Privacy Page

What are cookies and why we use them?

Cookies are files that are downloaded on your computer or mobile device when you visit certain websites. Cookies allow a website, for instance to identify a user session, recall your preferences (e.g. language), gather information about your browsing habits. We use essential cookies for our legitimate interest in facilitating access to and use of the website, and we make you aware of using advertising, and analytics cookies (non-essential cookies) so we can measure how you interact with the website content. However, you can withdraw your consent at any time. We may send a cookie which may be stored by your browser on your computer’s hard drive. We use this information for the following purposes:

• Assisting you in navigation on the website

• Improve the functionality of the website

• Store login details for our secure sites

• System administration

• Reporting information for research purposes

• Assisting with our promotional and marketing efforts

• Providing you with personalized content, advertising and messages.

We also use clear gifs in HTML-based emails sent to our users to track which emails are opened and clicked on by recipients. We may use the information we obtain from the cookie in the administration of this website, to improve the Site’s usability and for marketing purposes. We may also use that information to recognize your computer when you visit our Site, and to personalize our Site for you. Cookies and information captured through this site is stored for a certain retention period, however you can eliminate these cookies any time before the expiration date.

How to Restrict Cookies

You can adjust the settings in your browser in order to restrict or block cookies that are set by the Services (or any other site on the Internet). Your browser may include information on how to adjust your settings. Alternatively, you may visit www.allaboutcookies.org to obtain comprehensive general information about cookies and how to adjust the cookie settings on various browsers. This site also explains how to delete cookies from your computer. You can control and delete these cookies through your browser settings through the following:

• Google Chrome

• Mozilla Firefox

• Safari

• Opera

• Microsoft Internet Explorer

• Safari for iOS (iPhone and iPad)

• Chrome for Android

• Windows Phone

Or you can also use the following cookie management and disposal tool from Google Analytics by downloading and installing the browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout. Please be aware that restricting cookies may impact the functionality of the Services. Most browsers allow you to refuse to accept cookies. (For example, in Internet Explorer you can refuse all cookies by clicking “Tools”,” “Internet Options”,” “Privacy”,” and selecting “Block all cookies”) This will, however, have a negative impact upon the usability of many websites, including this one.

LINKING SITES

The Site contains links to other sites. Western Winter Workshop is not responsible for the privacy practices or the content of such websites, including any sites that may indicate a special relationship or partnership with us (such as co-branded pages or "powered by" or "in cooperation with" relationships). We do not share information we gather with other websites or any other entities or individuals unless such

sharing is approved in advance by you. Other linked sites, however, may collect personal information from you that is not subject to our control. To ensure protection of your privacy, always review the privacy policy of the sites you may visit by linking from the Site. Please note that this Privacy Policy applies only to our Site, and not to other companies' or organizations' websites to which we link. For instance, information collected through Google Analytics is shared with Google and its partners who may combine it with other information you’ve provided to them or they’ve collected from your use of their services. This information will be stored in Google’s servers in the United States of America according to their privacy practices.

SOCIAL MEDIA

We may collect information from other sources, such as social media platforms that may share information about how you interact with our social media content. We do not control how your personal information is collected, stored or used by such third-party sites or to whom it is disclosed. You should review the privacy policies and settings on any social networking site that you subscribe to so that you understand the information they may be sharing. If you do not want your networking sites to share information about you, you must contact that site and determine whether it gives you the opportunity to opt-out of sharing such information. The Western Winter Workshop is not responsible for how these third-party sites may use information collected from or about you.

SECURITY

The Western Winter Workshop employs security measures utilizing industry-standard technology to protect the loss, misuse or alteration of personal information that you disclose through the Site or through our other means of communicating with you. Personal information is stored in a secured database and always sent via an encrypted Internet channel. Further public disclosure here of our security measures could aid those who might attempt to circumvent those security measures. If you have additional questions regarding security, please feel free to contact us directly at

info@co-pilots.com. To ensure that our employees comply with our privacy policies, we have developed a training program that provides all employees with the tools and knowledge to protect member privacy in all aspects of their work. Any employee who violates our privacy policies is subject to disciplinary action, including possible termination and civil and/or criminal prosecution.

