1. PRIVACY POLICY

At Wincredibles LLC (“Wincredibles,” “We,” “Us,” “Our”), we respect our users (“user(s),” “you,” “your”) privacy. This Privacy Policy (the “Privacy Policy”) describes how we treat information received about users when they visit our Platform. Please read the Privacy Policy carefully.

This Privacy Policy applies to all users of our website (http://wincredibles.com) and the Wincredibles mobile application (the “Wincredibles App”), which includes any other use of our applications and services linking this Privacy Policy, owned or operated by Wincredibles (collectively, our “Platform”). This Privacy Policy describes the privacy practices of Wincredibles only and does not cover the practices of other companies with whom you may engage through the Platform, including those that may advertise or sponsor content, products, or services on the Platform.

We are committed to only collecting the information necessary to provide services and improve our Platform. We take your privacy seriously and will only use and disclose this information as described in this Privacy Policy.

By using our Platform, or by creating or linking an account on our website or the Wincredibles App, you signify your consent to the terms of our Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not use our Platform, or submit any personal information to us.

2. INFORMATION WE COLLECT ABOUT YOU

For the purposes of this Privacy Policy, personal information means any information that could, alone or together with other information, personally identify, or otherwise be reasonably linked or connected with, a particular consumer or householder (“Personal Information”). Information such as a username and password, an email address, a real name, voice, photograph, birthdate, and a geographic location are examples of Personal Information.

We collect Personal Information when you voluntarily provide it through our Platform, or when you provide it to use through the following other means, including:

• when you register on the Platform as a member;
• when you update your information;
• you purchase any goods and services;
• you take part in promotions or send emails to us; and
• through information we use to store and process, including, without limitation:
  1. your first and last name;
  2. your address;
  3. your phone number;
  4. your email address;
  5. your credit and debit card information;
     1. All credit and debit card information and Personal Information will not be stored, sold, shared, rented or leased to any third parties.
  6. your purchase and transaction history;
  7. your interests;
  8. your image and voice for the purposes of promoting you as the winner; and
  9. your gender, age, location, nationality, and other similar information.

We may automatically collect and/or receive general information from and about you, as a result of your visits to, and use of, the Platform (“General Information”). This General Information includes, but not limited to:

• your Internet Protocol (IP) address;
• date and time you access the Platform;
• length of time you spend on the Platform;
• your browsing history (recorded by the text and graphics files that compose that page);
• the Internet address from which linked you directly to our Platform; and
• other similar information.

3. HOW WE COLLECT YOUR INFORMATION

The Personal Information and the General Information we collect from you will be processed for the purposes set out in this section of the Privacy Policy. When you use our services on the Platform, we may collect information that is automatically sent to us by your web browser or your device which runs our applications, including without limitation, the following:

• the hardware you use to interact with our Platform;
• operating system and version information;
• software you use;
• mobile network information;
• social media authentication platforms (i.e., Facebook, Instagram)
• your unique device information;
• referral website address used to access Our website or Wincredibles App.

A. INFORMATION COLLECTION AND TRACKING TECHNOLOGIES

We and third parties that we partner with may use cookies, web beacons, tracking pixels, flash cookies, (also known as locally shared objects), HTML5 cookies, entity tags, and other similar technological means (collectively, “Cookies”) on our Platform to help us collect information through technological means. These technological tools may track or collect information such as: (i) IP Addresses; (ii) the type of web browser and operating system used; (iii) the pages of the Platform visited; (iv) the URL that referred you to the Platform; (v) the aspects of our Platform you use; (vi) your activities on the Platform; and (vii) information about your device.

B. AUTOMATIC INFORMATION COLLECTION AND TRACKING

When you download, access, and use the Wincredibles App and the Platform, it may use technology to automatically collect:

• Usage Details. We may automatically collect certain details of your access to and use of the Wincredibles App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Wincredibles App.
• Location Information. The Wincredibles App collects real-time information about the location of your device when the Wincredibles App is running on the device.

The technologies we use for this automatic information collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.
• Flash Cookies. Certain features of our Platform may use local stored objects (or Flash Cookies) to collect and store information about your preferences and navigation to, from, and on our Platform. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons. Our Platform uses web beacons, (known as “Google Tracking Pixels”) to access cookies and to count users who visit our Platform and view our electronic messages. Google Tracking Pixels are graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of our users. In contrast to Cookies, which are stored on a user’s computer hard drive, Google Tracking Pixels, are embedded invisibly in web pages and email messages and Google will process the information to evaluate the use of the Platform, compile reports about the Platform’s activity on our behalf, and deliver other related services regarding Platform use. By using the Platform, you agree to Google’s processing of the type of information discussed in this section in the manner contemplated by this Privacy Policy.

