Date of publication and effective date of this version: March 20, 2026

Privacy and Personal Data Processing Policy

This Privacy and Personal Data Processing Policy (hereinafter referred to as the “Policy”) is an official document of WINIO TECHNOLOGIES L.L.C (hereinafter referred to as the “Company”), and defines the procedure for processing and protecting all information, including personal data as defined by the legislation of the United Arab Emirates (hereinafter referred to as “Personal Information”) regarding individuals (hereinafter referred to as “Users”) who use the “WINIO” Service (hereinafter referred to as the “Service”), which WINIO TECHNOLOGIES L.L.C may receive from Users upon registration with the Service, during the use of the Service, as well as in the course of WINIO TECHNOLOGIES L.L.C’s performance of any agreements and contracts concluded with the User in connection with the use of the Service.

The current version of the Policy is available to any User on the Internet at https://winio.ai/privacy.

Before you begin using the Service, you, as a User, are required to review this Policy on your own.

Use of the Service constitutes the User’s unconditional consent to the Policy and the terms and conditions for the processing of their Personal Information set forth therein.

If you do not agree with the Policy and the terms and conditions set forth therein, you must immediately cease any actions aimed at using the Service.

1. Terms and Definitions

WINIO TECHNOLOGIES L.L.C (hereinafter also referred to as the “Company” or “Contractor”) is a legal entity registered in the United Arab Emirates in accordance with United Arab Emirates law, whose details are specified in Section 14 of this Policy, which is the owner and operator of the Service, and, with respect to User Information, also acts as the personal data controller;
The “WINIO” Service (hereinafter also referred to as the “Service,” “Platform,” or “Site”) is the website of WINIO TECHNOLOGIES L.L.C, including all its sections, pages, elements, and functionality, accessible on the Internet at https://winio.ai/, the copyright holder of which is WINIO TECHNOLOGIES L.L.C, and on which WINIO TECHNOLOGIES L.L.C publishes information for Users about various esports events within the scope of topics determined by WINIO TECHNOLOGIES L.L.C, including information about upcoming tournaments (matches), esports news, as well as AI predictions and advanced analytics on esports events prepared by WINIO TECHNOLOGIES L.L.C, and through which WINIO TECHNOLOGIES L.L.C provides Users with Services as part of the Service’s Paid Features. The “WINIO” Service may also be provided by WINIO TECHNOLOGIES L.L.C to Users in the form of a mobile application;
User (hereinafter also “You,” “Customer”) is a legally competent natural person who is at least 18 years of age, meets the other requirements specified in the User Agreement, and uses the Service;
Personal information is any information about the User, including personal data, that WINIO TECHNOLOGIES L.L.C may receive from Users during the registration process on the Service, the use of the Service, as well as in the course of WINIO TECHNOLOGIES L.L.C’s performance of any agreements and contracts entered into with the User in connection with the use of the Service;
Personal data is any information relating directly or indirectly to the User as an identified or identifiable natural person (data subject);
Processing of personal data is any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, organization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data;
Confidentiality of personal data is a requirement that must be observed by WINIO TECHNOLOGIES L.L.C or any other person who has gained access to personal data, prohibiting the dissemination of such data without the consent of the data subject or the existence of another legal basis;
Cookies is a small piece of data sent by a web server and stored on the User’s computer, which the web client or web browser sends back to the web server in an HTTP request each time the User attempts to open a page on the relevant website;
IP address is a unique network address of a node in a computer network built using the IP protocol;
Personal data information system is a collection of personal data contained in databases and the information technologies and technical means that enable their processing;
User Agreement is a separate document available to any User on the Internet at: https://winio.ai/terms, which defines the terms and conditions of use of the Service;
Contract Offer for the Provision of Paid Services is a separate document available to any User on the Internet at: https://winio.ai/offer, which governs the procedure for the provision of paid services by WINIO TECHNOLOGIES L.L.C (as the Contractor) to the User (as the Customer) within the framework of using the Service, taking into account the Paid Features of the Service.

