Privacy Policy

PRIVACY POLICY

WGI, LLC, (The “Wheel”, “we” or “us”), developer and the operator of thewheel.com, is committed to preserving the privacy of those who visit the Site and who use our services to purchase the products displayed on the Site (“Services”). This document will outline how we gather and utilize various sources of information obtained during your visit to the Site and use of our Services. This Privacy Policy applies to personal information collected on the Site and is made a part of and incorporated into the Terms of Use.

This Privacy Policy communicates how, when, and why we gather information about our customers and what we do with such information. THIS PRIVACY POLICY DOES NOT APPLY TO OTHER WEBSITES TO WHICH WE LINK. YOU AGREE THAT YOUR USE OF THE SITE SIGNIFIES YOUR ASSENT TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU ARE NOT AUTHORIZED TO USE THIS SITE.

Residents of the European Economic Area (“EEA”), which includes the member states of the European Union (“EU”), residents of the United Kingdom (“UK”) and residents of Switzerland, should consult the sections of this policy relating to the “Rights of EEA, UK and Swiss Residents” and “International Data Transfers” for provisions that may apply to them.

California residents should consult the section titled “Your California Privacy Rights” for rights that apply to them.

INFORMATION COLLECTED.

Personal Information. If you create an account on the Site, as defined in the Terms of Use we will ask you for your name, e-mail address, shipping address, telephone number and credit card or payment information or certain other information that may be used to directly or indirectly identify you ("Personal Information"). We use this information to process and fulfill your order and to notify you of your order status. All archived credit card information is maintained in a secure and safe environment. Telephone numbers and e-mail addresses are used to contact you regarding your order. In addition, when you respond to a contest, survey, questionnaire, sweepstakes or other promotional feature, we may ask you for your name, address and email address or other Personal Information. We do not collect any Personal Information about you unless it is voluntarily provided by you. The Wheel will never sell, rent or share your Personal Information with any third parties for marketing purposes without your express permission except as noted below.

Non-Personally Identifiable Information. We may also collect non-personally identifiable information, such as IP host address, pages viewed, browser type, duration and frequency of visits, and other data, and may aggregate any information collected in a manner which does not identify any individual ("Aggregate Information"). Aggregate Information and Personal Information obtained in connection with the Site may be intermingled with and used by us in conjunction with information obtained through sources other than the Site, including both offline and online sources.

HOW WE USE YOUR INFORMATION.

Disclosure. We will not share or disclose your Personal Information to anyone except as described in this Privacy Policy.

ENHANCED AND PERSONALIZED SHOPPING EXPERIENCE.

We use Personal Information in order to give you a more enjoyable and convenient shopping experience and to help us identify and/or provide information, products or services that may be of interest to you. We use your Personal Information to support and enhance your use of the Site, and its features, including without limitation: fulfilling your order; providing customer service; tracking email invitations you send; and otherwise supporting your use of the Site. We may also track your past purchases to provide you with a personalized profile of your shopping history. In addition, we may notify you about new services or special promotional programs, or send you offers or information. Third parties may be permitted to access your Personal Information, but only in connection with their performance of services to maintain and operate the Site, and certain features on the Site, unless as otherwise provided in this Privacy Policy or agreed to by you. For example, we may use third parties to host the Site, operate various features available on the Site, send emails, analyze data, provide search results and links, and assist in fulfilling your orders.

AFFILIATES; CONSULTANTS; THIRD PARTIES.

Unless you specifically consent to the disclosure of your Personal Information or as otherwise provided for in this Privacy Policy, only we, our affiliates, technical consultants, third party auditors, payment processors, delivery services, warehousing services, and other third parties who develop, maintain, service, or otherwise operate the Site (collectively, “Affiliates”), shall have access to your Personal Information. Such Affiliates are bound by this Privacy Policy.

