Privacy Policy

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Last update on: June 06, 2023

This Privacy Policy explains the use of information, eventually collected due to the use of Winnin Insights platform, customer service operations and other activities (collectively, “Services”, “Winnin Insights”, “Winnin Platform”), offered and operated by Winnin Inc and its subsidiaries (collectively, “Winnin Inc”). This policy will help You (“User”) understand what information we collect, why we collect it, how we process this data and how you can update, manage, export, and delete Your information.

Winnin Insights allows You to map culture in real time and helps You understand what is relevant to different audiences and cultural niches to empower content creators with data. And for that, we integrate, through APIs, Winnin Insights with the following third-party sites: Youtube, Facebook, Instagram and Twitch.

We inform You that we will process Your data lawfully and fairly in full respect of your rights and, in particular, Your privacy, according to the Laws 12.965/2014 and 13.709/2018 – Brazil General Data Protection Law( LGPD) and and in accordance with other applicable laws and regulations (collectively, “Rules”).

In compliance with the rules and the best privacy practices in the market, You have the right to access, rectify, transfer, delete and confirm the processing of Your data by us, at any time, through the email dpo@winnin.com. Through this channel, You will have access to our Data Protection Officer (“DPO”) and will be able to request more information about our practices in relation to the data. In addition, You also have the right to contact the National Data Protection Agency (“ANPD”) directly.

I – Definitions

For the purposes of this document the following definitions shall apply to “User’s Information”:

• (i) “Personal Information” means any information, manually provided to Winnin Inc, about one of our Users which could, alone or together with other information, personally identify them or otherwise be reasonably linked or connected to them. The collected information to access the Winnin Insights Platform or our services are: full name, country of access, company name and it market, position, e-mail, login and password to access Winnin Insights, phone number, and any other data that may be needed to use the Service, upon previous communication to the User;
• (ii) “Access Information” means any information collected automatically from the use of our Service, that can be used to identify data about the User’s account, his requests and activities during the use of Winnin Platform, the interaction with a service, the messages sent or disclosed, the Address Internet Protocol (“IP”), the URLs of the website of origin and the next website that User might visit throughout the Winnin Platform, the type and language of the browser, one or more cookies that can identify the User’s browser or account, general and specific information about the User’s computer hardware, mobile phone or other device, Internet connection, operating system and the number of the version in use.

II – For what purposes do we collect your data?

By using the Service, the device through which you accessed Winnin Platform automatically generates and provides data to Winnin Inc, that We collect and use to provide better service to all our Users. So, the information collected and processed from User’s is used to:

1. Customize the User experience when using Winnin Insights, such as maintaining certain aggregated information for the User when accessing Winnin Platform; Users identity authentication; permission to access our Services; maintenance of Your preferences and registration information; presentation and help in measuring and researching the effectiveness of Winnin Inc email communications and authorized third parties, among other processes that might improve Your Winnin Insights experience.
2. Help develop new services, for analysis and measurement to understand how our Services are used, as well as to directly interact with You, such as to notify You in case We detect suspicious activity on Your account, or to inform You of upcoming changes or improvements to our Services; and to keep a record of any requests to help us resolve any issues You may be experiencing.
3. Help improve the security and reliability of our Service. This includes detecting, preventing and responding to fraud, abuse, security risks and technical issues that could harm Winnin Inc, our Users, the public or partners.
4. Internal Processing and sharing of statistics and graphic representations, individually and/or in aggregate way, in accordance with the legitimate interests of Winnin Inc.
5. We also collect and store information to comply with data protection laws and other applicable regulations.

By accessing Winnin Insights, You agree and accept that the data collected by Winnin Inc. may be stored in our databases, processed and transferred to the third-parties listed in item V below and territories, for the purposes described herein.

III – What data is collected by accessing Winnin Insights?

The data activity we collect from You by using Winnin Insights may include:

• Full or partial Name
• Business Email
• Business Title
• Number and age of User’s account
• Browsing history time
• Cookies information
• Terms searched
• Videos watched
• Activity on third-party sites and apps that We use on our Service
• Location information through IP address

In addition, We may collect information about You that may exist on our Partners Platforms, such as Youtube, Facebook, Instagram and Twitch, as it is through them that We collect information about what people are watching online.

