Introduction

This Privacy Policy describes how Shenzhen Winline Technology Co., Ltd. collects, uses and shares information about you through Winline Technology websites or mobile apps operated by us from which you are accessing this Privacy Policy (“Winline Technology websites”), through Winline Technology’s social media pages (“Social Media Pages”) as well as through email messages, and text messages that Winline Technology may send to you that link to this Privacy Policy (collectively, including Winline Technology websites and Social Media Pages, the “Services”).

This Privacy Policy does not apply to Winline Technology’s data collection activities offline or otherwise outside of the Services. By using the Services, you agree to Winline Technology’s Terms and Conditions. By consenting to and/or acknowledging this Privacy Policy, you consent to and/or acknowledge Winline Technology’s collection, use and disclosure practices, and other activities described in this Privacy Policy. If you do not agree and/or do not consent, discontinue use of the Services, and uninstall Service downloads and applications.

“Personal Information“ is information, is Privacy Policy shall (unless the context otherwise requires) shall be deemed to include reference to “sensitive personal information” as such term is defined by applicable law, which may include but is not limited to:

• Name;
• E-mail address;
• Postal Address (including billing and shipping address);
• Geolocation information;
• Telephone number;
• Fax number;
• Bank information and credit references (if applicable);
• Winline Technology Account Number; and Credit or debit card number

1.  CHANGES TO THIS PRIVACY POLICY

Winline Technology reserves the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Subject to applicable law, your continued use of Winline Technology’s Services may indicate your consent and/or acknowledgment to the privacy policy posted. If the changes are material, Winline Technology may provide additional notice to your e-mail address where applicable. Where required to do so by applicable law, Winline Technology will obtain your consent to such changes.

2.  HOW Winline TechnologyCOLLECTS INFORMATION
3.  Information You Give Us

Winline Technology may (with your consent, where required by applicable law) collect Personal Information you provide directly to Winline Technology via the Services. For example, Personal Information may be collected when you use or register for Winline Technology’s Services, subscribe to Winline Technology’s notifications, post on Winline Technology’s Services, participate in promotional activities, apply for a job, communicate with Winline Technology through the Services, or use an app installed on a device. You may choose to voluntarily submit certain other information to us through the Services, including Personal Information, but you are solely responsible for your own Personal Information in instances where Winline Technology has not collected such information or requested that you submit such information to us. De-Identified Data or Personal Information once “de-identified” may not be subject to this Privacy Policy and Winline Technology and Winline Technology’s Service Providers (defined below) may treat it as non-Personal Information and use it without obligation to you except as prohibited by applicable law.

1.  Information Winline TechnologyCollects Automatically from Your Use of Winline Technology’s Services

Winline Technology and Winline Technology’s Service Providers collect information about the Services that you use and how you use them. Winline Technology does this with your consent where required by applicable law. Certain information is collected automatically through your device, such as your: IP address; device identifier, Ad ID, browser type; operating system characteristics; information about your use of Winline Technology’s Services; and data regarding network connected hardware (e.g., computer or mobile device) (“Usage Information”). To the extent that Usage Information is Personal Information under applicable law or is combined with Personal Information, Winline Technology will treat that information as Personal Information under this Privacy Policy.

• The methods that Winline Technologyand Winline Technology’s Service Providers may use to collect Usage Information include :
• Log Information:Winline Technology collects information about your use of Winline Technology’s Services, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, cookies that may uniquely identify your browser or your account, and related data, and store it in log files.
  • Information Collected by Cookies and Other Tracking Technologies:Winline Technology and Winline Technology’s Service Providers may use cookies or other tracking technologies (“Tracking Technologies”) to collect and store information about interactions with  Winline Technology’s Services, including information about your browsing and purchasing behavior. Further information about how Winline Technology uses cookies is set out in Winline Technology’s Cookie Policy.

1.  Personal Information Collected from Other Sources

Winline Technology may (with your consent, where required by applicable law) receive your Personal Information from other sources, such as public databases, joint marketing partners, and social media platforms, and combine that with information Winline Technology collects about you. To the extent Winline Technology combines such third-party sourced information with Personal Information Winline Technology collects directly from you, Winline Technology will treat the combined information as Personal Information. Subject to applicable law, Winline Technology is not responsible for the accuracy of the information obtained from third parties or third-party practices.