DISCLOSURE OF INFORMATION

The Western Winter Workshop may disclose personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating any agreement with the Western Winter Workshop , or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Site users, or anyone else that could be harmed by such activities. We may disclose information in response to a subpoena, search warrant, in connection with judicial proceedings, or pursuant to court orders, legal process or other law enforcement measures. The Western Winter Workshop may disclose or access personal information when we believe in good faith that the law requires it, to establish our legal rights or to defend against legal claims, and for administrative and other purposes that we deem necessary to maintain, service and improve our products and services.

RESPONSE TO “DO NOT TRACK” SIGNALS

Some Internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for “Do Not Track” signals have not yet been adopted, The Western Winter Workshop does not process or respond to “Do Not Track” signals.

CHILD ONLINE PRIVACY PROTECTION ACT (COPPA) COMPLIANCE AND RELATED INFORMATION

The Child Online Privacy and Protection Act (COPPA) regulates online collection of information from persons under the age of 13. It is our policy to refrain from knowingly collecting or maintaining personally identifiable information relating to any person under the age of 18. If you are under the age of 18, please do not supply any personally identifiable information through the site. If you are under the age of 18 and have already provided personally identifiable information through the site, please have your parent or guardian contact us immediately using at info@co-pilots.com so that we can remove such information from our files.

CHANGES TO THE PRIVACY POLICY

This Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display an effective date on this Privacy Policy at the top of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any material change to this Privacy Policy regarding use or disclosure of personal information, we will provide advance notice on this Site. Changes will apply to information collected after the change is effective. Please check this Privacy Policy periodically for changes. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. Your use of the Site constitutes acceptance of the provisions of this Privacy Policy and your continued usage after such changes are posted constitutes acceptance of each revised Privacy Policy. If you do not agree to the terms of this Privacy Policy or any revised Privacy Policy, please exit the Site immediately. If you have any questions about this Privacy Policy, the practices of the Site, or your dealings with the Site, you can email at  info@co-pilots.com.

INTERNATIONAL PRIVACY INFORMATION

Both the above general Privacy Policy and this European Union and Canada Privacy Policy (the “International Policy”) applies to Canada and EU data subjects except that, for such persons (and only for such persons), where the provisions of the general Privacy Policy and the Canadian and International Policy cannot be construed consistently, the Canadian and International Policy will govern. The Personal Information Protection and Electronic Documents Act (“PIPEDA”) of Canada and the General Data Protection Regulation (“GDPR”) impose requirements regarding the collection, use, and disclosure of personal information in relation to our commercial activities, as does private-sector privacy legislation in their local jurisdictions, provinces and territories. THIS INTERNATIONAL POLICY APPLIES TO ALL PERSONAL INFORMATION ABOUT YOU THAT WE COLLECT, HOLD, USE AND DISCLOSE, REGARDLESS OF THE WAY IN WHICH WE COLLECT IT (I.E. WHETHER THROUGH A SITE OR OTHERWISE).

Personal Information

Under European and Canadian privacy laws (and in this International Policy), personal information is generally any information about an identifiable individual. It may include your name, age, mailing address, residential phone number, or e-mail address, personal history (including financial and credit information, donations, personal health information, billing history, personal family and relationship

matters, and penal or criminal information), personal information related to corporate involvements, work experience (past and present), discipline, income and benefits, medical records, tax records, and security clearances.

Collection of Personal Information

We collect personal information from this Site, as well as through correspondence, faxes, live chats, e-mails, telephone inquiries, web forms, and other means of communication. We collect such information when we provide publication services, digital services, and other lawful purposes. We (and our affiliates and authorized service providers) may collect, store, and use information:

(a) about your visits to and use of this Site.

(b) when you order or agree to purchase or avail yourself of goods or services, as well as in the case of registrations (e.g., user groups, leagues, and other communities);

(c) to provide you with personalized content and advertising.

(d) to provide product information (whether with regard to content, events, products, services or otherwise);

(e) about any transactions carried out between you and us, including information relating to online subscriptions, digital products, surveys and other services.

(f) you provide to us if you correspond with us.

