WINZO PRIVACY POLICY

Last Updated: December [day], 2023

WE WILL POST ANY CHANGES TO THIS PRIVACY POLICY IN A NOTICE OF THE CHANGE AT THE BOTTOM OF OUR WEB PAGE WITH A HYPERLINK THERETO. PLEASE REGULARLY REVIEW THIS PRIVACY POLICY. NOTWITHSTANDING IF YOU CONTINUE TO USE OUR SERVICES, YOU ARE BOUND BY ANY CHANGES THAT WE MAKE TO THIS PRIVACY POLICY.

INTRODUCTION

WinZO US Inc. (“WinZO,” “we,” “us,” or “our”) respects the privacy of its users (“User,” “your,” or “you”). This Privacy Policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your information when you use WinZO Platform (the “Platform”) through WinZO’s website at https://www.winzogames.com/pt-br & https://www.winzogames.com/en-br (the “Website”) or WinZO’s mobile application (the “App”) accessible at https://play.google.com/store/apps/details?id=com.winzo.platform&hl=pt&gl=BR

WinZO operates a global online platform, which hosts skill-based games to be played for free. For further details on our Services, please visit our Terms of Services at [https://www.winzogames.com/pt-br/blog/terms-of-service-winzo-us-inc/] (“Terms of Services”).

WinZO is committed to protecting the privacy of its Users whose Personal Data is collected and stored while using WinZO’s Platform through our Website or App. This Privacy Policy is applicable to our Platform and all the App. Your use of our Website, App, or Platform shall constitute your acceptance of this Privacy Policy and to all of the terms and conditions stated under this Privacy Policy.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR PERSONAL DATA AND HOW WE WILL PROCESS IT. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE OUR PLATFORM.

IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT PRIVACY@WINZOGAMES.COM.

WE DO NOT SELL YOUR PERSONAL DATA, NOR DO WE INTEND TO DO SO. WE DO NOT GIVE ACCESS TO YOUR PERSONAL DATA TO THIRD PARTIES EXCEPT TO THIRD PARTIES WHO ASSIST US IN THE PROVISION OF OUR SERVICES TO YOU.

DEFINITIONS

Please see below some data protection terms used in this Privacy Policy:

“Personal Data” is any information related to an identified or identifiable person, for instance, Users’ name, address, telephone number, email address, ID number, voice chat records, date of birth, IP address, among others;
“Data Subject” is a person to whom the Personal Data refer to – in this case, the Users;
“Data Controller” is a natural or legal person that make decisions regarding the processing of Personal Data, for instance, definitions of purposes and means of the processing of Personal Data – in this case, WinZO;
“Data Processor” is a natural or legal person that processes Personal Data on behalf of the Data Controller – in this case, WinZO’s affiliates and/or certain third parties hired by WinZO to perform data processing activities on behalf of WinZO;
“Processing” is any operation which is performed on Personal Data, for instance, collection, recording, storage, adaptation, alteration, use, disclosure, erasure and destruction;
“Data Protection Officer” or “DPO” is the natural or legal person appointed out by WinZO to act as a communication channel between the Data Controller, the Data Subject and the Brazilian Protection Authority;
“Brazilian Protection Authority” or “ANPD” is a public authority responsible for the implementation and the supervision of LGPD in Brazil;
“LGPD” is the Brazilian Data Protection Law, Law 13,708/18, which purpose is to regulate the processing activities carried out with Personal Data within Brazil; and
“Applicable Data Protection Laws” encompass LGPD and any other data protection law or regulation, including rules enacted by ANPD, applicable to the Processing carried out by WinZO related to the performance of the Service.

Other capitalized terms have the same meaning as ascribed in our Terms of Services as applicable, unless otherwise noted here.

TERRITORIAL RESTRICTION

Our Platform is 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, create account, and/or use our Website, App, or Platform. If you have any questions regarding this Section, please email us at privacy@winzogames.com.

WHAT PERSONAL DATA DO WE COLLECT?

