Privacy Policy

Privacy Policy

Please be aware that the privacy policy may be available in multiple languages to assist you in understanding its terms, depending on your country of residence. Nevertheless, the English version is the legally binding one.

The headings and titles in the policy are for convenience only and do not have any legal effect.

This Privacy Policy (the “Policy”) outlines the data collection and processing practices of Compsquad LLC and its subsidiaries and affiliated companies (referred to as “Winoids,” “we,” “us,” or “our”). It details the types of data we collect, the reasons for collecting it, and how we use it when you access our websites linked to this Policy (each, a “Website” and collectively, the “Websites”), download or use any of our software products (“Product(s)”), Products, the “Services”).

Introduction

We understand the importance of providing safe products and safeguarding our customers' privacy rights. To this end, we have crafted this Policy in clear language and a modular format.

This Policy is part of your agreement with us and should be reviewed and agreed upon in conjunction with the terms of service and/or license agreement of the relevant Service.

Please read the Policy thoroughly to ensure you understand and agree with its terms before using any of the Services. If you do not agree with the terms or find that our options do not address your concerns, please refrain from accessing or using the Services. For any questions or concerns regarding this Policy or your privacy rights, please contact our data protection officer at: dpo@winoids.com.

 2.General provisions

1. Jurisdiction and language Please be aware that this Policy is crafted to comply with the California Privacy Rights Act (CPRA) and the ePrivacy Directive (collectively, the “Applicable Laws”). If you live outside California or the United States and wish to understand how we handle Personal Information in your specific region, please refer to the supplemental notices for your jurisdiction listed below.
The Policy may be available in various languages to facilitate your understanding based on your country of residence, but the English version is the legally binding one.

Scope and applicability

1. Controller Information
Compsquad LLC acts as the data controller for Personal Information processed in relation to the Services. Our postal address is 229 Raindollar Ave #H, Marina, CA 93933.
For general inquiries, please reach out to us at contact@winoids.com. For privacy-related concerns, contact us at dpo@winoids.com.

2. Data Protection Officer (DPO) If you have any questions or concerns regarding this Policy, please feel free to reach out to us using the address provided above or by emailing our Data Protection Officer (DPO) at: dpo@winoids.com.

3. Categories of Data Subjects
This Policy is applicable to the following categories of Data Subjects:

(a) Visitors: Individuals who visit a Website, including any Product webpage or landing page that links to this Policy or our Privacy Portal.

(b) Users: Individuals who download, install, or otherwise interact with any of our Products or Services, including accessing, downloading, installing, consuming, or using them.

(c) Customers: Business clients, partners with a contractual relationship with us, or prospective clients and partners who have not yet entered into a contract with us.

(d) Vendors: Suppliers, service providers, or processors. Unless specified otherwise in this Policy, all these categories of Data Subjects are collectively referred to as "you."

Changes to this policy

We may occasionally update, add to, or remove sections of this Policy to reflect changes in our Services, Products, data processing practices, or new legal requirements. Any updated Policy will be posted on this Portal and on the website for the relevant Product or Service, with the changes noted in the “last updated” date.

For significant changes, we will provide more prominent notifications, such as posting an announcement on the Website or sending an email if we have your email address. Continued use of the Site or Services after the effective date of any modifications signifies your acceptance of and agreement to the revised Policy.

Transparency, consent and choice

You are not legally required to provide us with Personal Information (as defined below), and you acknowledge that sharing this information with us is voluntary. However, please note that without this information, we may not be able to deliver the Services or process your requests effectively.

Some Services may require you to provide additional Personal Information beyond what we already have. You can decide whether to use these additional Services based on your preference.

For more details on your rights concerning your Personal Information, please refer to the relevant section of this Policy below.

Personal information we may process and how

The information we process in relation to the Services can include:

- Personal Information (PI): This refers to data that can identify you as an individual or be used in combination with other information to identify you. Examples include your name, email address, phone number, physical address, and other contact details. In some jurisdictions, such as the EU, an IP address, device ID, and cookies may also be considered Personal Information depending on the context in which they are used.

- Non-Personal Information (non-PI): This is data that cannot be used to identify or lead to the identification of an individual. Examples include aggregated statistics or other types of data that cannot be traced back to you.

