# **Player Privacy and Protection Policy** ### **1\. Introduction** This Privacy Policy (the "Policy") explains how **Winna.com** collects, uses, stores, and protects your personal data when you use our website or services. By using www.winna.com, you confirm that you have read, understood, and accepted the practices described in this Policy. We are committed to protecting your data in line with international data protection laws and the **regulations of the Tobique Gaming Commission**. ### **2\. Company Information** **Winna.com** is operated by **GG Gaming LLC**, a company established under the laws of **Costa Rica**, with the following details: - Registered Address: Sabana Business Center, Boulevard Ernesto Rohrmoser, Mata Redonda, San José, Costa Rica - Company Registration Number: 3-102-916906 - Contact Email: [support@winna.com](mailto:support@winna.com) ### **3\. Player Data We Collect** We collect and process the following categories of data: #### **Registered Player Details** - Full name - Date of birth - Residential address - Email and phone number - Username and password - Gender - Country of residence #### **Verification Data (KYC)** - Valid ID document (passport, driver's license, etc.) - Proof of address (utility bill, bank statement) - Proof of payment ownership - Photo or video verification (if required) - Source of funds (where applicable) #### **Payment & Transaction Data** - Deposit and withdrawal history - Payment methods used (e.g., last 4 digits of card) - Bonus and loyalty program activity - Bet history and session times #### **Technical & Automatically Collected Data** - IP address - Browser and device details - Site usage behavior (clicks, pages visited) - Cookies (see Cookie Policy) ### **4\. Legal Basis for Data Processing** We process your personal data on the following legal grounds: - To fulfill our contract with you (Article 6(1)(b) GDPR) - To comply with legal obligations (AML, CTF) (Article 6(1)(c) GDPR) - For legitimate business interests such as fraud prevention or service improvement (Article 6(1)(f) GDPR) - Based on your consent (e.g., marketing) (Article 6(1)(a) GDPR) ### **5\. Protection of Funds** Winna maintains all player funds in **segregated accounts**, fully separate from operating capital, in accordance with international best practices and **Tobique regulatory standards**. This ensures your deposits are protected even in the unlikely event of company insolvency. ### **6\. Account Security Controls** We take appropriate technical and organizational measures to protect your personal and financial data, including: - SSL encryption for data transmission - Two-Factor Authentication (2FA) - Role-based employee access controls - Regular internal audits and third-party security assessments - Account lockouts after repeated failed login attempts We strongly advise users to choose secure passwords and keep login credentials confidential. ### **7\. Complaint Procedure** If you wish to file a complaint related to your data, account, or our services: - Email: [support@winna.com](mailto:support@winna.com) - Include your name, registered email, and a description of the issue We aim to: - Acknowledge your complaint within **48 hours** - Provide a full response within **14 business days** If unresolved, you may escalate the complaint to the **Tobique Gaming Commission**. ### **8\. Use of Player Data** We use your data for the following purposes: - To register and manage your account - To process deposits and withdrawals - To comply with anti-money laundering (AML) and counter-terrorism financing (CTF) laws - To prevent fraud, abuse, or underage access - To personalize services (e.g., bonuses, VIP support) - To send communications (transactional or marketing, if opted in) ### **9\. Data Sharing and International Transfers** We may share your data with trusted third parties such as: - Payment processors and banks - Identity verification providers - Customer support tools - Game providers - Legal, compliance, and audit partners - Data centers and hosting services Your data may be transferred internationally, including outside the EEA. In such cases, we ensure: - Adequacy decisions by the EU Commission - Standard Contractual Clauses (SCCs) - Appropriate technical safeguards (encryption, pseudonymization) ### **10\. Retention Period** We retain player data for up to **6 years after account closure**, as required for legal and regulatory compliance. After this period, your data will be securely deleted or anonymized. ### **11\. Your Rights** As a data subject under GDPR, you have the following rights: - Access to your personal data - Rectification of incorrect or outdated data - Erasure ("right to be forgotten") - Restriction or objection to processing - Data portability - Withdrawal of consent (where applicable) - Right to lodge a complaint with a data protection authority To exercise any of these rights, contact: [support@winna.com](mailto:support@winna.com) ### **12\. Children's Data** Access to Winna is restricted to individuals **18 years or older**, or the legal age in your jurisdiction. If we identify underage use, we will immediately **close the account and delete all related data**. ### **13\. Website Information & Cookies** We use cookies and analytical tools (e.g., Google Analytics, Hotjar) to: - Improve Website functionality - Understand player behavior - Provide tailored content You can manage cookie preferences via your browser or our Cookie Policy page. ### **14\. External Links** Winna.com may contain links to third-party websites. We are **not responsible** for the privacy practices of those sites. We recommend reading their privacy policies before providing any personal information. ### **15\. Changes to This Policy** We may update this Policy periodically. Any changes will be posted here and, if significant, communicated via email to registered users. Continued use of the Website constitutes your acceptance of the revised Policy. ### **16\. Language** This Policy is provided in English. Translations are available for convenience. In case of discrepancies, the English version prevails.