PRIVACY POLICY

WIN REALITY, LLC and its affiliates (hereinafter “WINR,” “we”, “us,” “our,” “WIN Reality”) provide online and mobile services through various websites and applications, including but not limited to “winreality.io”, and “winreality.co”, (hereinafter collectively “the WIN Reality Sites”), widgets, computer programs and mobile applications hosted by or on behalf of WINR (collectively, the “WINR Services”) intended to enhance your use of the performance and monitoring products offered by WIN (hereinafter collectively the “WINR Technology”).

WINR is committed to maintaining the privacy, integrity, and security of any personal information about our users. This Privacy Policy (hereinafter the “Policy”) explains how we protect the personal information we collect in connection with your use of the WINR Services, and how we use and in some cases disclose that information. “Personal information” for purposes of this Policy means information that identifies you, such as your name, address, phone number, fax number or email address.

This Policy is subject to the provisions our Terms of Service, which are incorporated by reference.

What Personal Information We Collect:
The WINR Technology works in conjunction with a user account (hereinafter “WINR User Account”) created on any of the WINR Sites.

When you sign up for a WINR User Account, you are required to provide an email address, username (which will be used as your login ID) and to create an account password (collectively the “Registration Information”).

In order to benefit fully from the WINR Technology, you can also add additional personal details to your WINR User Account, including but not limited to height, weight, gender, and age. Information sent wirelessly from your mobile device to us is stored in your WINR User Account. Information that you add manually to the WINR Services is stored in your WINR User Account.

Information Collected and How it is Used:
The WINR Services and the WINR Technology may collect Customer Data and Personal Information, and other types of information, including but not limited to Users’ names, address, location, IP address, and other personally identifiable information including Users’ birth date, height, weight, and other physical traits. This data is not solicited by WINR and is entered at will by the User. This information is stored securely, anonymized, and used in an aggregated fashion when referring to data if it is used at all. Certain parts of the WINR Sites and mobile app(s) is/are only accessible if you obtain a password. We may collect personal information when you register for a password or make a payment. We do not share personal User information with advertisers or marketers.

Customers of WINR have statistical and measurement data recorded during each training session, including, but not limited to, information pertaining to the User’s age, height, weight, strength, and other physical traits. WINR uses information collected to provide you with the services you request, to analyze user performance and improve training suggestions. WINR provides objective, data-based training, which requires the collection, aggregation, manipulation, and analysis of personal data from each User. We utilize proprietary software to analyze data of each individual User and an aggregate of all Users to meet our goals as a company: to help our Users meet their goals as individuals. Using proprietary software, we can monitor and track Users’ progress through a mobile-friendly system capable of logging personally identifiable information including Users’. Without the ability to analyze the aggregate of our Users’ data, WINR would not be able to measure our User’s training, abilities nor would we be able to provide the individualized instruction, guidance, and training demanded by our Users to create a more skilled athlete. We collect information from our Users both directly and indirectly. Some information is collected with the User’s full awareness, knowledge, and express authority. For example, Users may electronically submit data or information remotely to the WINR Services. Other information may be collected without the User’s direct knowledge including but not limited to anonymized evaluation data, gaze patterns, etc.

WINR uses your personal information to:
Provide you with the WINR Service, analyze WINR Site usage and improve the WINR Service, deliver to you any administrative notices and communications relevant to your use of the WINR Services and the WINR Technology, provide you with updates regarding WINR Technology, perform internal research on an aggregated basis, project planning in conjunction with clients, troubleshooting problems, and to detect and protect against error, fraud or other criminal activity, and to enforce the WINR Terms of Use.

Disclosure to Third Parties:
At times WINR may make certain personal information available to strategic partners that work with WINR to provide services to you. All personal information is anonymized and delivered in an aggregate fashion.

We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users or if we are required to do so by any applicable law, rule, regulation, subpoena or other legal processes. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

Use of Aggregated Anonymous User Data:
WINR may disclose non-personally identifiable aggregated user-data, such as aggregated gender, age, height, weight, and usage data (without the inclusion of a User’s name or other identifying information) to Users of the WINR Service for purposes of comparison of their performance.

Cookies and Other Technology:
The WINR Technology may use “cookies” and other technologies such as pixel tags and web beacons.

Cookies are alphanumeric identifiers in the form of text files that are inserted and stored by your Web browser on your computer’s hard drive. These technologies tell us which parts of our website you have visited or help us better determine which WINR Services you may like to see or to alert you to software compatibility issues. They are also used to analyze and improve the design and functionality of our Service.

If you choose to delete cookies from your device or block them from being stored on your device, please note that the full functionality of WINR Services may not be available to you.
“Web beacons” are images embedded in a Web page or email for the purpose of measuring and analyzing website usage and activity. WINR, or third party service providers acting on our behalf may use Web beacons to help us analyze WINR Site usage and improve the WINR Service.

We may use third-party service providers to help us analyze certain online activities and improve our products and the WINR Service. For example, these service providers may help us measure the performance of our online campaigns or analyze visitor activity on the WINR Sites. We may permit these service providers to use cookies and other technologies to perform these services for WINR. We do not share any personal information about our customers with these third party service providers, and these service providers do not collect such information on our behalf. Our third party service providers are required to comply fully with this Policy.