This Policy applies to Personal Information and outlines how it can be processed or derived in the following ways:

1. Information You Provide:

- Contact Details: If you contact us, open an account, subscribe to our mailing list, or reach out to support, we may collect your contact information (e.g., name, email address, phone number). This information is used to manage communications and provide support.

- Mailing List Subscriptions: If you subscribe to our email list, you’ll need to provide your email address. You can unsubscribe anytime by using the link in the email or by contacting our DPO at dpo@winoids.com. We use this information to send updates, tips, and promotional materials related to our Products and Services.

- Account Registration: For some Services, you need to create an account by providing details such as your email address and name. This information is used to authenticate your account, manage your purchases, and provide updates about our Services.

Product License Purchase: To buy a product license, you must provide contact and payment information. This information is used to process your order, issue a license key, and manage your account. Payment details are handled securely by our payment processing partners.

- Support Requests: When you contact us for support, we collect the details of your inquiry and your contact information to address your request effectively. This may include using third-party services to assist with tracking and resolving your inquiry.

- Business Customer Information: For business partners or potential partners, we may store contact and job-related information in our CRM systems for business and CRM purposes.

- File and Media Uploads: If you upload documents or media through our Products, any Personal Information contained in those files will be managed by you. We do not retain your content but may keep metadata necessary for the operation and support of the Product.

- Browser and Mobile Permissions: When you install our Product on a mobile device or browser, we may request your consent for certain permissions, such as access to media files.

- Job Applications: If you apply for a job with us, we collect and process your application details and CV. This information is retained while your application is under review or as required by applicable laws.

For more information about your rights and how we handle your Personal Information, please refer to the relevant sections of this Policy.

Information automatically processed

This category pertains to the methods we use to enhance the experience of our Customers and Visitors and to optimize the performance of our Services.

When you interact with our Websites, download or use a Product, or otherwise engage with our Services, we may collect information about your actions, device, and website visits. This data helps us provide, maintain, and improve our Services, understand user behavior, and ensure security. The types of information processed include:

1. Online Identifiers:

- When you access our Websites or use our Products, we may collect online identifiers such as your IP address, cookies (as outlined in our Cookie Policy), and other digital information stored locally through cookies, pixel tags, and log files.

- Purpose: We use this data for analytics and to understand how Visitors and Users interact with our Websites and Services. It helps us detect and prevent fraud, customize content based on your location, and, with your consent, serve targeted advertising. Necessary cookies are used to ensure the functionality of our Websites.

- Retention: We retain online identifiers as long as needed to fulfill the purposes for which they were collected or until they are anonymized. Details about cookie retention can be found in our Cookie Policy.

2. Device Information:

- We may gather information about the device you use to access our Websites or Products, such as browser type, operating system, device type, and language settings. If you purchase a license for multiple devices, we associate your license key with your email and device information.

- Purpose: This information helps ensure compatibility, offer device- specific features, and manage licenses. It also supports the Product’s functionality, including space management and optimization.

- Retention: Device information is retained as long as necessary to provide and support the Product, manage your license, and ensure proper functionality.

3. Online Activity:

- We collect data on your interactions with our online content, such as clicks on advertisements and buttons, and may use third-party services for retargeting.

- Purpose: This information is used for marketing and advertising purposes, to enhance the responsiveness and functionality of our Services, and to measure and prevent ad fraud.

4. Installation Reports:

- When you install our Product, we may collect data such as your operating system type, version, language, and installation timestamp, along with your IP address. This helps us ensure that installations are legitimate and compatible.

- Purpose: We use this data to verify installation authenticity, ensure compatibility, and support Product functionality.

- Retention: We retain this information while the Product is installed and may keep it longer if needed to address potential fraudulent activity.

5. Product Activity:

- We automatically record and process information related to how you use our Product, including actions taken and functionality used.

- Purpose: This data helps us respond to your actions and allow you to revert changes if needed.

6. Media Buying and Marketing Channels:

- When you arrive at our Website through an advertisement, we collect information about the source of the traffic, including referral URLs and IP addresses, via tags and cookies.

- Purpose: This data helps us measure the effectiveness of our marketing efforts, calculate advertising performance, and detect fraudulent activities associated with our marketing channels.

