This Privacy Policy (the “Privacy Policy”) applies to the website located at www.5wins.io (the “Site”) operated by 5wins Inc. and its associated websites, subdomains, mobile versions, any associated applications, and services (“5wins”). This Privacy Policy describes how 5wins collects, uses, shares, and secures the personal information you provide. It also describes your choices regarding use, access, correction, and deletion of your personal information.

We collect the following personal information from you: A. INFORMATION THAT YOU PROVIDE TO US ABOUT YOURSELF When you sign up for our newsletter or create an account, if account creation becomes available, we ask you for information such as: (i) contact information, including your name, email address, mailing address, or phone number; and (ii) unique identifiers, such as username, account name or password. This information allows us to provide you with an account and operate our Site. When you make a purchase on the Site, a third-party payment processor will collect your full name, email address, postal address, contact details and credit or debit card information (“Billing Information”). This record will be stored and processed in the United States and other countries. By making a purchase, you grant to us and to all other persons and entities involved in the operation of the Site, the right to use, store, monitor, retrieve and transmit your account information in connection with the operation of the Site and as otherwise provided herein. You also agree that such access and use of your personal information is governed by their privacy policies. We are not responsible or liable for the content, activities or privacy policies of any third-party sites. Accordingly, please refer to their respective privacy policies. We ask for personal information via enter-to-win contests held through email, social media, and paid media campaigns. This information is collected for the purpose of contacting winners and for marketing or promotional purposes. You may unsubscribe from these communications by following the instructions contained within the communication or emailing us at: team@5wins.io Please note that due to marketing production schedules you may receive messages already in production. We may also obtain your personal information through your use of social media depending on your settings or the privacy policies of these services. To change your settings on these services, please refer to their respective privacy notices. B. INFORMATION COLLECTED AUTOMATICALLY When you use our Site, either logged-in or as a guest, we use cookies and similar technologies to collect information about your location, and your activities on our Site, information about your device and log information. Among the items these cookies and similar technologies collect are anonymized Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. 5wins allows Google Analytics and other similar services to use these technologies to analyze trends, administer the Site, track users movements around the Site, and to gather demographic information about our user base as a whole for the purpose of analyzing use of our Site and improving our Site. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Site.

To offer our Site to you: We use your information to identify you, provide you with technical support and assistance; and communicate with you about the Site and promote the Site to you via email. For example, we may contact you to notify you of any issues with the Site or any suspicious activity in your account. The legal basis for these uses is the performance of services requested by you by your visiting the Site. To optimize or improve the Site: We use your information to understand your usage of our Site, improve the content on our Site, and improve user experience generally. The legal basis for these uses is our legitimate interest in the improvement and optimization of our Site and service offerings. To administer a contest or other promotion, survey, or other features; and To allow us to disclose your information to the extent permitted by law.

We share your personal information only with (i) certain third-party service providers, (ii) as required by law, and (iii) in connection with the protection and enforcement of our legal and contractual rights. With Service Providers: We share your information with third parties who provide services on our behalf to help with our business activities. This includes: providing customer service, sending marketing communications, setting cookies for marketing purposes, conducting research and analysis and providing cloud computing infrastructure. The legal basis for sharing this information is our legitimate interest in providing our Site efficiently and we implement measures to safeguard your information. With Public Authorities or Law Enforcement: In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law (such as to comply with a subpoena or other legal process), when we believe in good faith that disclosure is necessary to protect our rights, when we believe there is a violation to any of our terms or other agreement with us, to protect your safety or the safety of others and minors, to investigate fraud, to respond to a government request, if we are involved in a merger, acquisition, or sale of all or a portion of our assets or if we are involved in a bankruptcy or liquidation proceeding. The legal basis for this is our legitimate interest in protecting our legal rights and those of others, compliance with legal obligations and our legitimate interest in fulfilling legal obligations imposed by legal authority. Prevent fraud and abuse of the Site: We will share information to prevent or detect fraud or to address technical issues and if we believe it is necessary to investigate, prevent, or act regarding situations that involve abuse of the Site infrastructure. The legal basis for this is our legitimate interest in the maintaining the security of our Site. We also process and share information in an aggregated, de-identified manner, where the information is shared as part of a statistical report and does not contain personal information. We may make available services such as blogs, message boards and chat functionality to which you are able to post information and materials. Please note that any information you disclose through such services or otherwise on the Site becomes public information, and may be available to visitors to the Site and to the general public. In addition, when you choose to make a posting on such services certain personal information will be available for other users to view. We urge you to exercise discretion and caution when deciding to disclose personal information about you, or any other information, on the Site. WE ARE NOT RESPONSIBLE FOR THE USE BY ANY THIRD PARTY OF ANY PERSONAL INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH ANY SUCH SERVICES OR OTHERWISE ON THE SITE; and with your express consent.

The security of your personal information is important to us. We implement adequate measures to protect the personal information submitted to us, both during transmission and once it is received. 5wins takes steps to ensure that such data remains private and confidential. We restrict access to personal information to 5wins employees, contractors and agents who need to know that information in order to operate, develop or improve our service. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. If you have any questions about the security of your personal information, you can contact us via the contact information below.

