WE DO NOT SELL YOUR PERSONAL INFORMATION, NOR DO WE INTEND TO DO SO. WE DO NOT GIVE ACCESS TO YOUR PERSONAL INFORMATION TO THIRD PARTIES EXCEPT TO SUBPROCESSORS TO ASSIST US IN THE PROVISION OF OUR SERVICES TO YOU.
Our Website, App, and Platform are not available for use or download by residents of, visitors to, or your employees who reside in the European Union (collectively a “European”). If you are a European, please do not download, register, and/or use our Website, App, or Platform. If you have any questions regarding this Section, please email us at email@example.com.
WHAT INFORMATION DO WE COLLECT?
When you register to use our Website, App, or Platform, we collect personal information (also referred to as personally identifiable information or “PII”) which may include your name, address, online contact information such as your email address or username, phone number, and other personal information. The information so collected will be stored on our servers. You are able to change your personal information collected by us via email by contacting us at firstname.lastname@example.org or through your profile or account settings on our Website, App, or Platform.
Geolocation and Equipment Information
We may collect information that does not personally identify you such as (i) your geolocation, and (ii) information about your internet connection, the equipment you use to access our Website, App, or Platform, and usage details related to our Website, App, or Platform. We ask Users for their explicit consent prior to collecting information on your geolocation at the time of registration on the App.
We do collect and store information regarding the mode of payment associated with your Wallet such as whether a User uses Unified Payments Interface, Bank Transfer, Credit Card, Debit Card on their Wallet. This information cannot identify a User and is not PII
KYC related Information.
All Users on our App must provide phone numbers to be linked to their profiles and account. All Users must go through the mobile one time password (“OTP”) verification process before using our Services. YOU SPECIFICALLY CONSENT TO OUR SENDING YOU SMSES OR MOBILE MESSAGES TO AUTHENTICATE EACH TIME YOU ATTEMPT TO REGISTER OR LOGIN TO YOUR ACCOUNT OR PROFILE FROM OUR APP. In future, we might allow log-ins and registrations via social media handles such as Facebook, Gmail, Apple Id (“Social Media Sites”), in which case once the user logs in and register for our Services we will the user’s email id and limited profile information, including User’s profile pictures and images from the from such social media sites. We will inform you via reasonable means if we start collecting such information from you.
We collect data related to (i) the Games played by the Users, such as number of Games played, time spent playing each Game, or name of Game played (“Game-Play Data”); and (ii) commercial purchase information for the transactions or purchases made by the User on our Website or App, such as deposit added by the User to User’s Wallet, boot amount paid for participating in a game (“Boot”), or Winnings on each Game won in a particular game, etc. (“Transaction Data”).
HOW DO WE COLLECT INFORMATION?
We collect personal information from you in the following ways:
At registration on our Website, App, or Platform
In email, text, and other electronic messages between you and our Website, App, or Platform
Through mobile and desktop applications your downloads from our Website, App, or Platform, which provides dedicated non-browser based interaction between you and our Website, App, or Platform
From you placing an order, which includes details of transactions you carry out on our Website, App, or Platform
From your responses to a survey
From forms filled out by you
From records or copies of correspondences (including email addresses) if you contact us
From search queries on our Website, App, or Platform.
We collect information from you automatically when you navigate through our Website, App, or Platform in the following ways:
- Usage details
- IP addresses.
We also collect information from third parties such as business partners such as our KYC Partners and Social Media Sites necessary to provide our Services to you. If you have any questions regarding this Section, please email us at email@example.com
HOW DO WE USE YOUR INFORMATION?
We use the information that you provide to:
Personalize your experience in using our Platform
Provide you with information, products, or services requested from us
Present our Website, App, and Platform and their contents to you
Provide you with notices about account and/or subscription, including expiration and renewal notices
Carry out obligations and enforce rights arising from contracts entered into between you and us, including billing and collection
Notify you about changes to our Website, App, and Platform and any products or services
Allow you to participate in interactive features on our Website, App, and Platform
Improve the Website, App, and Platform
Improve our customer service
Administer contests, promotions, and surveys or other Website, App, and Platform features
Anonymize data and aggregate data for statistics
Contact you for other purposes with your consent
Contact you about our products and services that may be of interest
Enable the display of advertisements to our advertisers’ target audiences, although personal information is not shared with advertisers without your consent
Send you periodic emails, in accordance with the CAN-SPAM Act of 2003 as detailed in Section 14, via the email address provided by you to (i) send information, respond to inquiries, and/or other requests or questions; (ii) process orders and send information and updates pertaining to such orders; (iii) send additional information related to your product and/or service; and (iv) market to our mailing list or continue to send email to you after the original transaction has occurred.
