under 16 years old, do not use or provide any information on the Website or on or through any of its features. If we learn we have collected or received personal data from a child or minor, without verification of parental consent or as permitted by law, we will delete that personal data. If you believe we might have any personal data from or about a child or minor under 16 years old, please contact us.
Personal Data We Collect: Direct and Indirect Sources
Personal Data We Collect and How We Collect It
We collect personal data you send to Winscale for purposes relevant to Winscale’s business operations. When you interact with the Winscale, we may further gather various types of personal data, including:
Identifying Information: We may collect personal data details, such as your name and contact details (such as address, zip code, email, and phone number).
Payment Information: We may collect credit card or debit card information and information about the payment methods and services you use in connection with the Services. We use third party payment processors to manage financial transactions. We do not receive any additional personal data from these third party payment processors.
Account History: We may collect information about your subscription, account, transactions, purchases, order history, or discounts.
Location Information: We may collect general geographic location such as country, state or province, or city.
Images, Voice recordings, and Videos: We may collect or store images, voice recordings, and videos in connection with the Services, if you have consented to such information collection. See our Photography and Video section below.
Event Participation: When you register for or attend Winscale events or participate in Winscale activities, we collect personal data. This may include personal data about your involvement with Winscale, personal background, and any additional relevant personal data.
Correspondence and Communication Records: We maintain personal data about your interactions with Winscale, including the time and subject of your inquiries, as well as your preferred communication methods, and other personal data you provide in forms you fill out or information that you submit.
Security and Monitoring: We may collect video or audio recordings on our premises for safety purposes, or as further described in the Photography and Video section of this Policy.
We may also collect any other personal data that you provide to us.
Personal Data We Collect Indirectly from You
We gather personal data about your use of the Services through cookies and other technologies. We may collect the following personal data through cookies on the Website: standard web browser information, including browser type, Internet Protocol address, pages viewed on the Website, and links clicked, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the Website. We may use strictly necessary, analytics, performance, and targeting cookies.
Tracking Technologies
We also collect personal data from you when you access the Website and when you subscribe to our email services. We may collect personal data about the computer, mobile device or other device you use to access the Website such as Internet protocol (IP) address, geolocation information, unique device identifiers, browser type, browser language or other information of this nature in order to improve our Services.
On the Website, we may use web analytics tools, including Google Analytics. Google Analytics collects information and reports Website trends. We use the information collected to understand how our visitors are using the Website and to make improvements for a better online experience. Google Analytics uses third party cookies to track visitor interactions and collects an anonymized version of the Internet protocol (IP) address of Website visitors in order to provide us with a sense of where our visitors come from. It is Google Analytics position that it does not store or report to us visitors’ actual IP address information.
You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visit activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy.
Use of Cookies and Similar Technologies
Cookies are small files that are stored on your computer (unless you block them). The Website may use cookies to:
Understand and save your preferences for future visits.
Compile aggregate data about Website traffic and Website interaction so that we can offer better Website experiences and tools in the future.
Speed up your searches.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
You can control and/or delete cookies as you wish – for details, see www.aboutcookies.org.
Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email that are designed to: (1) collect usage information, like ad impressions or clicks, and email open rates; (2) measure popularity of services and associated advertising or promotions; and (3) access user cookies.
For more information regarding our cookies, including the precise cookies we use, please see the consent mechanism on the Website (i.e., the pop-window that allows you to opt-out or opt-in to the placement of certain cookies).
System Logs and Data Collection
Winscale servers automatically collect and log information when you use the Services or Winscale’s computer systems. Log data may include your IP address, date and time the Services or systems were used, and technical information about your devices and preferences.
Log data may be used to facilitate your access to the Services, monitor system performance, troubleshoot problems, and facilitate Winscale’s response in the event of prohibited uses of computing resources, or unauthorized access to sensitive data. Log files are stored for at least five (5) days and no longer than they are needed for performance monitoring, troubleshooting, and forensic purposes.
Financial Transactions
We do not directly collect or store payment information. We use third party, PCI-compliant, payment processors, who collect payment information on our behalf in order to complete transactions with our customers. While our administrators are able to view and track actual transactions via the user portals of the payment processors, we do not have access to, or process, credit card information.