This Policy may contain terms not defined above in this section. In such cases, the meaning of such terms shall be determined in accordance with the text of the Policy. In the absence of an unambiguous interpretation of a term in the text of the Policy, the interpretation of the term shall be guided by: first and foremost - other official documents binding on all Users of the Service, posted on the Service, and governing the relations between the Parties when using the Service and interacting through the Service; secondly, by the legislation of the United Arab Emirates; thirdly, in accordance with the information on the Service; and then by the established (commonly used) meaning on the Internet. The terms specified in this section of the Policy, as well as other terms specified throughout this document, may be used in the singular or plural, and with an uppercase or lowercase letter, which does not affect their meaning or intent.

2. General Provisions and Scope of This Policy

2.1. This Policy establishes the obligations of WINIO TECHNOLOGIES L.L.C, including as a personal data controller, to comply with the requirements set forth by the United Arab Emirates legislation regarding personal data, for the purpose of ensuring the protection of the User’s rights and freedoms with respect to their personal data, non-disclosure, and ensuring the protection of the confidentiality of Personal Information (including Personal Data) received from the User during the User’s registration on the Service, the User’s use of the Service, as well as during the performance by WINIO TECHNOLOGIES L.L.C of any agreements and contracts concluded with the User in connection with the use of the Service.

2.2. WINIO TECHNOLOGIES L.L.C places great emphasis on the protection and confidentiality of Users’ Personal Information.

2.3. Any Personal Information about a User received by WINIO TECHNOLOGIES L.L.C is used exclusively for the purposes specified in this Policy.

2.4. This Policy applies only to the Service and to Personal Information (including Personal Data) provided by the User exclusively through the Service.

WINIO TECHNOLOGIES L.L.C does not control and is not responsible for third-party websites and software that the User may access via links available on the Service and/or in the information and materials provided through the Service.

On other third-party websites, the User may be asked to provide or have other information collected, and other actions may be performed for which WINIO TECHNOLOGIES L.L.C is not liable.

2.5. WINIO TECHNOLOGIES L.L.C does not verify the accuracy of the information provided by Users and does not monitor their legal capacity.

However, WINIO TECHNOLOGIES L.L.C assumes that the User provides accurate and sufficient information and keeps this information up to date.

The User guarantees to WINIO TECHNOLOGIES L.L.C that the personal data provided is accurate, up-to-date, and does not violate the laws of the United Arab Emirates.

If the personal data provided pertains to a third party, the User has obtained the third party’s consent to transfer the personal data to WINIO TECHNOLOGIES L.L.C for the purpose of processing personal data.

The consequences of providing inaccurate information are defined in the User Agreement and the laws of the United Arab Emirates.

3. Information about the data being processed

3.1. WINIO TECHNOLOGIES L.L.C processes (or may process) the following data; the content, legal basis, duration, and purposes of such processing are specified below:

List of Personal Information	Purposes of processing
The data provided by the User to WINIO TECHNOLOGIES L.L.C upon registration/login to the Service by filling out the registration/login form on the Service: email address; password. If the User registers/logs in to the Service using accounts on third-party services listed below, the User grants WINIO TECHNOLOGIES L.L.C access to the following data: via a Google account: name and profile photo; email address; When registering or logging in to the Service using accounts from other third-party services - a list of which is displayed to the User within the Service during registration or login - the User grants WINIO TECHNOLOGIES L.L.C access to the data from the User’s account on such a third-party service, which is displayed to the User when switching from the “WINIO” Service to such a third-party service during the registration/login process. If the User does not agree with the list of data provided by the User during registration/authorization in the Service via their account on any third-party service, the User must immediately cease attempting to register/authorize in the Service via their account on such third-party service. After registering on the Service, the User’s account may be assigned an internal ID number.	to register the User on the Service, to enable the creation of a User account on the Service, authorizing the User on the Service and enabling the User’s continued use of the Service in accordance with the Service’s functional capabilities, to identify Users registered/authorized on the Service, to send informational messages to Users, including, but not limited to, information about the Service’s operation, notifications of changes to documents posted on the Service, notifications of Service downtime, changes to the Service’s functional capabilities, and the provision of advertising and marketing information, as well as to facilitate other interactions between WINIO TECHNOLOGIES L.L.C and the User during the User’s use of the Service and its functional capabilities, including during the use of the Service and during the resolution of disputes between the Parties.
Additional information voluntarily provided by the User via the Personal Account on the Service while using the Service: first name; nickname (alias); phone number; photo (avatar); other information that the User may choose to provide and that the User specifies in the “Profile” section of the Personal Account Additional data provided by the User upon request by WINIO TECHNOLOGIES L.L.C: in accordance with the list specified in the request, and/or provided by the User in response to the request.	for the User’s continued use of the Service, taking into account the Service’s functional capabilities, to further verify the ownership of the account and/or the User’s data, including for the purpose of preventing abuse and violations of the User’s rights or the rights of others, for example, when restoring the User’s access to the account, as well as for more personalized interaction between WINIO TECHNOLOGIES L.L.C and the User during the User’s use of the Service and its functional capabilities and during the resolution of disputes between the Parties.
Bank card details and/or other electronic payment method details, as well as other payment information provided by the User and/or received by WINIO TECHNOLOGIES L.L.C from other parties involved in the payment transaction between the User and WINIO TECHNOLOGIES L.L.C.	for the purpose of settling payments between the User and WINIO TECHNOLOGIES L.L.C in connection with providing the User with access to the Paid Features of the Service and rendering Services to the User within the scope of such Paid Features of the Service, taking into account the functional capabilities of the Service, in accordance with the Agreement-Offer for the Provision of Paid Services and/or in connection with other mutual settlements between the Parties within the framework of their interaction related to the use of the Service.
Data obtained when the User uses the Service, including data on: the number of forecasts available to the User and used by the User as part of the Service’s Free Features; the Plan selected by the User as part of the Service’s Paid Features; the number of Subscription Services ordered and consumed by the User, taking into account the Plan paid for by the User, and/or the number of One-Time Services ordered and consumed by the User within the Paid Features of the Service.	to provide the Service’s functionalities, ensure the availability of information and materials provided to the User as part of the Service’s Free and Paid functionalities, track the volume of forecasts available to the User and used by the User within the Service’s Free functionality, as well as the volume of Services provided to the User within the Service’s Paid functionality.
Data automatically collected when the User accesses the Service, which may include information about technical equipment (devices) and technical interactions with the Service, including: IP address; information about the User’s device used to access the website (model, operating system, screen resolution); information about the web browser (or other program used to access the Service); Internet service provider (ISP); information about the country and/or city where the device is located; time of access to pages (sections/modules) of the Service; address of the requested page (section/module) of the Service; other information about the User’s activity while using the Service, including, but not limited to, clicks and navigation within the Service’s interface; a link to the user provided during registration/authentication via social networks and/or third-party services; information from cookie files.	to provide the Service’s features, monitor use of the Service, ensure the Service’s functionality and security, improve and personalize the Service, and develop the Service, collect non-personal information about Users, save preferences and other information on the User’s computer or mobile device to save Users time by eliminating the need to repeatedly enter the same information in the Service’s forms, and to display content during the User’s subsequent visits to the Service.

Processing period: until the purpose is achieved or consent to processing is withdrawn.

Legal basis for processing: based on and in accordance with any agreements and contracts entered into by WINIO TECHNOLOGIES L.L.C with the User in connection with the use of the Service (including the User Agreement, the Offer Agreement for the Provision of Paid Services, and other documents binding on the User relating to the procedure for using the Service and posted by WINIO TECHNOLOGIES L.L.C on the Service and/or brought to the User’s attention by WINIO TECHNOLOGIES L.L.C by any other means), as well as for the performance and fulfillment of the functions, powers, and obligations imposed on WINIO TECHNOLOGIES L.L.C by the current legislation of the United Arab Emirates.

3.2. The Service’s features and terms of use may allow the User to provide, within the Service and/or by other means, any other information (if applicable) in addition to that specified in Section 3.1 of this Policy, provided that such information does not conflict with the requirements of the United Arab Emirates law, for example, when posting User Reviews/comments regarding the operation of the Service and the use of the Service. By posting such information about themselves, including that contained in Reviews/comments, the User understands that it may be accessible to other Users, as well as to other third parties, subject to the provisions of Section 11 of the User Agreement.