Through search systems that help us understand what Users are looking for, We may present subjects of interest to You such as personalized search results or other features customized to the way You use our Service. We also use algorithms to recognize patterns in the data and provide a better User experience on our Platform.

Besides that, Winnin Inc may use cookies, web beacons (web bugs) or similar technology for the aforementioned purposes, and You may configure your browser to accept all cookies, reject them or notify when a cookie is set. However, if You reject all cookies, You may not be able to use Winnin Insights in its entirety. Winnin Inc also uses local storage such as browser storage or caches of data application, databases and server logs in handling Personal Information.

Your consent is requested before We use Your information for any purpose that is not covered in this Privacy Policy.

IV – What data is handled by the APIs of the Partner Platforms?

We collect and process the following data from the private API’s of our Partners Platform:

Post	Creator
Likes	Likes
Comments	Comments
Share	Share
Earned subscribers	Earned subscribers
Lost subscribers	Lost subscribers
Viewers	Viewers
Videos added to playlists	Videos added to playlists
Average viewing duration	Average viewing duration
Estimated minutes watched	Estimated minutes watched
Audience Index	Audience Index
Relative performance retention	Relative performance retention
Percentage of viewers	Percentage of viewers

We use this raw data to generate aggregated metrics and proprietary insights.

V – With whom does Winnin Inc shares your data?

Winnin Inc shares Personal Information with third-party service providers, whose have their own privacy policies and work on our behalf for the purposes described in this Privacy Policy, upon User’s consent obtained through the acceptance of this Police and the use of Winnin Platform, or as necessary to comply with the laws or respond to lawful requests and legal process.

The third-party service providers with whom We Your data are listed below:

• Amazon Web Services – Cloud computing web services that help Winnin Inc strengthen the security of Winnin Insights with encryption.
• Hubspot – Platform that helps Winnin Inc with email flows with regard to internal teams.
• Google Drive – Cloud computing web service that allows Winnin Inc to save files online and access them anywhere;
• Mixpanel – Helps Winnin Inc to group all events performed by Users, allowing the visualization a timeline related to each one of them, individually;
• Sudo – Helps Winnin Inc to control access and provide logins to Winnin Platform, in addition to enabling an enhanced customer experience.
• D4Sign – Document management and signature service.
• Slack – Platform that helps Winnin Inc with internal employee communication.
• Hotjar – Online data analysis tool that provides insights into the behavior of Winnin Insights users.
• Basecamp – Task organization and management platform.
• Intercom – Platform that helps Winnin Inc to communicate with its customers on Winnin Insights.

Whenever We have any changes to these tools, we will let you know.

In addition, if Winnin Inc is involved in a merger, acquisition, asset sale, or if all or a substantial part of its assets are acquired by another company, your information may be disclosed to our directors and to prospective buyers and will be one of the assets transferred to the new owner thereof. Notwithstanding, We will continue to ensure the confidentiality of your User Information and We will notify affected Users before User Information is transferred or becomes subject to a different privacy policy.

VI – How can You manage Your personal data?

Winnin Inc collects customer technical information, content and any other information received from Users or third parties through the interaction with Winnin Platform. The User may obtain a copy of the content in his/her profile and change the Personal Information provided in his/her registration at any time by requesting this change to cs@winnin.com .

When we receive formal written complaints, we will respond by contacting the person who made the complaint within three (3) business days. We will work with the appropriate regulatory authorities, including local data protection authorities, to solve complaints related to the handling of Your data that We may not be able to solve directly with You.

The User who has consented to the processing of his data by Winnin Inc, may eventually withdraw the consent, at any time, via the email dpo@winnin.com with the subject “Withdrawal of Consent”, informing which specific consent the User would like to remove. The User may also request the revocation of Winnin’s access to their shared data during the use of Winnin Insights through the Google Security Settings, Winnin’s Partner Platform. Please note that if User chooses not to provide User Information to Winnin Inc, User may not have access to the Service or certain Winnin Insights tools.