Social Media Interactions and Data Use
We may use social media plug-ins (e.g., Instagram, Facebook, LinkedIn, X (formerly Twitter), YouTube, and Threads). These features may collect your IP address (and/or other information as set forth in each social media platform’s privacy policy), which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. We may also have a presence on some social media platforms, including, where applicable, Instagram, Facebook, LinkedIn, X (formerly Twitter), YouTube, and Threads. Through our accounts on social media platforms, we may in some instances collect personal data when you interact with our page or otherwise communicate with us through those accounts. Any personal data that you post on social media is governed by each social media platform’s privacy policies, and any personal data that we collect via our social media accounts will be processed in accordance with this Policy.
Personal Data Obtained From Third Party Sources
We collect personal data from third parties as part of performing services for third parties and to support Winscale’s business operations. When gathering your personal data, we may obtain personal data from various external sources, in compliance with applicable data protection laws:
Our Third Party Marketing and Business Partners
We collect personal data from third party marketing and business partners, who may provide us with certain personal data about your interests.
This personal data collection enhances our ability to provide you with tailored services and make informed decisions. We prioritize data accuracy and transparency, with the objective that all personal data gathered is relevant, up-to-date, and obtained through lawful means.
Photography and Video
Photos or video taken at our events, programs, or other interactions you have with Winscale may be used in publications such as brochures, newsletters, magazines, and video presentations. Such photos or videos may also be used electronically in online publications, on the Website, emails, social networking websites (such as Facebook, LinkedIn, X (formerly Twitter), YouTube, and Threads), or in other electronic or print forms of media. These images and videos may be retained in perpetuity as historical and archival records of Winscale. Winscale will use such images and videos in accordance with this Policy. If you are pictured and would like us to discontinue using a photo or video, please contact us at privacy@winscale.ai.
How We Use Your Personal Data
We may use your personal data for the following purposes:
Services and Engagement: To operate and manage the Services, track customer interaction history, and oversee the allocation of promotional programs; to enhance and support initiatives related to customer recognition, corporate events, and other engagement opportunities; and/or to maintain relationships with customers, organize Winscale-sponsored events, facilitate incentive programs, and foster ongoing engagement with the broader business and professional community.
Financial Transactions: To process financial transactions via our third party payment processors.
Regulatory Compliance and Documentation: To assist with the preparation of necessary documentation and adherence to applicable regulations.
Communication and Outreach: To send important updates and notices, respond to inquiries, and maintain an ongoing connection with customers, supporters, and community partners.
Winscale Research and Program Improvement: To conduct internal analyses for the improvement of Winscale products, programs, operations, and services.
Legal Compliance and Obligations: To fulfill legal obligations and comply with applicable laws and regulations.
Security and Data Protection: To maintain Winscale data security and customer privacy, including necessary notifications.
Marketing and Awareness Campaigns: To provide information about Winscale products, programs, services, and events.
Additional Services and Benefits: To provide other customer support services.
Any email address you provide may be used to send you information, respond to inquiries, and/or other requests or questions. We may also use your personal data to contact you about products or services that may be of interest to you. If you do not want us to use your personal data in this way, please contact us at privacy@winscale.ai.
Sharing and Disclosure of Your Personal Data
We may share user personal data with third parties for purposes related to our business activities.
Third Party Service Providers
We engage trusted third party service providers to assist us in various operational aspects:
Payment processing and management
Communication and technical services
Data analysis to improve our Services and customer outreach strategies
IT and cloud service providers
These providers are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them.
Additional Personal Data Disclosures
We disclose the following categories of personal data:
Category of Personal Data
Third Party
Personal Identifiers
Affiliates and third party suppliers and service providers, including without limitation, marketing and advertising services, transactional support, and technical services.
Demographic Information
Affiliates and third party suppliers and service providers, including without limitation, marketing and advertising services, transactional support, and technical services.
Internet/Network Information
Affiliates and third party service providers, including without limitation, marketing and advertising services, payment services, transactional support, and technical services.
Audio/Video
Affiliates and providers of technical services.
We may also disclose your personal data to fulfill the purpose for which you provide it and for any other purpose disclosed by us when you provide the personal data.