Wincredibles, our respective suppliers, and any of our shareholders, including our affiliates, are not liable for any direct, indirect, punitive, incidental, or consequential damages or loss arising out of, or in way connected with, the use of the type of information discussed in this section.

Additionally, the amount of information that is sent to us by technological means depends on your browser or device and settings you use. The information practices of these third parties are not covered by this Privacy Policy and you should refer to the instructions provided by your browser or device if you want to learn more about what information it sends to services you use, or how you may restrict this.

4. HOW WE USE YOUR INFORMATION

A. PERSONAL INFORMATION

We use Personal Information to improve our understanding of how users use our Platform, and to provide you with better services, and in particular to:

• keep internal records;
• improve Our products, services, and Platform;
• communicate with you if you have ordered, purchased, or participated in anything on the Platform;
• keep correspondence with you if you contact us through the Platform or email contacts on the Platform;
• contact you for market research purposes; and
• provide you with information about new opportunities, promotions, special offers and other information that We may feel is relevant to you.

B. GENERAL INFORMATION

We use General Information to improve the Platform and make the Platform more useful to users, including, but not limited to:

• assessing content of interest to visitors of the Platform;
• determining the Platform’s technical design specifications;
• identifying system performance or problem areas;
• tracking activity on the Platform;
• preparing reports, assessing trends; and
• otherwise monitoring the way the Platform is being used.

C. YOUR CHOICES ABOUT HOW WE USE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. We obtain your consent to our Cookies by providing you with transparent information in our Privacy Policy and providing you with the opportunity to make your choice. You have the right to object to the use of Cookies. Regular Cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Please be aware that if you disable or remove theses Cookies, some part of our Platform will not work and that when you revisit our Platform your ability to limit Cookies is subject to your browser settings and limitations.
• Opting Out of Marketing Communications. On the Platform, you can choose whether you wish to receive marketing communications from us or you can opt out of all marketing communications by (i) clicking the “unsubscribe” link at the bottom any marketing emails we send you, or (ii) by sending us an email at support@wincredibles.com. Once we have processed the request, you will not receive any more marketing communications unless you opt back in.

5. Disclosure to Third Parties

• We may reserve the right to share your Personal Information within our group entities and subsidiaries (collectively, the “Company”). While we may receive your Personal Information and use your Personal Information for purposes stated in this Privacy Policy, we do not sell our users’ Personal Information to third parties outside of our Company, except we may disclose your Personal Information for any other purpose permitted by law or to which you consent under this Privacy Policy.
• We may also reserve the right to transfer Personal Information to a third party in the event that we merge or are acquired by a third party, or as part of the negotiations leading up to such merger or acquisition.
• We may reserve the right to transfer your Personal Information provided to us to another country when your Personal Information is stored in a data center in that country. We will take all reasonable steps to ensure that your Personal Information is protected in accordance with this Privacy Policy and applicable data protection laws by using appropriate safeguards, including, enforceable rights and an effective remedy for users whose Personal Information is transferred.
• We may also disclose your Personal Information for legal compliance purposes, to cooperate with or carry out investigations, and in compliance with any court order or subpoena.
• Residents of certain states, such as Texas, California, Connecticut, Virginia, Utah, Iowa, Indiana, Tennessee, Montana, and Florida may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

6. REVIEW, CORRECTION, AND RETENTION

If provided by applicable law, you have the right to request that we disclose what Personal Information we collect, use, disclose, and sell, if any. You may submit a verifiable request to know, correct, or delete the personal information you provide us – to the extent required by applicable law – by contacting: (1) info@wincredibles.com

We will only respond to verifiable requests that contain sufficient information for us to properly understand, evaluate, and respond to the request. In order to verify a request, we may request certain Personal Information we have on file to verify that you are the person on whom we have information or an authorized representative of such person.

We will not treat you differently for exercising any rights provided by applicable law.

7. YOUR STATE PRIVACY RIGHTS

State consumer privacy laws may provide their residents with additional rights regarding the use of their Personal Information. California, Connecticut, Virginia, Utah, Iowa, Indiana, Tennessee, Montana, and Florida each provide their state residents with the rights to:

• Confirm whether we process their Personal Information
• Access and delete certain Personal Information
• Data portability
• Opt-out of personal data processing for targeted advertising and sales.

