Privacy Policy

Effective date: [launch date]
Last updated: [launch date]

This Privacy Policy describes how Wanta Thome PLC collects, uses and discloses your information when you use our website, and the privacy rights available to you.

By using the website, you agree to the collection and use of information in accordance with this Privacy Policy.

1. Interpretation and definitions

Interpretation

Capitalized words have the meanings set out below. These definitions apply whether they appear in singular or plural form.

Definitions

You means the individual accessing or using the Service, or the entity on whose behalf that individual is acting. Under GDPR, you may be referred to as the Data Subject or the User.

Company (also “We”, “Us”, “Our”) refers to Wanta Thome PLC, located at 100 S 5th St Ste 1200, Minneapolis, MN 55402. For GDPR purposes, the Company is the Data Controller.

Affiliate means an entity that controls, is controlled by, or is under common control with a party, where control means ownership of 50% or more of the shares, equity interest or other voting securities.

Website refers to Wanta Thome PLC, accessible at https://www.wantathome.com

Service refers to the Website.

Country refers to: United States.

Service Provider means any natural or legal person who processes data on our behalf — third-party companies or individuals we engage to facilitate the Service, perform services related to it, or help us analyze how it is used. Under GDPR, Service Providers are Data Processors.

Facebook Fan Page is the public profile named Wanta Thome PLC at https://www.facebook.com/wantathomeplc

Personal Data is any information relating to an identified or identifiable individual. Under GDPR, this includes a name, identification number, location data, online identifier, or factors specific to physical, physiological, genetic, mental, economic, cultural or social identity. Under the CCPA, it means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked to you.

Cookies are small files placed on your computer, mobile device or other device by a website, recording details of your browsing activity on that site among other uses.

Device means any device able to access the Service, including a computer, cellphone or tablet.

Usage Data refers to data collected automatically, generated either by use of the Service or by the Service infrastructure itself — for example, the duration of a page visit.

Data Controller, under GDPR, refers to the Company as the legal person that alone or jointly determines the purposes and means of processing Personal Data.

Business, under the CCPA, refers to the Company as the entity that collects consumers’ personal information and determines the purposes and means of processing it.

Consumer, under the CCPA, means a natural person who is a California resident.

Sale, under the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating a consumer’s personal information to a third party for monetary or other valuable consideration.

2. Data we collect

Personal Data

When you contact us through the website, we may ask you to provide information that can be used to contact or identify you:

• Email address
• First and last name
• Phone number, including mobile number
• Information you choose to include when describing your situation in a contact or intake form
• Usage Data

Information you submit through an intake or contact form may describe your employment, your employer, and the events that led you to contact us. Provide only what you are comfortable sharing. Submitting a form does not create an attorney-client relationship.

Usage Data

Usage Data is collected automatically. It may include your device’s IP address, browser type and version, the pages of the Service you visit, the time and date of your visit, time spent on those pages, unique device identifiers, and other diagnostic data.

When you access the Service through a mobile device, we may automatically collect the device type, its unique ID, its IP address, the mobile operating system, the mobile browser type, and other diagnostic data. We may also collect information your browser sends whenever you visit the Service.

3. Cookies and tracking technologies

We use cookies and similar technologies — including beacons, tags and scripts — to track activity on the Service, store certain information, and analyze how the Service is used.

Cookies. A cookie is a small file placed on your device. You can set your browser to refuse all cookies or to notify you when one is sent. If you refuse cookies, some parts of the Service may not work.

Web beacons. Some sections of the Service and some of our emails contain small electronic files — also called clear gifs, pixel tags or single-pixel gifs — that let us count users who visited a page or opened an email, and gather related statistics.

Cookies are either persistent or session cookies. Persistent cookies remain on your device when you go offline; session cookies are deleted when you close your browser.

HubSpot, our website and CRM platform, sets cookies in the necessary, functionality and analytics categories, including __hstc, hubspotutk, __hssc and __hssrc. These identify your browser across visits so we can attribute a form submission to the pages that preceded it.

CallRail, our call-tracking provider, sets a persistent first-party cookie that stores the source of your visit. We use it to show a tracking phone number on the website and to record which visit produced a call. The cookie lasts up to six months, or until you clear your cookies, and is extended when you return.

You can manage your cookie choices through the consent banner on the website or through your browser settings. Changing browsers or clearing cookies resets your choices.