(g) if you create an account with us, we may ask you for your name, age, geo-location and other demographic information, e-mail address, street address or other personal information (You may, however, visit the Site without providing that information);

(h) if you purchase the Western Winter Workshops products and services, we collect billing and credit card information.

(i) anonymous demographic information, which is not unique to you, such as your age and gender.

We also may collect information about your computer and your visits to this Site such as your IP address, geographical location, browser type, domain names, referring website addresses, access times, length of visit and number of page views. We may use this information in the administration of this Site, to improve the Site’s usability, to provide better service, to send you newsletters, updates, marketing communications, and other information or that may be of interest to you. We also use outside services such Google Analytics to gather data about our Site visitors. We may sometimes permit our authorized service providers to have access to aggregate statistics about our customers, sales, traffic patterns, usage and related information. We often collect personal information from you or from third parties and as agents on behalf of third parties, where we have obtained the requisite consent to do so or as otherwise permitted by law. Third parties include, as examples, organizations for whom we provide services to you or on your behalf, and organizations that perform outsourcing and other services for us (such as payment processors, order fulfillment organizations, shipping companies, warranty and other service organizations, and systems development and maintenance organizations). Where we are the Data Controller with regard to that data we will inform data subjects how you can exercise your rights as data subject, including the right to object to the processing of your personal data when it is processed based on legitimate interests.

How We Use Personal Information

As a general matter, we collect your personal information primarily to provide services to our customers, for administrative or management requirements, and to enhance our relationship with customers. The Western Winter Workshop collects and uses your personal information to operate its website(s) and deliver the services you requested. The Western Winter Workshop may also use your personal information to inform you of other products or services available from The Western Winter Workshop

and its affiliates. The Western Winter Workshop may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered. The Western Winter Workshop does not sell, rent or lease its customer lists to third parties.  The Western Winter Workshop may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personal information (e-mail, name, address, telephone number) is not transferred to the third party. The Western Winter Workshop may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide services to you, and they are required to maintain the confidentiality of your information. The Western Winter Workshop may keep track of the websites and pages our users visit within The Western Winter Workshop, to determine what The Western Winter Workshop services are the most popular. This data is used to deliver customized content and advertising within The Western Winter Workshop to customers whose behavior indicates that they are interested in a particular subject area. The Western Winter Workshop will disclose your personal information, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on The Western Winter Workshop or the site; (b) protect and defend the rights or property of The Western Winter Workshop; and, (c) act under exigent circumstances to protect the personal safety of users of The Western Winter Workshop, or the public. We may share your personal information with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of The Western Winter Workshop’s business or assets to such business entity (including due to a sale in connection with a bankruptcy). We will require any such purchaser, assignee or other successor business entity to honor the terms of this privacy statement. We rely on the following legal grounds to process your personal information, namely:

• Performance of a contract – We may need to collect and use your personal information to enter into a contract or to perform a contract that you or your company has with us.

• Consent – Where required by applicable laws, we will rely on your consent for collecting you personal information.

• Legitimate interests – We may use your personal information for our legitimate interests to improve our services. Consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable laws, we may use technical information as described in this Policy and use personal information for our marketing purposes. We will only process personal data for a specific purposes or for any other purposes specifically permitted by the data protection legislation.

Obtaining Consent

Except when otherwise permitted by law, we obtain the requisite consent prior to collecting and, in any case, prior to using or disclosing your personal information for any purpose. You may provide your consent to us orally, in writing, by electronic communication, or any other means reasonably capable of conveying your consent. We will obtain your express consent if we collect, use or disclose sensitive

information as Data Controller. We may also share data with third parties partners for whom you have given us consent. Your consent may also be intrinsic to the circumstances such as in the case where you have already provided personal information to us and you maintain your relationship with us or where you provide our representatives with your phone number so that we can contact you. Except when otherwise permitted by law, we will only use the information for the purpose for which it was given. From time to time, we may collect, utilize, or disclose your personal information based on your consent and as otherwise permitted by law. When your consent is required, you can withdraw consent at any time (unless withdrawing the consent would frustrate the performance of legal obligations) upon providing to us a 30-day notice. However, the withdrawal of your consent may adversely affect our ability to provide services to you and to maintain our relationship.