3.3. WINIO TECHNOLOGIES L.L.C does not request and does not intend to process biometric data (which characterizes a person’s physiological and biological characteristics, on the basis of which their identity can be established) or other special categories of personal data (relating to Users’ race, nationality, political views, religious or philosophical beliefs, health status, or private life) of Users.

The User undertakes not to provide, enter, or specify such data on the Service, nor to include it in Reviews or comments regarding the operation of the Service and the use of the Service, published in accordance with the provisions of Section 11 of the User Agreement.

4. Processing of Personal Information

4.1. The processing of Users’ Personal Information is carried out by WINIO TECHNOLOGIES L.L.C in accordance with the following principles:

the lawfulness of the purposes and methods of processing the Information;
good faith;
the consistency of the purposes of processing Information with the purposes predetermined and stated at the time of collection;
the consistency of the scope and nature of the Information being processed, as well as the methods of processing, with the purposes of processing Information;
the prohibition on combining databases containing Information created for incompatible purposes.

4.2. WINIO TECHNOLOGIES L.L.C processes Personal Information (including Personal Data) through the following actions: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), blocking, deletion, and destruction.

4.3. WINIO TECHNOLOGIES L.L.C does not process Users’ Personal Information without sufficient legal grounds.

Therefore, WINIO TECHNOLOGIES L.L.C processes Users’ Personal Information only if:

processing is necessary to fulfill any agreements and contracts concluded by WINIO TECHNOLOGIES L.L.C with the User in connection with the use of the Service, including the User Agreement, the Offer Agreement for the provision of paid services and other documents binding on the User relating to the procedure for using the Service and posted by WINIO TECHNOLOGIES L.L.C on the Service and/or brought to the User’s attention by WINIO TECHNOLOGIES L.L.C in any other manner, which also includes ensuring the operation of the Service;
processing is necessary for the performance and fulfillment of the functions, powers, and obligations imposed on WINIO TECHNOLOGIES L.L.C by the current legislation of the United Arab Emirates;
processing is necessary to ensure the rights and legitimate interests of WINIO TECHNOLOGIES L.L.C or third parties, provided that this does not violate the User’s rights and freedoms;
processing is necessary to resolve disputes between WINIO TECHNOLOGIES L.L.C and the User, both in pre-trial and judicial proceedings, as well as to enforce a judicial order, an order of another authority, or an official act subject to enforcement in accordance with the legislation of the United Arab Emirates;
in other cases provided for by the current legislation of the United Arab Emirates and/or applicable international law.

4.4. If applicable law requires the User’s separate consent to the processing of Personal Information and/or Personal Data as a separate legal basis for such processing, then the User’s commencement of use of the Service, as well as the User’s entry of their data into registration, authorization, and other forms on the Service, the filling out of additional data in the User’s profile in the Personal Account, registration/authorization on the Service using the User’s accounts on social networks or other third-party services, the provision of data when contacting the Service’s support team, when submitting inquiries/complaints/ demands/requests to WINIO TECHNOLOGIES L.L.C, posting Reviews/comments about the Service’s operation and use of the Service in accordance with Section 11 of the User Agreement, as well as the automatic provision of such data by the User’s technical means when using the Service via technologies, web protocols, cookies, web beacons, constitutes the User’s consent to the processing of their personal data.

If, while using the Service, the User is located outside the territory of the United Arab Emirates and/or is not a citizen of the United Arab Emirates, and in accordance with the laws of the country where the User is located and/or the country of the User’s citizenship, the provision of the User’s Personal Data and/or other Personal Information in connection with the use of the Service, as well as its subsequent processing by WINIO TECHNOLOGIES L.L.C carried out by WINIO TECHNOLOGIES L.L.C within the territory of the United Arab Emirates in accordance with the laws of the United Arab Emirates, requires the User to provide separate consent, then any of the actions specified in the preceding paragraph of this section shall also constitute the User’s consent to the processing of their personal data.