Information about you

This category covers data we may obtain from third parties related to the Services we offer you. It includes:

1. Billing Information:

- When you purchase a Product, our payment processor handles your payment and billing details. We receive order and billing information but do not access your credit card details.

2. Authentication and Social Media:

- If you use social or email authentication to create an account or sign up for our Services, we may receive metadata (such as tokens) and, with your consent, access to your public social media profile.

3. Marketing:

- When we engage in media buying and marketing for our Products and Services, we may receive aggregate online data about visitors from third- party media platforms like Facebook or Google. This data does not personally identify you but helps us evaluate the effectiveness of our marketing campaigns.

Cookies and web technologies

A cookie is a small text file placed on your computer's browser or similar device by the websites you visit. Cookies are commonly used to ensure websites function properly, enhance their efficiency, and provide information to the website operators. They simplify your use of the Site and Services, improve functionality, and streamline tasks like logging in, managing your shopping cart, and remembering your preferred country, language, and currency. Additionally, cookies help track your activity across the Site.

Some Services, features, and tools integrated into our Site and Services may use their own cookies for proper operation. For detailed information about our cookies and those from third parties, please refer to the cookie policy available on the website you are visiting. Be aware that you can configure your browser to refuse or block cookies from us or our third-party partners; however, doing so may affect the functionality of some Services.

Purpose and how we use personal information We use your Personal Information for the purposes outlined for each data type above, as well as for the following reasons:

a. Providing, Supporting, Improving, and Securing Our Services: To deliver our Services effectively, enhance their performance, ensure their security, and market and advertise them more effectively.

b. Preventing Fraud: To detect and prevent fraudulent activities and fake installations.

c. Account Management: To open, manage, and support your account.

Lawful basis for processing Personal Information

In addition to the legal grounds specified for each data category:

If you are a Customer, our lawful basis for processing your Personal Information is either a contract or steps taken to enter into a contract. In other situations, we may process Personal Information based on your consent, as required by applicable laws, or due to our legitimate interests. The lawful basis for processing will vary depending on the type of Personal Information and the specific circumstances in which it is collected:

(a) We typically process Personal Information with your consent, such as when you submit a form, open an account, or agree to our use of cookies.

(b) In certain cases, processing may be justified by our legitimate interests, provided these interests are not outweighed by your data protection rights. This includes instances such as delivering core Services or preventing fraud.

In some instances, we may also have a legal obligation to collect Personal Information or need it to protect your vital interests or those of another person. If we request your Personal Information to meet a legal requirement or fulfill a contract, we will clearly inform you whether providing this information is mandatory.

For questions about the legal basis for our data collection and use, or to understand how our legitimate interests are balanced against your rights, please contact us for more information.

How we share personal information

We use third-party services to provide, operate, maintain, and improve our Services, as well as to offer additional products and features. This means that we may share Personal Information with various categories of third parties for specific purposes:

1. Hosting Services and Storage Vendors: We rely on third-party hosting and storage providers, including cloud services, to manage our Websites and store your data. These providers may be located globally, and we require them to uphold strict privacy and security standards, though their practices are governed by their own privacy policies.

2. Analytics, Business Intelligence, and Statistics Vendors: We use analytics services to understand how Users interact with our Websites and Services, helping us improve and optimize our offerings.

3. Support and Customer Services: To provide efficient support, we may use external help desk and customer service platforms. This helps us offer faster and more effective assistance.

4. Authentication and Authorization Services: For account management, we may integrate authentication services to facilitate secure access and authorization.

5. Payment Processors: When you purchase products, payment processors handle your billing information. These processors adhere to strict security standards to protect your financial details.

6. Customer Relations Management and Mailing Lists: We use services to manage your Personal Information and handle subscriptions, notifications, and communication preferences.

7. Technology Partners: Our products and Services may include third-party technologies or features to enhance functionality. For example, we might use platforms like WordPress for website management.

8. Advertising and Retargeting Services: We use third-party services to serve and display ads based on your interaction with our Websites. This may involve retargeting ads across the web. You can opt out of such advertising through the ad settings of the third-party service or as detailed in our cookie policy.

9. Business Partners: If we collaborate with other businesses that integrate their technologies with ours, they may access certain Personal Information related to your usage. You can review their privacy policies before using their combined services.

10. Affiliated Companies: We may disclose Personal Information to affiliated companies, including parent and subsidiary companies, for the purposes described in this Policy.

11. Legal Proceedings or Law Requirements: We may share Personal Information to comply with legal obligations, enforce our agreements, detect and prevent fraud, or protect the rights and safety of our companies, users, and the public.

12. Merger, Sale, or Bankruptcy: In the event of a merger, acquisition, or sale of assets, we may transfer your Personal Information to the acquiring entity. We will ensure that the new entity adheres to similar data protection practices.

13. Special Cases: We may share information with your consent, in fraud prevention efforts, or for investigations. Non-Personal and Personal Information may be stored, used, or shared in the contexts outlined above. Aggregated data, which combines information from multiple users, may be transferred to third parties for various purposes, including commercial use.

If you have any questions about how your Personal Information is handled or need further details about third-party services we use, please contact us.

International transfers of data

We may transfer your Information, including Personal Information, to countries outside the one in which it was originally collected or where you reside. This includes transfers to countries like the United Kingdom or the United States, which may not provide the same level of data protection as your country of residence.

To ensure the security of your Personal Information during such transfers, we implement contractual safeguards and take necessary measures.

hese may include verifying that the third-party services we use have adequate protection measures in place, such as security certifications and other standards to assess their data protection practices.

By providing your Personal Information and using our Services, you expressly consent to the transfer of your Information to other countries as described in this Privacy Policy, including transfers to the UK or the US. If you have any concerns or questions about these transfers or our data protection practices, please contact us for more information.

Rights of Data Subjects

Depending on your country of residency and how you use our Products and Services, you may have certain rights regarding your Personal Information. These rights include:

- The Right to Know: You have the right to be informed about the Personal Information we collect and process about you, including details on any third parties with whom we share your information. Our Privacy Policy is designed to be as detailed and transparent as possible, and we provide additional disclosures throughout our Services at points where Personal Information is collected.

- The Right to Access: You can request access to the Personal Information we hold about you.

- The Right to Rectification: You can request that we correct any inaccurate or incomplete information we hold about you. If you manage an account with us, you can make these updates directly from your account settings.

- The Right to Erasure: You may request the deletion of certain Personal Information about you, or that we stop using it. This right is subject to legal limitations, and there may be cases where we need to retain information to complete transactions, comply with legal obligations, or continue providing our Products and Services.

- The Right to Data Portability: You can request an export of your Personal Information in a structured, commonly used, and machine-readable format, or you can request that we transfer this information directly to another service provider.

- The Right to Withdraw Consent: If you have given us consent to use your Personal Information for a specific purpose, you can withdraw this consent at any time. We will stop using your information for that purpose unless we have a legitimate interest or a legal requirement to continue processing it.

02. Privacy Rights for Specific Jurisdictions

In addition to the general rights mentioned above, specific jurisdictions may provide additional privacy rights. These rights vary depending on the region, and you should refer to the relevant privacy regulations applicable in your location for more information.

03. Exercising Your Privacy Rights

To exercise your privacy rights, your requests must be verifiable. You can do so through the following methods:

1. Directly from Your Account: Many of your privacy rights, such as editing, exporting, or deleting information, can be exercised directly from your account settings or through the specific services and communications associated with your account.

2. Form Submission: You can complete a designated form and submit it digitally or via email to dpo@winoids.com.

3. Email: Send your request to dpo@winoids.com.

4. Post: Mail your request to:
Compsquad LLC
229 Raindollar Ave #H
Marina, CA 93933

Include sufficient information about your request, the relevant Service, and your identity to help us verify your request. We will process verifiable requests within the timeframe specified by applicable regulations. Note that we may request additional information to verify your identity.

Please be aware that even if you unsubscribe from our marketing services, you may still receive transactional emails related to your purchases or product use. These include order confirmations, product notices, expiry notifications, bug fixes, security alerts, compatibility updates, and other essential communications.

Response times for processing your rights requests may vary depending on your residency. For more detailed information on response times specific to your region, refer to the "Special Jurisdiction" section of our Privacy Policy.

