Privacy Policy
Effective June 2026
1Who we are
Warm Winter (“we,” “us”) is a decision-intelligence service based in Cheyenne, Wyoming, United States. For any privacy question or request, contact privacy@warmwinter.io.
2Information we collect
We collect only what the service needs to function:
- Account information — your email address, password (stored only as a one-way hash), and optionally your name and business name.
- Business metrics you enter — the figures you type into simulations and snapshots (such as revenue, customer counts, churn rate, and the scenarios you model). You choose what to enter; you are not required to use real figures.
- Decision and outcome records — the decisions you choose to log and any outcomes you later report back to us.
- Technical data — limited log data such as your IP address and basic request metadata, used for security and abuse prevention.
We do not knowingly collect special-category data, and we ask that you not enter sensitive personal information into simulation fields.
3How we use your information
- To operate the service — run simulations, compute your health score, and store your history.
- To secure the service — authenticate you and prevent abuse.
- To improve accuracy — see Sections 5 and 6.
- To communicate with you about your account and, only if you opt in, product updates. You can opt out of marketing at any time.
4Legal bases (GDPR)
Where the EU/UK GDPR applies, we rely on: contract (to provide the service you sign up for), legitimate interests (to secure and improve the service, including the anonymized model improvement described in Section 5), and consent (for optional marketing communications).
5Data retention and anonymized model improvement
While your account is active, we retain your data so the product works for you. When you delete your account, we remove your personal profile and all directly identifying information.
We may retain the anonymized substance of your simulations — the (business state, action, result) patterns — with your user identifier and all personally identifying fields removed, and use those anonymized patterns to train and improve our models and the product. Once anonymized, these records can no longer be linked back to you or your business. We rely on legitimate interests (GDPR Art. 6(1)(f)) — improving model accuracy — for this use.
You can opt out of having your data used for model training at any time from your account preferences. If you opt out, your simulations are excluded from the training corpus.
6Aggregate research sharing
We may share aggregate, anonymized, non-identifying statistical data derived from how the service is used — for example, decision-type distributions or outcome rates by industry and market condition — with research institutions, government economic research bodies, and academic partners for economic analysis.
This data is not sold. It is not individually identifiable. It contains no user identifier, email, business name, or any field that could identify a specific user or business.
7Who we share data with
We do not sell your personal information. We share it only with service providers who help us run Warm Winter (such as cloud hosting and database infrastructure), bound to protect it, and where required by law. The aggregate, anonymized sharing in Section 6 is the only research sharing we do.
8Your rights and choices
You can, at any time:
- Export a full copy of your data (data portability).
- Delete your account and personal data (right to erasure), subject to the anonymized retention in Section 5.
- Opt out of model training and of marketing communications.
California residents: we do not sell or share personal information as those terms are defined under the CCPA/CPRA, and you may exercise the access and deletion rights above without discrimination. To exercise any right, use the controls in your account or contact privacy@warmwinter.io.
9Security
Passwords are stored only as one-way hashes, traffic is encrypted in transit, and access to data is restricted. No system is perfectly secure, but we work to protect your information and to limit how much identifying data we hold in the first place.
10Age
Warm Winter is for business operators aged 18 or older. We do not knowingly collect data from anyone under 18.
11Changes to this policy
If we make a material change, we will update the effective date above and, where required, notify you. Continued use after a change means you accept the updated policy.