3.  HOW Winline TechnologyUSES PERSONAL INFORMATION Winline TechnologyCOLLECTS
4.  To provide, maintain, protect and improve Winline Technology’s Services, develop new services, and protect Winline Technologyand Winline Technology’s users;
5.  To facilitate, manage, personalize, and improve your online experience;
6.  To respond to your inquiries and fulfill your requests, such as to send you newsletters, brochures, catalogs, virtual event invitations, and e-mails;
7.  For Winline Technology’s business purposes, such as data analysis, audits, fraud monitoring and prevention, enhancing, improving, or modifying Winline Technology’s Services, identifying usage trends, and operating and expanding Winline Technology’s business activities; and
8.  To send you advertisements and communicate with you about products, services, offers, promotions, rewards, and events Winline Technologybelieves may be of interest to you.
9.  To contact you regarding your job application status including sending application instructions and/or interview scheduling options, if you have voluntarily applied for an employment position at Winline Technology.
10.  To send you employment recruiting information where you have affirmatively demonstrated an interest in employment with Winline Technology.

Where required by applicable law, Winline Technology will obtain your additional or separate consent if Winline Technology processes your Personal Information for purposes other than those stipulated in this Privacy Policy.

4.  HOW Winline TechnologySHARES INFORMATION

With your consent (where required by applicable law), Winline Technology’s agents, vendors, consultants, marketing service providers, and other service providers (collectively “Service Providers”) may receive, or be given access to your information, including Personal Information and Usage Information, in connection with their work on Winline Technology’s behalf. These Service Providers may be located in countries other than your country of residence. These Service Providers are prohibited from using your Personal Information for any purpose other than to provide this assistance on Winline Technology’s behalf, although Winline Technology may permit them to use de-identified data or aggregated information, which does not personally identify you or any other user of the Services (for example, Winline Technology may aggregate Personal Information to calculate the percentage of Winline Technology’s users who have a particular telephone area code). Winline Technology may also (with your consent, where required by applicable law) share information about you as follows:

1.  As necessary, for the following purposes: (a) to comply with legal process; (b) to respond to requests from public and government authorities, including public and government authorities outside your country of residence to meet national security or law enforcement requirements; (c) to enforce Winline Technology’s terms and conditions; (d) to protect Winline Technology’s operations and protect Winline Technology’s rights, privacy, safety or property, and/or that of you or others; and (e) to allow Winline Technologyto pursue available remedies or limit the damages that Winline Technologymay sustain;
2.  With Winline Technology’s affiliates for internal business purposes. For example, processing your orders, fulfilling your requests, providing customer service, and improving Winline Technology’s products and services to better serve you;
3.  With Winline Technology’s subsidiaries, affiliates, business partners, and other third parties for their own business purposes. For example, improving their products and services; and
4.  To a third party in connection with or during negotiations of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Winline Technology’s business, assets or stock (including in connection with any bankruptcy or similar proceedings).

When Winline Technology engages Service Providers and when disclosure of Personal Information to such providers is necessary for the provision of such service, Winline Technology ensures that such providers will protect Personal Information in a manner consistent with this Privacy Policy and all applicable data privacy laws.

Aggregated Information

Without limiting the forgoing, in Winline Technology’s sole discretion, Winline Technology may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose.

5.  HOW Winline TechnologyRETAINS YOUR INFORMATION

Winline Technology retains your information for as long as necessary to fulfil the purposes for which the information was collected or pursuant to applicable laws and regulations, court or administrative proceedings, and audit requirements.

6.  Winline TechnologySWEEPSTAKES, CONTESTS, AND PROMOTIONS

Where allowable under applicable law, Winline Technology may offer sweepstakes, contests and other promotions (each, a “Promotion”) jointly sponsored or offered by third parties that may require submitting Personal Information. If you voluntarily choose to enter a Promotion, your Personal Information may be disclosed to third parties for administrative purposes and as required by law (e.g., on a winners list). By entering a Promotion, you are agreeing to the official rules that govern the particular Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.

7.  INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS

The Services may permit you to post or submit written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personal Information (collectively, “User Content”). If you choose to submit User Content to any public area of Winline Technology’s Services, your User Content will be considered “public” and will be accessible by anyone, including Winline Technology, will not subject to this Privacy Policy and may be used to the fullest extent permitted by applicable law.

