PRIVACY POLICY

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 Winzo Website (the “Website”)or WinZO’s mobile application (the “App”). WinZO operates a global online platform, which hosts skill-based games (“Games”) to be played for free, or in a pay to play for a winning format (“Services”). Users will be able to play/participate against each other and win real money in skill based Games (“Winnings”), with such Winnings being deposited by us and available for deposit by Users through their User wallets (“Wallets”).

WinZO is committed to protecting the privacy of its Users whose information is collected and stored while using WinZO’s Platform through our Website or App. This Privacy Policy is applicable to our Website, Platform and all applications offered for sale to the public.

The capitalized terms have the same meaning as ascribed in our Terms of Use or Terms of Service as applicable, unless otherwise noted here.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY ACCESSING OR USING OUR WEBSITE, APP, AND PLATFORM, YOU AGREE TO ACCEPT ALL THE TERMS CONTAINED IN THIS PRIVACY POLICY AND ACKNOWLEDGE AND AGREE WITH THE PRACTICES DESCRIBED HEREIN. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE OUR WEBSITE, APP, AND 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 INFORMATION, NOR DO WE INTEND TO DO SO. WE DO NOT GIVE ACCESS TO YOUR PERSONAL INFORMATION TO THIRD PARTIES EXCEPT TO SUBPROCESSORS TO ASSIST US IN THE PROVISION OF OUR SERVICES TO YOU.

Our Website, App, and Platform is available for use in the US. Some of our offerings are not available in certain US states, defined as Restricted States in our a href='/en-us/terms-of-service'>Terms of Service (“Restricted States”). If you are a resident of the United States (“US”), the laws of the State where we are incorporated (Delaware), the state where we are headquartered (Delaware), and the state in which you live may apply. If you reside outside the United States, you must ensure compliance with your local laws. All Users must comply with this Privacy Policy, our Terms of Use and Terms of Service, as applicable.

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

When you register to use our Website, App, or Platform, we collect personal information (also referred to as personally identifiable information or “PII”) which may include your name, address, online contact information such as your email address or username, phone number, and other personal information. The information so collected will be stored on our servers. You are able to change your personal information collected by us via email by contacting us at privacy@winzogames.com or through your profile or account settings on our Website, App, or Platform.

1. Geolocation and Equipment Information
   We may collect information that does not personally identify you such as (i) your geolocation, and (ii) information about your internet connection, the equipment you use to access our Website, App, or Platform, and usage details related to our Website, App, or Platform. We ask Users for their explicit consent prior to collecting information on your geolocation at the time of registration on the App.
2. Financial Information
   We currently do not collect or store any credit cards or bank information, as we are using a third-party payment processor, such as PayPal and Checkout. However, we will update this Privacy Policy when we start using and storing such information. We will also inform you via reasonable means if we start collecting such information from you.
3. Payment Methods
   We do collect and store information regarding the mode of payment associated with your Wallet such as whether a User uses Unified Payments Interface, Bank Transfer, Credit Card, Debit Card on their Wallet. This information cannot identify a User and is not PII
4. KYC related Information.
   We currently do not collect or store any sensitive personal information as we are using a third-party, Jumio (“KYC Partner”) to perform Know Your Customer compliance checks (“KYC”) for all our Users. Our KYC Partner’s Privacy Policy is available at https://www.jumio.com/legal-information/privacy-notices/. Our KYC Partner, as part of the KYC process may ask you to submit (a) government-issued identification, such as a driver's license or passport; (b) proof of address, such as a utility bill or bank statement; (c) financial information such as credit card information, credit rating, credit history or financial reports. Please note that the specific requirements for KYC compliance can vary depending on the regulations in the state or jurisdiction where you are residing and our KYC Partner’s discretion is operating. Our KYC Partner is also responsible for conducting checks on each User to determine compliance with anti-money laundering (“AML”), Office of Foreign Assets Control (“OFAC”), and countering the financing of terrorism (“CFT”) regulations and may seek additional information and data from you in this regard. All information collected, processed, or stored by the KYC Partner on behalf of WinZO for Users is referred henceforth as “KYC Information.” WE DO NOT COLLECT, PROCESS, OR STORE ANY KYC INFORMATION AS WE USE OUR KYC PARTNER FOR THIS PURPOSE. PLEASE REFER TO OUR KYC PARTNER’S POLICIES TO UNDERSTAND WHAT KYC INFORMATION IS COLLECTED, HOW THE KYC INFORMATION IS PROCESSED, STORED, AND DISCLOSED, FOR HOW LONG THE KYC INFORMATION IS RETAINED, AND YOUR RIGHTS WITH RESPECT TO SUCH KYC INFORMATION. IT IS EXPRESSLY CLARIFIED AND USER UNDERSTANDS THAT WINZO IS NOT RESPONSIBLE OR LIABLE FOR ANY HANDING, USE, PROCESSING, STORING, DELETING, OR DISCLOSURE OF SUCH KUC INFORMATION.
5. OTP Information
   All Users on our App must provide phone numbers to be linked to their profiles and account. All Users must go through the mobile one time password (“OTP”) verification process before using our Services. YOU SPECIFICALLY CONSENT TO OUR SENDING YOU SMSES OR MOBILE MESSAGES TO AUTHENTICATE EACH TIME YOU ATTEMPT TO REGISTER OR LOGIN TO YOUR ACCOUNT OR PROFILE FROM OUR APP. In future, we might allow log-ins and registrations via social media handles such as Facebook, Gmail, Apple Id (“Social Media Sites”), in which case once the user logs in and register for our Services we will the user’s email id and limited profile information, including User’s profile pictures and images from the from such social media sites. We will inform you via reasonable means if we start collecting such information from you.
6. 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”); and (ii) commercial purchase information for the transactions or purchases made by the User on our Website or App, such as deposit added by the User to User’s Wallet, boot amount paid for participating in a game (“Boot”), or Winnings on each Game won in a particular game, etc. (“Transaction Data”).