Information security

Data Security and Privacy Protection

We are committed to safeguarding our Customers' and Users' privacy and protecting their Personal Information through both organizational and technical measures. Here's how we ensure data security:

- Organizational and Technical Measures: We implement robust security practices and use third-party services specializing in data protection. This includes regular reviews and updates of our information and data collection practices to maintain high security standards.

- Third-Party Security Services: We engage with third-party processing and serving services that adhere to stringent information security standards and certifications. These third-party services play a crucial role in safeguarding data and reducing security risks.

- Access Control: We monitor and filter access to data within our organization, ensuring that only authorized personnel have access to sensitive information. This helps mitigate the risk of unauthorized access.

- Security Breach Risks: While we take extensive measures to protect against security breaches, it's important to note that no system can offer absolute security. The nature of the global network means there is always some level of risk. As such, we cannot guarantee that our Site and servers are completely immune to unauthorized access or other security threats. For any questions or concerns regarding the security of our Websites or Services, please contact us at contact@winoids.com.

Highlights of our General Security Policy

For more detailed information on our security practices and policies, please visit our Information Security Page. This page provides insights into the measures we take to protect your data and ensure privacy.

Children’s Privacy

Our Services are not designed for or directed at children under the age of 16. We do not knowingly collect Personal Information from individuals we know to be under 16 years old.

If we become aware that we have collected Personal Information from a child under 16, we will take commercially reasonable steps to delete that information promptly.

If you believe we may have inadvertently collected Personal Information from a child under 16, please contact us immediately at dpo@winoids.com.

Special Jurisdictions: The EU, EEA and the UK

Supplementary Information for Data Subjects in the EU, EEA, or the UK In addition to the rights detailed in our privacy statement, Data Subjects residing in the EU, EEA, or the UK have the following rights:

1. Right to Restrict Processing: You may request that we temporarily restrict the processing of your Personal Information, either wholly or for specific purposes. Please be aware that this restriction may impact our ability to provide you with some or all of our Products and Services.

2. Objection to Processing: You have the right to object to the processing of your Personal Information. Similar to restriction requests, this may affect your access to our Products and Services.

3. Right to Lodge a Complaint: If you reside in the EU, EEA, or UK, and believe that your rights have not been upheld, you can lodge a complaint with the data protection authority in your country of residence. We encourage you to contact us first to resolve any issues. You can reach us at dpo@winoids.com for assistance.

or any data protection-related concerns or inquiries, please contact our Group Data Protection Officer at dpo@winoids.com

Special jurisdictions: California, USA

• Privacy Notice for California Residents

• This notice supplements the general privacy statement and applies to Visitors, Users, and Customers residing in California, USA. It is designed to comply with the California Privacy Rights Act of 2020 (CPRA) and other relevant California privacy laws. Any terms defined in the CPRA have the same meaning when used in this notice.

• Last Updated: January 11, 2023

• For any data protection-related inquiries, please contact our Data Protection Officer at dpo@winoids.com.

• 1. Categories of Personal Information We Collect and Process

• We may process the following categories of personal data:

• - Identifiers: Such as email address, physical address, and phone number.

• - Online Identifiers: Such as cookies and IP addresses.

• - Online and Network Activity: Engagement with us online, including clicks and page views.

• - Device and OS Information: Including type, versions, and models.

• - Installation Reports: Timestamp and type of installation.

• - Products Usage Information: Activity logs related to product usage.

• - Payment and Billing Information: Details collected during transactions.

• - Marketing and Advertising Information: Includes clicks, campaign metrics, and referrer URLs.

• - Customer Support and Relations Information: Includes support tickets, subject matter, and status.

• - Signing Up, Registration, and Account Management: Information provided during account creation and management.

• - Subscription Information: Details related to subscriptions.

• - Analytics and Business Intelligence: Data used for analytical and business intelligence purposes.

• For more detailed information about these categories, please refer to our Privacy Policy.

• 2. How We May Share Personal Information

• - Sale of Personal Information: We do not sell your personal information for monetary gain. However, sharing information with advertising vendors such as Google, Facebook, Bing, and LinkedIn for targeted advertising may be considered as “data selling” under California law. You can opt out of this type of data sharing by using the “Do Not Sell My Data” option available in the footer of our pages.