We may also disclose your personal data to legal, financial, insurance and other advisors in connection with corporate transactions, the management of our organization and operations, to defend against legal claims; to investigate, prevent, or act against illegal activities, suspected fraud, situations involving potential threats to safety, or violations of our terms of use; to protect our operations, assets, and intellectual property; to allow us to pursue appropriate legal remedies or limit damages; to pursue any reorganization, merger, sale, joint venture, assignment, transfer of assets, or other disposition of all or any portion of our organization, assets, or stock; or as otherwise required by law or pursuant to a lawful order.
Your Choices Regarding the Use and Disclosure of Your Personal Data
We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your personal data:
Tracking Technologies and Advertising
You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.
We do not control third parties’ collection or use of your personal data to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your personal data collected or used in this way. For example, you can use Google ad settings (https://www.google.com/settings/ads) to manage the Google ads you see and turn off personalized ads. You can also opt-out using Meta’s opt-out tools at https://www.facebook.com/settings/?tab=ads. However, even if you turn off personalized ads, you may still see ads based on factors such as your general location derived from your IP address, your browser type, and your search term.
Other websites where you see our ads, such as Facebook, may use interest preferences that you have chosen on those sites, as well as registration and other information about you, to choose which ads to display to you. Some Internet browsers, websites such as Facebook and mobile devices offer opt-outs for interest-based advertising. Please refer to the website that you are visiting, your browser and/or your device settings for additional information.
You can also opt-out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
We may send you promotional or marketing emails. You can unsubscribe to these emails at any time by selecting the “unsubscribe” link at the end of all our marketing and promotional emails or by updating your communications preferences by removing yourself from our mailing lists or by contacting us.
Targeted Advertising & Profiling Disclosure and Opt‑Out
We engage in processing your personal data for targeted advertising (e.g., delivering ads tailored to your interests based on your online behavior over time). You may opt out of this processing by contacting us at privacy@winscale.ai or by otherwise following the instructions in this Your Choices Regarding the Use and Disclosure of Your Personal Data section.
Accessing, Updating, and Correcting Your Personal Data
You can review and change your personal data by contacting us at privacy@winscale.ai.
Personal Data Retention Practices
We will retain your personal data where we have lawful legitimate need to do so. For example, we will retain your personal data to provide you the Services or comply with applicable legal, tax or accounting requirements. Additionally, we cannot delete personal data when it is needed for the establishment, exercise or defense of legal claims (also known as a “litigation hold”). In this case, the personal data must be retained as long as needed for exercising or defending against respective potential legal claims. We will delete your personal data promptly once those retention requirements expire.
“Do Not Track” Requests
Your Internet browser and mobile device may allow you to adjust your browser settings so that “do not track” (DNT) requests are sent to the websites you visit. Our Website does not currently respond to DNT signals due to the absence of an industry-standard protocol. For more information on DNT settings generally, please visit https://allaboutdnt.com.
Safeguarding Your Personal Data
We implement and maintain reasonable safeguards designed to protect the security, confidentiality, and integrity of personal data—including protection during disposal. These measures include policies that aim to limit access to your personal data to the fewest number of individuals who need that personal data for operational and strategic purposes. Firewalls, intrusion detection and prevention, log monitoring, data encryption, and other technical measures are used to safeguard your personal data from unauthorized access.
The safety and security of your personal data also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website or the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of personal data via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
Third Party Websites and External Links
Our Website may contain links to the websites of third parties. We are not responsible for the content, or the privacy practices employed by those other websites. A link to another website does not constitute an endorsement of that website or any of the content or information provided by that website. We encourage our visitors and users to be aware when they leave our Website and to read the privacy policies of each website they visit.
International Personal Data Transfers
Your personal data may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide your personal data to us, we may transfer your personal data to the United States and process it there. Where we transfer your personal data, we will take all reasonable steps to ensure that your privacy rights continue to be protected.
Whenever we transfer personal data beyond the country of origin, we will do so in accordance with applicable laws, including where required, pursuant to a valid data transfer mechanism.
How to Contact Us for Privacy Inquiries
To ask questions or comment about your privacy rights, our Policy, and our privacy practices, or to exercise your rights hereunder, please contact us at the information provided in our About Us and How to Reach Our Privacy Team section of this Policy, as set forth above.