4. How we use, share and retain your data

Use of your Personal Data

We may use Personal Data to:

• Provide and maintain the Service, including monitoring its usage
• Respond to your inquiry and evaluate whether we may be able to help with your matter
• Contact you by email, phone call, text message or other electronic communication about your inquiry or about updates to the Service
• Send you news and general information about services and events similar to those you have inquired about, unless you have opted out
• Deliver advertising tailored to your interests or location, and measure its effectiveness
• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other transfer of some or all of our assets, where Personal Data is among the assets transferred
• Analyze data, identify usage trends, assess the effectiveness of our campaigns, attribute phone calls to the visits that produced them, and improve the Service

Sharing

We may share your personal information:

• With Service Providers, to host the Service, manage our CRM, monitor and analyze usage, attribute phone calls to the visits that produced them, advertise to you on third-party sites, and contact you
• For business transfers, in connection with or during negotiation of any merger, sale of assets, financing or acquisition
• With Affiliates, who are required to honor this Privacy Policy
• With business partners, to offer you certain services
• With your consent, for any other purpose

We do not share the mobile phone numbers or SMS consent information described in Section 6 with third parties for their own marketing purposes.

Retention

We retain Personal Data only as long as necessary for the purposes set out in this Privacy Policy, and to comply with our legal obligations, resolve disputes and enforce our agreements and policies. Usage Data is generally retained for a shorter period, except where it is used to strengthen security, improve the Service, or where we are legally obligated to retain it longer.

Transfer

Your information is processed at our offices and wherever the parties involved in processing are located. It may be transferred to and maintained on computers outside your state, province or country, where data protection laws may differ. Your submission of information represents your agreement to that transfer. We will take all steps reasonably necessary to ensure your data is treated securely and in accordance with this Privacy Policy.

Disclosure

Business transactions. If we are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will give notice before your Personal Data is transferred and becomes subject to a different privacy policy.

Law enforcement. We may be required to disclose your Personal Data if required by law or in response to valid requests by public authorities, such as a court or government agency.

Other legal requirements. We may disclose your Personal Data in the good-faith belief that it is necessary to comply with a legal obligation, protect our rights or property, investigate possible wrongdoing in connection with the Service, protect the personal safety of users or the public, or protect against legal liability.

Security

No method of transmission over the internet or of electronic storage is completely secure. We use commercially acceptable means to protect your Personal Data, but cannot guarantee its absolute security.

5. Analytics, call tracking, advertising and session replay

The Service Providers we use may have access to your Personal Data. They collect, store, use, process and transfer information about your activity on the Service in accordance with their own privacy policies.

Website and CRM platform

HubSpot. Our website, forms and customer relationship management system run on HubSpot. HubSpot hosts the Service, processes contact and intake form submissions, stores the resulting records, and sets the cookies described in Section 3. Information you submit through a form on this website is stored in HubSpot. See https://legal.hubspot.com/privacy-policy

Analytics

Google Analytics 4. A web analytics service offered by Google that tracks and reports website traffic. Google uses the collected data to track and monitor use of the Service, and may use it to contextualize and personalize advertising across its network. You can opt out by installing the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout, which prevents the Google Analytics tag from sharing information about your visit. For more on Google’s privacy practices, see https://policies.google.com/privacy

Call tracking

CallRail. We use CallRail to attribute phone calls to the visit that produced them. CallRail’s script may replace the phone number shown on the website with a tracking number, and it sets the cookie described in Section 3 so the same number is shown if you return. When you call that number, CallRail records the call together with the visit that led to it, including the caller’s phone number and, when available, the name shown on caller ID. See https://www.callrail.com/privacy

Session replay

Microsoft Clarity. We use Microsoft Clarity to understand how visitors interact with the website through behavioral metrics, heatmaps and session replay. This records page interactions such as mouse movement, scrolling, clicks and keystrokes in order to reconstruct a visit. Clarity is configured to mask text entered into form fields; we do not use it to capture the content of what you type into a contact or intake form. Website usage data is captured using first- and third-party cookies and other tracking technologies. We use this information for site optimization, fraud and security purposes, and advertising. See the Microsoft Privacy Statement at https://privacy.microsoft.com/en-us/PrivacyStatement

Behavioral remarketing

We use remarketing services to advertise to you after you have visited the Service. We and our third-party vendors use cookies and non-cookie technologies to recognize your device and understand how you use the Service, so we can serve advertisements likely to be of more interest to you. This allows us to:

• Measure and analyze traffic and browsing activity on the Service
• Show advertisements for our services on third-party websites and apps
• Measure and analyze the performance of our advertising campaigns

Some vendors use non-cookie technologies that may not be affected by browser settings that block cookies, and your browser may not permit you to block them. We may share hashed email addresses or other online identifiers with these vendors so they can recognize and deliver advertisements to you across devices and browsers.