In addition, to delete the Winnin Insights account, you must notify Winnin Inc via email dpo@winnin.com. In that case, , the use and storage of User Information will be discontinued and disposed of by Winnin Inc, within 30 days and/or in accordance with the applicable law. This is because, in some cases, we need to keep the data for a longer period, due to legislation, court order, fraud prevention, credit protection and other legitimate interests.

VII – Information about Winnin Platform access security

Winnin Inc may take certain steps to verify requests made by You, using information available to us, including User’s email address and any information associated with User’s account. Personal Information provided to Winnin Inc for verification will only be used to verify and maintain records regarding User’s request.

The User’s Information will be protected in accordance with strict confidentiality standards. The security of Your Personal User Information is very important to us and therefore We use our best efforts to protect it through a variety of means, including the use of commercially acceptable measures, such as: use of our softwares and libraries most updated versions ; two-factor authentication; in transit data encryption dwi (use of TLS 1.2 or 1.3), and at sleep (AES-256); application redundancy (contributes to availability); access control using RBAC (Role Based Access Control); backups, logs for traceability and audit (contributes to integrity), test and production environments segregation and; network segregation, including firewalls and VPN’s to restrict or release access.

Although We adopt the best practices and recommendations, We cannot guarantee that all technologies involved will be free of security flaws due to the constant evolution of technologies.

Winnin Inc will not disclose, sell or rent the User’s Information collected to third parties, except as provided in this Privacy Policy. Winnin Inc may send User’s Information capable of identifying the User to third parties in the following cases: (i) with your consent; (ii) when necessary to provide the product or service requested or authorized by the User; (iii) to companies or persons trusted by Winnin Inc for any of the purposes described above, and (iv) to third parties to comply with any applicable law, Court order, governmental request, or to detect, prevent or address any form of technical, fraud or security issues, protect rights, the property or the security of Winnin Inc, Winnin Insights, its Users or third parties, as requested or permitted by law, as well as to enforce applicable Terms of Service, including investigation of potential violations.

The User’s Information eventually processed by Winnin Inc is limited to staff, agents, employees and service providers (“Staff”) under contract with Winnin Inc, who need to be aware of this User’s Information in order to process it on behalf of Winnin Inc and help with our business operations. That means we limit the amount of people that have access and we make sure that User’s Information can only be read, copied, modified or removed by properly authorized Staff. We monitor internal activity to ensure the safety and accuracy of User’s Information. Winnin Inc Staff is required to conduct themselves in a manner consistent with the company’s guidelines regarding confidentiality, ethics, and appropriate usage of User’s Information, including being subjected to confidentiality agreements.

Unless otherwise stated, the third parties indicated by Winnin Inc will not be entitled to use User’s Information submitted beyond what is necessary to fulfill the needs of Winnin Inc, and will be subjected and in compliance to our Privacy Policy, instructions and any other appropriate confidentiality and security measures.

Winnin Insights may provide links to other sites which may collect personally identifiable information from the User. Thus, You acknowledge and agree that Winnin Inc is not responsible for the privacy practices of other websites and platforms and encourages the User to carefully read the privacy statements of each and every website and platform that handles personal data. Our Partners Platforms are:

Google  https://policies.google.com/privacy;

Meta (Facebook e Instagram)https://help.instagram.com/581066165581870–

Twitch https://www.twitch.tv/p/legal/privacy-notice/

By clicking on the names of the Partner Platforms, You will be redirected to their Privacy Policies.

This Privacy Policy applies only to information collected and processed by Winnin Inc. This Privacy Policy doesn’t apply to services that have separate privacy policies that do not incorporate this Privacy Policy.

We maintain servers around the world and Your information may be processed on servers located outside of the country where you live. Data Protection Laws vary among countries, with some providing more protection than others. Regardless of where Your information is processed, We apply the same protections described in this Policy.

This Privacy Policy can be modified from time to time by Winnin Inc. We will not reduce Your rights under this Privacy Policy without Your explicit consent. The changes will be in force automatically on the date of publication of the new version on Winnin Insights. If changes are significant, we’ll provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). In order to continue to access Winnin Insights after the changes come into effect, the User must agree and accept the Privacy Policy last version.

This Privacy Policy is a supplementary document to any other written agreement in effect between Winnin Inc and our Users.

If you have any questions about this Privacy Policy, You can contact us on legal@winnin.com