WINIO TECHNOLOGIES L.L.C hereby informs Users that Users have no obligation to provide WINIO TECHNOLOGIES L.L.C with any Personal Information when using the Service; accordingly, any provision of Personal Information (including Personal Data) is based solely on the User’s free will, and any provision of Personal Information (including Personal Data) by the User is voluntary, specific, informed, conscious, relevant, and deliberate.

At the same time, the User acknowledges that without providing Personal Information (including Personal Data), WINIO TECHNOLOGIES L.L.C will not be able to provide the User with the opportunity to use the Service and its full functionality, and such use of the Service may be limited by WINIO TECHNOLOGIES L.L.C, at its sole discretion, to those features that WINIO TECHNOLOGIES L.L.C has determined do not require the collection and processing of the User’s Personal Information.

4.5. WINIO TECHNOLOGIES L.L.C always processes Users’ Personal Information (including Personal Data) only for specific purposes and only that Personal Information (Personal Data) relevant to achieving such purposes.

4.6. When processing Users’ Personal Information, WINIO TECHNOLOGIES L.L.C complies with the current legislation of the United Arab Emirates.

The processing of Personal Information (including Personal Data) is carried out by WINIO TECHNOLOGIES L.L.C within the territory of the United Arab Emirates.

4.7. The processing of Personal Information (including Personal Data) will primarily be carried out by WINIO TECHNOLOGIES L.L.C using automated means (automated systems). However, in certain cases, such processing may be carried out without the use of automation tools, for example, if it is necessary for the Parties to exchange documents containing Personal Information (including Personal Data) in paper form, if it is necessary to provide WINIO TECHNOLOGIES L.L.C with documents containing Personal Information (including Personal Data) in paper form to courts and other authorized bodies, as well as in other cases where non-automated processing (without the use of automated means) of Personal Information (including Personal Data) is necessary in connection with compliance with the requirements of the legislation of the United Arab Emirates or other applicable legislation.

5. Use of Cookies

5.1. Cookies are small pieces of data that websites request from the browser used on the User’s computer or mobile device (hereinafter referred to as “Cookies”).

Cookies store and send back to the Service information that facilitates the User’s interaction with the Service and allows the Service to remember the User’s preferences over time, such as browser settings or the User’s account.

Cookies are stored locally on the User’s computer or mobile device.

5.2. WINIO TECHNOLOGIES L.L.C may collect and process Cookies regarding Users who use the Service via the website or mobile application.

5.3. The following types of Cookies may be used in the Service:

Strictly necessary cookies: these are essential for the Service to function and to provide the Service to the User; among other things, they allow WINIO TECHNOLOGIES L.L.C to identify the User’s hardware and software, including the browser type;
Statistical/analytical cookies: these allow us to recognize Users, count their numbers, and collect information such as the actions performed by the User on the Service, including information about the web pages visited and the content received by the User;
Technical cookies: these collect information on how the User interacts with the Service, which allows for the identification of errors and the testing of new features to improve the Service’s performance;
Functional cookies: these enable the provision of certain features to facilitate the User’s use of the Service, such as saving the User’s preferences (such as language and location);
(third-party) tracking/advertising cookies: these collect information about Users, traffic sources, pages visited, and advertisements displayed to the User, as well as the advertisement through which the User clicked to visit the advertised page. These cookies enable the display of advertisements that may be of interest to the User, based on an analysis of the Personal Information collected about the User. They are also used for statistical and research purposes.

5.4. Cookies are processed by WINIO TECHNOLOGIES L.L.C exclusively for the purposes specified in Section 2.1 of this Policy, under the terms and in the manner set forth in this Policy.

In particular, based on data obtained through cookies, WINIO TECHNOLOGIES L.L.C develops the most useful features for the Service, conducts statistical research, corrects errors in the Service, and tests new features to improve the Service’s performance, personalizes them, and displays information most relevant to the User.

5.5. Information collected through cookies placed on the User’s device may be transferred to and accessed by WINIO TECHNOLOGIES L.L.C and/or third parties that are owners of web analytics services and/or other similar services.

5.6. WINIO TECHNOLOGIES L.L.C uses cookies exclusively for the time necessary to process them for the purposes specified in this Policy.