We collect personal information from you in the following ways:

1. At registration on our Website, App, or Platform
2. In email, text, and other electronic messages between you and our Website, App, or Platform
3. Through mobile and desktop applications your downloads from our Website, App, or Platform, which provides dedicated non-browser based interaction between you and our Website, App, or Platform
4. From you placing an order, which includes details of transactions you carry out on our Website, App, or Platform
5. From your responses to a survey
6. From forms filled out by you
7. From records or copies of correspondences (including email addresses) if you contact us
8. From search queries on our Website, App, or Platform.

We collect information from you automatically when you navigate through our Website, App, or Platform in the following ways:

1. Usage details
2. IP addresses.

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

We use the information that you provide to:

1. Personalize your experience in using our Platform
2. Provide you with information, products, or services requested from us
3. Present our Website, App, and Platform and their contents to you
4. Provide you with notices about account and/or subscription, including expiration and renewal notices
5. Carry out obligations and enforce rights arising from contracts entered into between you and us, including billing and collection
6. Notify you about changes to our Website, App, and Platform and any products or services
7. Allow you to participate in interactive features on our Website, App, and Platform
8. Improve the Website, App, and Platform
9. Improve our customer service
10. Administer contests, promotions, and surveys or other Website, App, and Platform features
11. Process transactions
12. Anonymize data and aggregate data for statistics
13. Contact you for other purposes with your consent
14. Contact you about our products and services that may be of interest
15. Enable the display of advertisements to our advertisers’ target audiences, although personal information is not shared with advertisers without your consent
16. Send you periodic emails, in accordance with the CAN-SPAM Act of 2003 as detailed in Section 14, via the email address provided by you to (i) send information, respond to inquiries, and/or other requests or questions; (ii) process orders and send information and updates pertaining to such orders; (iii) send additional information related to your product and/or service; and (iv) market to our mailing list or continue to send email to you after the original transaction has occurred.

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 all of these technologies as “Cookies.”
While we do not use Cookies on our Website and App, we do integrate certain trusted third-party services and Cookies on our Website and App 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 (e) allow trusted third-party services that track this information on our behalf. You can set your browser to refuse all or some browser Cookies. And it will not affect your User experience.
We use third parties (“Sub-processors”), who have access to personal information of our consumers to perform some of the operational functions to provide a full service to our Users. Please see Section 15 for more information on our Sub-processors.