Meta (Facebook). See https://www.facebook.com/about/ads and https://www.facebook.com/privacy/policy

Microsoft Advertising. See https://about.ads.microsoft.com/en/resources/policies/personalized-ads and https://privacy.microsoft.com/en-us/PrivacyStatement

You can decline the collection and use of information for interest-based advertising through:

• The NAI opt-out platform: https://optout.networkadvertising.org/
• The DAA opt-out platform: https://optout.aboutads.info/
• The EDAA opt-out platform: https://www.youronlinechoices.com/

You may also opt out of personalized advertising by enabling privacy features on your mobile device, such as Limit Ad Tracking on iOS or Opt Out of Ads Personalization on Android.

6. Text messaging (SMS)

If you provide your mobile number and consent to receive text messages, we may contact you by SMS about your inquiry, your matter, or appointment scheduling.

We do not sell, rent or share mobile phone numbers or SMS consent information with third parties or affiliates for their marketing purposes. Mobile opt-in data is excluded from every sharing and sale category described elsewhere in this Privacy Policy. This information is shared only with the service providers that deliver the messages on our behalf, and only for that purpose.

Consent to receive text messages is not a condition of any service or of our evaluation of your matter.

Message frequency varies. Message and data rates may apply. Reply STOP to any message to opt out. Reply HELP for assistance, or call (612) 252-3570.

Text messages are not a secure channel. Do not send sensitive details about your situation by text.

7. GDPR

Legal basis for processing

We may process Personal Data on the following bases:

• Consent — you have given consent for one or more specific purposes
• Performance of a contract — processing is necessary to perform an agreement with you or to take pre-contractual steps
• Legal obligations — processing is necessary to comply with a legal obligation
• Vital interests — processing is necessary to protect your vital interests or those of another person
• Public interests — processing relates to a task carried out in the public interest
• Legitimate interests — processing is necessary for our legitimate interests

We will clarify the specific legal basis that applies on request, including whether providing Personal Data is a statutory or contractual requirement.

Your rights under the GDPR

If you are within the EU, you have the right to:

• Request access to your Personal Data, and receive a copy of what we hold
• Request correction of incomplete or inaccurate information
• Object to processing where we rely on legitimate interests, or where we process for direct marketing
• Request erasure where there is no good reason for us to continue processing
• Request transfer of your Personal Data in a structured, commonly used, machine-readable format
• Withdraw consent at any time

Exercise these rights by contacting us using the details in Section 10. We may ask you to verify your identity before responding.

You also have the right to complain to a Data Protection Authority. If you are in the European Economic Area, contact your local data protection authority.

Facebook Fan Page

We operate a public Facebook page at https://www.facebook.com/wantathomeplc. For that page, we and Facebook act as joint controllers under terms largely based on the Facebook Terms of Service at https://www.facebook.com/terms.php

We use the Facebook Insights function to obtain anonymized statistical data about visitors to that page. For this purpose, Facebook places a cookie on the device of each visitor. Each cookie contains a unique identifier and remains active for two years unless deleted earlier. Facebook receives, records and processes the information stored in that cookie.

For more on how Facebook handles Personal Data, see https://www.facebook.com/privacy/policy or contact Facebook at Meta Platforms, Inc., ATTN: Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, United States.

8. California privacy rights (CCPA)

This section supplements the rest of this Privacy Policy and applies only to California residents.

Categories of personal information collected

The categories below are those defined in the CCPA. Listing a category does not mean every example within it was collected.

Under the CCPA, personal information does not include publicly available government records, deidentified or aggregated information, or information excluded from the CCPA’s scope such as data covered by HIPAA, the CMIA, FCRA, GLBA or the Driver’s Privacy Protection Act.

Sources

We obtain personal information directly from you (forms you complete), indirectly from you (observing your activity on the Service), automatically (cookies set as you navigate), and from Service Providers.

