Privacy Policy

WINR CORP. PRIVACY POLICY

WINR Corporation Pty Ltd., will be referred to herein as “WINR”, “we”, “us”, and “our.”

WINR, a company based in Sydney Australia, respects the privacy of our users and has developed this Privacy Policy to demonstrate its commitment to protecting your privacy. This Privacy Policy is intended to describe for you, as an individual who uses our services, the information we collect, how that information may be used, with whom it may be shared, and your choices about such uses and disclosures.

We encourage you to read this Privacy Policy carefully when using our website or services or transacting business with us. By using our website, you are accepting the practices described in this Privacy Policy.

If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us.

Who is WINR? What does WINR do?

WINR serves and distributes advertising content online that may include video and display content.

Our clients are publishers and advertisers. We work with them to ensure that advertising is displayed on the websites owned or operated by the publishers we work with.

In this Privacy Policy, we will refer generally to the video and display ads and other content we serve as “Distributed Content” and the sites we work with in our publisher network which offer and display our clients’ ads as “Participant Sites.”

All Participant Sites are operated or controlled by third parties (“Partners”), and the collection, use and disclosure of information collected by a Participant Site or other parties working with such site are governed by its or their privacy policies. This Privacy Policy does not apply to the Participant Sites or such other parties.

The Distributed Content we display on Participant Sites allow you to view offers, promotions, app download invitations, surveys/poll invitations and interact with other marketing services(collectively “Offers”) from third-party brands (“Brands”). Some Offers may invite you to sign up to receive communications in respect of such Offers, including by email, phone or SMS, from Brands or Partners, and from WINR.

If you do not agree to have your information used in any of the ways described in this Privacy Policy, you may discontinue use of any and all services provided by WINR as it relates to the adoption of these services by our clients. By using any site where WINR’s technologies are utilised by our clients (Participant Sites), you are consenting to the placing of cookies and other telecommunications tools on your device which allow WINR to collect certain information. We provide more detail on this below.

Information we collect about you on Participant Sites

In General. We may collect personal information that can identify you such as your name and email address and other information that does not identify you. When you provide personal information through a Participant Site, the information may be sent to servers located in Australia, the United Kingdom, the EU, the United States and other countries around the world.

Information you provide. We may collect and store any personal information you enter on a Participant Site or provide to us in some other manner. This includes identifying information, such as your name, address, e-mail address, and telephone number. We also may request information about your interests and activities, your gender and age, and other demographic information.

Information from other sources. We may also periodically obtain both personal and non-personal information about you from other business partners, contractors and other third parties. Examples of information that we may receive include (but are not limited to): updated delivery and address information, purchase history, and additional demographic information.

Information collected automatically. We automatically collect information from your browser when you visit a Participant Site. This information includes your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us (see “Cookies” below), and the referring website address.

Cookies:
A cookie is a small piece of text sent to your browser by a website you visit. The cookie allows the website to remember information about you, such as your preferred language and other general settings.

Most of the cookies are stored in your browser which usually gives you the ability to manage them (though browsers for mobile devices may not offer this possibility).

Cookies play an important role. Without them, browsing the web would be a much more frustrating experience, as they enable the simplicity and ergonomics of the online daily routine. Working with our participant sites, we may use cookies for a number of purposes, such as preventing you from watching the same ad over and over again (i.e. frequency capping).

WINR uses cookies on the WINR site to help regulate and facilitate the use by our clients of the console and other client account areas.

A user may configure his or her web browsers to accept or reject or delete the cookies, or notify the user when a cookie is being set.

Pixels:
A tracking “pixel” is a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page and allows for the collection of information regarding the use of the web page that contains the tracking pixel. WINR collects technical and usage information (see below) through the use of tracking pixels.

Clients:
Some advertisers or other clients (and their third-party service or technology providers) may use additional pixels, cookies, flash cookies, web beacons and/or similar technologies which are activated when their Distributed Content is viewed by users across our network of Participant Sites.

We may request and receive aggregate, non-personal information from our clients from time to time but we do not actively seek from our clients (or their service providers) any information about any individual users. This Privacy Policy does not apply to the Participant Site or such other parties.

Third party suppliers or services:
WINR does work with third party technology or service providers, such as, for example, Google, Facebook, Amazon Web Services and AppNexus. These may provide it with hosting, cloud-based computation, serving, general campaign or site analytics, ad serving data.

Such third party providers may utilise pixels, cookies, flash cookies, web beacons and/or similar technologies that may be activated when our clients’ Distributed Content is encountered on a Participant Site.

In all instances where the use, collection and disclosure of information is by one of these third party providers, their privacy policies shall govern and this Privacy Policy does not apply.

We do not actively seek or knowingly receive information from these third party providers about individual users.

Technical Information:
When we serve distributed content, we log and analyse technical information that is openly available to our servers such as information about the kind of browser being used (e.g., Safari, Internet Explorer), the type of operating system it’s running on (e.g., Windows, Mac OS, mobile OSes), the speed and type of Internet connection (e.g., narrowband, broadband, mobile), and other technical information.

This information is anonymous and generally non-personal but does include “internet protocol addresses” or “IP addresses”. WINR archives all technical information (including any such IP addresses) in various formats.

Information we collect about you on the WINR site

Personal Data is collected on the WINR site in various instances including, when a client, prospect or job applicant may be required to provide his or her contact details, which may include or feature personal information, in order to get in touch with WINR. Doing so provides implicit consent from said user for WINR to contact them.

WINR does not share personal information of any clients with other organisations for their marketing or promotional uses without your express consent.