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

Our Website and App are reasonably scanned to meet or exceed PCI Compliance. Our Website and App receive regular security scans and penetration tests. Our Website and App also receive regular malware scans. In addition, our Website and App use an SSL certificate as an added security measure. We require username and passwords for our employees who can access your personal information that we store and/or process on our Platform and servers. In addition, we actively prevent third parties from getting access to your personal information that we store and/or process on our Platform and servers. We accept payment by credit card through a third party credit card processor on our behalf. We will implement reasonable security measures every time you (a) place an order, or (b) enter, submit, or access your information, (c) register, or (d) access our Platform, on our Website and App.

1. Security Measures.
   We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information 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 Website, App, or 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. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website, App, or Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our Website, App, or Platform.
2. Fair Information Practice Principles
   In the event of a personal data breach, we will notify you within forty eight (48) hours via (i) mobile message or email, and/or (ii) our Platform notification system on our Website and/or App. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
3. Open-Source Software:
   We use the following open-source software in the provision of our Services, which can be found here.

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

1. Disclosure of Personal Information.
   • We may disclose aggregated, de-personalized information about you that does not identify any individual to other parties without restriction, such as for marketing, advertising, or other uses.
   • We may disclose personal information to our subsidiaries and affiliates.
   • We may disclose personal information to contractors, services providers, and other third parties.
   • We require all contractors, service providers, and other third parties to whom we disclose your personal information to be under contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose them.
   • We may disclose personal information in the event of a merger, sale of business, etc.
   • We may disclose to third parties to market their products and services to you if you have either consented or not opted out of these disclosures.
   • We require all other Partners, to whom we disclose your personal information, to enter into contracts with us to keep personal information confidential and use it only for the purposes for which we disclose it to such Partners.
   • We disclose personal information to fulfill the purpose for which you have provided it, for instance, if you gave us an email address to use the “email a friend” feature of the Platform.
   • We may only disclose personal information as described in this Privacy Policy or your consent.
2. Other Disclosure of Personal Information.
   • We will disclose personal information
     1. to comply with any court order, law, or legal process, including to respond to any government or regulatory request,
     2. to enforce or apply our Terms of Use or Terms of Service and other agreements, including for billing and collection purposes,
     3. if we believe it is necessary or appropriate to protect the rights, property, or safety of WinZO, our Users or others, and/or
     4. if it is necessary or appropriate to protect the rights, property, or safety of WinZO, our Users, or others, and this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
3. Third Party Disclosure.
   • We do not sell, trade, rent, or otherwise transfer personal information to others, unless we provide you with advance notice. This does not include our hosting partners and other parties who assist us in operating our Website, App, or Platform, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.
   • We provide non-PII (disaggregated, de-personalized) to other parties for marketing, advertising, or other uses. Please note, however that such non-PII 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.
4. Choices Users Have About How WinZO Uses and Discloses Information.
   • Tracking Technologies and Advertising.
     You can set their browser to refuse some or all the browser cookies, and it will not affect your User experience.
   • Disclosure of User’s Information for Targeted Advertising.
     Users can opt-out by (i) checking the relevant form or checkbox when we collect the data, or (ii) filling out an online form letting us know of their desire to opt-out.

Google, as a third-party vendor, uses Cookies to serve advertisements to Users on our Website, App, and Platform. Google uses first-party Cookies, such as Google Analytics Cookies, to compile 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 data regarding User interactions with ad impressions and other ad service functions as they relate to our Website or App.

1. For Our Brazilian Users
   This Section supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others to our Website, App, or Platform, who reside in Brazil (“consumers” or “you”). We comply with the Lei Geral de Proteção de Dados (General Data Protection Law, or LGPD) and any terms defined in the LGPD have the same meaning when used in this Section.
   • Brazilian Data Protection Officer
     We have appointed a Brazilian Privacy and Data Protection Officer, at privacy@winzogames.com to make sure the privacy rights of our Brazilian users are protected in compliance with LGPD.
   • Data Breach
     In the event of a personal data breach, we will notify the User within 48 hours via (i) email or message, and/or (ii) our Platform notification system on our Website/Platform. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non compliance by data processors.