BUSINESS PARTNERS

We may offer products of our business partners on the Site.  For example, as part of our Services we may offer products of selected businesses that offer products that are subject to particular laws and regulations, such as tobacco or alcohol products.  Your purchase of such products is subject to specific provisions of our Terms of Use.  In conjunction with the sales of such products we may provide Personal Information to such business partners, such as your name, address, e-mail address and payment information necessary for them to process your orders for such products.  The processing of such orders by business partners may also be subject to our business partners’ terms and conditions.  Our business partners will not retain your payment information but may contact you for marketing communications.  

LAW ENFORCEMENT AND INVESTIGATIONS.

The Wheel reserves the right to and may disclose Personal Information about you in response to (a) requests from local, state or federal law enforcement officials; (b) any judicial, administrative or similar proceeding or order, such as subpoena; (c) if required by law; or (d) to investigate suspected fraud, harassment, physical threats, or other violations of any law, rule or regulation, the Site’ Term of Use, rules or policies, or the rights of third parties or to investigate any suspected conduct which is alleged to be improper.

CHANGE OF CONTROL.

We reserve the right to transfer your Personal Information and other information as an asset in connection with a proposed or actual merger or sale (including any transfers made as part of an insolvency or bankruptcy proceeding) involving all or part of our business or as part of a corporate reorganization, stock sale or other change in control. In such a circumstance the transferee would be bound by the terms of this Privacy Policy.

SWEEPSTAKES.

If you make a purchase on thewheel.com, or otherwise submit your email address to be added to a mailing list or Sweepstakes or other promotion, we will use the email address for the sole purpose of sending you announcements, special offers from The Wheel and its promotional partners. Each email we send will contain information on how to unsubscribe from our mailing list. You can also unsubscribe by sending an email to [email protected]

USE OF COOKIES.

Our Site may pass a "cookie" (a string of information that is sent by a web site to be resident on your system's hard drive, and/or temporarily in your computer's memory blocks). The purpose of a cookie is to tell the web server that you have returned to a particular page. The Site may use cookies in on-line catalogs to keep track of your status and contents of your shopping cart, the site may use cookies to determine when purchases are not complete and send communication (email or SMS) reminders. Cookies are also used to retain customer information which allow you access to password-protected areas of the Site. You may set your browser to decline cookies. If you do so, however, you may not be able to fully experience some interactive features of the Site.

PIXEL TAGS OR BEACONS.

In addition to cookies, we also collect Aggregate Information through the use of "tracking pixels," also known as "beacons." A tracking pixel is a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page and, in combination with a cookie, allows for the collection of information regarding the use of the web page that contains the tracking pixel. We use tracking pixels to tell when an advertisement has been clicked on or otherwise interacted with, and use that information to judge which advertisements are more appealing to users. In some cases, we use third party service providers to help us collect and analyze this information. You can also generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance's Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website.

HOW WE PROTECT YOUR INFORMATION.

We are committed to protecting your Personal Information and Aggregate Information. However, The Wheel is not liable for disclosures of your Personal Information due to errors in transmission or unauthorized acts of third parties. We have undertaken commercially reasonable efforts to prevent unauthorized Internet access to visitor data retained in our servers, however, due to the inherent open nature of the Internet, The Wheel cannot ensure or warrant the security of any information you transmit to us or any information provided online, and you do so at your own risk. Users of the Site accept all risks associated with any data transmission, including the risk that their Personal Information may be intercepted in transit. The Site encrypts your credit card number and other Personal Information using secure socket layer (SSL) technology to provide for the secure transmission of the information from your computer or device to our servers. Only those The Wheel employees and third parties who need access to your information in order to perform their duties are allowed such access.

ACCESSING AND UPDATING YOUR PERSONAL INFORMATION AND PREFERENCES.

If you register or otherwise create an account on the Site, as defined in the Terms of Use, you may access and update your registration information, Personal Information, and your preferences to receive email or other communications from us by sending an email to [email protected]. We will take commercially reasonable steps to implement your opt-out requests promptly, but you may still receive communications from us for up to ten business days as we process your request. While we make efforts to accommodate requests to restrict our use of your information, we reserve the right to delete all or any portion of customer information if we are not able to reasonably accommodate a requested restriction.