At any time, you can add or remove your name from a 5wins list by contacting us at team@5wins.io. We will endeavor to comply with your request as soon as reasonably practicable. In certain circumstances, we may be required by law to retain your personal information or may need to retain your personal information in order to continue providing service. You may sign-up to receive email or newsletters or other communications from us. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or by contacting us via the contact information below.

We may retain your information for as long as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements. In certain circumstances, we may be required by law to retain your personal information or may need to retain your personal information to continue providing access to the Site. Even if you delete your account, keep in mind that the deletion by our third-party providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time.

The Site is not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If you are under 13, please do not use the Site and do not provide any personal information to us. If you become aware that a child under 13 has provided us with personal information without your consent, please contact us at team@5wins.io. Visit www.OnGuardOnline.gov for tips from the Federal Trade Commission on protecting children’s privacy online.

This Site is hosted in the United States. In order to communicate with you about content, the information that we collect from you may be transferred to, stored, used and processed by 5wins in the United States or one of our service providers based in the United States or outside of the United States. Such entities may be engaged in, among other things: (i) preparing and sending newsletters to which you subscribe; (ii) the processing of payment details; and (iii) the provision of support services. If you are visiting from the European Union or other regions with laws governing information collection and use that may differ from United States law, please note that you are transferring your personal information to the United States. The laws of some countries may not provide the same levels of protection of personal information as your home country, particularly if you are resident in the European Union. By using this Site, you agree to the collection, transfer, storage, use and processing of information about you for the purposes described in this Privacy Policy. When you provide personal information to us or our service providers or vendors, you consent to the processing of your information in the United States as the Site is operated in the United States. We will take reasonable steps to ensure that information about you is treated securely in accordance with this Privacy Policy, and that all information you provide to us is stored on our secure servers or those of our service providers. YOU ACKNOWLEDGE THAT THE LAWS OF THE UNITED STATES TREAT YOUR INFORMATION IN A MANNER THAT MAY BE SUBSTANTIALLY DIFFERENT FROM, AND LESS PROTECTIVE THAN, THE TREATMENT REQUIRED UNDER THE LAWS OF OTHER COUNTRIES AND JURISDICTIONS. IF YOU DO NOT WANT YOUR INFORMATION TRANSFERRED TO THE UNITED STATES, YOU SHOULD NOT SHARE YOUR PERSONAL INFORMATION WITH US, OR MAKE USE OF THIS SITE. TO THE EXTENT ALLOWED BY THE LAW OF THE COUNTRY IN WHICH YOU ARE LOCATED, YOU EXPRESSLY WAIVE ANY RIGHT YOU MAY HAVE TO REQUIRE US TO TREAT YOUR IDENTIFYING INFORMATION IN ACCORDANCE WITH THE LAWS OF ANY COUNTRY OR JURISIDICTION OTHER THAN THE UNITED STATES. HOWEVER, THE FOREGOING WAIVER MAY NOT BE LEGALLY BINDING IN SOME COUNTRIES, SUCH AS THE MEMBER STATES OF THE EUROPEAN UNION. TO THE EXTENT IT IS NOT LEGALLY BINDING IN THE COUNTRY IN WHICH YOU ARE LOCATED, THE FOREGOING WAIVER DOES NOT APPLY TO YOU.

Some browsers offer a “do not track” (“DNT”) option. Because no common industry or legal standard for DNT has been adopted by industry groups, technology companies, or regulators, we do not respond to DNT signals. We will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

We may need to update this policy from time to time, and we reserve the right to do so as we deem necessary or desirable. We will notify you of such changes by revising the “Last updated” date provided herein, and/or by any other legal means, and your use of the Site after any such changes shall constitute your consent to such changes. We encourage you to periodically review this page for the latest information on our privacy practices.

We are not responsible nor will be liable to you in any way for events beyond our direct control. Because of the complex and constantly changing nature of our technology and business, we cannot guarantee, nor do we represent that our performance will be error free, and to the maximum extent permitted by law we will not be liable for any direct, indirect, incidental, consequential or punitive damages or other loss suffered by you and relating to the use or release of your personal information. YOUR CALIFORNIA PRIVACY RIGHTS SHINE THE LIGHT LAW A California privacy law that went into effect on January 1, 2005, the “Shine the Light” law, allows California residents to obtain a list of third parties to whom a business has disclosed personal information if it shares such information with third parties for their direct marketing purposes. However, if a business adopts and discloses in its privacy policy a policy of not disclosing customers’ personal information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, the business may comply with the law by notifying the customer of his or her right to prevent disclosure of personal information and by providing a cost-free means to exercise that right. As stated earlier in this Privacy Policy, personal information submitted at the time of registration or submission may be used for marketing and promotional purposes only with the user’s permission. Whenever a user agrees to allow us to collect personal information, we provide the user with an option to prevent such information from being shared for marketing and promotional purposes with third parties. Furthermore, you may exercise this cost-free option at any time by sending an email to team@5wins.io. Because the Site has a comprehensive privacy policy and provides you with details on how you may opt- in or opt-out of the use of your personal information by third parties for direct marketing purposes, we are not required to provide you with the third-party list.

If you have questions or concerns about our Privacy Policy please contact us at team@5wins.io.