To exercise any of these rights as a resident of any of these states, please email support@wincredibles.com

8. YOUR TEXAS PRIVACY RIGHTS

If you are a Texas resident, Texas law may provide you with additional rights regarding our use of your Personal Information. Taking effect on July 1, 2024, under the Texas Data Privacy & Security Act (TDPSA), consumers have the right over their data similar to those in other state privacy laws, including:

• Right to Know and Access Your Personal Information. You have the right to:
  1. know the categories of Personal Information, including sensitive Personal Information, that we collect and the categories of sources from which we got the information;
  2. know the business or commercial purposes for which we collect and provide Personal Information to others;
  3. know the categories of third parties and other entities to whom we provide Personal Information; and
  4. access the specific pieces of Personal Information we have collected about you.
• Right to Correct Your Personal Information. You may request that modify or update your Personal Information if it is inaccurate. Please be aware that not all Personal Information is able to be corrected, and we reserve the right to deny a request to correct your information where exceptions apply.
• Right to Request Deletion. In some circumstances, you may ask us to delete your Personal Information, subject to certain exceptions and requirements.
• Right to Obtain a Copy of Personal Information. You have the right to obtain a copy of your Personal Information in a portable and readily usable format.
• Right to opt Out. You may limit or opt out of the use of your Personal Information for certain purposes. Please review our entire Privacy Policy for how we use your information. Please remember that cookie-level opt-outs are browser and device-specific and applied to the Platform with respect to which you complete the opt out request. If you use multiple devices such as your smartphone, laptop, or tablet to visit the Platform, you will need to submit separate requests for these activities.
1. Right to Opt Out of Sale/Targeted Advertising: We do not “share” Personal Information with third parties for target advertising purposes or in ways that constitute a “sale” under the TDPSA. If we do, you have to right to request that we do not “sell” or “share” your Personal Information for these purposes on a going forward basis.
   If you choose to use the Platform and successfully win a Draw, we will provide the other user or third party, as appropriate, with your Personal Information to facilitate the transaction you requested (including your name and contact information). This type of sharing does not constitute a “sale” of your Personal Information by us as it is done at your direction.
2. Right to Limit Processing of Sensitive Personal Information: Certain pieces of Personal Information that we have about you may be considered “sensitive” under TDPSA, including information needed to provide you with access to the Platform (i.e., account and payment information). These pieces of information are not subject to the right to limit.

In addition to the above, you have the right to withdraw your consent to the processing of your Personal Information at any time. Such withdrawal has no effect on any processing of your Personal Information that has occurred prior to the withdrawal of your consent.

If you have any questions about the type of Personal Information that we hold about you or wish to exercise any of your data subject rights, please send a written request tosupport@wincredibles.com

9. PERSONAL INFORMATION SECURITY

The security of your Personal Information is important to us and preventing unauthorized access is of utmost priority to us. We take all steps reasonably necessary to protect your Personal Information against any unauthorized access, use, alteration, disclosure, or destruction.

No method of transmission or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security and will not be held responsible for any unauthorized access by third parties. In the event of a data breach that affects your Personal Information we will act promptly to mitigate the impact of a breach and notify any affected users without undue delay.

10. Policy Modifications

We may change this Privacy Policy from time to time. We will post any changes to this Privacy Policy on this Privacy Policy. This Privacy Policy was last updated on October 26th, 2023. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Platform and this Privacy Policy to check for any changes. All amended terms automatically take effect immediately upon posting. Your continued use after an updated Privacy Policy is posted, means that you accept and consent to all its revisions.

11. Retention Policy

We retain your Personal Information that we collect about you for as long as necessary to fulfill the purposes outlined in this Privacy Policy. We may retain Personal Information for legitimate business purposes or as required and permitted by law.

12. Age Restriction

Our Platform is not intended for persons under twenty-one (21) years of age or the legal age applicable in your jurisdiction to enter into a contract. No one under the age of twenty-one (21) may provide Personal Information to or on our Platform. We do not knowingly collect Personal Information from anyone under twenty-one (21). If you are under twenty-one (21), do not use or provide any information on our Platform or through any of its features, register on the Platform, make any purchases through the Platform, or provide any information about yourself to us, including your name, birth, address, telephone number, email address, or any screen name or username you may use. If we learn that we have collected or received Personal Information from a person under twenty-one (21), we will delete that information. If you believe we might have any information from or about a person under twenty-one (21), please contact us at support@wincredibles.com or through the contact information set forth in the How to Contact Us section below.

13. LICENSE

This Agreement is between you and the Company only and not with Apple. The Company, not Apple, or any internet service or mobile network provider or any other intermediary, is solely responsible for Wincredibles App and the content on the app.

14. How to Contact Us

To ask questions, comment on, or to register a complaint or concern about this Privacy Policy and our privacy practice, or to request information relevant to your Personal Information, contact us at:

Email: support@wincredibles.com