We understand that you expect your non-public personal financial information to be kept private and secure. Although all transactions done with Winthrop are solely for business or commercial purposes, we respect your concern about privacy and have implemented certain procedures with regard to non-public personal information which may be collected in connection with business transactions, such as non-public personal information relating to transaction guarantors and non-public personal information relating to individuals who do business as a sole proprietorship.

When you browse. When you visit the Winthrop website and browse, we do not collect any information about you. We do record the date and time of visits to our website and the pages visited while at our site. We do this to determine which pages are visited most often, so we can enhance our website to make it more useful to our customers.

Use of "cookie" technologies. Many websites place permanent cookies, or permanent electronic files, on your hard drive; the cookies collect data. We occasionally use permanent cookies and place a permanent electronic file on your computer which keeps track of the number of visits to our website. We also use temporary cookies, which are automatically deleted at the end of a session or expire within 24 hours.

When you want information. When you visit the Winthrop website and request information, we may collect the information we believe is necessary to process the transaction you have requested.

When you submit information: Information you submit to us becomes our property and we may use any ideas, concepts, know-how, images or techniques contained in such information for any purpose, including developing, producing and marketing products and services.

Sharing your information when permitted or required by federal or state law. We may share your information with other parties when permitted or required by federal or state law. For example, we share information in order to protect against fraud, report transactions to consumer reporting agencies, respond to subpoenas, and when you ask us to.

Employee access to customer information. We restrict access to non-public personal information about you to those employees who need to know that information to perform their job at Winthrop. Our employees are trained to respect customer privacy and to access customer information only when they have a business reason to know the information.

Confidentiality and security. Winthrop maintains physical, electronic and procedural safeguards that comply with federal regulations to guard your non-public personal information. Notwithstanding, data, including e-mail and electronic communications using the internet, network communications facilities, telephone or any other electronic means may be accessed by unauthorized third parties when communicated between you and by transmitting data to us using such means you agree that Winthrop is not responsible or liable for any such unauthorized third party access.

Collection of Information:  Like most Web sites, Winthrop also collects and logs information automatically and through the use of electronic web beaconing tools that may be transparent to you, such as your IP address, the name and location of your Internet Service Provider, the type and version of your browser, the length of time that you stay on Winthrop, search queries, your click-stream data, the location that referred you to Winthrop and the average number of pages viewed. If you visit another Web site prior to browsing Winthrop, that Web site might place information within a URL, such as search queries, which may be logged by us. Your IP address is the identifier assigned to your particular computer when you access the Internet. Depending on how you connect to the Internet, your IP address may always be the same, or it may change each time you access the Internet. Note that logging your IP address does not provide us with personally identifiable information such as your name, e-mail address or home or work address.

Changes and Updates to This Policy. We reserve the right to change the information, services, features and policies at any time. We will post changes to this and any other policies on this website in writing.