Cookie Policy

Effective Date: August 15,2025

Last Updated: August 15, 2025

At Pinwheel, we believe in transparency about how we collect and use data. This Cookie Policy explains how we use cookies and similar technologies when you visit www.pinwheel.com (the “Site”). It also explains your choices regarding these technologies.

1. What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They help us recognize your device, remember your preferences, improve your experience, and analyze usage.

We use both first-party cookies (set by Pinwheel) and third-party cookies (set by our partners, such as Google and Meta/Facebook).

2. Types of Cookies We Use

3. Do We Sell or Share Your Personal Information?

No. Pinwheel does not sell your personal information for monetary value.

Under California law (CPRA), we do share limited information about your website visit (which does not include personally identifiable information) with third-party advertising platforms such as Meta (Facebook) and Google for:

• Retargeting ads (showing relevant Pinwheel ads to you on other websites based on your interactions with our site)
  
  
• Advertising suppression (removing you from future ad campaigns)

This type of data sharing may fall under the CPRA’s definition of “sharing” for cross-context behavioral advertising and under other state laws’ definitions of “targeted advertising”.

We may also use the email you provide at checkout to exclude you from future advertising on platforms like Facebook. This is done only for suppression, not for ad targeting, and we consider this to be within our legitimate interest and aligned with user expectations.

4. Your Cookie Choices

You have control over your cookie preferences:

• Cookie Banner: When you first visit our site, you will see a cookie banner allowing you to accept or reject non-essential cookies, and opt-out of sharing your personal information.
  
  
• Settings Icon: You may revisit your cookie preferences at any time by clicking “Cookie Settings” in the footer.
  
  
• Browser Controls: Most browsers allow you to block or delete cookies through settings.

For more information on managing cookies, visit www.allaboutcookies.org.

5. Regional Privacy Rights Related to Cookies and Data Sharing

5.1 California Residents (CPRA)

If you are a resident of California, you have the right to opt out of the sale or sharing of your personal information, including sharing for cross-context behavioral advertising such as retargeting ads.

Although we do not sell your data for monetary value, we may share limited information about your website visit with third-party advertising platforms (such as Meta and Google) for retargeting purposes, providing more relevant ads, or excluding you from certain ads.

You can exercise your right to opt out by:

• Clicking the “Do Not Share My Personal Information” link in our website footer, or
  
  
• Emailing privacy@pinwheel.com with the subject line “Do Not Share My Personal Information.”

We will also honor browser-enabled Global Privacy Control (GPC) signals as a valid opt-out request.

5.2 Other US State Privacy Laws

If you are a resident of a US state with a comprehensive privacy law — including but not limited to Colorado (CPA), Connecticut (CTDPA), Virginia (VCDPA), and Utah (UCPA) — you may have the right to opt out of:

• The sale of your personal information, and/or
  
  
• The sharing or processing of your personal information for targeted advertising.

While Pinwheel does not sell personal information for monetary value, we may share limited information about your website visit with advertising platforms for purposes that could be considered “targeted advertising” or “sharing” under these state laws.

You can opt out by:

• Clicking the “Privacy Choices” or “Do Not Share My Personal Information” link in our website footer, or
  
  
• Emailing privacy@pinwheel.com with the subject line “Opt-Out Request.”

We also honor Global Privacy Control (GPC) signals where required or recognized by applicable state law.

5.3 United Kingdom & European Union Residents (UK GDPR / EU GDPR / PECR)

If you are located in the UK or EU, we will only place non-essential cookies (including analytics, personalization, or marketing cookies) on your device with your explicit consent in line with the UK GDPR, EU GDPR, and the Privacy and Electronic Communications Regulations (PECR).

You have the right to:

• Refuse non-essential cookies when you first visit our site via our cookie banner.
  
  
• Withdraw your consent at any time by revisiting the cookie settings in our footer or adjusting your browser settings.
  
  
• Object to the processing of your personal data for direct marketing or profiling related to advertising.

If you consent to marketing cookies, we may share limited information about your website visit with advertising platforms (such as Meta and Google) for purposes of providing relevant content or excluding you from certain ads. This will only occur where you have given consent.

If cookie-related data is transferred outside the UK or EU (for example, to our service providers in the United States), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses or the UK International Data Transfer Agreement.

To manage your preferences at any time, click the “Cookie Settings” link in our website footer.

How This Works in Practice

• Our website’s cookie banner and footer links are tailored so you can easily exercise the rights that apply in your location.
  
  
• We maintain records of consent and opt-outs to ensure your preferences are respected globally

6. Global Privacy Control (GPC)

Our website supports the Global Privacy Control (GPC) signal. If your browser sends a GPC signal, we treat it as a valid opt-out request under applicable US privacy laws.

7. Updates to This Policy

We may update this Cookie Policy from time to time. We will update the “Last Updated” date at the top of this page and notify you as required by law.

8. Contact Us