1. Your California Privacy Rights
   • California Civil Code.
     WinZO does not sell, trade, or otherwise transfer to outside third parties your “Personal Information” as the term is defined under the California Civil Code Section § 1798.82(h). Additionally, California Civil Code Section § 1798.83 permits Users of our Website, App, or Platform that are California residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. To make a request for such disclosure, or identification and/or deletion of Personal Information in all our systems that we store on you, please send an email to privacy@winzogames.com or write us at WinZO, 1000 N. West Street, Suite 1200, Wilmington, Delaware, USA- 19801. Note that (i) if we delete your Personal Information as requested, we will no longer be able to provide our services to you and (ii) we may need to keep such Personal Information for a while during the shutting down and billing process. If you would like to discuss our Personal Information storage and processing process with us, please send us an email at privacy@winzogames.com or write us at WinZO, 1000 N. West Street, Suite 1200, Wilmington, Delaware, USA- 19801.
   • CPRA
     This Section supplements the information contained in our Privacy Policy above and applies solely to all visitors, users, and others to our Website, App, or Platform, who reside in the State of California (“consumers” or “you”). We adopt this Section to comply with the California Privacy Rights Act that is effective from January 1, 2023 (“CPRA”) and any terms defined in the CPRA have the same meaning when used in this Section.
     1. Right to Request Personal Information: Upon request, we will provide you with (i) a list of all Personal Information that we have collected on you, (ii) from whom we obtained such Personal Information, (iii) the reason why we collected such Personal Information, and (iv) with whom (if any) we have shared such Personal Information. If we sell your Personal Information or disclose your Personal Information to third parties, upon request, we will provide you with (i) a list of the Personal Information that we have collected on you, (ii) a list of the Personal Information that we sell or disclose to others on you, and (iii) to whom we have sold or disclosed your Personal Information. A consumer can make such a request only twice in a 12-month period. We require such Personal Information to be able to provide to you our Services. Unless otherwise specified, we only collect Personal Information from you. We do not use others to provide us with your Personal Information.
     2. Disclosure of Personal Information. We only share your Personal Information with service providers, e.g., billing and collection agents, who enable us to provide our Services to you. We do not sell or give your Personal Information to third parties for purposes unrelated to our provision of Services to you.
     3. Right to have Personal Information Deleted. Upon request, we will delete all of your Personal Information that we have collected on you and will direct our Service Providers to also delete all of your Personal Information. But note that if we do delete all of this Personal Information, you will no longer be able to use our Services.
     4. Non-Discrimination Right. We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not:
        