We use third parties (“Sub-processors”), who have access to personal information of our consumers to perform some of the operational functions to provide a full service to our Users. Please see Section 15 for more information on our Sub-processors.
Occasionally, at our discretion, we may include links to third-party products or services on our Website, App, or Platform. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Website, App, or Platform and welcome any feedback at about these sites. Please contact us at firstname.lastname@example.org.
HOW DO WE PROTECT INFORMATION WE COLLECT?
Our Website and App are reasonably scanned to meet or exceed PCI Compliance. Our Website and App receive regular security scans and penetration tests. Our Website and App also receive regular malware scans. In addition, our Website and App use an SSL certificate as an added security measure. We require username and passwords for our employees who can access your personal information that we store and/or process on our Platform and servers. In addition, we actively prevent third parties from getting access to your personal information that we store and/or process on our Platform and servers. We accept payment by credit card through a third party credit card processor on our behalf. We will implement reasonable security measures every time you (a) place an order, or (b) enter, submit, or access your information, (c) register, or (d) access our Platform, on our Website and App.
DATA SECURITY MEASURES.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password or OTP for access to certain parts of our Website, App, or Platform, you are responsible for keeping this password and OTP confidential. We ask you not to share your OTP or password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website, App, or Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website, App, or Platform.
Fair Information Practice Principles
In the event of a personal data breach, we will notify you within forty eight (48) hours via (i) mobile message or email, and/or (ii) our Platform notification system on our Website and/or App. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
We use the following open-source software in the provision of our Services, which can be found here.
DISCLOSURE OF PERSONAL INFORMATION
There are times when Personal Information that you have shared with us may be shared by WinZO with others to enable us to provide you or Services, including contractors, service providers, and third parties (“Partners”). This section discusses only how WinZO may share such information with Partners. We will ensure that our Partners protect your Personal Information. The following describe how and with whom we may share your Personal Information:
Disclosure of Personal Information.
We may disclose aggregated, de-personalized information about you that does not identify any individual to other parties without restriction, such as for marketing, advertising, or other uses.
We may disclose personal information to our subsidiaries and affiliates.
We may disclose personal information to contractors, services providers, and other third parties.
We require all contractors, service providers, and other third parties to whom we disclose your personal information to be under contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose them.
We may disclose personal information in the event of a merger, sale of business, etc.
We may disclose to third parties to market their products and services to you if you have either consented or not opted out of these disclosures.
We require all other Partners, to whom we disclose your personal information, to enter into contracts with us to keep personal information confidential and use it only for the purposes for which we disclose it to such Partners.
We disclose personal information to fulfill the purpose for which you have provided it, for instance, if you gave us an email address to use the “email a friend” feature of the Platform.
Other Disclosure of Personal Information.
Third Party Disclosure.
We do not sell, trade, rent, or otherwise transfer personal information to others, unless we provide you with advance notice. This does not include our hosting partners and other parties who assist us in operating our Website, App, or Platform, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
We provide non-PII (disaggregated, de-personalized) to other parties for marketing, advertising, or other uses. Please note, however that such non-PII data is only shared with trusted third party services who assist WinZO to conduct business and to service the users, as part of day to day business activities.
Choices Users Have About How WinZO Uses and Discloses Information.
Tracking Technologies and Advertising.
You can set their browser to refuse some or all the browser cookies, and it will not affect your User experience.
Disclosure of User’s Information for Targeted Advertising.
Users can opt-out by (i) checking the relevant form or checkbox when we collect the data, or (ii) filling out an online form letting us know of their desire to opt-out.
GOOGLE ADSENSE AND GOOGLE ANALYTICS
We have implemented advertising features on our Website, App, and Platform including: (a) Google Display Network Impression Reporting and (b) Google AdWords. We use these Cookies to compile data regarding User interactions with ad impressions and other ad service functions as they relate to our Website or App.
OTHER PRIVACY RIGHTS
Your California Privacy Rights
California Civil Code.
WinZO does not sell, trade, or otherwise transfer to outside third parties your “Personal Information” as the term is defined under the California Civil Code Section § 1798.82(h). Additionally, California Civil Code Section § 1798.83 permits Users of our Website, App, or Platform that are California residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. To make a request for such disclosure, or identification and/or deletion of Personal Information in all our systems that we store on you, please send an email to email@example.com
or write us at WinZO, 1000 N. West Street, Suite 1200, Wilmington, Delaware, USA- 19801. Note that (i) if we delete your Personal Information as requested, we will no longer be able to provide our services to you and (ii) we may need to keep such Personal Information for a while during the shutting down and billing process. If you would like to discuss our Personal Information storage and processing process with us, please send us an email at firstname.lastname@example.org
or write us at WinZO, 1000 N. West Street, Suite 1200, Wilmington, Delaware, USA- 19801.
- Right to Request Personal Information: Upon request, we will provide you with (i) a list of all Personal Information that we have collected on you, (ii) from whom we obtained such Personal Information, (iii) the reason why we collected such Personal Information, and (iv) with whom (if any) we have shared such Personal Information. If we sell your Personal Information or disclose your Personal Information to third parties, upon request, we will provide you with (i) a list of the Personal Information that we have collected on you, (ii) a list of the Personal Information that we sell or disclose to others on you, and (iii) to whom we have sold or disclosed your Personal Information. A consumer can make such a request only twice in a 12-month period. We require such Personal Information to be able to provide to you our Services. Unless otherwise specified, we only collect Personal Information from you. We do not use others to provide us with your Personal Information.
- Disclosure of Personal Information. We only share your Personal Information with service providers, e.g., billing and collection agents, who enable us to provide our Services to you. We do not sell or give your Personal Information to third parties for purposes unrelated to our provision of Services to you.
- Right to have Personal Information Deleted. Upon request, we will delete all of your Personal Information that we have collected on you and will direct our Service Providers to also delete all of your Personal Information. But note that if we do delete all of this Personal Information, you will no longer be able to use our Services.
- Non-Discrimination Right. We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not:
- Deny you goods or services
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services
- Financial Incentives. However, we may offer you certain financial incentives permitted by the CPRA that can result in different prices, rates, or quality levels. Any CPRA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
- Under 16. We will not sell your Personal Information of any Users, including any persons under the age of 16.
- Right to Opt-Out. At any time, upon your request, we will stop selling your Personal Information (sometimes called your Opt Out-Right). You may send the request to Opt Out (i) to email@example.com, or (ii) by writing to us at Privacy Officer, 1000 N. West Street, Suite 1200, Wilmington, Delaware, USA- 19801.
- Data Protection Officer. We have appointed a Privacy and Data Protection Officer at firstname.lastname@example.org to make sure the privacy rights of our Users are protected.
