WELLSPRING PICKS

Privacy Policy

Last Updated: July 1, 2025

Wellspring Picks deeply respects your privacy and is committed to protecting your personal data. This Privacy Policy details how we collect, use, store, share, and protect your information when you visit our website wellspringpicks.com. Our goal is to be fully transparent about our data practices, in compliance with applicable data protection laws in the jurisdictions where we operate and where our users reside, including, but not limited to:

  • The General Data Protection Regulation (GDPR) of the European Union.
  • The UK General Data Protection Regulation (UK GDPR) of the United Kingdom.
  • The California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) of the United States.
  • The Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada.
  • The Lei Geral de Proteção de Dados (LGPD) of Brazil.

By using our Site, you agree to the practices described in this Privacy Policy.

Information We Collect

We collect different types of information for various purposes, in order to provide and improve our services.

1.1. Personal Data You Provide Voluntarily: This is information you provide to us directly when interacting with the Site. This may include:

  • Contact Data: Name, email address, when you contact us through forms, email, or subscribe to newsletters.
  • Communication Data: The content of your messages and any other information you choose to provide to us.

1.2. Automatically Collected Data (Usage and Browse Data): When you access and use our Site, we may automatically collect certain information about your device, Browse actions, and usage patterns. This data is collected through cookies, web beacons, pixels, and other tracking technologies. This may include:

  • Device Information: IP address (which may be used to infer your general location), browser type, operating system, unique device identifiers.
  • Browse Data: Pages visited, time spent on pages, links clicked, referring URLs, date and time of access, and other clickstream data.
  • Location Data: Approximate location information inferred from your IP address.

How We Use Your Information (Purposes and Legal Bases)

We use the collected information for the following purposes, with the respective legal bases as per data protection laws:

  • To Provide and Maintain Our Site: To operate, maintain, and optimize the functionality of the Site.
    • Legal Basis: Legitimate interest (to ensure the technical functioning of the Site) and, where strictly necessary, consent for essential cookies.
  • To Respond to Your Inquiries and Requests: To manage and respond to your communications and provide customer support.
    • Legal Basis: Performance of a contract (if the request relates to a service you have contracted) or legitimate interest (for general communication and support).
  • To Improve and Personalize User Experience: To understand how users interact with our Site, analyze trends, personalize content, and enhance usability.
    • Legal Basis: Consent (for performance, analytical, and personalization cookies, and related data processing).
  • For Marketing and Advertising (Including Affiliate Marketing): To display relevant ads, measure the effectiveness of advertising campaigns, and track affiliate performance. This includes the use of data for remarketing and custom audiences.
    • Legal Basis: Consent (for targeted advertising and advertising/tracking cookies/pixels). We may also rely on legitimate interest for direct marketing where permitted by law (e.g., in specific “soft opt-in” scenarios for existing customers).
  • To Comply with Legal and Regulatory Obligations: To meet legal, regulatory, tax, and accounting requirements, and to respond to legal requests from authorities.
    • Legal Basis: Compliance with a legal obligation.
  • To Protect Our Rights and Interests: To detect, prevent, and address fraud, abuse, security or technical issues, and to protect the property or safety of WellspringPicks.com, our users, or the public.
    • Legal Basis: Legitimate interest (to protect our assets and users).

Cookies and Tracking Technologies

Our Site uses cookies and similar tracking technologies to collect information and enhance your experience.

3.1. What Are Cookies? Cookies are small data files stored on your device (computer, tablet, mobile) when you visit a website. They are widely used to make websites work more efficiently, as well as to provide information to the website owners.

3.2. Types of Cookies We Use:

  • Essential (Strictly Necessary) Cookies: These are indispensable for the basic functioning of the Site, allowing you to navigate and use its features. They do not require consent, but you are informed of their use.
  • Performance/Analytical Cookies: Collect anonymous information about how visitors use the Site (e.g., most visited pages, errors). This helps us improve the Site’s operation. Examples include Google Analytics.
  • Functionality Cookies: Allow the Site to remember your choices (e.g., language, region) and offer enhanced, more personalized features.
  • Advertising/Tracking Cookies: Used to display ads more relevant to you and your interests. They are also used to limit the number of times you see an gem and to measure the effectiveness of advertising campaigns. This includes cookies from platforms like Google AdSense, Google Ads, and Meta Ads, as well as from affiliate tracking platforms.

3.3. Third-Party Cookies: We use third-party services that may set their own cookies on your device. This includes:

  • Google Analytics: For traffic analysis and user behavior.
  • Google AdSense/Google Ads: For ad serving and remarketing.
  • Meta Ads (Facebook/Instagram): For targeted advertising and campaign measurement.
  • Affiliate Platforms: To track clicks and conversions from affiliate programs.

These third parties may collect information about your online activities over time and across different websites.

3.4. Managing Cookies and Consent: For users in the European Union, United Kingdom, Brazil, and Canada, we seek your explicit consent for non-essential cookies (performance, functionality, advertising) through a cookie consent banner (CMP – Consent Management Platform) that appears on your first visit to the Site. You will have the option to accept, refuse, or customize your cookie preferences.