CHILDREN'S PRIVACY AND PARENTAL CONTROLS.

These Site and the App are not intended for persons under the age of 13, and we have no intention of collecting or soliciting Personal Information from persons under the age of 13. If you are not 13 or older, you are not authorized to use the Site or the App. Parents should be aware that there are parental control tools available online that you can use to prevent your children from submitting information online without parental permission or from accessing material that is harmful to minors. If a child under age 13 has provided us with Personal Information, we will use all reasonable efforts to delete such information from our database.

LINKS TO THIRD PARTY SITES.

The Site may contain links to other websites, including our affiliated or co-branded websites. Other websites may also reference or link to our Site. These "other" domains (websites) are not controlled by The Wheel. We encourage our users to be aware when they leave our Site to read the privacy policies of each and every website that collects personally identifiable information. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites. Visiting these other web sites is done at your own risk.

SITE TERMS AND CONDITIONS.

Use of this Site is governed by, and subject to, the legal notices contained in our Terms of Use, which are incorporated herein by reference. Your use, or access, of the Site constitutes your agreement to be bound by these Terms of Use. IF YOU DO NOT AGREE TO THESE TERMS YOU MAY NOT ACCESS OR OTHERWISE USE THE SITE.

PRIVACY POLICY CHANGES.

We reserve the right, in our sole and absolute discretion, to change, modify, add, or remove portions from this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post the revised Privacy Policy on the Site so you will know what information we gather, how we might use that information and how it may be disclosed, if at all. Your continued use of the Site constitutes your agreement to the Privacy Policy as posted. Please check this page periodically for changes to this Privacy Policy. If we make any change to this Privacy Policy that we in our sole discretion deem material, we will notify you in a manner we deem appropriate.

RIGHTS OF EEA, UK AND SWISS RESIDENTS

This section of this Privacy Policy is applicable to residents of the European Economic Area (“EEA”).  The EEA consists of the member states of the European Union, i.e., Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and Iceland, Liechtenstein, and Norway.  This section also applies to residents of the United Kingdom (“UK”) and Switzerland.

All processing of Personal Information of EEA Residents is performed by The Wheel in accordance with the General Data Protection Regulation (2016/679) of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of Personal Information and on the free movement of such data (“GDPR”).  We also process the Personal Information of residents UK and Switzerland in accordance with the privacy laws of those countries.

Under these privacy laws, The Wheel is a controller or processor of the Personal Information of residents of the EEA, UK and Switzerland.  The Wheel’s purpose for processing Personal Information is to fulfill a contract for the Services that we offer, responding to inquiries or for providing the Services to residents of the EEA, UK and Switzerland. The legal basis for collecting Personal Information is your consent and fulfilling a contractual obligation.  You may withdraw consent by contacting us at [email protected].

Please note that if you are a resident of the EEA, UK or Switzerland that you have certain rights under applicable privacy laws in regard to your Personal Information.  These rights may include the Right of Access, Right to Rectification, Right to Erasure, Right to Restrict, Right to Object, Right to Data Portability, and Right to not be Subject to Automated Decision Making.  

If you are a resident of the EEA, UK or Switzerland and believe that we have Personal Information about you, and you wish to access or correct the Personal Information that we have about you or exercise any other rights that you may have or have any questions relating to the processing of your Personal Information, please contact us at [email protected].

International Data Transfers

If you are resident outside the United States, including in the EEA, UK and Switzerland we transfer Personal Information provided by you to us for processing in the United States.  Please note that the United States does not have data protection laws equivalent to those in the EEA and other jurisdictions.  

YOUR CALIFORNIA PRIVACY RIGHTS

The following section pertains to the rights of individuals or households in California (“California consumers”).  