Other State Privacy Rights
The Massachusetts Data Protection Law (201 CMR 17.00), sets standards for the protection of personal information of residents of Massachusetts. Residents of Massachusetts have the following rights under Massachusetts law (i) the right to request access to their personal information that is held by us and to receive a copy of that information; (ii) the right to request the correction of any inaccurate or incomplete personal information; (iii) the right to request that we delete your personal information; (iv) the right to opt-out of the collection, use, or disclosure of your personal information for marketing purposes; (v) the right to be notified in the event of a data breach involving their personal information; and (vi); the right to Opt-in for collection, use or disclosure of Sensitive Personal Information. Further, you have the right to file a complaint with the Massachusetts attorney general if you believe we have violated the Massachusetts Data Protection Law by calling (617) 727-8400 or filing a complaint at https://www.mass.gov/how-to/file-a-consumer-complaint
The Colorado Privacy Act (Colo. Rev. Stat. § 6-1-1301 et seq.) protects the privacy of Colorado consumers. Residents of Colorado have following privacy rights (i) you have the right to opt out of the processing of your personal data for the purposes of targeted advertising, the sale of your personal data or profiling in furtherance of decisions that produce legal or similarly significant effects; (ii) you have the right to confirm whether we are processing personal data concerning you and to access your personal data; (iii) you have the right to correct inaccuracies in your personal data; (iv) you have the right to delete your personal data; and (v) when accessing your data, you have a right to obtain that data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit that data to another business
WinZO does not sell, trade, or otherwise transfer to outside third parties your “Personal Data” as the term is defined under Connecticut’s Privacy Act and Act Concerning Personal Data Privacy and Online Monitoring. Connecticut Laws permits residents of Colorado who are Users of our Website, App, or Platform that are Connecticut residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. Further, Users have the right to (i) confirm whether or not we are processing the your personal data and access such personal data, unless such confirmation or access would require us to reveal a trade secret; (ii) correct inaccuracies in the User’s personal data; (iii) opt out of the processing of the personal data for the purposes of targeted advertising, sale, or profiling in furtherance of solely automated decisions; and (iv) you have the right to obtain a copy of your personal data processed by the controller, in a portable and, to the extent technically feasible, readily usable format
On March 24, 2022, Utah enacted the Utah Consumer Privacy Act (UCPA § 13-61-102(1)) which will go into effect on December 31, 2023. The UCPA gives residents of Utah who are users of our Website and App the right to (i) you to opt out of the processing of your personal data for the purposes of targeted advertising, the sale or profiling; (ii) correct inaccuracies in your personal data; (iv) delete your personal data; and (v) obtain that data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit that data to another business.
The New York Privacy Act sets strict rules about how businesses must handle consumers’ personal information and gives individuals new rights concerning data. New York residents have the rights to (i) access, correct, deletion, and disclosure regarding your Personal Information; and (ii) know what personal information is being collected about them, how it is being used, and with whom it is being shared.
The Virginia Consumer Data Protection Act (Va. Code § 59.1-571 et seq.) effective from January 1, 2023 provides Virginia residents with certain rights regarding the collection, use, and sharing of their personal information namely (i) the right to know what personal information is being collected about them, how it is being used, and with whom it is being shared; (ii) the right to request that a business delete personal information that the business has collected from the resident; (iii) the right to non-discrimination for the exercise of their privacy right; (iv) the right to access the personal information held about them, including the categories of personal information collected, used, shared, and the categories of third parties with whom the information is shared; (v) the right to obtain a copy of their personal information in a structured, commonly used and machine-readable format
To exercise any of the rights mentioned un Section 11(b), please (i) send an email to email@example.com
, or (ii) write to us at Privacy Officer, 1000 N. West Street, Suite 1200, Wilmington, Delaware, USA- 19801.
Note that (i) if we delete your Personal Information as requested, we will no longer be able to provide our services to you and (ii) we may need to keep such Personal Information for a while during the shutting down and billing process. We have appointed a Privacy and Data Protection Officer to make sure the privacy rights of our Users are protected.
COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY)
The Children’s Online Privacy Protection Act (“COPPA”) is a federal legislation that applies to entities that collect and store “Personal Information,” as the term is defined under COPPA, from children under the age of 13. We are committed to ensure compliance with COPPA. Our Website, App, and Platform are not meant for use by children under the age of 13. Our Website, App, and Platform do not target children under the age of 13. If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at firstname.lastname@example.org. IF YOU ARE UNDER 18, PLEASE DO NOT ACCESS OR USE OUR WEBSITE, APP, OR PLATFORM.
CAN-SPAM ACT OF 2003
The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will:
not use false or misleading subjects or email addresses
identify the email message as an advertisement in some reasonable way
include the physical address of WinZO, which is 1000 N. West Street, Suite 1200, Wilmington, Delaware, USA- 19801
monitor third-party email marketing services for compliance, if one is used
honor opt-out/unsubscribe requests quickly
give an “opt-out” or “unsubscribe” option
If you wish to opt out of email marketing, follow the instructions at the bottom of each email or contact us at email@example.com
and we will promptly remove you from all future marketing correspondences.