        • Deny you goods or services
        • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
        • Provide you a different level or quality of goods or services.
        • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services
     5. Financial Incentives. However, we may offer you certain financial incentives permitted by the CPRA that can result in different prices, rates, or quality levels. Any CPRA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
     6. Contact Information. You may contact us (i) at privacy@winzogames.com, (ii) by phone at our toll-free number [1-800- ], or (iii) by writing to us at Privacy Officer, at 1000 N. West Street, Suite 1200, Wilmington, Delaware, USA- 19801 to (i) make a Personal Information Request, (ii) lodge a complaint about our use or storage of your Personal Information, (iii) ask us to delete such Personal Information, and/or (iv) discuss our Privacy Policy and/or anything that has to do with it. We will respond within forty-five (45) days of receiving such request or query. Additionally, in order for us to respond to your request or query, we will need to collect information from the requesting party to verify their identity.
     7. Under 16. We will not sell your Personal Information of any Users, including any persons under the age of 16.
     8. Opt In Consent. We will only process, collect, use and store your Personal Information upon receiving your express consent to do so. YOU EXPRESSLY AGREE THAT YOU HAVE READ, UNDERSTOOD, AND CONSENT TO WINXO COLLECTING, USING, PROCESSING, DISCLOSING, STORING, AND RETAINING YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY, OUR TERMS OF SERVICE, AND OUR TERMS OF USE WHEN YOU CHECK THE APPLICABLE BOX SIGNIFYING YOUR CONSENT. YOU EXPRESSLY AGREE THAT THIS CONSENT IS FREELY GIVEN, EXPRESS, AND AFFIRMATIVE.
     9. Right to Opt-Out. At any time, upon your request, we will stop selling your Personal Information (sometimes called your Opt Out-Right). You may send the request to Opt Out (i) to privacy@winzogames.com, or (ii) by writing to us at Privacy Officer, 1000 N. West Street, Suite 1200, Wilmington, Delaware, USA- 19801.
     10. Data Protection Officer. We have appointed a Privacy and Data Protection Officer at privacy@winzogames.com to make sure the privacy rights of our Users are protected.
2. Other State Privacy Rights
   This Privacy Policy explains how we collect, use, and disclose your Personal Information in the Sections above. This Section describes how to exercise your rights under the various state privacy laws as detailed below (“State Privacy Laws”)
   • Massachusetts
     The Massachusetts Data Protection Law (201 CMR 17.00), sets standards for the protection of personal information of residents of Massachusetts. Residents of Massachusetts have the following rights under Massachusetts law (i) the right to request access to their personal information that is held by us and to receive a copy of that information; (ii) the right to request the correction of any inaccurate or incomplete personal information; (iii) the right to request that we delete your personal information; (iv) the right to opt-out of the collection, use, or disclosure of your personal information for marketing purposes; (v) the right to be notified in the event of a data breach involving their personal information; and (vi); the right to Opt-in for collection, use or disclosure of Sensitive Personal Information. Further, you have the right to file a complaint with the Massachusetts attorney general if you believe we have violated the Massachusetts Data Protection Law by calling (617) 727-8400 or filing a complaint at https://www.mass.gov/how-to/file-a-consumer-complaint.
   • Colorado
     The Colorado Privacy Act (Colo. Rev. Stat. § 6-1-1301 et seq.) protects the privacy of Colorado consumers. Residents of Colorado have following privacy rights (i) you have the right to opt out of the processing of your personal data for the purposes of targeted advertising, the sale of your personal data or profiling in furtherance of decisions that produce legal or similarly significant effects; (ii) you have the right to confirm whether we are processing personal data concerning you and to access your personal data; (iii) you have the right to correct inaccuracies in your personal data; (iv) you have the right to delete your personal data; and (v) when accessing your data, you have a right to obtain that data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit that data to another business
   • Connecticut
     WinZO does not sell, trade, or otherwise transfer to outside third parties your “Personal Data” as the term is defined under Connecticut’s Privacy Act and Act Concerning Personal Data Privacy and Online Monitoring. Connecticut Laws permits residents of Colorado who are Users of our Website, App, or Platform that are Connecticut residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. Further, Users have the right to (i) confirm whether or not we are processing the your personal data and access such personal data, unless such confirmation or access would require us to reveal a trade secret; (ii) correct inaccuracies in the User’s personal data; (iii) opt out of the processing of the personal data for the purposes of targeted advertising, sale, or profiling in furtherance of solely automated decisions; and (iv) you have the right to obtain a copy of your personal data processed by the controller, in a portable and, to the extent technically feasible, readily usable format
   • Utah.
     On March 24, 2022, Utah enacted the Utah Consumer Privacy Act (UCPA § 13-61-102(1)) which will go into effect on December 31, 2023. The UCPA gives residents of Utah who are users of our Website and App the right to (i) you to opt out of the processing of your personal data for the purposes of targeted advertising, the sale or profiling; (ii) correct inaccuracies in your personal data; (iv) delete your personal data; and (v) obtain that data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit that data to another business.
   • New York:
     The New York Privacy Act sets strict rules about how businesses must handle consumers’ personal information and gives individuals new rights concerning data. New York residents have the rights to (i) access, correct, deletion, and disclosure regarding your Personal Information; and (ii) know what personal information is being collected about them, how it is being used, and with whom it is being shared.
   • Virginia.
     The Virginia Consumer Data Protection Act (Va. Code § 59.1-571 et seq.) effective from January 1, 2023 provides Virginia residents with certain rights regarding the collection, use, and sharing of their personal information namely (i) the right to know what personal information is being collected about them, how it is being used, and with whom it is being shared; (ii) the right to request that a business delete personal information that the business has collected from the resident; (iii) the right to non-discrimination for the exercise of their privacy right; (iv) the right to access the personal information held about them, including the categories of personal information collected, used, shared, and the categories of third parties with whom the information is shared; (v) the right to obtain a copy of their personal information in a structured, commonly used and machine-readable format

To exercise any of the rights mentioned un Section 11(b), please (i) send an email to privacy@winzogames.com, or (ii) write to us at Privacy Officer, 1000 N. West Street, Suite 1200, Wilmington, Delaware, USA- 19801.

