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Win2Win App - Privacy Policy

Last Revised :
January 25, 2019

This Privacy Policy describes the information in which Confatalis Limited Liability Company and its subsidiaries and affiliates (“Win2Win”, “we”, “our”, or “us”) collect through websites that we operate and any mobile application of ours (each, an “App”, or “Win2Win”), how we use, disclose and protect your information and the choices you can make about your information.

Consent

By accessing Win2Win, you expressly consent to the collection, use, disclosure and storage of your information and other information received by us as a result of such use in accordance with this Privacy Policy and the User Agreement or your consent, and as permitted or required by applicable law. If you do not agree with the terms of this Privacy Policy or User Agreement, you should immediately stop using or accessing Win2Win.

Please note that Win2Win may be hosted in countries other than yours, including the United States. By accessing Win2Win, you expressly consent to the transfer of your information outside of your home country, which may provide for different data protection rules than in your country. We make use of third-party service providers, including service providers located in the United States and the European Union to store and process data, including your information, on our behalf.

When acting on our behalf, such service providers are only authorized to collect, use, disclose or store Personal Information as described in this Privacy Policy. However, the government, courts, law enforcement, security, or regulatory agencies of a particular country may be able to obtain access to or disclosure of Personal Information as permitted by the laws of that country.

Collection and Use of Information

The types of information collected are as follows:

(a) Direct Information : We may ask for certain information, such as your first name, last name, email address, and telephone number from you in order to operate, maintain, and provide to you the features and functionality of Win2Win.

(b) Third-Party Information : We may receive information about you from third parties including third party social networking services. You should always review, and if necessary, adjust your privacy settings on third party websites and services. We also may collect information about you from third party business partners, publicly available sources and our subsidiaries and affiliates.

(c) Analytics Information : We may directly collect information or use analytics tools to help us measure traffic and usage trends for Win2Win.

(d) Cookies Information : When you visit Win2Win, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your device that uniquely identifies your browser and lets us help you log in faster and enhance your navigation (“Cookie”).

A Cookie may also convey information to us about how you use Win2Win (e.g., the pages you view, the links you click and other actions you take), and allow us and/or our third party business partners to track your usage of Win2Win over time.

A persistent Cookie remains on your device after you close your browser. Persistent Cookies may be used by your browser on subsequent visits to Win2Win. Persistent Cookies can be removed by following your browser's directions.

A session Cookie is temporary and disappears after you close your browser. You can set your browser to refuse certain Cookies or to indicate when a Cookie is being sent. However, some features of Win2Win may not function properly if the ability to accept Cookies is limited or disabled.

(e) Server Log File Information : We may receive server log information relating to your device and your use of Win2Win. When you use Win2Win, our servers automatically record certain log file information. The information contained in these server logs is used to monitor, assess, manage, diagnose problems with, improve and otherwise administer Win2Win.

(f) Device Identifiers : When you access Win2Win by or through a mobile device (including but not limited to smart phones or tablets), we and/or our third party business partners may access, assign, collect, monitor and/or remotely store one or more unique device-specific identifiers, such as a universally unique identifier (UUID) (“Unique Identifiers”).

Unique Identifiers are small data files or similar data structures stored on and/or associated with your mobile device, which uniquely identify your mobile device. A Unique Identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by us.

A Unique Identifier may convey information to us about how you browse and use Win2Win. A Unique Identifier may also be used to help you log in faster and enhance your navigation through Win2Win.

(g) Location Data : When you access Win2Win by or through a mobile device, we may access, collect, monitor and/or remotely store location data, which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device (“Location Data”).

Location Data may convey to us information about how you browse and use Win2Win. Location Data may be used to personalize and customize your experience when using Win2Win, facilitate the functionality of certain features within Win2Win, and to improve Win2Win. Some features of Win2Win, particularly location-based services, may not function properly if use or availability of Location Data is impaired or disabled.

Sharing of Information

Information may be disclosed to third parties in accordance with this Privacy Policy.

(a) Third-Party Information Sharing : We may share your information with third party business partners that function on our behalf. Examples include, but are not limited to, companies that assist us with serving advertisement within Win2Win, analyzing data, and providing marketing assistance. We may share information about you that they need to perform their functions. We will use contractual or other means to protect Personal Information disclosed to such third parties. We may also share your information with any subsidiary or affiliate of ours for purposes consistent with this Privacy Policy. Any subsidiary or affiliate of ours will be required to maintain that information in accordance with this Privacy Policy.

(b) A Business Change Event : If we become involved in a merger, consolidation, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, we may share or transfer your information to a third party or parties in connection therewith.