• - Business Purposes: We may share personal information with third parties for business purposes, including with our affiliated companies. When doing so, we ensure that we have contracts in place that describe the purpose of the sharing and require the recipients to maintain the confidentiality of the information and use it only for the contracted purpose.

• - Categories of Personal Information Shared: In the past twelve (12) months, we have shared the following categories of personal information for business purposes:

• - Identifiers

• - Online identifiers

• - Online and network activity

• - Device and OS information

• - Installation reports

• - Products usage information

• - Payment and billing information

• - Marketing and advertising information

• - Customer support and relations information

• - Signing up, registration, and account management information

• - Subscription information

• - Analytics and business intelligence data

• If you have questions or need further information, please contact us at dpo@winoids.com.

Here's a structured outline of how we share various categories of personal information, including the business purposes for each category:

Categories of Personal Information and Their Business Purposes

1. All Categories

- Business Purpose: Hosting, processing, infrastructure, and security service providers to provide, facilitate, process, and secure the Applications, data, and services.

2. Internet and Network Data

- Business Purpose: Service providers, web platforms, analytics services, and online marketing platforms for tracking and improving online interactions and effectiveness.

3. Support and Customer Services

- Business Purpose: Support and help desk services to provide assistance and resolve issues.

4. Customer Relations Management and Mailing Lists

- Business Purpose: Manage and secure personal information, manage subscriptions, and handle notification lists.

5. Business Relations

- Business Purpose: CRM and mailing list platforms for managing business interactions and communications.

6. Contact Information

- Business Purpose: Customer support services for responding to inquiries and providing assistance.

7. Billing Information

- Business Purpose: Payment processing services for handling transactions and billing.

8. Advertising and Retargeting Services

- Business Purpose: Displaying and serving ads and offers through advertising platforms.

9. Affiliated Companies

- Business Purpose: Disclosing data to affiliated companies, parent companies, or subsidiaries to deliver and manage services.

10. Technology Partners Integrated into Products or Websites

- Business Purpose: Enhancing product functionality through integrated widgets, features, or technologies.

11. Cookies and Certain Online Identifiers

- Business Purpose: Marketing and advertising of the Services, analytics, and improving website and service functionality.

12. Legal Proceedings or Law Requirements

- Business Purpose: Complying with applicable laws, regulations, legal processes, or governmental requests.

13. Merger, Sale, or Bankruptcy

- Business Purpose: Due diligence and managing data transfers in the event of structural changes, such as mergers or acquisitions.

14. Special Cases

- Business Purpose: Handling specific situations like fraud prevention or investigations.

For any questions or concerns about how your data is used or shared, please contact us at dpo@winoids.com.

3. Consumer privacy rights

Here’s a clear outline of the rights under the California Privacy Rights Act (CPRA) and how to exercise them:
CPRA Rights and How to Exercise Them

1. Access and Data Portability Rights
You have the right to:

- Access: Request information we have about you from the past 12 months.

- Data Portability: Obtain this information in a human-readable format.

- Information Includes:

- Categories of personal information collected.

- Sources of personal information.

- Business purposes for collection.

- Categories of third parties with whom we share the information.

- Specific pieces of personal information collected.

- Whether we sold or shared your personal information for a business

purpose.

How to Exercise:

- Directly via Account: If you have an account, use the access feature in your account settings.

Form Submission: Use the form available in your account portal or send a request via email to dpo@winoids.com.

Limitations:

- You may request this information up to twice within a 12-month period.

2. Delete Personal Data

You have the right to request deletion of your personal information, subject to certain exceptions:

- Exceptions to Deletion:

- Completing transactions or providing requested services.

- Detecting or protecting against security incidents or illegal activities.

- Debugging errors in products.

- Exercising free speech or ensuring another consumer’s free speech rights.

- Complying with laws or regulations (e.g., CalOPPA).

- Conducting public or peer-reviewed research.

- Internal uses aligned with consumer expectations.

- Complying with legal obligations.

How to Exercise:

- Directly via Account: If you have an account, use the delete feature in your account settings.

- Request Submission: Send your request via email to dpo@winoids.com.

3. Rectify Personal Information

You have the right to request correction of inaccurate personal information.

