Swordpoint Privacy Policy

PLEASE READ THIS PRIVACY POLICY STATEMENT CAREFULLY. YOU MUST BE AT LEAST EIGHTEEN YEARS OF AGE TO USE THE SWORDPOINT SERVICES.

This privacy policy statement ("Privacy Policy") explains how Swordpoint Services, LLC, a Georgia limited liability company, and/or its subsidiary and affiliated entities (collectively, "Swordpoint", "we", "us", or "our") may collect information about you through the Swordpoint services, including its mobile application WINGEN, and its other websites, SMS, APIs, and email notifications, that are operated by Swordpoint and link to this Privacy Policy (collectively, the "Services") and how this information may then be used, shared, disclosed, transferred, and/or stored.

The Services expressly include any Swordpoint or WinGEN top-level-domain as well as any re-directs to Swordpoint branded areas and sub-domains of third-party websites. This Privacy Policy does not apply to portions of the Services that do not display or link to this Privacy Policy, that have their own privacy policy, or to information collected in other ways. We may update this Privacy Policy by posting updated terms on the Services. By interacting with or accessing the Services after an update, you acknowledge that you have read the updated terms and consent to the revised privacy practices.

We do not intentionally gather Personal Information about visitors under the age of 18. By using the Services, you acknowledge that you have read this Privacy Policy and consent to the practices described here, including use and disclosure of Personal Information to the retailers we serve for the purposes described below.

Residents of California should also read the California Residents - Your Privacy Rights section below.

IF YOU DO NOT CONSENT TO THESE PRIVACY PRACTICES, DO NOT REGISTER, SUBSCRIBE, CREATE AN ACCOUNT, PARTICIPATE IN AN ONLINE SURVEY, OR OTHERWISE INTERACT WITH OR ACCESS THE SERVICES. IF A SCREEN REQUESTS INFORMATION YOU DO NOT WANT TO SHARE, DO NOT ENTER THE INFORMATION OR PROCEED.

Information We May Collect Through the Services

This Privacy Policy applies to information collected through the Services.

Collection and Use of Personal Information

Personal information ("Personal Information") is information that can identify, locate, or contact a person, such as a name, address, telephone number, or email address. It also includes other information associated with Personal Information.

You may be asked to provide Personal Information when you register, subscribe, create an account, purchase a product or service from a retailer we serve, participate in a survey, contact us, or otherwise interact with the Services. We may combine this information with other information to provide and improve products, services, content, and advertising.

What Personal Information We May Collect

• First and last name, zip code, mailing address, phone numbers, email addresses, social-media account names, other communication addresses, and contact preferences.
• Information you provide about other people when you share content, such as names, addresses, email addresses, and phone numbers.
• Lifestyle, location, interests, product and service preferences, social-media interaction information, and demographic information such as birth date, age, and gender.
• Information about how you interact with retailers, products, services, offers, users, merchants, business partners, and service providers.

How We May Use Your Personal Information

We may use Personal Information to:

• Develop, deliver, and improve products, services, content, and advertising.
• Create and publish content through the Services.
• Register you, develop your profile, and enable Service features.
• Send announcements, offers, event information, updates, security alerts, support messages, service bulletins, and marketing.
• Send notices about purchases and changes to terms, conditions, or policies.
• Administer promotions, surveys, sweepstakes, contests, and sponsored activities.
• Manage everyday business needs, including administration, fulfillment, analytics, fraud prevention, auditing, research, and legal compliance.
• Identify you as a provider of content and respond to forms such as Contact Us and Sign Up.

When and Why We May Share, Disclose, Transfer, and Store Personal Information

We may share Personal Information with:

• Affiliated companies, subsidiaries, and retailers from whom you may buy goods and services.
• Service providers, agents, and contractors that support communications, information processing, hosting, fulfillment, customer service, research, payments, and related business operations.
• Affiliates, strategic partners, marketers, and other parties that may offer products or services or use information for research, administration, or business purposes.
• Third parties where required by law, legal process, fraud prevention, protection of rights or safety, or verification of information.
• Third parties involved in a merger, acquisition, reorganization, or sale of assets.
• Third parties receiving non-identifying aggregate usage and statistical information.

We seek to ensure that unaffiliated third parties use Personal Information only for the purposes for which they are responsible, but we cannot guarantee that they will not use it for another purpose.

Collection and Use of Non-Personal Information

We may collect information that does not permit direct association with a specific individual, including technical information, demographic information, activity on the Services, occupation, language, zip code, area code, unique device identifier, location, and time zone ("Non-Personal Information").

Examples

• IP address: Used to deliver requested pages, tailor Services, and measure traffic.
• Cookies: Small text files used to operate the Services, remember preferences, support security, and serve relevant advertising. You may configure your browser to reject cookies, but some areas or features may then be unavailable.
• Web beacons: Small graphic files used to count visitors, measure campaign effectiveness, and determine whether HTML email has been opened.
• Click-through URLs: Links that may pass through a separate server so we can measure interest and customer communications. Do not select these links if you prefer not to be tracked in this way.

You can enable or disable location services through your device settings. We may collect, use, share, disclose, transfer, and store Non-Personal Information for any purpose. If combined with Personal Information, the combined information is treated as Personal Information while it remains combined.