For users in the United States, your choices regarding advertising and tracking are typically managed through your browser settings and specific opt-out tools provided by advertising partners (such as Google’s Ad Settings). For California residents, please refer to the “Your Privacy Rights” section for specific rights related to the sale or sharing of personal information.

You can manage your cookie preferences at any time through your browser settings. However, disabling certain cookies may affect the functionality of the Site.

Sharing and Disclosure of Your Information

We may share your personal information with the following categories of third parties, for the purposes described in this Policy:

  • Service Providers: Companies that assist us in operating the Site, such as hosting, data analysis, payment processing, email services, and customer support. These providers are contractually obligated to protect your data and use it only for the purposes for which they were engaged.
  • Advertising and Marketing Partners: Including Google (Google Ads, AdSense, Analytics), Meta (Facebook, Instagram), and affiliate networks. We share information (such as cookie data and device identifiers) to deliver targeted ads, measure campaign effectiveness, and track affiliate performance.
    • Google Ads: We use Google Ads for advertising, including remarketing services. This means Google and other third-party vendors may display our ads on websites across the internet based on your past visits to our Site, using cookies and/or device identifiers. You can opt out of Google’s use of cookies or device identifiers by visiting Google’s Ad Settings.
    • Meta Ads (Facebook/Instagram): We use Meta’s advertising services (Facebook, Instagram) to deliver targeted ads and measure campaign performance. This may involve using data collected via Meta pixels or other tools on our Site, including information you provide through lead forms. Meta processes this data in accordance with their own privacy policies.
  • Affiliates and Group Companies: If we have affiliated companies or within the same group, we may share information for operational and business purposes.
  • Legal and Regulatory Authorities: When required by law, court order, or to cooperate with government investigations.
  • Business Successors: In the event of a merger, acquisition, sale of assets, or insolvency, your information may be transferred to the successor entity.

We do not “sell” your personal information in the traditional sense of the term. However, the sharing of certain information with advertising and analytics partners may be considered a “sale” or “sharing” under the CCPA/CPRA for California residents. For more details, please refer to the “Your Privacy Rights” section.

International Data Transfers

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.

If you are located in the European Union, United Kingdom, or Brazil and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there. We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy and applicable laws.

For transfers of personal data from the EU/UK/Brazil to countries that do not offer an adequate level of data protection (such as the US), we implement appropriate safeguards, such as the Standard Contractual Clauses (SCCs) approved by the European Commission or other recognized data transfer frameworks, to ensure your data receives a level of protection equivalent to that of the GDPR/UK GDPR/LGPD.

Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, regulatory, tax, and accounting obligations, as well as to resolve disputes and enforce our agreements. The criteria used to determine retention periods include:

  • The duration of your relationship with us and the provision of our services.
  • The existence of a legal obligation to retain the data.
  • The need to retain data for litigation or investigation purposes.

Data Security

We implement industry-standard technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no data transmission over the Internet or electronic storage method is 100% secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

Your Privacy Rights

Depending on your location and applicable data protection laws, you may have the following rights regarding your personal data:

  • Right to Access/Confirmation: The right to confirm whether we are processing your personal data and to request access to it.
  • Right to Rectification: The right to request the correction of inaccurate or incomplete personal data.
  • Right to Erasure (“Right to be Forgotten”): The right to request the deletion of your personal data under certain conditions (e.g., the data is no longer necessary for the purposes for which it was collected).
  • Right to Restriction of Processing: The right to request the restriction of the processing of your personal data under certain conditions.
  • Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
  • Right to Object: The right to object to the processing of your personal data in certain situations (e.g., for direct marketing purposes).
  • Right to Withdraw Consent: The right to withdraw your consent at any time, when the processing of your personal data is based on consent. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
  • Right to Opt-Out of Sale/Sharing (for California Residents): For California residents, the right to opt out of the sale or sharing of your personal information for cross-context behavioral advertising. You can exercise this right by clicking the “Do Not Sell/Share My Personal Information” link (or similar) that will be available in the footer of our Site.
    • Action Required: Crucially, ensure this ‘Do Not Sell/Share My Personal Information’ link is actually implemented and prominently visible in your site’s footer, and that it functions correctly to record user opt-out preferences.

To exercise any of these rights, please contact us using the information provided in the “Contact” section. We will respond to your request in accordance with applicable law. We may need to verify your identity before fulfilling your request.

Children’s Privacy

Our Site and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we will take steps to remove that information from our servers.

Third-Party Links

Our Site may contain links to third-party websites that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services. We strongly advise you to review the privacy policies of every site you visit.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last updated” date at the top. If the changes are significant, we will make reasonable efforts to provide a more prominent notice (e.g., by email or a notice on our Site). We encourage you to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact

If you have any questions about this Privacy Policy or our data practices, please contact us:

By email: linkup@wellspringpicks.com

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