2Win! Global, LLC
Updated may 24, 2018
The Information We Collect; Use of Information
We may automatically collect personally identifiable information from you when you access the Website. We may also collect personally identifiable information from you through voluntary sources on the Website, such as orders, responses, registrations, reviews, comments, e-mails, postings, messages, photos or other electronic submissions and communications sent by you to 2Win! or the Website. The personally identifiable information we may collect from you includes, without limitation: domain name and IP address, business e-mail address, business contact information (including address, zip code, and phone number), and other information volunteered by you. We will maintain the confidentiality of any contact information you provide to us, and we will use it only for the purposes for which we have collected it (subject to the exclusions and disclosures we have listed below), unless you otherwise agree (in this Policy or otherwise) that we may disclose it to other third parties.
The personally identifiable information 2Win! collects from users of the Website (both registered and unregistered) may be used for a variety of purposes; for example, to provide the services and products offered through the Website to users of the Website, to customize advertising and other content displayed on the Website and/or the layout of the Website for each individual user of the Website, to notify users of the Website about updates to and activities on the Website and about goods and services that we feel may be of interest to you, to improve the content of the Website, to analyze data and patterns regarding usage of the Website, to contact users of the Website for marketing purposes, and to contact users of the Website for information verification purposes. We process your personally identifiable information pursuant to our Terms of Service located at www.2winglobal.com.
We provide you with a choice whether to receive certain e-mails. We provide you the opportunity to “opt-out” of having your personally identifiable information used for certain purposes. If you are a user of the Website and you no longer wish to receive e-mails, newsletters, mail, or telephone calls from us or have your e-mail address or postal address shared with third parties, you may opt-out these communications. All opt-out requests can be made by emailing us at email@example.com.
Non-Personally Identifiable Information; Cookies; Web Beacons
Where possible, 2Win!’s server automatically recognizes each visitor’s Internet Protocol address. We also collect information about how visitors use the Website (for example, what pages are viewed). This information allows us to improve the content of the Website and facilitate market research.
A cookie does not collect or keep your name or other personally identifiable information; however, we may link the information obtained through cookies to other personally identifiable information to give us a better understanding of your preferences, so that we can provide a more meaningful experience to you on the Website.
Consent to the Use of Third Parties Providers
2Win! may contract with third parties to provide various services to 2Win! relating to the Website on an outsourced basis rather than performing the services itself. By visiting the Website, all visitors consent to 2Win! providing both personal and non-personal information received from those visitors to these third-party providers for the purpose of enabling the third-party provider to provide these outsourced services to 2Win!. In addition, all visitors consent to the collection, maintenance, and processing of their personal and non-personal information by 2Win! and these third-party providers. Such third parties are prohibited from using your information except to provide the outsourced services, and they are required to maintain the confidentiality of your information.
2Win! allows users to pay for 2Win! products and services through the Website. When transferring money to the Website, you provide personal information, credit, debit, or bank account information, and an address through 2Win!’s third party payment processor. This payment process is external to 2Win!. By using the Website for these purposes, you grant our third-party providers the right, power, and authority to act on your behalf to access and transmit your personal and financial information from relevant financial institutions according to terms of our third-party providers’ privacy policies.
In accordance with and as permitted by applicable law and regulations, we will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business. When you close your account, we may continue to communicate with you about our products and services, give you important updates that may affect you, and let you know about products and services that may interest you, unless you have opted out of receiving marketing communications. We may also continue to use some of your information for business purposes and to improve our offerings or in some cases to develop new ones. We will retain and use your information as required by applicable laws and regulations.
Certain websites of 2Win!’s affiliates, promotional partners, advertisers, sponsors, and other third-party websites are accessible through the Website. These third-party websites have their own privacy and data collection policies and practices. 2Win! IS NOT RESPONSIBLE FOR ANY ACTIONS OR PRIVACY POLICIES OF SUCH THIRD PARTIES. YOU SHOULD CHECK THE APPLICABLE PRIVACY POLICIES OF THOSE THIRD PARTIES WHEN PROVIDING PERSONALLY IDENTIFIABLE INFORMATION THROUGH LINKED WEBSITES.
We will use commercially reasonable security measures on the Website to protect the loss, misuse, unauthorized access, disclosure, alteration, or destruction of the information under 2Win!’s control. While there is no such thing as “perfect security” on the internet, we will take commercially reasonable steps to ensure the safety of your personal information. In particular, emails sent to or from the Website may not be secure. Therefore, you should take special care in deciding what information you send to us via email.
