1.1 Personal Information: Information that identifies, relates to, describes, or can reasonably be linked, directly or indirectly, to a specific customer.

1.2 Customer: Refers to a person or user who is a California resident and uses the Platform for recreational purposes. This includes individuals who interact with our website, applications, or marketing materials, and those who are in California for purposes other than temporary or transitory.

1.3 Service Provider: Refers to a for-profit entity or individual that processes personal information on behalf of our business for a specific business purpose. As defined by the California Consumer Privacy Act and California Privacy Rights Act, Service Providers are prohibited from retaining, using, or disclosing personal information for any purpose other than those specified in a written agreement with us or as permitted by law.

1.4 Third Party: Any person, organization, entity, or subject that is not owned, controlled, or directly affiliated with the ALPHAX SOLUTIONS LIMITED. Third parties may include social media platforms, service providers, business partners, advertisers, affiliates, or external platforms that assist in delivering, analyzing, or improving our services, products, or communications.

1.5 API: A set of guidelines and protocols that enables different software applications to communicate and work together. APIs allow the integration of functions from one system into another, enabling access to data, execution of operations, or interaction with services provided by external platforms.

2.1 We collect the following categories of personal information from California residents:

3.1 We may gather your information in various ways, such as directly from you when you visit our website, create an account, make transactions on https://winlycoins.com/, or interact with us by filling out forms (e.g., customer service inquiries), using our chat features, or through other communication methods.

3.2 We may also collect data about your usage of our products and services through technologies present on https://winlycoins.com/ or within our applications on third-party platforms. These technologies include cookies, which are small text files placed on your device that help us remember your preferences, settings, and past interactions with our site. They do not contain personal information and cannot be used to identify you as an individual. Cookies help us improve the functionality of our site and understand how users engage with it. For more detailed information, please refer to our Cookie Policy.

3.3 Information about you may also be obtained from third parties, such as our business partners, affiliates, service providers, advertising networks, or publicly accessible sources. This can include demographic details, interest-based information, or data shared by social media platforms when you connect your account to our services.

3.4 We may collect data related to your behavior and preferences while using our website and applications, including your browsing patterns, session durations, and the pages you view.

3.5 If you share content like reviews, comments, or other posts on our site or application, this information may also be collected and processed.

3.6 We use analytics tools to gather additional information when you visit https://winlycoins.com/ or interact with our applications and services on third-party websites or platforms.

4.1 We use your personal information for the following purposes.

4.2 We may collect sensitive personal information such as your social security number, financial account details, precise geolocation, or other sensitive data. You have the right to limit the use and sharing of such sensitive personal information. If you wish to limit the use of your sensitive personal information, please contact us at dataprivacy@winlycoins.com.

5.1 We do not sell Customers' personal information, but we may transfer the necessary information to Third parties that provide services for our Platform, including:

5.2 We may also share data with advertising partners, but only in an anonymized or aggregated form that does not identify you as an individual.

5.3 All Service Providers are required to enter into a data processing agreement with us, which ensures compliance with security, confidentiality, and data use requirements for the specified purposes only.

5.4 We may disclose or transfer your personal data where such disclosure is required by law, regulation, legal process, or enforceable governmental request. Any such disclosure will be made strictly in accordance with applicable legal requirements, and only to the extent necessary to comply with those obligations.

5.5 Over the past twelve (12) months, we have not collected, disclosed and sold any categories of personal information.

6.1 We implement comprehensive measures to safeguard your personal information through administrative, technical, and physical protections, including password security, secure servers, and encrypted data transmission.

6.2 Access to personal data is limited to authorized personnel with a legitimate business need. Access rights are periodically reviewed to ensure compliance and appropriateness.

6.3 We conduct regular security audits and vulnerability assessments to identify and address potential risks. Sensitive data is encrypted during both transmission and storage to protect it from unauthorized access.

6.4 Our incident response plan ensures a quick and effective approach to mitigate security breaches and minimize risks.

6.5 Employees undergo ongoing security awareness training to improve their ability to identify threats and properly handle confidential information.

6.6 Advanced monitoring systems and real-time detection tools enable us to proactively identify and respond to unusual activity or potential security threats.

7.1 If you are a California resident, you have the following rights:

7.2 You have the right to opt-out of the sale of their personal information. If you are a California resident, you may request that we do not sell your personal information. To exercise this right, please click on the 'Do Not Sell My Personal Information' link on our website or contact us directly at dataprivacy@winlycoins.com

8.1 To exercise any of your rights under the CCPA, you may: Submit a request: Email us at dataprivacy@winlycoins.com

8.2 Verify your identity: For your protection, we may need to verify your identity before processing your request by asking for additional information and documents (ID card, driving license, passport and proof of address).

8.3 These contact options are available to submit any requests related to your rights under the CCPA, including but not limited to requests for access, deletion, or opt-out.

9.1 We retain your personal information only as long, as needed to verify your identity and meet compliance duties. The legal bases are legal obligation and our legitimate interests in fraud prevention, security, record-keeping, and defending legal claims. Identification/compliance records are kept for the period required by law. All other data not required for identification or legal obligations is kept no longer than 36 months from last activity or service completion, then securely deleted or anonymized; longer retention may apply where a legal hold is in place.

10.1 Our Platform is only for customers who are 18 years of age or older. We do not knowingly collect personal information from individuals under the age of 18. If you believe we have unintentionally collected information from a minor, please contact us at dataprivacy@winlycoins.com, and we will take steps to delete such information.

11.1 We are firmly committed to protecting your personal data and information, and we will take reasonable technical measures accepted in our industry to ensure the security of your information and protect it from loss, misuse, or alteration. However, if you notice any risk or security breaches, we encourage you to report them to us at dataprivacy@winlycoins.com so that we can address the issue as quickly as possible.

12.1 We may update this Privacy Policy from time to time, but at least once per year. When we make changes, we will notify you by updating the "Last Updated" date at the top of this page.

13.1 If you have any questions or concerns about this Privacy Policy or how we handle your personal information, please contact us at: