1.1 Personal Information: Any information that is linked or can be linked to an identified or identifiable individual. This does not include de-identified or publicly available information.

2.1 Processing: Any operation carried out on personal data, whether manually or through automated means, including but not limited to collection, use, storage, disclosure, analysis, deletion, or modification.

3.1 Customer: Refers to a user or individual who engages with our platform for recreational activities, including those who interact with our website, applications, or marketing materials.

4.1 Service Provider: Refers to any third-party entity that processes personal information on our behalf to support the delivery of our services. This may include hosting providers, payment processors, marketing agencies, customer support platforms, and analytics services. Service Providers are required to process personal information strictly for the purposes outlined by us and in compliance with applicable laws.

5.1 Third-Party: Any person, organization, entity, or subject that is not directly controlled by, affiliated with, or part of WinlyCoins. Third parties may include social media platforms, service providers, business partners, advertisers, affiliates, and any external platforms that help in providing, analyzing, or improving our services, products, or communications.

5.2 API: Set of rules and system protocols that allow different software applications to interact with each other. APIs allow you to integrate functions from one system into another, such as accessing data, performing operations, or interacting with services provided by third-party platforms.

2.1 We collect the following types of information:

3.1 We may collect your information in various ways, including directly from you when you access or visit the website, register for an account, make purchases or redemptions on https://staging.winlycoins.com/, or communicate with us by filling out a form (e.g., customer service emails or requests), using our chats, or through other communication methods. We may also collect information about your use of our products and services through various technologies, including cookies, flash cookies, pixels, tags, and application program interfaces ("API"), present when you visit the site or use our applications on third-party sites or platforms, regardless of whether you are logged in or registered.

3.2 We may receive and collect information and data about you from third parties, including our business partners, affiliates, service providers, advertising networks, and publicly available sources. This can include demographic and interest-based data or information provided by social media platforms when you link your account to our services.

3.3 We may collect data regarding your behavior and preferences when using our site and applications, including clickstream patterns, session lengths, and the pages you view. If you post content such as reviews, comments, or other materials on our site or application, we may also collect and process this information.

3.4 We also use analytics tools to collect information when you visit the site or use our applications and services on third-party sites or platforms.

4.1 You have several rights concerning your personal information, subject to applicable laws:

4.2 To exercise these rights, please email us at dataprivacy@winlycoins.com. We may request additional information and doсuments (ID card, driving license, passport and proof of address) to verify your identity. Please note that withdrawing permission may result in the inability to access all or part of certain features on the website.

5.1 We use your personal information to:

6.1 We take reasonable administrative, technical, and physical security measures to protect your personal information. These include password protection, secure servers, and encrypted data transmission.

6.2 Access to your personal information is restricted to authorized personnel who require it to perform their duties and meet legal obligations. We regularly review access permissions to ensure that only those with a legitimate need can access your data.

6.3 We conduct routine security audits and vulnerability assessments of our platform to identify and resolve any potential threats or weaknesses in our security systems.

6.4 In the event of a security incident, we have a detailed response plan in place to promptly address and minimize any risks.

6.5 All sensitive data is encrypted both during transmission and while stored, ensuring protection against unauthorized access, both online and offline.

6.6 We provide regular security awareness training for our employees, enhancing their ability to identify and respond to potential security threats and ensuring they handle personal and confidential information with the highest level of care.

6.7 We continuously monitor our systems for unusual activity and use advanced detection tools to identify and respond to potential threats or breaches in real time.

7.1 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.

8.1 We do not sell personal data, we transfer only information to service providers acting on our behalf under contract for: payments; hosting/CDN and cybersecurity; analytics, A/B testing, and personalization; CRM and support; communications (email/SMS/push); KYC/AML and sanctions checks; auditing, accounting, and legal support; and government agencies — when required by law. For advertising/statistics, we only disclose data in an de-identified or aggregated form.

9.1 We use cookies and similar technologies to enhance your experience on our website and mobile application. 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.

10.1 We or our partners may use technologies such as cookies to collect information about your activities for targeted advertising purposes. If you wish to opt out of targeted advertising, please email us at dataprivacy@winlycoins.com.

11.1 Our services are not intended for children under the age of 18, and we do not knowingly collect personal information from individuals under 18. If we discover that we have collected such information, we will promptly delete it.

11.2 If you are under 18, please do not use this Website or any of its features. Do not register, make purchases, or provide any information about yourself, including your name, address, phone number, email address, or any screen name or username. If we learn that we have inadvertently collected personal information from a child under 13 without verified parental consent, we will delete that information. If you believe we have information from or about a child under 13, please contact us at dataprivacy@winlycoins.com.

12.1 For questions or concerns about our privacy practices, contact us at:

13.1 This Privacy Policy may be updated from time to time. Any changes will be posted on our website and will take effect immediately upon publication. We recommend that you review this page periodically to stay informed about how we protect your personal data.

14.1 If you are a California resident, additional rules and rights apply to your data under the CCPA/CPRA. For a complete description, please see our California Privacy Policy. In the event of any conflict between this Policy and the California Privacy Policy for California residents, the California Privacy Policy shall prevail. To exercise your rights, please use the contact information in the Exercise Your CCPA Rights section of this Policy.