When you create an account to use our Platform (“Account”), we collect your Personal Data which may include your name, address, online contact information such as your email address or username, phone number, and other Personal Data. The Personal Data so collected will be stored on servers owned by WinZO and/or our affiliates. You are able to update your Personal Data collected by us via email by contacting us at privacy@winzogames.com or through your profile or the Account settings on our Platform.

Geolocation and Equipment Information. We may collect (i) your geolocation, and (ii) information about your internet connection (such as internet protocol), the equipment you use to access our Platform, and usage details related to our Platform. The purpose of collection of this Personal Data is to ensure that a User is not operating from a restricted area (outside the territory of Brazil). Any User that does not allow for us to collect and process geolocation information shall not be permitted to access our Platform or use our Services.

Information for Verification: When a User creates their Account on our Platform and every time a User logins on our Platform, the User will be prompted to provide their mobile number on which they shall receive a one-time password or OTP as an SMS/message/WhatsApp message/message through any other channel/mode, along with permission to access contacts, phone call logs, and permission to manage phone calls. The purpose of collecting this mobile number and the above permission is to verify the User’s identity, implement fraud prevention mechanisms and to enable a seamless sign-up on our Platform and for our referral features (“Verification”).

One-time password or OTP Information. All Users on our Platform must provide phone numbers to be linked to their profiles and account. All Users must go through the mobile one-time password verification process before using our Services. WE WILL SEND YOU SMSs OR MOBILE MESSAGESAS AN SMS/MESSAGE/WHATSAPP MESSAGE/MESSAGE THROUGH ANY OTHER CHANNEL/MODE TO AUTHENTICATE EACH TIME YOU ATTEMPT TO CREATE AN ACCOUNT OR LOGIN TO YOUR ACCOUNT OR PROFILE FROM OUR PLATFORM We may also allow logins and account creation/account linking via social media handles such as Facebook, Gmail, Apple ID (“Social Media Sites”), in which case once the user creates an account for our Services, we will use the User’s email ID and limited profile information, including User’s profile pictures and images from such social media sites. We will inform you via reasonable means if we start collecting such information from you.

Game-Play Data. 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”).

Chats. We store messages and voice chats carried out between Users in our Platform and may access the content of those communications to investigate user claims and prevent fraud.

HOW DO WE COLLECT PERSONAL DATA?

We collect Personal Data from you in the following ways:

At creation of the Account on our Platform;
In email, text, and other electronic messages sent by you on our Platform;
Through mobile and desktop applications you download from our Platform, which provides dedicated non-browser based interaction between you and our Platform;
From your responses to a survey related to Games, our Services and the Platform;
From forms filled out by you related to Games, our Services and the Platform;
From records or copies of correspondences (including email addresses) if you contact us; and
From search queries on our Platform.

We collect Personal Data from you automatically when you navigate through our Platform in the following ways:

Usage details; and
IP addresses.

We also collect Personal Data through third parties, such as business partners such as our Partners and Social Media Sites, when it is necessary to provide our Services to you. If you have any questions regarding this Section, please email us at privacy@winzogames.com.

HOW DO WE USE YOUR PERSONAL DATA?

We use the Personal Data that you provide to:

Personalize your experience in using our Platform;
Provide you with information, Games, or Services requested from us;
Present our Platform and their contents to you;
Provide you with notices about the Account and/or subscription, including expiration and renewal notices;
Carry out obligations and enforce rights arising from contracts entered into between you and us;
Notify you about changes to our Platform and any Games or Services;
Allow you to participate in interactive features on our Platform, if any;
Improve the Platform;
Improve our customer service;
Administer surveys or other Platform features;
Anonymize data and aggregate data for statistics;
Contact you for other purposes with your consent;
Contact you about our Games and Services that may be of interest;
Enable the display of advertisements to our advertisers’ target audiences, although Personal Data is not shared with advertisers without your consent; and
Send you periodic emails via the email address provided by you to (i) send information, respond to inquiries, and/or other requests or questions; (ii) send additional information related to your Games and/or Service; and (iii) market to our mailing list or continue to send email to you after the original transaction has occurred.