How we use the information we collect

Interaction with our Advertising Units and Other Usage Information:
WINR uses a proprietary advertising unit to serve our clients’ Distributed Content.

This unit can be hosted on a web page, be featured as part of an application or widget, or be embedded within another advertising unit.

WINR collects data about a user’s interactions with the unit, such as what Distributed Content has been featured, played or clicked; when it is video, whether playback is paused or stopped, and information collected in relation to the serving and display of Distributed Content, etc.

Additionally, we may also collect information about the page you visited at a Participant Site if our unit or Distributed Content is present on said page, including what site or page you came from, how long you spent on our unit, your click activity on the unit.

The usage and interaction data helps us understand and report to our clients about whether and how often an item of Distributed Content is watched and interacted with, whether partially or fully, and in what context, by users across our network of Participant Sites.

Offers. Some Distributed Content may invite you to sign up to an Offer. There is no obligation to sign up to an Offer. When you engage with an Offer, we may share personal information with the party identified in the Offer, to offer you those products, services and/or promotions. When you elect to engage in a particular Advertiser’s Offer, you authorize us to provide your personal information, including name, and contact details such as email address, mobile phone number or postal address to that Advertiser, so that they may contact you by mail, telephone/sms/mms and email.

CHILDREN’S PRIVACY
WINR does not knowingly collect personal information from individuals under the age of 13. If we learn that we have collected Personal Information on a child under the age of 13, we will delete that data from our systems. WINR encourages parents and guardians to monitor their children’s activities online.

OTHER INFORMATION SHARING
WINR may disclose one or more clients’ and/or individual users’ information if required to do so by law (or in a good-faith belief that such action is necessary or advisable in order to comply with any laws of any country or region which may assert jurisdiction) or in order to respond to a judicial or other governmental action, order, subpoena, request, demand or warrant.

We may make such disclosures without providing notice to you.

WINR may also reserve the right to disclose one or more clients’ and/or individual users’ information if it is appropriate or necessary in WINR’s discretion in order to: Take precautions against liability; protect against fraudulent, abusive, or unlawful uses; investigate or defend against any third-party actions or allegations (including assisting a client or third party to do so); assist government enforcement agencies; or protect the security, integrity, rights, property, or personal safety of WINR, its systems and services, as well as its employees, clients or others.

WINR may in the future, and shall have the right to implement technology to, collect or share any information, including any client’s or individual user’s information, that we determine to be necessary or advisable in order to comply with a judicial order or to cooperate with government and law enforcement officials.

There is the possibility that WINR, or parts of the company or its affiliates, may one day be purchased by, or merged with, another company or otherwise disclosed or transferred as part of a merger, acquisition, debt financing or sale of assets, including in the event of an insolvency, bankruptcy or receivership. In that the case, the acquiring (or merging) company will have access to your information.

Your rights

You have a number of rights regarding the processing of your Personal Information, including:

Right of access. You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; together with information regarding the nature, processing and disclosure.

Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.

Right to delete your information. You have a right to request, on legitimate grounds, to delete any personal information which we are holding about you.

Right to restrict use of your information. You have a right to request, on legitimate grounds, to restrict the way that we process your personal information.

Right to data portability. You have a right to ask us to provide your personal information to a third party provider of services.

Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.

Right to file. You have the right to file a complaint with a Data Protection Authority regarding the processing of your Personal Information by us or on your behalf.

We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period allowed by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Privacy Policy, or about processing of your Personal Information, please use the contact methods described below. If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

DATA PROTECTION & RETENTION

How we protect your personal information

We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal information from unauthorized access and disclosure. For example, only authorized employees are permitted to access personal information, and they may do so only for permitted business functions. We use firewalls to help prevent unauthorized persons from gaining access to your personal information.

Data Retention

WINR sets data retention periods in consultation with Partners and Brands in determining how long to retain the Personal Information about you and supplied to us by them, subject to you exercising your lawful data subject rights, and further subject to any requirement for us to hold data for such period as may be required to establish, exercise or defend legal rights or ongoing legitimate interests (e.g to prove that you signed up to a particular Offer). These periods may vary in accordance with the laws of the country you live in. If WINR has no ongoing legitimate business need to process your Personal Information, we will take all reasonable steps to delete and/or ensure your Personal Information is deidentified.

WINR is not responsible for how long Partners or Brands may retain your Personal Information. You should consult the privacy notices provided by Partners and Brands with whom you interact.

CHANGES TO THIS POLICY

WINR may update this Privacy Policy from time to time, and so you should review this Policy periodically.

If there are significant changes to our information practices, you will be provided with appropriate online notice.

You may be provided other privacy-related information in connection with your use of offerings from WINR, as well as for special features and services not described in this Privacy Policy that may be introduced in the future.

CONTACT US

UK enquiriesFor UK Based Enquiries:

VeraSafe has been appointed as WINR Corporation’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union.

VeraSafe can be contacted in addition to info@winr.com.au, only on matters related to the processing of personal data.

To make such an inquiry, please contact VeraSafe using this contact form:

https://www.verasafe.com/privacy-services/contact-article-27-representative

or via telephone at: +420 228 881 031.

Alternatively, VeraSafe can be contacted at:

VeraSafe United Kingdom Ltd.
Suite 1, 3rd Floor 11-12 James Square
London SW1Y 4LB

United Kingdom

AU enquiriesFor Australian and all other enquiries:

If you have questions about this Privacy Policy or complaints, please contact us via email at:
info@winr.com.au

Or you may contact us by mail at:

WINR Corporation Pty Ltd (ACN 630 368 188)
50 Miller St,
North Sydney
NSW 2060
Australia

Effective Date: 1st June, 2020.