Privacy Policy

Last updated: March 1, 2020

Privacy Notice

We know that you care about how your information is used and shared, and we, WinTogether (dba WinTogether.org, “the Company,” “we,” “our,” “us”) care about your privacy. This Privacy Notice explains how WinTogether.org collects, uses, and stores some of your personal data (excluding special categories of personal data and data relating to criminal convictions and offenses) through the use of our website, app, and services (“Product(s)”). This notice also outlines how we protect your personal data when you visit our Products (regardless of where you visit it from) and informs you of your privacy rights and how the law protects you. Please see the “Definitions” portion of this notice to understand many of the terms used throughout.

If you are a California resident, please see the “Note to California Residents” section below.

1. PURPOSE OF THIS NOTICE AND WHO WE ARE

The Purpose of This Notice
We provide this Privacy Notice explaining our online information practices and the choices you can make about the way your Personal Information is collected and used in connection with our Products and certain services that we offer through or in connection with our Products. “Personal Information” is defined below in the Definitions Section. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

By using our Products, you consent to the terms of this Privacy Notice and to the processing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Notice, please do not use our Products.

Our Contact Details
If you have any concern about our privacy practices, our use and disclosure practices, your consent choices, or if would like to exercise your rights, please contact us by email at hello@wintogether.org, or write to us at:

 

WinTogether.org
20808 State Highway 71 W, Unit B
Spicewood, TX 78669-6824

Third Parties
This Product may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Product, we encourage you to read the privacy notice of every website you visit.

2. THE INFORMATION WE COLLECT ABOUT OUR USERS

Information That You Provide

• Registration and Profile Information includes identity data, such as first name, maiden name, last name, phone number, street address, email, and date of birth.
• Financial Information includes payment cards and bank information or other service provider information necessary to transfer and receive funds.
• Marketing and Communications that you initiate with us, such as contacting our Customer Happiness team, may result in us receiving additional information such as your the contents of a message or attachments that you may send us, and other information you may choose to provide. If you choose to opt-out or unsubscribe from any marketing emails, we will also have your marketing and communications preferences.
• Career Information. In the event that you apply for a career with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience.

Information We Collect When You Use Our Products

• Location Information. When you use our Products, we receive your general location information (for example, your internet protocol (“IP”) address may indicate your more general geographic region).
• Device Information. We receive information about the device and software you use to access our Products, including IP address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.
• Usage Information includes information about how you use our Products.
• Information We Infer. We may derive information or draw inferences about you based on information we collect about you. For example, based on your browsing or purchasing activities, we may infer your purchasing preferences.
• Information from Cookies and Similar Technologies. We and third-party partners collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files that are stored on your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Products. Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies, some of the features may become inaccessible or not function properly.

3. HOW WE COLLECT YOUR DATA

We collect data about you using various methods including but not limited to:

• Automated interactions and/or technologies – As you interact with our Products, some technical data is automatically collected about your browsing, browsing patterns, and equipment. This data is collected through such technologies as log files and cookies.
• Direct interactions – You may provide us with some personal information when you communicate with us by email, phone, or otherwise. This includes personal data you provide when you: create an account in our Products; verify your account; receive payments from us (for winnings) or make purchases with us; make a donation; send us an email or “contact us” request; request marketing to be sent to you; enter a sweepstakes, promotion, or survey; or provide us with feedback.
• Third Parties – We may receive personal data about you from various third parties and public sources, like social media. You may engage with our content, such as video, applications, and other offerings. When you engage with our content on or through social networking sites, plug-ins or applications, you may allow us to have access to certain information from your public social media profile or as part of the operation of the application.

4. HOW WE USE THE DATA WE COLLECT

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

When we need to comply with a legal or regulatory obligation.

When we need to perform the contract we are about to enter into or have entered into with you.

When it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via push notifications, email, text message, or phone. You have the right to withdraw consent to marketing at any time by contacting us at hello@wintogether.org.

Your data is used, however, usage is not limited to the following ways:

• To set up your account and service our Products
• To verify your identity and authenticate your access to our Products
• To process and deliver your purchases, including the management of payment to and from you
• To prevent money laundering, fraud, and other illegal activity
• To provide you with support and troubleshooting assistance
• To communicate with you and keep you apprised of our updates
• To market our Products
• To perform analytics and research to improve our Products and the Products of our partners
• To ensure enforcement of our policies, to investigate any violations, and to comply with laws, subpoenas, government authorities, or similar legal entities, requirements, or processes.

5. DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES

We do not sell, rent, or share your Personal Information with third parties except as described in this Privacy Notice:

• Affiliates and subsidiaries – We may disclose your information with our affiliates and subsidiaries for any of the purposes described in this Privacy Notice.
• Vendors and Service Providers – We may share any information we receive with vendors and service providers retained in connection with the provision of our Products.
• Third-Party App Integrations – If you connect a third-party application to our Products, we may share information with that third party.
• Analytics Partners – We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• Advertising Partners. We may work with third-party advertising partners to show you ads we think may interest you. These advertising partners may set and access their own cookies, pixel tags and similar technologies on our Products and they may otherwise collect or have access to information about you which they may collect over time and across different websites and online services. For more information about interest-based ads, and to learn about options for opting out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices or, if you are in the EU, www.youronlinechoices.eu/. You can also access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt-out of personalized ads in mobile apps.
• Anonymized, Aggregated, or De-identified Form. We may make certain automatically-collected, aggregated, or otherwise de-identified information available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through our Products. Anonymized data does not fall within the confines of this Privacy Notice and as such may be used how we so choose.
• As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (i) comply with law enforcement requests and legal process, such as a court order or subpoena or other lawful requests by public authorities, including to meet national security or law enforcement requirements; (ii) respond to your requests; or (iii) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through our Products..
• Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Notice in effect at the time the applicable information was collected.
• Consent. We may also disclose your information with your permission or at your direction.

6. YOUR LEGAL RIGHTS

You have a right to request access to and receive information about the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place. If you wish to access or amend any Personal Information we hold about you. In addition, you may have the right to withdraw any consent you previously provided to us regarding the processing of your personal information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal.

You have the right to withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal. If you would like to exercise any of these rights, you may contact us.

7. INTERNATIONAL

The information we collect about you may be transferred to, and accessed from within, the United States and other countries, as permitted by applicable law. These other countries may not offer the same level of data protection as your home jurisdiction. We will take steps to maintain an adequate level of protection for this information in the jurisdiction(s) in which we process it.

If you are in the European Economic Area (EEA), UK, or Switzerland, you have certain rights and protections under the law regarding our processing of your personal data. Please see https://edpb.europa.eu/about-edpb/board/members_en for contact details of your local data protection authority.

8. DATA SECURITY

The security of your personal information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical, and technical safeguards, to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed in an unauthorized way. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

To the extent that we collect sensitive personal data from you (for example, your bank account number or other financial personal information), we use SSL encryption to protect that information. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. If you have any questions about the security of our Products, you may contact us.

We have put procedures in place to deal with any suspected personal data breach and will always notify you and any applicable regulator of a breach where we are legally required to do so.

9. DATA RETENTION

We store the information we collect about you for as long as is necessary for the purposes for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law, and the statute of limitations.

We may rectify, replenish or remove incomplete or inaccurate information at any time and at our own discretion.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use such information indefinitely without further notice to you.

10. NOTICE OF CHANGES

We will continue to evaluate this Privacy Policy against new technologies, business practices and our users’ needs, and may make changes to the Privacy Policy accordingly. Please check this page periodically for updates. You acknowledge that your continued use of our Products after the posting of any changes to this Privacy Policy means that you agree to be bound by such change.

11. NOTE TO CALIFORNIA RESIDENTS

This section provides details about rights afforded to California residents under the California Consumer Privacy Act (or “CCPA”), and supplemental details about the personal information we collect about California residents.

In the last 12 months, we collected the following categories of personal information: identifiers (such as name, contact information and device identifiers); internet or other network activity information (such as browsing behavior and other usage data); location data; inferences (such as purchasing preferences); demographic data (such as age); electronic, visual, or similar information (such as customer support call information); professional or employment-related information (such as in resumes you provide); and other personal information (such as product feedback or payment method information). For more details about the personal information we collect, including the categories of sources, please see the section THE INFORMATION WE COLLECT ABOUT OUR USERS above. We collect this information for the business and commercial purposes described in the HOW WE USE THE DATA WE COLLECT section above. We share this information with the categories of third parties described in the DISCLOSURES OF YOUR PERSONAL DATA section above.

Subject to certain limitations, the CCPA provides California residents the right to request to access to details about the categories or specific pieces of personal information we have collected in the last 12 months (including information we disclosed for a business purpose), to request to delete their personal information, to opt out of any electronic communications that may occur, and to not be discriminated against for exercising these rights.

We may use third-party cookies and related technologies to send targeted ads and this may be deemed a “sale” under the CCPA. To opt out of these “sales,” contact hello@wintogether.org.

California residents may make “request to access” or deletion requests by emailing us at hello@wintogether.org. We will verify your request by asking you to provide information that matches the information we have on file about you. You can also designate an authorized agent to exercise these rights on your behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly.

12. DEFINITIONS

Personal Information means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, or other contact information. It does not include data where the identity has been removed (anonymous data).

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best and most secure services, product, and experience. We always consider your rights and weigh any potential impact on you (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or are otherwise required or permitted to by law.

Performance of Contract means processing your information when necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data when we are obligated to comply with a legal or regulatory obligation.