International Transfer of Information

We may transfer information, including Personal Information, to subsidiaries, affiliates, or third parties across borders and into the United States. If you are visiting from the European Union or another region with different data-protection laws, you consent to transfer to the United States and to the uses and disclosures described in this Privacy Policy.

Legal Basis for Processing Under GDPR

If you are in the European Economic Area, our legal basis depends on the Personal Information and context. Swordpoint may process Personal Information because we need to perform a contract, you have granted permission, processing is in our legitimate interests and is not overridden by your rights, or processing is required to comply with law.

Retention of Data

Swordpoint retains Personal Information only as long as necessary for the purposes set out in this Privacy Policy and as needed to comply with legal obligations, resolve disputes, and enforce agreements and policies. Usage Data is generally retained for a shorter period unless needed for security or functionality or where longer retention is legally required.

Transfer of Data

Your information may be transferred to and maintained on computers or servers outside your jurisdiction where data-protection laws differ. If you are outside the United States and provide information, you agree to its transfer to and processing in the United States. Swordpoint will take reasonably necessary steps to treat data securely and in accordance with this Privacy Policy.

Disclosure for Law Enforcement and Legal Requirements

Swordpoint may disclose Personal Information when required by law or valid public-authority request, or where it believes disclosure is necessary to comply with a legal obligation, protect rights or property, investigate wrongdoing, protect personal safety, or protect against legal liability.

Security of Data

No transmission or storage method is completely secure. We strive to use commercially acceptable means to protect Personal Information but cannot guarantee absolute security.

Do Not Track Signals Under CalOPPA

We do not support Do Not Track ("DNT"). You can enable or disable DNT through your device or browser settings.

Your Data Protection Rights Under GDPR

Residents of the EEA may have rights to access, update, delete, rectify, object to or restrict processing of Personal Information, receive data in a structured and machine-readable format, and withdraw consent. We may ask you to verify your identity. You may also complain to a local Data Protection Authority.

Access to Information and Parental Access

Registered members and account holders can review and update their profile by signing in. A parent or guardian may request review or deletion of information about a child or request that collection or use stop. We verify the identity of persons making such requests. The Services are not directed to anyone under 18.

Opt-Out

We may send primarily informational account communications that users generally cannot opt out of. You may opt out of other communications, such as marketing emails, texts, product updates, and sharing of Personal Information with third parties, by contacting us or by using an unsubscribe link where provided.

Service Providers

We may employ third-party companies and individuals to facilitate or provide Services, perform related tasks, or help analyze Service use. These parties may access Personal Information only to perform these tasks and are obligated not to disclose or use it for another purpose.

Analytics

We may use third-party providers to monitor and analyze use of the Services.

Google Analytics

Google Analytics tracks and reports website traffic. Google may use collected data to track use of the Services and to contextualize and personalize advertising. See the Google Privacy Policy.

Advertising

We may use third-party providers to show advertisements that support and maintain the Services.

• Google AdSense DoubleClick Cookie: Google may use cookies to serve advertisements based on visits to the Services or other websites. See Google Ads Settings.
• AdMob by Google: See AdMob opt-out information, Google partner data practices, and the Google Privacy Policy.
• Bing Ads: See Bing personalized-ad information and the Microsoft Privacy Statement.

Third-Party Websites and Advertisers

The Services may link to third-party websites and may use third-party advertisers and promotional companies. We are not responsible for their websites, content, products, services, or privacy practices. You are responsible for recognizing when you leave the Services and for reviewing the terms and privacy policies of other parties.

Protection of Information

You transmit information over the Internet at your own risk. After receipt, we make reasonable efforts to protect our systems, including use of firewalls, but cannot guarantee that information will not be accessed, disclosed, altered, or destroyed.

If we learn of a security breach, we may notify you electronically, post a notice on the Services, or contact you at the email address or mobile number provided. You may have additional rights to written breach notices under applicable law.

You can help protect information by using secure browsers, anti-virus and anti-malware tools, signing out carefully, using strong passwords, changing passwords regularly, and contacting us if credentials may have been compromised.

Assignment

You consent to assignment of your account and information, including Personal Information, if all or part of our assets or Services are sold or acquired or in the event of a merger.

Terms and Conditions

Please read the applicable Terms and Conditions. By using the Services, creating an account, or submitting content or materials, you acknowledge and consent to those terms.

Privacy Questions

If you have questions or concerns about this Privacy Policy or data processing:

• Email: support@wingenapp.com
• Website: www.wingenapp.com

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page. We may provide notice by email and/or a prominent Service notice before a change becomes effective and will update the effective date. Changes take effect when posted.

California Residents - Your Privacy Rights

As provided by California Civil Code Section 1798.83, a California resident who has provided Personal Information to a business in connection with a personal, family, or household business relationship may request information about disclosures to third parties for direct-marketing purposes.

A business may comply by publicly maintaining a policy not to disclose customers' Personal Information to third parties for direct marketing unless the customer affirmatively agrees, and by providing a cost-free way to prevent such disclosure. We do not share information with third parties for their direct-marketing purposes unless you affirmatively agree, typically by opting in.

To prevent disclosure for third-party direct marketing, do not opt in. If you later want a third party to stop using information, contact that third party directly. California customers may contact us for further information. We are required to respond to one request per customer each year and only to requests made through the stated contact method.