Civil Code Section 1798.83

Under certain circumstances, California Civil Code Section 1798.83 states that, upon receipt of a request by a California consumer, a business may be required to provide detailed information regarding how that business has shared that customer’s Personal Information with third parties for direct marking purposes. However, the foregoing does not apply to businesses like ours that do not disclose Personal Information to third parties for direct marketing purposes without prior approval or give customers a free mechanism to opt out of having their Personal Information disclosed to third parties for their direct marketing purposes.

Rights under the CCPA

As of January 1, 2020, the CCPA (California Civil Code Section 1798.100 et seq.) provides California consumers with additional rights regarding Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer or household. The categories of Personal Information we collect are generally described above but differ for individual consumers depending on the Services used by such consumers.

Under the CCPA, qualifying California consumers may have the following rights:

Right to Know and Right to Delete.

A California consumer has the right to request that we disclose what Personal Information we collect, use, disclose and sell. A California consumer also has the right to submit requests to delete Personal Information.

When we receive a request to know or delete from a California consumer, we will confirm receipt of the request within 10 days and provide information about how we will process the request, including our verification process. We will respond to such requests within 45 days.

Right for Disclosure of Information.

A California consumer may also submit requests that we disclose specific types or categories of Personal Information that we collect.

Under certain circumstances, we will not provide such information, including where the disclosure creates a substantial, articulable and unreasonable risk to the security of that Personal Information, customers’ account with us, or the security of our systems or networks. We also will not disclose California consumers’ social security numbers, driver’s license numbers or other government-issued identification numbers, financial account numbers, any health insurance or medical identification numbers, or account passwords and security questions and answers.

Submitting Requests

If you are a California consumer and would like to make any requests under the CCPA, please direct them to: [email protected].  

Verifying Requests

If we receive any request we will use a two-step process for online requests where the California consumer must first, clearly submit the request and then second, separately confirm the request. We will use other appropriate measures to verify requests received by mail or telephone.

In submitting a request, a California consumer must provide sufficient information to identify the consumer, such as name, e-mail address, home or work address, or other such information that is on record with us so that we can match such information to the Personal Information that we maintain. Do not provide social security numbers, driver’s license numbers, account numbers, credit or debit card numbers, medical information or health information with requests. If requests are unclear or submitted through means other than outlined above, we will provide the California consumer with specific directions on how to submit the request or remedy any deficiencies. If we cannot verify the identity of the requestor, we may deny the request.

California Do Not Track Disclosures

Although some browsers currently offer a “do not track (‘DNT’) option,” no common industry standard for DNT exists. We therefore do not currently commit to responding to browsers’ DNT signals.

CONTACT.

If you have any questions about The Wheel Privacy Policy please contact us at: [email protected].

SMS AND AUTO DIALED CALLS.

By filling out a Wheel profile, you expressly request to receive information via telephone call, email and text/SMS message (including through the use of an automatic telephone dialing system or artificial/prerecorded voice, SMS or MMS (text) messages, even if your telephone number(s) is/are currently listed on any state, federal or corporate Do Not Call list). Consent is not a requirement to purchase goods The Wheel offers. Standard text message rates and cellular data charges apply. You may opt-out by replying “stop” to any message you receive.

EMAIL COMMUNICATION.

By filling out The Wheel, including providing any personal information, you opt in to The Wheel occasionally sending you newsletters and emails regarding special offers, promotions, features and/or product updates as well as general marketing emails. We may also communicate with you on behalf of third parties about special offers, promotions, features and/or product updates we think may be of interest to you, or you may have opted-in to receive newsletters or special promotions from one of our trusted third party providers. If you decide you do not wish to receive these communications, you may opt-out by clicking the unsubscribe link or by following the instructions included in the communication. Note, however, that as a user of our Services you cannot opt-out of some administrative communications that are reasonably necessary to the Services, such as billing, or service notifications. You may also opt-out of certain targeted advertising by emailing [email protected].

EFFECTIVE DATE.

This Privacy Policy is effective as of October 13, 2021.