5.7. The User may opt out of the processing of cookies and other similar files in the settings of their browser/device/mobile application.

In this case, WINIO TECHNOLOGIES L.L.C will use only those cookies that are strictly necessary for the Service to function and provide its features.

The User may also change the settings for accepting cookies and other similar files in the settings of their browser/device/mobile application or disable them entirely; however, in such a case, some features of the Service may not function properly.

5.8. WINIO TECHNOLOGIES L.L.C may also use web beacons (pixel tags) to access cookies previously placed on the User’s device for the following purposes:

to track the User’s actions on the Service and during the use of the Service by accessing and using cookies stored on the User’s device;
to collect statistical information related to the operation of the Service or the products, utilities, and offers of WINIO TECHNOLOGIES L.L.C.

6. Use of Analytics Services and Web Analytics Tools

6.1. WINIO TECHNOLOGIES L.L.C uses the “Google Analytics” to collect information about the use of the Service, such as the frequency of visits to the Service by Users, pages visited, and websites Users were on before accessing the Service, as well as to improve the Service’s functionality.

The Google Analytics web analytics tool used by WINIO TECHNOLOGIES L.L.C allows for the collection of anonymized information about traffic sources and Service traffic, as well as for evaluating the effectiveness of advertising. To track Users, Google Analytics uses anonymous browser identifiers, which are stored in cookies. You can read more about Google Analytics cookies at https://support.google.com/analytics/answer/11397207?hl=en

6.2. This service/tool places a persistent cookie in the User’s web browser to identify the User as a unique user upon the User’s next visit to the Service. This cookie cannot be used by anyone other than Google LLC.

The web analytics tool ‘Google Analytics’ is a free multifunctional service for analyzing traffic to websites or applications, developed by Google LLC.

Google LLC stores information in cookies on its services.

The user hereby consents to the processing and transfer of data by Google LLC.

6.3. WINIO TECHNOLOGIES L.L.C does not combine information obtained through Google Analytics with other personal information.

6.4. Google LLC’s ability to use and transfer to third parties information collected by Google Analytics regarding your visits to the Service is limited by Google LLC’s Privacy Policy.

6.5. The User may prevent Google Analytics from recognizing the User during repeat visits to the Service by disabling Google Analytics cookies in their browser.

However, if this is done, certain features of the Service may not be available to the User.

7. Storage and Transfer of Personal Data

7.1. WINIO TECHNOLOGIES L.L.C stores Users’ Personal Information (including Personal Data):

on services located within EMEA;
on secure electronic media;
solely for the purposes set forth in the Policy until the User revokes consent or the purposes of processing personal data are fulfilled.

7.2. WINIO TECHNOLOGIES L.L.C ensures that necessary and sufficient organizational and technical measures are taken to protect Users’ Personal Information (including Personal Data) from unauthorized or accidental access, destruction, alteration, blocking, copying, or distribution, as well as from other unlawful actions by third parties. To protect Users’ Personal Information (including Personal Data), WINIO TECHNOLOGIES L.L.C employs the necessary legal, organizational, and technical measures.

7.3. Access to Users’ Personal Information (including Personal Data) is granted only to authorized employees of WINIO TECHNOLOGIES L.L.C in compliance with data protection rules.

7.4. WINIO TECHNOLOGIES L.L.C may transfer data to third parties:

upon a substantiated request from judicial authorities, state security agencies, the prosecutor’s office, the police, investigative authorities, or other agencies and organizations in cases provided for by applicable laws and regulatory legal acts of the United Arab Emirates that are binding;
for the purpose of preventing and suppressing unlawful actions by the User and protecting the legitimate interests of WINIO TECHNOLOGIES L.L.C and third parties;
to third parties engaged by WINIO TECHNOLOGIES L.L.C only if such transfer is necessary for WINIO TECHNOLOGIES L.L.C to provide the User with Services within the scope of the Paid Functionality of the Service, including when WINIO TECHNOLOGIES L.L.C participates in or engages such third parties in fulfilling its obligations to the User in connection with the User’s use of the Service, and only to the extent necessary for such third parties to fulfill the obligations to WINIO TECHNOLOGIES L.L.C for which such third party was engaged by WINIO TECHNOLOGIES L.L.C as part of its obligations to the User;
in other cases expressly specified in this Policy, as well as in cases established by the legislation of the United Arab Emirates.

