WINR Corporation Pty Ltd., will be referred to herein as “WINR”, “we”, “us”, and “our.”
WINR serves and distributes advertising content online that may include video and display content.
Our clients are publishers and advertisers, we work with both parties to ensure that advertising is displayed on the websites owned or operated by the publishers we work with.
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.
If you have any queries about how we collect or use data, please contact us at email@example.com
WINR is invested in complying with the GDPR in relation to a user’s interaction with Distributed Content on a Participant Site, or through the use of the WINR site or other services.
TECHNOLOGIES USED BY WINR TO COLLECT INFORMATION
WINR reserves the right to use one or more varieties of technologies to collect information at Participant Sites and WINR sites.
These are listed and described below.
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.
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).
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.
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.
Third party suppliers or services:
WINR does work with third party technology or service providers, such as, for example, Google, 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.
We do not actively seek or knowingly receive information from these third party providers about individual users.
Information collection on participant sites:
When you visit a participant site in our advertising network and view distributed content placed by us, we collect information about your activities as described below. We do not collect any personal information as defined by the GDPR on participant sites.
We may merge data we collect about you from third parties to assist us in our ability to provide the Site, including, without limitation, to advertise and provide content to you. Our work in this respect is compliant with the Digital Advertising Alliance’s Principles for the Self-Regulation of Online Behavioral Advertising.
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.
Some Distributed Content may seek to collect personal or other information as part of a client campaign. Consent to do so will be sought before proceeding and the particulars of the processing will be made clear at that point.
Notwithstanding the above, WINR will not, collect, use or sell personal information to or for its benefit or the benefit of any third party.
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.
At this time we do not respond to browser ‘Do Not Track’ signals, as we await the work of interested stakeholders and others to develop standards for how such signals should be interpreted.
Personal Data Collection on the WINR site:
Personal Data is collected on the WINR site in various instances including, without limitation:
- Access to web-based client interface
- Access to web-based client interfaces do not require personal information.
A client or prospect 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.
USE OF INFORMATION
We generally use non-personal information in aggregated form to help measure the performance and effectiveness of WINR services.
This information may be used:
- To operate and improve our services
- To communicate with you and respond to your inquiries
- To conduct research about and analyse your use of our services
- To provide reporting to our partners about the performance of our advertising, analytics and other services
Additionally, you should be aware of the following:
WINR does not share personal information of any clients with other organisations for their marketing or promotional uses without your express consent.
USER ACCESS & CONTROL
In the event that you provide your information to us via our website or ad placements, WINR may periodically send promotional materials or notifications related to the Company to the email address you may have provided to us. If you want to stop receiving such promotional materials, please send an email to firstname.lastname@example.org
If you would like to access, review, correct, update, suppress, or otherwise limit our use of your personal information you have previously provided directly to WINR, you may do so by contacting us via email at email@example.com. In your request, please include your name and specify clearly what information you would like to access, change, update and/or whether you would like to have your personal information suppressed from our database, or if you have other questions about your personal information.
WINR does not knowingly collect personal information from individuals under the age of 18. In the event you become aware that an individual under the age of 13 has enrolled without parental permission, please advise us immediately by email at firstname.lastname@example.org
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.
We retain information that we collect and receive in non-aggregate form for as long as is reasonably necessary for the purposes for which it was collected.
CHANGES TO THIS POLICY
If there are significant changes to our information practices, you will be provided with appropriate online notice.
LOCATION OF DATA
The Site is hosted in and managed from Australia. If you are a user located outside Australia, you understand and consent to having any personal information transferred to and processed in Australia.
Or you may contact us by mail at:
WINR Corporation Pty Ltd (ACN 630 368 188)
Suite 42, 41 McLaren Street, Sydney NSW 2000
Effective Date: May 24, 2019.