WinkLeads AdServing and Platform Privacy Policy

The purpose of this Privacy Policy (this “Policy”) is to inform you about the use of data within WinkLeads and its affiliates, including data processors, sub-processors, and third-party partners. This Policy also explains how you can manage certain data collected about you.

Definitions

• Company: WinkLeads, a registered company.
• Platform: The services we provide to Clients.
• Clients: Advertisers and Publishers who use the Platform to create, edit, and maintain advertising campaigns or sell advertising placements.
• User: An individual who receives or interacts with an advertisement.
• Data Subject: Any person whose personal data is collected, including Clients and Users.
• Processor: Technology providers or sub-processors who maintain a data processing agreement with the Company.

Personally Identifiable Information (PII)

PII is information about you that can identify or contact you, such as your name, username, phone number, email, and physical address. We retain PII for a maximum of one (1) year before deletion.

Personal Data

Personal Data refers to information that can single out an individual User. Through ad tags and cookies, we collect information that may indirectly identify your device or geolocation for targeted advertising. Under European privacy law, certain data collected via cookies and log data is considered personal information. Personal Data is retained for no more than one (1) year before deletion.

Information Collected for Client Accounts

• Registration Information: Name, mailing address, phone number, email, Skype contact, and similar details.
• Technical/Access Information: IP address, User-Agent, pages accessed, and data entered, stored for fraud prevention and security auditing.

This information is necessary for secure account access and platform security. It will not be sold or transmitted for commercial purposes.

Information Collected Relating to Users and Advertising

• Device and Connection Information: IP address, User-Agent, URLs or apps accessed. This helps target ads without identifying individual Users.
• Retargeting: Ads may be targeted to Users based on prior interaction with advertiser websites or apps. Clear consent is obtained before retargeting is applied.

Your Rights as a Resident of the European Economic Area (EEA)

If you are located in the EEA, you have rights including accessing, correcting, deleting, porting, or objecting to the use of your personal data. Personal data may be processed for:

• Providing services to Clients.
• Preventing risk and fraud.
• Communications, marketing, and advertising.
• Reporting and analytics.
• Third-party integration.
• Troubleshooting and support.
• Testing features and improving services.

Consent, Opting-Out, and Data Requests

Clients may revoke consent via account settings. EEA Users may submit inquiries or requests regarding their personal information using the contact information provided below.

Children’s Online Privacy Protection Act (COPPA)

The Platform is intended for general audiences and not directed at children under 13. We do not knowingly collect personal information from children under 13. If you discover a child has provided personal data without parental consent, please contact us at info@WinkLeads.com. We will remove such information and terminate associated accounts.

Data Policies

Data Retention: Advertiser or publisher registration information is retained unless deleted or updated by the Client.

Data Related to Advertisements: Data related to connections, ads served, or other information processed on behalf of Clients is retained for up to six (6) months. Afterwards, data may be used in aggregated form for analysis, legal compliance, dispute resolution, and contract enforcement.

How We Protect Your Information

Physical Measures

We maintain private, secure cloud infrastructure. Access is restricted via keycards and monitored 24/7 by onsite security. Log access is strictly controlled.

Technical Measures

Data transmitted to and from the Platform is encrypted via HTTPS. Security measures comply with accepted industry standards.

Data Breach

While we make good-faith efforts to prevent misuse or unauthorized access, we cannot guarantee complete protection. In case of a breach involving personal information, affected parties and relevant authorities will be promptly notified.

Disclosure to Third Parties

• To prevent, investigate, or act on illegal activities, fraud, or violations of platform terms.
• To comply with legal requests, court orders, or law enforcement requirements.
• In the event of a merger, acquisition, or similar transaction, information may be transferred to the acquiring entity with notice posted on our home page.

Cookies

We and our partners may use cookies, web beacons, tags, scripts, advertising identifiers, and similar technologies. Cookies may track device information, browsing activity, ads displayed, and interactions. Cookies can be persistent or session-based.

Cookie Purposes

• Processes: Ensure the service functions as expected.
• Authentication, Security, Compliance: Prevent fraud and protect data.
• Preferences: Remember user preferences and settings.
• Advertising: Deliver relevant ads to users.
• Analytics: Understand how visitors use the Platform.

You can manage cookie preferences in your device or browser settings. Some functionality may be affected if cookies are disabled. Opt-out for advertising cookies here: Opt-Out Page.

Changes to the Privacy Policy

We may update this policy to reflect changes in practices, operational, legal, or regulatory requirements. The most current version governs how your information is collected, used, and disclosed. Continued use after updates acknowledges acceptance of the revised policy.

How to Contact Us

If you have any questions about this Privacy Policy, please contact us via email: info@winkleads.com.