7.5. Users’ personal information (including personal data) is retained by WINIO TECHNOLOGIES L.L.C until the purposes of its processing are fulfilled, provided there is a legal basis for doing so.

WINIO TECHNOLOGIES L.L.C may also store personal data until the expiration of the statute of limitations established by the legislation of the United Arab Emirates to ensure the protection of the rights and interests of WINIO TECHNOLOGIES L.L.C, as well as for the period necessary and established by the current legislation of the United Arab Emirates.

In the event of the deletion of the User’s account on the Service, WINIO TECHNOLOGIES L.L.C has the right to store the necessary User data for the period required and established by the current legislation of the United Arab Emirates.

If the User withdraws consent to the processing of personal data, WINIO TECHNOLOGIES L.L.C has the right to continue processing personal data without the User’s consent, as the data subject, if there are grounds provided for by the current legislation of the United Arab Emirates, for the period established by such legislation.

8. Updating and Deletion of Personal Data

8.1. WINIO TECHNOLOGIES L.L.C will update personal data if it is confirmed that such data is inaccurate.

8.2. The User may at any time modify (update, supplement) the Personal Information (including Personal Data) provided by them, or any part thereof, by using the information editing feature within the Service in the User’s Personal Account under the “Profile” section.

8.3. WINIO TECHNOLOGIES L.L.C destroys Personal Data in the following cases:

if there is a threat to the security of the Service;
upon expiration of the retention period for Personal Data;
upon achievement of the purposes of processing Personal Data;
upon the User’s request to withdraw consent for the processing of personal data (except in the cases specified in Section 7.5 of this Policy).

8.4. WINIO TECHNOLOGIES L.L.C destroys Personal Data by formatting the storage medium or by other means that preclude further processing and storage of such data.

9. User Rights

9.1. The User has the right to request that the Company correct, block, or delete their data if such data is incomplete, outdated, inaccurate, obtained unlawfully, or not necessary for the stated purpose of processing.

9.2. The User has the right to request the following information from WINIO TECHNOLOGIES L.L.C regarding the processing of the User’s personal data:

confirmation of the fact of processing;
the legal basis for processing;
the purposes and methods of processing;
the specific personal data being processed and the source from which it was obtained;
the duration of processing, including the retention period for personal data;
the procedure for exercising the rights provided for by the legislation of the United Arab Emirates;
information about the persons to whom personal data may be disclosed based on a contract with WINIO TECHNOLOGIES L.L.C or in accordance with the legislation of the United Arab Emirates;
the name or surname, first name, patronymic, and address of the person carrying out the processing on behalf of WINIO TECHNOLOGIES L.L.C, if the processing has been or will be entrusted to such a person;
other information required by the legislation of the United Arab Emirates.

9.3. The User is also entitled to exercise other rights provided for in this Policy and/or applicable laws governing the processing of personal data.

9.4. The User may submit a request to WINIO TECHNOLOGIES L.L.C in accordance with the provisions of Section 11 of this Policy.

10. Company Obligations

10.1. WINIO TECHNOLOGIES L.L.C is obliged to:

provide, upon the User’s request, information regarding the processing of personal data or a reasoned refusal;
take measures necessary and sufficient to fulfill the obligations provided for by the legislation of the United Arab Emirates;
at the User’s request, correct the personal data being processed, block or delete it if it is incomplete, outdated, inaccurate, obtained unlawfully, or unnecessary for the stated purpose of processing personal data;
ensure the lawfulness of the processing of personal data. If it is impossible to ensure the lawfulness of the processing of personal data, WINIO TECHNOLOGIES L.L.C is obligated, within a period not exceeding 10 business days from the date of detection of unlawful processing of personal data, to destroy or ensure the destruction of the personal data;
cease the processing of personal data and destroy the personal data (if their retention is no longer required for processing purposes) within a period not exceeding 30 days from the date of receipt of the User’s withdrawal of consent, except in cases where the processing of personal data may be continued in accordance with the legislation of the United Arab Emirates.