YOU ACKNOWLEDGE AND AGREE THAT WE MAY USE, STORE, BACK-UP, COPY, TRANSMIT, DISTRIBUTE, COMMUNICATE AND OTHERWISE MAKE AVAILABLE, THE USER DATA YOU PROVIDE, UPLOAD, SHARE, TRANSMIT OR OTHERWISE MAKE AVAILABLE TO OR FROM, OUR PLATFORM, SOLELY FOR THE PURPOSES OF ENABLING YOU TO USE OUR SERVICES AND FOR ANY OTHER PURPOSE RELATED TO PROVISION OF THE SERVICES TO YOU.

OUR COOKIE POLICY

Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this Privacy Policy, we refer to these technologies as “Cookies.”

We integrate certain trusted third-party services and Cookies on our Platform to (a) understand and save your preferences for future visits, (b) compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future, and (c) allow trusted third-party services that track this information on our behalf. You can set your browser to refuse all or some browser third-party Cookies.

We use third parties who have access to Personal Data of our Users to perform some of the operational functions to provide a full service to our Users.

Occasionally, at our discretion, we may include links to third-party products or services on our 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 Platform and welcome any feedback at about these sites. Please contact us at privacy@winzogames.com.

Google AdSense and Google Analytics

In addition to the above, Google, as a third-party vendor, uses Cookies to serve advertisements to Users on our Platform. Google uses first-party Cookies, such as Google Analytics Cookies, to compile Personal Data regarding User interactions with ad impressions and other ad service functions as they relate to our Platform. We currently use Google Analytics to collect and process certain Website and App usage data. To learn more about Google Analytics and how to opt-out, please visit https://policies.google.com/privacy/google-partners.

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 Personal Data regarding User interactions with ad impressions and other ad service functions as they relate to our Platform through our Website or App.

HOW DO WE PROTECT PERSONAL DATA WE COLLECT?

Our Platform receives regular security scans and penetration tests, including malware scans. In addition, our Platform uses an SSL certificate as an added security measure. We require username and passwords for our employees who can access your Personal Data that we store and/or process on our Platform and servers. In addition, we actively prevent third parties from getting access to your Personal Data that we store and/or process on our Platform and servers. We will implement reasonable security measures every time you (a) place an order, or (b) enter, submit, or access your information, (c) create an Account, or (d) access our Platform, through our Website and App.

DATA SECURITY MEASURES

Security Measures. We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. All Personal Data you provide to us is stored on our secure servers behind firewalls. The safety and security of your Personal Data 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 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, as it is subject to third parties who acts in bad faith. We do our best to protect your Personal Data, but please be aware while providing any Personal Data via internet, including for us or any other third parties.

Data Breach. In the event of a breach involving Personal Data that may create risk or relevant damage to Users, we will notify you on our Platform.

DATA RETENTION.

If not set out otherwise in this Privacy Policy, WinZO will retain the Personal Data for (i) the period necessary to fulfill the purposes outlined in Section 6 (How Do We Use Your Personal Data?), in particular as long as necessary to identify potentially fraudulent behavior and (ii) as long as required by law or (iii) as long as relevant potential legal claims are not yet time-barred.

DISCLOSURE OF PERSONAL DATA

There are times when Personal Data that you have shared with us may be shared by WinZO with others to enable us to provide you our Services, including Data Processors, 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 Data. The following describe how and with whom we may share your Personal Data:

Disclosure of Personal Data.

We may disclose aggregated and de-personalized information related to you that does not identify you or any individual to other parties without restriction, such as for marketing, advertising, or other uses. Under LGPD, anonymized data is not deemed as Personal Data. In any case, we will make sure that process of anonymization applied to your Personal Data will not be reversed;
We may disclose Personal Data to our subsidiaries, parent company, group companies and affiliates that integrate WinZO Group.
We require all Partners to whom we disclose your Personal Data to entered into contracts with us and to be under contractual obligations to keep Personal Data confidential and to use it only for the valid and regular purposes for which we disclose them.
We may disclose Personal Data in the event of a merger, sale of business, etc.
We disclose Personal Data to fulfill the purpose for which you have provided it.
We may only disclose Personal Data as described in this Privacy Policy or your specific consent.

Other Disclosure of Personal Data.

We will disclose Personal Data (i) to comply with any court order, law, or legal process, including to respond to any government or regulatory request, (ii) to enforce or apply our Terms of Service and other agreements, and (iii) if we believe it is necessary or appropriate to protect the rights, property, or safety of WinZO group our Users or others, and this includes exchanging information with other companies and organizations for the purposes of fraud protection.

Third Party Disclosure.

We do not sell, trade, rent, or otherwise transfer Personal Data to others. This does not include our Partners who assist us in operating our Website, App, or Platform, conducting our business, or servicing you, and may have access to your Personal Data. IN ANY CASE, WE DO NOT SELL, TRADE AND RENT ANY OF YOUR PERSONAL DATA.

We provide disaggregated and de-personalized data to other parties for marketing, advertising, or other uses. Please note that such 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 Personal Data.

Tracking Technologies and Advertising. You can set their browser to refuse some or all the browser Cookies which are not necessary for our Services, and it will not affect your user experience.

Disclosure of User’s Personal Data for Targeted Advertising. We may send promotional messages about us and our Services related to our Platform to your email. Users can opt-out through opt-out option provided on the Platform.

INTERNATIONAL DATA TRANSFER

WinZO may transfer the Personal Data across national borders to its affiliates, external firms and third parties, WinZO will ensure that this international transfer occurs in compliance with the Applicable Data Protection Laws. Therefore, WinZO provides below some examples of international transfer that may occur during WinZO’s activities:

WinZO’s International Data Transfer
Personal Data	Purposes	Recipients	Countries
All Personal Data collected from Users	Storage of Personal Data on Cloud Environment	Cloud Providers	US
All Personal Data collected from Users	Storage of Personal Data on Cloud Environment	Cloud Providers	India
Data regarding User interactions on the Platform	Conducting analytics of user interactions	Data analytics provider	USA

PRIVACY RIGHTS

As a Data Subject, the User has the right to, at any time and by any means:

Revoke consent, through a free and facilitated procedure. In case of revocation of consent, the processing activities carried out based on the Data Subject consent, before the revocation, will remain lawfully valid;
Confirm the Existence of Processing, at any time. The Data Subject has the right to confirm the existence of processing activities involving their Personal Data;
Access the Personal Data;
Correction and update the Personal Data. Data Subject has the right to correct and update the incorrect, incomplete, or out-of-date Personal Data that WinZO storages;
Anonymization, block, and deletion any Personal Data that is considered unnecessary, excessive, or processed in noncompliance with Applicable Data Protection Laws;
Information about their Personal Data such as whether their Personal Data has been disclosed to third party vendors, details of Personal Data shared and for what purposes such Personal Data was shared; and
Review Decisions Based Solely on Automated Processing. The Data Subject also has the right to access clear and adequate information about the criteria of the decision made solely on the automated processing of Data Subject’s Personal Data, provided that industrial and commercial secrecies are respected.

To exercise any right related to your Personal Data collected and processed by WinZO, please fill the form available on our Platform or email us at privacy@winzogames.com. Note that (i) if we delete your Personal Data as requested, we will no longer be able to provide our Services to you, depending on the category of Personal Data excluded, and (ii) we may need to keep such Personal Data for a while during the shutting down process. We may be unable to delete certain Personal Data that must be retained by us to comply with legal obligations, respond to legal queries, or detect and report fraud.

We have appointed a Privacy and Data Protection Officer to make sure the privacy rights of our Users are protected and can be exercised at any time by our Users.

MODIFICATIONS TO OUR PRIVACY POLICY

We will post any changes to this Privacy Policy in a notice of the change at the bottom of our web page with a hyperlink thereto. Please regularly review this Privacy Policy. Notwithstanding if you continue to use our Services, you are bound by any changes that we make to this Privacy Policy.

CONTACT US

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:

Privacy Officer
Email: privacy@winzogames.com

IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE OUR WEBSITE, APP, OR PLATFORM.

PRIVACY POLICY