Introduction: 

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This privacy policy and cookie statement explains how Winners Circle collects, stores and processes Personal Information in relation to the SERVICE. This policy does not pertain to websites, applications, destinations, events or other services that are not owned, or controlled by Winners Circle. 

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This policy can be accessed at any time in the footer of the Service’s home page, through the hamburger/menu located at the top right hand side of the screen or as indicated on the particular Service you are engaging with. By interacting with our Service including but not limited to, visiting, accessing, utilising, viewing, purchasing, or using, you acknowledge that you have read, understood and accepted the terms of this policy. If you do not agree with the terms within this policy, please discontinue the interaction with our Service immediately. We recommend that you keep a copy of this policy accessible for your reference in the format you deem suitable, if you wish to use our Service. 

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Additionally please review our Terms of Service and any other terms and conditions as provided on the Service you interact with. These terms are also part of the agreement between us and you.  

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The policy is subject to modification. We encourage you to revisit this policy from time to time. Winners Circle will maintain a “Last Updated” date at the beginning of this document and will post a notice on the Service. Any continued interaction with the Service will be deemed as your acceptance of any changes to this policy.

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If you need to contact us, regarding questions, concerns or any other reason related to this policy, please email ADMIN@WINNERSCIRCLE.MEDIA.

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Categories of Personal Information Acquired About You:

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Based on which Service you interact with, we may collect, obtain or acquire and develop and retain inferences from any of the following types of Personal Information about you:

1. Registration and sign up information such as first name, last name, email addresses, passwords, phone numbers, account number, title, company, age, address, city, postal code, zip code and similar information listed on the sign-up form.
2. Activity and Usage information such as how you accessed our services, how long you remained on our services, where you landed from our services, clicks on our services, engagement metrics, likes, comments, interactions, follows, shares, clickstream, length of visits, social media handles, page response times, user preferences and similar usage metrics.    
3. Technical information such as unique online identifiers, IP addresses, User ID, Device ID, browser type, operating system, internet provider, network activity information, and other device and browser attributes and settings.  
4. Location Information such as device information, devices interaction with our service, precise location, country, coordinates, and potentially Identifiers for Advertisers.
5. Publicly shared or submitted content (User Content) such as information posted on our blog, submissions to any competitions, draws, magazine content submissions, participation in surveys, comments on our social media and fan pages, recordings, videos, public posts, and digital events.
6. Transaction information such as payment information, purchase history, favourited products, reviews, returns, exchanges, and postal code. 
7. Contact and Query information that may be received when you communicate with us through our chat function, website forms, email, ticketing system, social media, and call centres. 

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The policy does not contain any information that limits, restricts or determines how we collect, use and process de-identified, aggregate information.

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How We Collect Personal Information:

1. Information you provide us. We collect personal information because you provide it to us. For example when you sign up for our newsletter or our membership services, you provide your name(s), contact information, location information, payment information, user preferences or demographic information. There are various points through our services where you provide personal information. If you do not wish to provide certain personal information, do not interact with that particular service. 
2. Automatically collected information. Some personal information we receive about you is automatic upon usage of any of our services. This type of personal information includes but is not limited to, activity and usage information, technical information and location information. We use a host of technologies such as cookies, flash cookies, tags, analytics software, and web beacons to collect this information.  

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Security of Data

Any and all data that is collected is stored in a secure location that is accessible only to select Winners Circle Media authorities who have an obligation to preserve the safety of any collected information.       

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How is my information used?

Any information collected from the usage of our Service is utilised by Winners Circle Media to determine the performance of our content. Your personal information is not transmitted, shared or transferred to any 3rd party outside of the Winners Circle Media brands. 

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From time to time, we may share aggregate data such as number of monthly visitors, location of visitors, etc. to 3rd parties for us to obtain their services, or to provide our service to them. 

Where is my information stored?  

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA) that may not be subject to equivalent Data Protection Law.

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Winners Circle collects information from users around the world and it is stored on servers in the United States. Such storage is necessary for us to process information. 

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We may transfer your personal information outside the EEA, including but not limited to, the following reasons:

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• in order to store it.
• in order to enable us to provide goods or services to you and fulfil our contract with you. This includes order fulfilment, processing of payment details, and the provision of support services.
• where we are legally required to do so.
• in order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

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We may transfer your personal information to the following countries and entities outside the EEA:

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Google LLC

Who is my information shared with?

Our Service Providers

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We utilise 3rd party services which require the transmission of certain information for them to provide us their services. Unless we tell you otherwise, our service providers may only use Personal Information we share with them in accordance with our instructions.

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Our service providers include:

• Customer support and engagement software & services
• Cloud storage hosting and providers
• Newsletter and email marketing providers
• Subscription fulfilment companies
• Advertising and marketing partners

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Aggregate information

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Aggregate information does not include any personal information which you can be identified from. We share aggregate information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them.

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In addition, these third parties may share with us anonymised, aggregated or otherwise non-personal information about you that they have independently developed or acquired.

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Information You Elect to Share

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You may access other Third Party Services, including other websites and platforms, through the Services for example by clicking on links to those Third Party Services from within the Site. We are not responsible for the privacy policies and/or practices of these Third Party Services, and you are responsible for reading and understanding those Third Party Services’ privacy policies. This Privacy Policy only governs information collected as part of our Services.

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How long we keep your information

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If you have subscribed to any of our newsletters, we retain Personal Information for as long as you remain subscribed. If you opt-out, we will retain only the minimum information needed to make sure you don't receive any unwanted communications from us.

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We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

Your rights

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You have the right, under certain circumstances:

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• to be provided with a copy of your Personal Information held by us;
• to request the correction or deletion of your Personal Information held by us;
• to request that we restrict the processing of your Personal Information (while we verify or investigate your concerns with this information, for example);
• to request that your provided Personal Information be moved to a third party;
• to object to the further processing of your Personal Information in some circumstances; and
• to withdraw consent from the processing of personal information that is processed by your consent, without any determinant

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If you have any questions or concerns regarding privacy using the Services, please send us an inquiry to ADMIN@WINNERSCIRCLE.MEDIA. We will make every effort to resolve your concerns.

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