Use for business or commercial purposes

We may use or disclose personal information to operate the Service, respond to your inquiries, fulfill the reason you provided the information, respond to law enforcement requests and legal obligations, perform internal administration and auditing, and detect and protect against malicious, deceptive, fraudulent or illegal activity.

Disclosure for business or commercial purposes

In the last twelve months we may have disclosed Categories A, B and F for business or commercial purposes. When we disclose personal information for a business purpose, we enter a contract requiring the recipient to keep it confidential and use it only to perform that contract.

Sale and sharing

The advertising and analytics technologies described in Section 5 may constitute a “sale” or “sharing” of personal information under California law, even where no money changes hands. On that basis, we disclose that in the last twelve months we may have sold or shared the following categories:

• Category A: Identifiers
• Category F: Internet or other similar network activity

We do not sell or share the contents of contact or intake form submissions, and we do not sell or share mobile phone numbers or SMS consent information. Those are disclosed only to the Service Providers that help us operate the Service, and only for that purpose.

Your right to opt out of sale or sharing

You may direct us not to sell or share your personal information. Use the Do Not Sell or Share My Personal Information link in the website footer, which opens an email to hello@wantathome.com, or contact us using the details in Section 10. Include the browser and device you want the request applied to, so we can confirm it took effect.

Global Privacy Control

We honor opt-out preference signals, including Global Privacy Control, transmitted by your browser or extension. Because the signal is stored per browser, you will need to send it from each browser and device you use.

Minors under 16

We do not sell or share the personal information of consumers we actually know are under 16, unless we receive affirmative authorization from a consumer between 13 and 16, or from the parent or guardian of a consumer under 13.

Your other CCPA rights

• Right to notice — to be told which categories of personal information are collected and why
• Right to request — to have us disclose the categories collected, the sources, our purposes, the third parties we share with, and the specific pieces of personal information we hold
• Right to opt out of sale or sharing
• Right to delete, subject to exceptions including completing a transaction, detecting security incidents, debugging, exercising free speech, complying with the California Electronic Communications Privacy Act, conducting public-interest research, enabling internal uses aligned with your expectations, and complying with legal obligations
• Right against discrimination — we will not deny you services, charge different rates, or provide a different level of service for exercising your rights

Exercising your CCPA rights

Contact us by email at hello@wantathome.com or by phone at (612) 252-3570.

Only you, or a person registered with the California Secretary of State whom you authorize, may make a verifiable request. Your request must provide enough information for us to reasonably verify you are the person about whom we collected personal information, and describe the request in enough detail for us to evaluate it. We cannot respond if we cannot verify your identity or confirm that the information relates to you.

We will respond within 45 days of receiving a verifiable request. That period may be extended once by a further 45 days where reasonably necessary, with prior notice. Disclosures cover the twelve-month period preceding receipt of the request. For portability requests, we will provide the information in a readily usable format.

Do Not Track

The Service does not respond to Do Not Track signals. You can enable or disable DNT in your browser’s settings. Separately, we do honor Global Privacy Control signals as described above.

Shine the Light

Under California Civil Code § 1798.83, California residents with an established business relationship with us may request information once a year about our sharing of their Personal Data with third parties for those third parties’ direct marketing purposes. Contact us using the details in Section 10.

Removal of content posted by minors

Under California Business and Professions Code § 22581, California residents under 18 who are registered users of online services may request removal of content they have publicly posted. Contact us using the details in Section 10. A request does not guarantee complete removal, and the law may not require removal in all circumstances.

9. Children’s privacy

The Service is not directed to children under 13, and we do not knowingly collect Personal Data from them. If you believe a child under 13 has provided us with Personal Data, contact us with enough detail for us to locate and delete it.

10. Links, changes and contact

Links to other websites

The Service may contain links to websites we do not operate. We have no control over, and assume no responsibility for, the content, privacy policies or practices of any third-party site. Review the privacy policy of every site you visit.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will post the new policy on this page and update the “Last updated” date at the top. Where the change is material, we will give notice by email or by a prominent notice on the Service before it takes effect. Changes are effective when posted.

Contact us

Email: hello@wantathome.com
Phone: (612) 252-3570

Wanta Thome PLC
100 S 5th St Ste 1200
Minneapolis, MN 55402