- Includes:

- Deleting incomplete or inaccurate personal information.

- Requesting direct correction if you have an online account and the information is available through the account.

Note: This right applies only to personal information collected directly from you, not from third parties.

How to Exercise:

- Directly via Account: Use the correction feature if available in your account settings.

- Request Submission: Send your request via email to dpo@winoids.com.

4. Opt-Out of Data Selling or Sharing

We do not sell or rent your personal information for direct marketing purposes. However, we may share your personal information for marketing, advertising, and analysis.

How to Opt-Out:

- Link to Opt-Out: Click the ‘Do Not Sell/Share My Personal Information’ link at the footer of our website. Cookies Settings

- Manage Cookies: Adjust your cookies settings through the cookie management tools available on our website.
For any data protection-related inquiries or to exercise your rights, please contact us at dpo@winoids.com.

4. Exercising your rights and choices

Here’s a clear summary of how to exercise your rights under the California Privacy Rights Act (CPRA), including details on verifiable consumer requests:

Exercising Your Rights

1. How to Exercise Your Rights

- Access, Data Portability, Deletion, and Rectification:

- Via Account: If you have an account, these requests can be made directly through your account settings.

- Without an Account: Submit a verifiable consumer request via:

- Email: dpo@winoids.com

- Privacy Rights Section: Use the ‘privacy rights’ section in the portal if available.

2. Verifiable Consumer Request

- Definition: A request made by:

- The Consumer: The individual whose data is being requested.

- Authorized Representative: A person authorized to act on behalf of the consumer, including a registered natural person with the Secretary of State.

- Verification Requirements:

- Registered California Resident: The request must be from a verified California resident or their authorized representative.

- Identity Verification: Provide sufficient information to verify your identity or the authority of the representative.

- Request Detail: Describe your request with enough detail to allow us to understand, evaluate, and respond accurately.

3. Verification of Requests

- Identity and Authority:

- We need to confirm that you are the person about whom we have collected personal information or an authorized representative.

- We use the information provided in the request only for verification purposes.

4. No Account Required

- Request Without Account: You do not need to create an account to make a request if you do not have one.

- Data Use: Personal information provided in a verifiable request is used solely for verifying identity and authority.

For any questions or assistance with exercising your rights under the CPRA, please contact us at dpo@winoids.com.

5. Response Timing and Format

Response to Verifiable Consumer Requests

1. Response Time

- Standard Time: We aim to respond to your verifiable consumer request within 45 days of receipt.

- Extension: If more time is needed, up to 90 days, we will notify you in writing (electronically) with the reason for the extension and the new response period.

2. Delivery of Response

- Without Account: If you do not have an account with us, responses will be delivered by email.

- Disclosure Period: The information provided will cover only the 12-month period preceding the receipt of your request.

- Explanation for Non-Compliance: If we cannot fully comply with your request, we will explain the reasons why in our response.

3. Data Portability

- Format: For data portability requests, we will provide your personal information in a format that is readily usable, allowing you to transmit it to another entity without difficulty.

4. Fees

- No Fee: Generally, there is no fee to process or respond to your verifiable consumer request.

- Fees for Excessive Requests: If a request is excessive, repetitive, or manifestly unfounded, a fee may be charged. We will inform you of the decision to impose a fee and provide a cost estimate before proceeding with your request.

6. Non-Discrimination

We are committed to respecting your rights under the California Privacy Rights Act (CPRA). Therefore, we will not discriminate against you for exercising any of your CPRA rights. Specifically:

No Denial of Goods or Services: We will not deny you access to our goods or services.

No Different Pricing or Rates: We will not charge you different prices or rates, including through discounts, benefits, or penalties.

No Different Quality: We will not provide a different level or quality of goods or services.

No Price or Quality Suggestions: We will not suggest that you may receive different pricing, rates, or quality of goods or services based on your exercise of CPRA rights.

7. Do not Track Signals (CalOPPA)

What It Is: The DNT Feature is a privacy setting available in some web browsers that allows users to signal to websites that they do not wish to have certain information about their visit collected.

Current Practice: As of now, Undertone does not respond to or recognize DNT Feature signals.

8. Changes to this privacy statement

We reserve the right to amend this privacy notice at our discretion and at any time. When changes are made, we will notify you using the notification mechanism described in our Privacy Policy, or as otherwise required by applicable laws.

9. Contact info

If you have any questions or comments about this notice, our privacy statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: dpo@winoids.com.

Special jurisdictions: Canada

Here's a refined version of your privacy notice tailored for Canadian residents, incorporating all the relevant information:

Last Updated: July 16, 2023

About this Statement

This statement complements (but does not replace) the general Privacy Policy provided by Compsquad LLC (“Winoids”) and its affiliated companies.

Scope and Applicability

This statement applies to Data Subjects residing in Canada and is designed to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), as well as the Quebec Privacy Legislation Modernization Act, also known as Law 25 (“Law 25”).

Terms and Definitions

Any terms defined in the Privacy Policy have the same meaning when used in this notice. Terms used in this Canadian notice that are not defined will have the meaning provided in the Privacy Policy or other agreements.

Collection of Personal Information

As described in our Privacy Policy, we collect the following categories of personal data about you:

- Identifiers (online and physical)

- Online and network activity

- Device information

- Usage information

- Payment and billing information

- Marketing and advertising information

- Customer support and customer relation information

For more details about each category, please refer to our general Privacy Policy.

Use of Personal Information

We may use your personal information for one or more of the following purposes:

- To provide products and services to you

- To communicate with you about your orders and shipments

- To improve our products and services

- To personalize your experience on our website

- To send you marketing communications

Retention and Disposal of Personal Information

Our general Privacy Policy explains the retention schedule for each type of personal data we collect. Generally:

- We retain personal data as long as necessary to fulfill the purpose for which it was collected.

- We retain personal data longer if required by applicable legislation (e.g., tax, labor laws).

- We may retain personal data longer for the purpose of developing and improving our products and services. Pseudo-anonymization measures may be employed to safeguard such data.

- Account and subscription information is retained until a valid and verified deletion request is processed.

We delete personal data under the following circumstances:

- Upon receipt of a valid and verifiable request for deletion.

- When data is no longer necessary for the purpose it was collected or to comply with legal requirements.

- If data was unlawfully processed (e.g., without valid consent).

Third Parties and Data Transfers

As part of Winoids's global operations, we share data with third parties, including those outside Quebec and/or Canada. Categories of third parties with whom we share personal data include:

- Compsquad affiliated companies (subsidiaries, parent companies)

- Hosting services and storage vendors (e.g., Microsoft, Google, Amazon Web Services)

- Analytics, business intelligence, and statistics vendors (e.g., Google Analytics)

- Support and customer services (e.g., ZenDesk)

- Compliance vendors (e.g., OneTrust)

- Customer relations management and mailing list platforms (e.g., Probance)

- Billing and payment solutions (e.g., Upclick)

- Advertising and marketing services (e.g., Google Adwords, Facebook, LinkedIn)

- Technology partners integrated into products or websites (e.g., Chip.de)

- Special cases (e.g., fraud prevention or investigation)

For more details about third-party data disclosures, refer to our general Privacy Policy or contact our DPO at dpo@winoids.com.

Your Rights

Subject to certain exemptions provided by law, you may request to exercise one or more of the following rights:

- Right to be informed

- Right to access

- Right to rectification

- Right to erasure

- Right to withdraw consent

- Right to restrict processing

- Right to data portability

Information about these rights and how to exercise them is available on our Privacy Rights policy page.

We will strive to respond to all legitimate requests within 30 days. If your request is complex or multiple requests are made, it may take longer. In such cases, we will notify you.

If you have a complaint about how we use your personal information, please contact us first at dpo@winoids.com. You also have the right to file a complaint with the Privacy Commissioner of Canada (OPC) or Quebec’s Commission d'accès à l'information (CAI), as applicable.

Roles and Responsibilities

- For questions regarding data privacy and governance, contact our Data Protection Officer (DPO) at :dpo@winoids.com. 

- For questions about data security, contact our DPO at the email above or our data security manager at: support@winoids.com

Further Information

For questions about the Privacy Policy or concerns regarding our compliance, please contact our privacy officer at:

Compsquad LLC, 229 Raindollar Ave #H Marina, CA 93933