LIST OF THIRD-PARTY SERVICE PROVIDERS
|Name of Third-Party Service Provider||Contact Information||Why we use the Third-Party Service Provider|
|Amazon Web Services Inc. (North Virginia, US)||Website: https://aws.amazon.com/premiumsupport/knowledge-center/aws-phone-support/ |
Address: 410 Terry Avenue North, Seattle, WA 98109-5210
|Technological infrastructure, maintenance and cloud services.|
|Google Analytics||Website: firstname.lastname@example.org |
Telephone: (855) 817-0841
|Data Analytics services|
|PayPal||Website: https://www.paypal.com/us/smarthelp/contact-us |
Address: 2211 North First Street San Jose, CA 9513
|Payment Gateway services|
|CleverTap||Website: https://clevertap.com/contact-us/ |
Address: 607 W Dana St. STE A Mountain View, CA 94041
|Data Analytics services|
|Data Dome||Website: https://datadome.co/contact/ |
Address: 524 Broadway, 11th Floor New York, NY 10012, USA
|Data Analytics services|
|Appsflyer||Website: https://www.appsflyer.com/company/contact/ |
Address: 100 1st Street, Floor 25 San Francisco, CA 94105 United States
|Jumio||Website: https://www.jumio.com/contact/support/ |
Address: 395 Page Mill Road, Suite 150 Palo Alto, CA 94306 USA
|MessageBird||Website: https://www.messagebird.com/en/about; https://support.messagebird.com/hc/en-us |
Address: Trompenburgstraat 2C 1079 TX Amsterdam, The Netherlands
|Checkout.com||Website: https://www.checkout.com/contact-sales |
Telephone: +1 415 691 4688
|Payment Gateway services|
|Freshchat||Website: https://www.freshworks.com/support/ |
Address: 2950 S. Delaware Street, Suite 201 San Mateo CA 94403
|Customer Support Services|
Additionally, if you have any questions or concerns about our third-party service providers, please email us at email@example.com
COPYRIGHT INFRINGEMENT/DMCA NOTICE
If you believe that any content on our Website, App, or Platform violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 (“DMCA Takedown Notice”)) must be provided to our designated Copyright Agent.
Your physical or electronic signature
Identification of the copyrighted work(s) that you claim to have been infringed
Identification of the material on our Website, App, or Platform that you claim is infringing and that you request us to remove
Sufficient information to permit us to locate such material
Your address, telephone number, and email address
A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law
A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner
WinZO’s Copyright Agent to receive DMCA Takedown Notices is [CONTACT PERSON], at firstname.lastname@example.org
and at WinZO, Attn: DMCA Notice, 1000 N. West Street, Suite 1200, Wilmington, Delaware, USA- 19801. You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney’s fees incurred by WinZO in connection with the written notification and allegation of copyright infringement
WinZO represents and warrants that it is fully aware of and will comply with, and in the performance of its obligations hereunder will not take any action or omit to take any action that would cause it or its customers to be in violation of, (i) U.S. Foreign Corrupt Practices Act, (ii) U.K. Anti-Bribery Act, (iii) India Prevention of Corruption Act of 1988, or (iv) any other applicable anti-bribery statutes and regulations, and (v) any regulations promulgated under any such laws. Company represents and warrants that neither it nor any of its employees, officers, or directors is an official or employee of any government (or any department, agency or instrumentality of any government), political party, state owned enterprise or a public international organization such as the United Nations, or a representative or any such person (each, an “Official”). Company further represents and warrants that, to its knowledge, neither it nor any of the Supplier Personnel has offered, promised, made or authorized to be made, or provided any contribution, thing of value or gift, or any other type of payment to, or for the private use of, directly or indirectly, any Official for the purpose of influencing or inducing any act or decision of the Official to secure an improper advantage in connection with, or in any way relating to, (A) any government authorization or approval involving WinZO, or (B) the obtaining or retention of business by WinZO. Supplier further represents and warrants that it will not in the future offer, promise, make or otherwise allow to be made or provide any payment and that it will take all lawful and necessary actions to ensure that no payment is promised, made or provided in the future by any of the Supplier Personnel.
- Privacy Officer: Saumya Singh
- Email: email@example.com
- Address: 1000 N. West Street, Suite 1200, Wilmington, Delaware, USA- 19801