(c) Legal Requirements : Regardless of the choices you make regarding your information and to the extent permitted or required by applicable law, we may disclose information about you to third parties to:

(i) enforce or apply the User Agreement;

(ii) comply with law, in response to subpoenas, warrants, or court orders, or in connection with any legal process or cooperate with government or law enforcement officials or private parties;

(iii) protect our rights, reputation, safety and property, or that of our users or others;

(iv) protect against legal liability;

(v) establish or exercise our rights to defend against legal claims; and/or

(vi) investigate, prevent or take action regarding suspected illegal activities, suspected fraud, the rights, reputation, safety or property of us, users or others, violation of the User Agreement, our policies or agreements or as otherwise required by law.

(e) Service Type Information : We may share certain service type information, including information obtained through tools such as Cookies, Server Logs, Unique Identifiers, and Location Data with our third party business partners for the purposes described in the section above on "Collection and Use of Information." We may also aggregate or otherwise strip data of all personally identifying characteristics (such as your name and email address) and may share that aggregated, anonymized data with third parties.

(f) Advertising Partners : We may also share certain information and data, such as Location Data, browser and Cookie data, Unique Identifier data, and other data relating to your use of Win2Win, with our advertising partners to deliver advertisements (“ads”) that may be of interest to you. We may allow third party advertisers, including but not limited to direct advertisers, ad networks, ad exchanges, and private advertising marketplaces (collectively “Advertisers”), to serve advertisements on Win2Win.

These Advertisers use technology to send, directly to your browser or mobile device, the ads and ad links that appear on Win2Win, and will automatically receive your Internet Protocol (IP) address when they do so. They may also use other technologies (such as Cookies, javascript, Unique Identifiers, Advertising Identifiers, and Location Data) to compile information about your browser's or device's visits and usage patterns on or off Win2Win and between multiple platforms such as your computer and your mobile device, measure the effectiveness of their ads, and personalize the advertising content to your interests.

You can opt out of receiving certain Cookies by adjusting your browser settings to refuse certain Cookies or to alert you when a Cookie is placed. Your browser settings may not permit you to block the use of certain non-Cookie technologies, and those browser settings that block Cookies may have no effect on such techniques.

Please note that Advertisers may ask us to show an ad to a certain audience of users (e.g., based on demographics or other interests). In that situation, we may

(i) determine the target audience and serve the ads to that audience, or

(ii) provide certain data as described above to the Advertisers to enable them to serve the ads to the target audience.

If you respond to such an ad, the Advertiser or ad server may conclude that you fit the description of the audience they are trying to reach.

We do not sell, rent, or share Personal Information we collect directly from you or about you from third parties with third party Advertisers for their own marketing purposes, unless you choose in advance to have such information shared for this purpose.

(g) Data Analysis : We may use third-party data analysis service providers to collect data and to provide information to us on the performance of Win2Win. These companies may use information about your use of Win2Win and other websites and mobile applications to compare information about the performance of Win2Win. These companies do not use personally identifiable information (such as your name, email address or telephone number) when performing data analysis.

These companies may also use non-Cookie technologies to recognize your computer, browser or mobile device and/or to collect and record information about your browsing activity, including your activities on or off Win2Win and between multiple platforms such as your computer and your mobile device. Please keep in mind that your browser settings may not permit you to block the use of these non-Cookie technologies, and those browser settings that block Cookies may have no effect on such techniques.

This Privacy Policy does not apply to, and we cannot control the activities of, third party Advertisers. Please consult the respective privacy policies of such Advertisers or contact such Advertisers for more information.

Security

We care about the security of your Personal Information, and take physical, technological and administrative measures to protect the information you submit via Win2Win against loss, theft, and unauthorized access, use, disclosure or modification. However, we cannot ensure or warrant the security of any information you transmit to us or guarantee that information on Win2Win may not be accessed, disclosed, altered or destroyed. Please remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

Children’s Privacy

We do not knowingly collect personally identifiable information from children under 18. In the case we discover that a child under 18 has provided us with Personal Information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with Personal Information, please contact us immediately at win2win@confatalis.com so that we can take the necessary appropriate actions.

Link to Other Sites

Win2Win may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

California Privacy Rights

Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of Personal Information the business has shared with third parties for those third parties' direct marketing purposes and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one (1) request each year by emailing us at win2win@confatalis.com.

If you are a California resident under age 18 and a registered user of Win2Win, you may ask us to remove content or information from Win2Win by emailing us at win2win@confatalis.com. Please note that such removal does not ensure complete or comprehensive removal of the content or information posted (for example, your content or information may remain visible because it was copied and posted or reposted by a third party).

European Economic Area Rights

If you are a natural person residing within the European Economic Area, additional rights as expressed under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 known as the General Data Protection Regulations (“GDPR”) are applicable to you.

Contact Us

For all inquiries relating to this Privacy Policy, please contact us at win2win@confatalis.com.