Information You Elect to Share With Others:
If you use a message board, blog, journal or any other method of posting user-generated content on the WINR Sites or through the WINR Services, you should be aware that such information can be read, collected or used by others and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these areas. Through the WINR Services, WINR enables you to share information with others. Many users find this to be an important motivator in achieving their goals. WINR is dedicated to providing you with full control of your personal data. WINR generally allows you to set notifications, categories or pieces of data to be private, viewable by friends only, or viewable by the public. We encourage you to consider these privacy settings before sharing information on the WINR Sites or through the WINR Services and to periodically review your privacy settings and adjust them in accordance with your preferences. Anonymous users have no access to the site.

WINR’s default settings for new users are as follows: Default Public – Basic information (e.g., profile photo, nickname, steps, and distance, etc.) will be available to everyone, Default Friends – Information your friends likely already know about you (e.g., real name, “About Me,” age, gender, height, location, etc.) will be available to your friends, Default Private – Information likely to be sensitive (e.g., activity data, food, weight, body data, measurements, journal, mood, allergies, sleep statistics, non-profile photos, etc.) will not be available to third parties Generally, WINR limits search engine access to the WINR Sites and instructs search engines not to index user profile pages. However, search engines may access profile information set to the “public” in your privacy setting.

Children:
We do not knowingly collect any personal information from children under 13. If we discover that a child under the age of 13 has provided us with personally identifying information, we will take steps to delete the information as soon as possible.

Your Right to Delete Your Data:
If you would like to cancel your WINR User Account you may do so by emailing support@winreality.io. When you request cancellation of your account, your personally identifiable information will be deleted, including but not limited your email address, name, photo(s), friends list and links to social and partner sites such as Facebook, Twitter, and Google Health. Archival copies of your account information that exists within our back-up the system will be deleted in accordance with our normal backup expiration schedule. Following cancellation or termination of your account, WINR may continue to utilize personally de-identified and anonymized historical data associated with your use of the WINR Services and the WINR Technology.

Email Communications From Us:
We may provide our registered customers with weekly summaries of their WINR User Account data and email alerts. We also allow users to subscribe to email newsletters and from time to time may transmit emails from us. WINR subscribers have the ability to opt-out of receiving our summaries and other emails and to terminate their newsletter subscriptions by following the instructions provided in such emails. Opting out in this manner will not end transmission of service-related emails, such as email alerts.

Data Security:
We use a combination of firewall barriers, encryption techniques, and authentication procedures, among others, to maintain the security of your data and to protect WINR User Accounts and systems from unauthorized access.

When you register for the WINR Services, WINR requires a password from you for your privacy and security. This password is stored in an encrypted fashion on our systems.
It is important to understand that these precautions apply only to the WINR Sites and systems. We exercise no control over how your information is stored, maintained or displayed by third parties or on third-party sites.

Privacy Complaints by European Union Citizens:
WINR Services are hosted and operated entirely in the United States and are subject to United States law. Any personal information that you provide to WINR is being provided to WINR solely in the United States and will be hosted on United States servers. You consent to the transfer of your personal information to the United States. If you are accessing the WINR Services from outside the United States, please be advised that United States law may not offer the same privacy protections as the law of your jurisdiction.

Enforcement and Dispute Resolution:
You acknowledge that WINR is located in the United States of America (“U.S.”) and will process and store your information in the U.S. and that as the result, U.S. governments, courts or law enforcement or regulatory agencies may be able to obtain disclosure of your information through the laws of the U.S.

If you have any questions, complaints or disputes regarding the manner in which WINR handles or protects your personal information, please contact us at support@winreality.io. WINR will investigate and attempt to resolve complaints and disputes in a reasonable time and in a manner that complies with the principles described in this Policy. If you do not want us to share your personally identifiable information with other companies or organizations, you may opt-out of this information sharing by contacting us at support@winreality.io.

With respect to any complaints related to this Policy that cannot be resolved through our internal process, you agree to participate in the dispute resolution procedures set forth by the American Arbitration Association. In the event that we or the appointed arbitrator(s) conclude that we did not comply with this Privacy Policy, we will take appropriate steps to address any adverse effects and assure our future compliance. WINR is headquartered in Delaware. The laws of the State of Delaware will govern this Policy, as well as any claim that might arise between you and us, without regard to conflict of law provisions. You agree that jurisdiction for any arbitration or legal action will be only in the State of Delaware.

Your Responsibility for Maintaining the Confidentiality of your Login ID and Password:
You are responsible for maintaining the security of your login ID and password, if you believe that your login ID or password have been compromised you should immediately change your password and contact support. We are not responsible if someone else accesses your account through registration information they have obtained from you or through a violation by you of this Policy or the WINR Terms of Service. If you have a security-related concern, please contact support@winreality.io.

Updates to this Policy:
We may update this Policy periodically and you will be notified of the change prior to posting. The date last revised appears at the top of the Policy.

Contact us if you have any questions or concerns:
If you have questions, comments, concerns or feedback regarding this Policy or any other privacy or security concern, send an e-mail to support@winreality.io.

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