Note that (i) if we delete your Personal Information as requested, we will no longer be able to provide our services to you and (ii) we may need to keep such Personal Information for a while during the shutting down and billing process. We have appointed a Privacy and Data Protection Officer to make sure the privacy rights of our Users are protected.

The Children’s Online Privacy Protection Act (“COPPA”) is a federal legislation that applies to entities that collect and store “Personal Information,” as the term is defined under COPPA, from children under the age of 13. We are committed to ensure compliance with COPPA. Our Website, App, and Platform are not meant for use by children under the age of 13. Our Website, App, and Platform do not target children under the age of 13. If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at privacy@winzogames.com. IF YOU ARE UNDER 18, PLEASE DO NOT ACCESS OR USE OUR WEBSITE, APP, OR PLATFORM.

The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will:

1. not use false or misleading subjects or email addresses
2. identify the email message as an advertisement in some reasonable way
3. include the physical address of WinZO, which is 1000 N. West Street, Suite 1200, Wilmington, Delaware, USA- 19801
4. monitor third-party email marketing services for compliance, if one is used
5. honor opt-out/unsubscribe requests quickly
6. give an “opt-out” or “unsubscribe” option

If you wish to opt out of email marketing, follow the instructions at the bottom of each email or contact us at privacy@winzogames.com and we will promptly remove you from all future marketing correspondences.

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. We will also send you an email describing such changes. 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.

WinZO uses the following third-party service providers for the provision of services as detailed under the Terms of Use or Terms of Service, as applicable

Additionally, if you have any questions or concerns about our third-party service providers, please email us at privacy@winzogames.com.

If you believe that any content on our Website, App, or Platform violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to the Digital Millennium Copyright Act of 1998 (“DMCA Takedown Notice”)) must be provided to our designated Copyright Agent.

1. Your physical or electronic signature
2. Identification of the copyrighted work(s) that you claim to have been infringed
3. Identification of the material on our Website, App, or Platform that you claim is infringing and that you request us to remove
4. Sufficient information to permit us to locate such material
5. Your address, telephone number, and email address
6. A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law
7. A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner

WinZO’s Copyright Agent to receive DMCA Takedown Notices is [CONTACT PERSON], at dmca@winzogames.com and at WinZO, Attn: DMCA Notice, 1000 N. West Street, Suite 1200, Wilmington, Delaware, USA- 19801. You acknowledge that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all the requirements of this Section. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney’s fees incurred by WinZO in connection with the written notification and allegation of copyright infringement

WinZO represents and warrants that it is fully aware of and will comply with, and in the performance of its obligations hereunder will not take any action or omit to take any action that would cause it or its customers to be in violation of, (i) U.S. Foreign Corrupt Practices Act, (ii) U.K. Anti-Bribery Act, (iii) India Prevention of Corruption Act of 1988, or (iv) any other applicable anti-bribery statutes and regulations, and (v) any regulations promulgated under any such laws. Company represents and warrants that neither it nor any of its employees, officers, or directors is an official or employee of any government (or any department, agency or instrumentality of any government), political party, state owned enterprise or a public international organization such as the United Nations, or a representative or any such person (each, an “Official”). Company further represents and warrants that, to its knowledge, neither it nor any of the Supplier Personnel has offered, promised, made or authorized to be made, or provided any contribution, thing of value or gift, or any other type of payment to, or for the private use of, directly or indirectly, any Official for the purpose of influencing or inducing any act or decision of the Official to secure an improper advantage in connection with, or in any way relating to, (A) any government authorization or approval involving WinZO, or (B) the obtaining or retention of business by WinZO. Supplier further represents and warrants that it will not in the future offer, promise, make or otherwise allow to be made or provide any payment and that it will take all lawful and necessary actions to ensure that no payment is promised, made or provided in the future by any of the Supplier Personnel.

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

• Privacy Officer: Saumya Singh
• Email: privacy@winzogames.com
• Address: 1000 N. West Street, Suite 1200, Wilmington, Delaware, USA- 19801