8.  THIRD-PARTY SERVICES AND SOCIAL FEATURES

Winline Technology’s Services may include hyperlinks to Winline Technology websites, locations, platforms, or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, Winline Technology web beacons, and other Tracking Technology to independently collect information about you and may solicit Personal Information from you. Certain functionalities on the Services permit interactions that you initiate between the Services and certain Third-Party Services, such as third-party social networks (“Social Features”). Examples of Social Features include “liking” or “sharing” Winline Technology’s content and otherwise connecting Winline Technology’s Services to a Third-Party Service. If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on Winline Technology’s Services or by the Third-Party Service that you use. Similarly, if you post information on a Third-Party Service that references Winline Technology’s Services (for example, by using a hashtag associated with Winline Technology in a tweet or status update), your post may be used on or in connection with Winline Technology’s Services. Also, both Winline Technology and the third-party may have access to certain information about you and your use of Winline Technology’s Services and the Third-Party Service. To the extent Winline Technology combines information from Third-Party Services with Personal Information Winline Technology collects directly from you on the Services, Winline Technology will treat the combined information as Personal Information under this Privacy Policy.

Third-Party Responsibility

The information collected and stored by third parties remains subject to their privacy practices, including whether they continue to share information with Winline Technology, the types of information shared, and your choices on what is visible to others on Third-Party Services. Winline Technology is not responsible for the collection, usage, and disclosure policies and practices (including the data security practices) of any other organization, including any Personal Information you disclose to other organizations through or in connection with Winline Technology’s Social Media Pages. Winline Technology makes no representations regarding the policies or business practices of any third parties or Third-Party Services and encourages you to familiarize yourself with and consult their privacy policies and terms of use.

9.  ADVERTISING, ANALYTICS SERVICES, AND ONLINE TRACKING

Winline Technology may use third-party advertising companies to serve advertisements on Winline Technology’s behalf on the Services and/or on Third-Party Services and to provide analytics services about the use of Winline Technology’s Services and the performance of Winline Technology’s ads and content on Third-Party Services. In addition, Winline Technology may participate in online advertising networks and exchanges that display relevant advertisements to Winline Technology’s Service visitors, on Winline Technology’s Services and on Third-Party Services and off Winline Technology’s Services, based on your interests as reflected in your browsing of the Services and certain Third-Party Services. These entities may use cookies and other Tracking Technologies to automatically collect information about you and your activities, such as registering a unique identifier for your device and tying it to your online activities on and off Winline Technology’s Services. Winline Technology may use this information to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Services and Third-Party Services, and better understand your online activity.

Online Behavioral Advertising

Some information about your browsing of the Services and certain Third-Party Services may be collected across time and services and shared with third parties to deliver ads and/or other content to you on the Services and certain Third-Party Services. Winline Technology may receive information about Third-Party Services that you have visited and use it for marketing purposes—a practice sometimes termed “(re)-targeting,” “interest-based advertising,” and “online behavioral advertising.”

Do Not Track

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, Winline Technology currently does not alter Winline Technology’s practices when Winline Technology receives a “Do Not Track” signal from a visitor’s browser.

10.  DATA SECURITY

Winline Technology seeks to use reasonable technical and organizational security measures to help protect your Personal Information from loss, theft, misuse and unauthorized access, disclosure, alteration, or destruction. In addition, Winline Technology will not keep your Personal Information for longer than necessary for the purposes set out in this Privacy Policy. Unfortunately, no data transmission or storage system is completely secure, and Winline Technology cannot guarantee the security of your information collected through Winline Technology’s Services. Your Personal Information is stored on servers in the U.S., U.K., and Hong Kong SAR and is maintained with the assistance of a third-party data storage provider.

11. 11.  CHILDREN‘S PRIVACY

Winline Technology’s Services are not intended for children and are not targeted to children under the age of thirteen (13). If you are a child under the age of thirteen (13), you are not permitted to use the Services and should not send us any information about yourself.

COPPA

Winline Technology does not knowingly collect any Personal Information from children under the age of 13 and, if Winline Technology learns that Winline Technology has received information from a user under the age of 13, Winline Technology will delete this information in accordance with the Children’s Online Privacy Protection Act (“COPPA”). If you are a parent or guardian and you believe that your child under the age of 13 has provided us with Personal Information without COPPA-required consent, please contact us at overseas@szWinline Technology.com.