Last Updated: 11/2020

Privacy Policy

Tradewinds Distributing Company, LLC collects some Personal Data from its Users.

Data Controller and Owner

Tradewinds Distributing Company, LLC - 10300 NW 19th St #105, Doral, FL 33172 (USA), info@twclimate.com

Types of Data collected

Among the types of Personal Data that Tradewinds Distributing Company, LLC collects, by itself or through third parties, there are: First Name, Last Name, Phone Number, Address, Email, Password, Company Name, Country, State, ZIP/Postal code, City, Cookie, Usage data and Geographic position.

Other Personal Data collected may be described in other sections of this privacy policy or by dedicated explanation text contextually with the Data collection. The Personal Data may be freely provided by the User or collected automatically when using Gemaire.com.

Any use of Cookies - or of other tracking tools - by Tradewinds Distributing Company, LLC or by the owners of third party services used by Tradewinds Distributing Company, LLC, unless stated otherwise, serves to identify Users and remember their preferences, for the sole purpose of providing the service required by the User. Failure to provide certain Personal Data may make it impossible for Tradewinds Distributing Company, LLC to provide its services.

The User assumes responsibility for the Personal Data of third parties published or shared through Tradewinds Distributing Company, LLC and declares to have the right to communicate or broadcast them, thus relieving the Data Controller of all responsibility.

Mode and place of processing the Data

Methods of processing

The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner.

Place

The Data is processed at the Data Controller's operating offices and in any other places where the parties involved with the processing are located.

Retention time

The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.

The use of the collected Data

The Data concerning the User is collected to allow the Application to provide its services, as well as for the following purposes: Registration and Authentication, Analytics, Remarketing and Behavioral Targeting, Managing email addresses and sending messages, Infrastructure monitoring, Hosting, Contacting the User, Location-based interactions and handling Payments. The Personal Data used for each purpose is outlined in the specific sections of this document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics on Tradewinds Distributing Company, LLC makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn't allow Google to personally identify an individual or permanently identify a particular device.

The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by Tradewinds Distributing Company, LLC.

The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.

Personal Data collected: Cookie.

Place of processing: USA - Privacy Policy

Contacting the User

Mailing List or Newsletter (Tradewinds Distributing Company, LLC)

By registering to the mailing list or to the newsletter, the User's email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Tradewinds Distributing Company, LLC. Each Newsletter sent will contain a link to remove your email address (opt-out) from the mailing list.

Personal Data collected: Email.

Transactional and Direct Response Emails

Tradewinds Distributing Company, LLC values your right to privacy. Tradewinds Distributing Company, LLC does not sell or share your contact information with unrelated third parties. The emails Tradewinds Distributing Company, LLC send may be related to a variety of issues, including: A Direct Response to an inquiry, Communication concerning an order (receipt, shipping confirmation, etc), or Promotional emails you have indicated you wish to receive. And from time to time, we may notify you of special offers based on your purchasing history. You may unsubscribe at any time by following the simple instructions contained in these emails. Transactional emails generated as part of the registration or purchasing process on Gemaire.com are excluded from the opt-out policies as these emails assist with authentication and security of being a User of Gemaire.com.

These services have the purpose of hosting data and files that enable the Application to run and be distributed. Some of these services work through servers geographically distributed, making difficult to determine the actual location where the Personal Data are

Managing email addresses and sending messages

These services make it possible to manage a database of email contacts to communicate with the User via email.

The services are used to collect data concerning the date and time when the mail is viewed by the User, as well as when the User interacts with incoming mail, such as by clicking on links included in the email.

Personal Data collected: Email.

Place of processing: USA - Privacy Policy

Registration and authentication

By registering or authenticating, Users allow Tradewinds Distributing Company, LLC to identify them and give them access to dedicated services.

Depending on what is described below, third parties may provide registration and authentication services.

In this case, Tradewinds Distributing Company, LLC will be able to access some Data, stored by these third party services, for registration or identification purposes.

Direct registration (Tradewinds Distributing Company, LLC)

The User registers by filling out the registration form and providing the Personal Data directly to Tradewinds Distributing Company, LLC.

Personal Data collected: Address, City, Company Name, Country, Email, First Name, Last Name, Password, Phone Number, State and ZIP/Postal code.

Remarketing and Behavioral Targeting

These services allow Tradewinds Distributing Company, LLC and its partners to inform, optimize and serve advertising based on past use of Tradewinds Distributing Company, LLC by the User.

This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.

 

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of Tradewinds Distributing Company, LLC or the related services.

The User is aware of the fact that the Data Controller may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, Tradewinds Distributing Company, LLC may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

System Logs and Maintenance

For operation and maintenance purposes, Tradewinds Distributing Company, LLC and any third party services may collect files that record interaction with Tradewinds Distributing Company, LLC (System Logs) or use for this purpose other Personal Data (such as IP Address).

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

The rights of Users

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

Tradewinds Distributing Company, LLC does not support "Do Not Track" requests. To determine whether any of the third party services it uses honor the "Do Not Track" requests, please read their privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using Tradewinds Distributing Company, LLC and can request that the Data Controller erase the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

Definitions and legal references

Personal Data (or Data)

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

Usage Data

Information collected automatically from Tradewinds Distributing Company, LLC (or third party services employed in Tradewinds Distributing Company, LLC), which can include: the IP addresses or domain names of the computers utilized by the Users who use Tradewinds Distributing Company, LLC, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using Tradewinds Distributing Company, LLC , which must coincide with or be authorized by the Data Subject, to whom the Personal Data refer.

Data Subject

The legal or natural person to whom the Personal Data refers to.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.

Data Controller (or Owner)

The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of Tradewinds Distributing Company, LLC . The Data Controller, unless otherwise specified, is the Owner of Tradewinds Distributing Company, LLC .

Tradewinds Distributing Company, LLC

The hardware or software tool by which the Personal Data of the User is collected.

Cookie

Small piece of data stored in the User's device.

Legal information

Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.

This privacy policy relates solely to Tradewinds Distributing Company, LLC.