The Website is not directed to children. We do not intentionally gather personal information from users who are under the age of 13. If a child under 13 submits personal information to the Website, and we learn that the personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 13, please contact us at firstname.lastname@example.org.
Amendments and Revisions
We reserve the right to change this Policy at any time. We reserve the right, at our sole discretion, to change, modify, add, or delete portions of this Policy at any time without further notice. If we do this, we will post the changes to this Policy on this page and will indicate at the top of this page the date these terms were last revised, which constitutes reasonable notice of such changes. Your continued use of the Website after any such changes constitutes your acceptance of the new Policy. If you do not agree to abide by this or any future Policy, do not use or access (or continue to use or access) the Website. It is your responsibility to regularly check the Website to determine if there have been changes to this Policy and to review such changes.
This Policy is governed by the internal substantive laws of the State of Colorado, without regard to any conflict of laws principles. Jurisdiction for any disputes, controversies, and claims arising under, in connection with, or out of this Policy lie exclusively with the state courts located in Colorado Springs, Colorado, or federal courts located in Denver, Colorado. If any such provision of this Policy is found to be invalid by a court of competent jurisdiction, the invalidity of such provision does not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect. UNDER NO CIRCUMSTANCE SHALL 2Win! HAVE ANY LIABILITY WHATSOEVER FOR ANY CONSEQUENTIAL, INCIDENTAL, INDIRECT, OR SPECIAL DAMAGES ARISING OUT OF THIS POLICY, HOWEVER OCCASIONED.
For Users Outside of the United States: GDPR and International Data Transfers
For users in the European Union, the following provisions apply to the European Union General Data Projection Regulation (GDPR).
Confidentiality. 2Win! is headquartered in the United States and has affiliates and service providers in other countries. Your information, including personal information that we collect from you, may be transferred to, stored at, and processed by us and our affiliates and other third parties outside the country in which you reside, including but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in your jurisdiction. We will take all reasonable steps to ensure that your data is treated securely and in accordance with this Policy.
References to “personal information” in this Policy are equivalent to “personal data” governed by the GDPR. We may transfer your personal information across national borders to other countries in compliance with applicable laws.
Transfers from EAA. Where 2Win! transfers your personal information to a country not within the European Economic Area (EAA) and not subject to an adequacy decision by the EU Commission, we rely on one or more of the following legal mechanisms: EU-U.S. Privacy Shield, Swiss-U.S. Privacy Shield, European Commission approved standard contractual data protection clauses that impose data prot.ection obligations on the parties to the transfer (“Standard Contractual Clauses”), and your consent in certain circumstances. A copy of the Standard Contractual Clauses can be found here. The Standard Contractual Clauses are expressly adopted by 2Win! for all data transfers of EU personal data to the United States, to the extent that 2Win! is not certified under the EU-US Privacy Shield.
Data Controller and Data Processor. We act both as a data controller (where we have direct control of your personal data) and as a data processor (where we may process your personal data on behalf of one of our Customers. Primarily, we act as a data processor. If you are using our services either (i) as an employee, contractor or similar of a Customer; or (ii) an individual interacting with a Customer, then your interactions with that Customer (including any associated personal information) are controlled by that Customer (as data controller) and we act as a data processor on their behalf and subject to their data processor agreements and/or policies. This Policy is intended to comply with and satisfy the obligations of any data protection agreements (“DPA” or “DPAs”) we have with our data controller Customers; in the event of any inconsistency with such DPAs, the DPA will govern. We will comply with confidentiality and GDPR provisions in our role as data controller or data processor, as applicable. In addition, all sub-processors of your information are required to comply with the confidentiality and GDPR provisions contained in this Policy.
European data protection laws give you certain rights regarding personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
- If you are resident in France, you also have the right to set guidelines for the retention and communication of your personal information after your death.
- If you wish to exercise one of these rights, please contact us at the e-mail contact below.
- You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
- Residents in other jurisdictions may also have similar rights to the above. Please contact us at the email contact below if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.
If you have any questions about this Policy, please contact us at email@example.com. You may also contact us by mail at:
2Win! Global, LLC
517 S. Cascade Ave., Suite A
Colorado Springs, CO 80903