Last Updated: 8/25/2021
What Information do we Collect?
Information Collection And Use - While using our Service, we may ask you (the “Parent” or“You”) to provide us with certain information that can be used to contact or identify you as the parent (“Personal Information”). This information may include your name, address, phone number, email address, or photograph. We collect this information for the purpose of providing the Service, identifying and communicating with you, responding to your requests/inquiries, servicing your purchase orders, notifying you about winning giveaways and/or sweepstakes, and improving our services like sending updates about your activity with our apps and services.
Non-personal information - We collect information about how you use the Winzos Platform, such as the features you use and the time spent on the Winzos Platform. We associate this information with an internal account we assign to you for our internal purposes, including, for example, to help us recognize you across devices you use to access the Winzos Platform and personalize your experience based on your last Winzos Platform use. When you access the Winzos Platform by or through a mobile device, we may collect certain information including, but not limited to, the type of mobile device you use, and your mobile operating system. We may collect analytics data to help us measure traffic and usage trends for the Winzos Platform and to understand more about the demographics of our users. We use this information to customize the function and appearance of the Winzos Platform based on information related to your account.
How We Use the Information We Collect
Platform Operation – We use the information we collect to operate, maintain, enhance, and provide all of the features of the Winzos Platform. We also use it to personalise your experience while using the Winzos Platform, including on various devices you use to access the Winzos Platform. For instance, we may remember your recent activity so we can keep track of your progress and position and recommend the most appropriate content for you on your next visit. In addition, we use the information collected to understand and analyse the usage trends, behaviours, and preferences of our users, to improve the way the Winzos Platform works and looks, and to develop new features and functionality. Lastly, we use the information to maintain, develop, support, and improve the Winzos Platform and other educational products and services we may offer from time to time.
Communications - We may use your Personal Information to contact you with newsletters, marketing or promotional materials, notifications regarding giveaways, and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
How We May Share or Transfer Information to Others
Communications - We may use your Personal Information to contact you with newsletters, marketing or promotional materials, notifications regarding giveaways, and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in anyThird-Party Vendors and Service Providers – We may share information with our trusted vendors, third-party service providers, and individuals to provide services or products for us or on our behalf, which may include hosting, email delivery, advertising, and business administration or professional services. When we share Personal Information with such third-parties, they are contractually obligated to maintain the security and confidentiality of that Personal Information. We use third-party advertising networks and other affiliates in association with cookies, pixel tags, or Iframes for visits to the Winzos Platform to (1) deliver interest-based advertising to those users, including Winzos-branded advertising, when you visit third-party websites; and (2) provide us with statistics about the effectiveness of our advertising on third-party websites. These third-party advertising networks may use this cookie information in accordance with their own privacy policies. We do not disclose the Personal Information of any User to third parties for any marketing or promotional purposes, except as explicitly described to you in certain circumstances, where your consent will be required (such as in advertising giveaway winners). Except as otherwise explicitly provided in specific situations, this information is for internal use only and is encrypted. email we send.
De-identified or Aggregate Information – We may share information in aggregated and/or anonymous form that cannot reasonably be used to identify any individual.
Compliance With Laws - We will disclose your Personal Information where required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and there as on able requests of law enforcement or to protect the security or integrity of our Service.
Third-Party Advertising – We use third-party advertising companies to serve ads when you visit our Web site. These companies may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other Web sites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please see: [http://www.networkadvertising.org/managing/opt_out.asp]
How We Approach Data Security
Data Retention - Winzos also retains data only as long as it is necessary to provide the service. If it is no longer needed, we delete data from our records within a reasonable timeframe. If you want to opt out of services, or review or delete your information, please contact us.
How to Access, Change, or Delete Information
You can review or change the information you provided when you registered for the Winzos Platform, including by adding or removing Child Users to or from the Account, by updating information through the Parent Section of the Winzos Platform. In addition, you may contact us at any time to request that we provide for their review, or delete from our records, any PersonalInformation you have provided about Child Users associated with your Account, or to cease collecting Personal Information from those Child Users, as applicable. Please keep in mind that are quest to delete Personal Information may lead to cancellation of your Account or the in ability to use certain services on the Winzos Platform.
We have designed our app for parents and their young children. Winzos is committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. We do not intend Winzos for use by children under the age of 13 without parental supervision. In addition, users must be 18 or older to be eligible to register for a Winzos account. We have taken measures so features are age-gated, so that they’re not for use by children, and we do not knowingly collect Personal Information from children under the age of 13 in connection to those features. We collect a username created by the Parent for the child. Any usage information when a child or parent uses the Winzos Platform is associated with the Parent’s information. We use it to operate, personalise, maintain, enhance, and provide all of the features of the Winzos Platform. This information is not used for marketing or advertising purposes.
Winzos also takes measures to prevent children from submitting Personal Information to us and prevent children from accessing features that may collect or publish such information. If you area parent or guardian and you learn that your children have provided us with PersonalInformation, please contact us. If we become aware that we have collected Personal Information from children under age 13 without verification of parental consent, we remove that information from our servers.
We take additional steps to protect children’s privacy, including: 1) Notifying parents about our information practices with regard to children 2) Limiting our collection of information to no more than is reasonably necessary to deliver our learning experiences.
As a parent, you can change the child’s username at any tie in the Winzos Platform. Parents should contact us at firstname.lastname@example.org to permanently delete the child’s information from our systems.
European Union Data Protection
For personal data subject to the European Union General Data Processing Regulations (GDPR),we rely on several legal bases to process the data. These legal bases include where:
● The processing is necessary to perform our contractual obligations in our Terms ofService or other contracts with you (such as to. provide you the Winzos Platform as described in our Terms of Service);
● You have given your prior consent, which you may withdraw at any time (such as for marketing purposes or other purposes we obtain your consent for from time to time);
● The processing is necessary to comply with a legal obligation, a court order or to exercise or defend legal claims;
● The processing is necessary for the purposes of our legitimate interests, such as in improving, personalising, and developing the Winzos Platform, marketing the Winzos Platform, such as new features or products that may be of interest, and promoting safety and security as described above.If you have any questions about or would like further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided below.Residents in the European Union are entitled to certain rights with respect to PersonalInformation that we hold about them:
● Right of access and portability. The right to obtain access to your Personal Information, along with certain related information, and to receive that information in a commonly used format and to have it transferred to another data controller;
● Right to rectification. The right to obtain rectification of your Personal Information without undue delay where that personal information is inaccurate or incomplete;
● Right to erasure. The right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the Personal Information is no longer necessary in relation to the purposes for which it was collected or processed;
● Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Information in certain circumstances, such as where the accuracy of the Personal Information is contested by you, for a period enabling us to verify the accuracy of that Personal Information; and
● Right to object. The right to object, on grounds relating to your particular situation, to the processing of your Personal Information, and to object to processing of your PersonalInformation for direct marketing purposes, to the extent it is related to such direct marketing.
You may also have the right to make a complaint to the relevant “Supervisory Authority.” If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. In some cases our ability to uphold these rights for you may depend upon our obligations to processPersonal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
California Privacy Rights
Effective January 1, 2020, the CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. In this section "you" or "your" refers to California residents only. Under the new law we are required to disclose the categories of sources from whom we collect personal information, and the third parties with whom we share it, which we have explained above. We are also required to communicate information about rights you have under California law, such as:
● Right to access Personal Information. You may be entitled to receive the specific pieces of your Personal Information we hold
● Right to data portability. You may be entitled to receive a copy of your electronicPersonal Information in a readily-usable format
● Right to disclosure. You may be entitled to receive information regarding the categories of Personal Information we collected, the sources from which we collected PersonalInformation, the purposes for which we collected and shared Personal Information, the categories of Personal Information that we sold and the categories of third parties to whom the Personal Information was sold, and the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding your request
● Right to deletion. You may be entitled to request that we delete the Personal Information that we have collected from you. We will use commercially reasonable efforts to honur your request, in compliance with applicable laws. Please note, however, that we may need or be required to keep such information, such as for our legitimate business purposes or to comply with applicable law.
Right to opt-out of certain sharing with third parties. You may be entitled to direct us to stop disclosing your Personal Information to third parties for monetary or other valuable consideration. You can exercise such right to opt-out.
We will never monetize the Personal Information of any Registered User of the Winzos Platform by providing it to a third party in exchange for money. The CCPA has a broader definition of the term "sell" which includes disclosing Personal Information to any third party for valuable consideration. When we work with our advertising partners we are disclosing certain information such as cookies for their services, which are of value to us. You may be entitled to direct us to stop disclosing your Personal Information to third parties for monetary or other valuable consideration. You can exercise such right to opt-out.
Information we Collect and Share
In addition, we are required to provide you certain information about the business and commercial purposes for which we collect and share your Personal Information.
Business and Commercial Purposes for which we use Personal Information: We use and disclose the information we collect from each of the Categories of Personal Information listed below for the business purposes described in this policy, including but not limited to: process payments, conduct research, detect security incidents and prevent fraud, debug and repair errors, maintain your account, provide customer service, enabling and affecting commercial transactions and advancing our commercial and economic interests, such as delivering interest-based advertising to Parent Users and analysing the effectiveness of our advertisements and other activities to improve our service, show advertising, market our services, and understand how users interact with our services.
Categories of Personal Information we collect: In the preceding 12 months, we have also disclosed the following categories of personal information for one or more business purposes:identifiers, commercial information, internet or electronic network activity information, and inferences we draw or derive about users.
Categories of Sources from which we collect Personal Information: We collect PersonalInformation from each of the aforementioned Categories of Personal Information from you.
Categories of Third Parties with whom we share Personal Information: We share PersonalInformation from each of the aforementioned Categories of Personal Information with the following categories of Third Parties, including as part of a sale or for commercial or business purposes:
Categories of Personal Information we share with Third Parties: We share, and have shared during the past 12 months, the following categories of Personal Information with Third Parties, including as part of a sale or for commercial or business purposes: personal identifiers such as name and credit card number; commercial information, such as services subscribed to, obtained or considered; and information regarding your interaction with or use of our products and services. We do not sell the Personal Information of children under 16 years of age.
Exercising Access, Disclosure, Data Portability, and Deletion Rights
To exercise the access, disclosure, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either contacting us at email@example.com
Only you or a person registered with the California Secretary of State that you authorise to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your child.
You may only make a verifiable consumer request for access or data portability twice within a12-month period. The verifiable consumer request must:
● Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorised representative.
● Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify there questior's identity or authority to make the request.
We fully support your privacy rights and will not discriminate against you for exercising any of your CCPA rights.