11. Procedure for Submitting Requests

11.1. The User or their representative may submit requests to WINIO TECHNOLOGIES L.L.C via email at: hi@winio.ai.

11.2. Content of the request/inquiry:

information confirming the User’s relationship with the Company (email address, name);
the representative’s details and confirmation of their authority (if the request is submitted by a representative);
the text of the request/inquiry.

To verify the legitimacy of the request, WINIO TECHNOLOGIES L.L.C has the right to require the User or their representative (if a representative is making the request) to submit the request in writing as an original hard copy.

11.3. WINIO TECHNOLOGIES L.L.C reviews requests within 10 business days of receipt.

12. Governing Law and Dispute Resolution

12.1. This Policy and the relationship between Users and WINIO TECHNOLOGIES L.L.C arising from the application of this Policy shall be governed by the laws of the United Arab Emirates.

12.2. The Parties shall endeavor to resolve any disputes, disagreements, and claims that may arise between them in connection with the application of this Policy through negotiations, in compliance with the mandatory pre-litigation claim resolution procedure.

Claims against WINIO TECHNOLOGIES L.L.C by the User shall be submitted by the User in the manner specified in Section 11 of this Policy.

The period for reviewing a claim and providing a response thereto is 30 (thirty) calendar days from the date of receipt of the claim.

If disputes between the User and WINIO TECHNOLOGIES L.L.C are not resolved through negotiations between the Parties or through the pre-trial claim procedure, they shall be considered in accordance with the procedure provided for by the current legislation of the United Arab Emirates in the court at the location of WINIO TECHNOLOGIES L.L.C.

For the purpose of resolving disputes between the Parties, both in and out of court, each Party shall have the right to resolve such disputes independently and/or by engaging third parties as representatives (lawyers, attorneys, or other persons who, in accordance with the provisions of the United Arab Emirates law, may act as authorized representatives of the relevant Party in the resolution of disputes), provided that the powers of such representatives are confirmed by a power of attorney or other document confirming their authority, executed in accordance with the requirements of the United Arab Emirates law. In this regard, the provision of information to such persons, as well as to a court in the context of dispute resolution, shall not be considered a violation of the confidentiality of information and personal data.

13. Final Provisions

13.1. WINIO TECHNOLOGIES L.L.C reserves the right, at its sole discretion, to amend and/or supplement the terms of this Policy at any time. WINIO TECHNOLOGIES L.L.C will notify Users of any amendments/additions to this Policy by posting a new version of the Policy on the Service, which will take effect on the date of such posting, unless otherwise specified on the Service or in the text of the new version of the Policy.

The current version of the Policy is always available at: https://winio.ai/privacy.

WINIO TECHNOLOGIES L.L.C reserves the right not to remove previous versions of the Policy from the Service after posting a new version of the Policy. However, after posting a new version of the Policy, such version becomes effective, and previous versions of the Policy cease to be effective.

The User undertakes to regularly review the current version of this Policy while using the Service, including to ensure prompt familiarization with any amendments and additions to the Policy.

If the User continues to use the Service after the new version of this Policy comes into effect, the User thereby agrees to the amended terms of the Policy specified in the new version of this Policy.

If the User disagrees with the terms of this Policy and/or the amendments made thereto, use of the Service must immediately cease.

13.2. If any provision of this Policy is or is deemed invalid or unenforceable, this shall not affect the validity of the remaining provisions, which shall remain in effect.

13.3. This Policy is written in English and, in some cases, may be provided (available) to the User for review in another language. In the event of a discrepancy between the English-language version of the Policy and the version of the Policy in another language, the provisions of the English-language version of the Policy will prevail.

14. Details of WINIO TECHNOLOGIES L.L.C

Name: WINIO TECHNOLOGIES LIMITED LIABILITY COMPANY (WINIO TECHNOLOGIES L.L.C)

Legal address: 000000, United Arab Emirates, Dubai, Ontario Tower - C1702, Business Bay

Tax Registration Number: 105175221800001

Email: hi@winio.ai