Third Parties

We remain responsible for all personal information communicated to third parties for processing. As such, we ensure that third parties that are engaged to provide products or services on our behalf and are provided with personal information are required to observe the intent of this International Policy by having comparable levels of security protection or, when required, by assuring us (through a confidentiality agreement) that they will not use or disclosure the personal information for any purpose other than the purpose for which the personal information was communicated.

Limitations

We only collect the personal information necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes or as required by law.

We do not use or disclose your personal information, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.

We do not, as a condition of providing services to you or on your behalf, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal information beyond that reasonably required for such purposes, or to comply with its obligations under applicable law.

Retention of Personal Information

We may keep a record of your personal information, including correspondence or comments, in the applicable file specific to you. We will utilize, disclose, or retain your personal information for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. We will establish minimum and maximum retention periods and procedures for maintaining and destroying your personal information. When personal information is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal compliance and data retention policies.

Access to Your Personal Information

Subject to the exceptions provided by the applicable law, we will make available to you any specific personal information about you that we have collected, utilized or disclosed, upon your written request. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes and using an alternative format, if required. Simply send

your request for access to the Privacy Officer listed below. Please be as specific as possible in your request so that we can meet the applicable time lines. REQUEST FORM on the last page of this policy.

Opt-Out & Unsubscribe

We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from Western Winter Workshop by contacting us

info@co-pilots.com If you are a located in the European Economic Area (EEA) the General Data Protection Rule (GDPR) allows Data Subject rights of access, rectification, erasure, restriction, objection, or portability in line with the type of services being provided and the right to lodge a complaint to your Supervisory Authority.

Accuracy

We will use reasonable efforts to ensure that your personal information is kept as accurate, complete, and up to date as possible. We will not routinely update your personal information, unless such a process is necessary. To help us maintain and ensure that your personal information is accurate and up to date, you must inform us, without delay, of any change in the information you provided to us.

You can at any time, challenge the accuracy or completeness of the personal information we have about you, subject to the exceptions provided by applicable law. If you successfully demonstrate that the personal information, we have on you is inaccurate or incomplete, we will amend the personal information as required. Where appropriate, we will transmit the amended information to third parties to

whom we have communicated your personal information.

Response Times

We will make every reasonable effort to respond to each of your written requests not later than 30 days after receipt of such requests. When applicable, we will advise you in writing if we cannot meet your requests within this time limit. When applicable, you have the right to make a complaint to the appropriate privacy commission with respect to this time limit.

Costs

We expect to provide access without charge as a general matter. However, we reserve the right to collect a reasonable charge when you request the transcription, reproduction, or transmission of such information. We will notify you, following your request for transcription, reproduction, or transmission, of the appropriate amount that will be charged. You will then withdraw your request.

Identifying You in Connection with Requests We may require that you provide to us sufficient information to identify yourself before we provide information about the existence, use, or disclosure of your personal information in our possession. Any such information shall be used only for this purpose.

Safeguards

We use security safeguards appropriate to the sensitivity of personal information to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances, and publishing this policy to appropriate personnel with instructions to act in accordance with its principles (for example, limiting access on a “need to know” basis), and technological measures, such as the use of passwords and/or encryption.

Contact

Personal information is generally located at our corporate or divisional offices. A list of corporations, divisions, subsidiaries and affiliates to which this Privacy Policy applies is available upon request. Please direct all complaints or other inquiries regarding personal information, the General Policy, or the International Policy to our Privacy Manager as follows. E-mail: info@co-pilots.com

CHANGES TO THE PRIVACY POLICY

This Privacy Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display an effective date on this Privacy Policy at the top of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any material change to this Privacy Policy regarding use or disclosure of personal information, we will provide advance notice on this Site. Changes will apply to information collected after the change is effective. Please check this Privacy Policy periodically for changes. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. Your use of the Site constitutes acceptance of the provisions of this Privacy Policy and your continued usage after such changes are posted constitutes acceptance of each revised Privacy Policy. If you do not agree to the terms of this Privacy Policy or any revised Privacy Policy, please exit the Site immediately. If you have any questions about this Privacy Policy, the practices of the Site, or your dealings with the Site, you can email at info@co-pilots.com.