This privacy policy relates to the Wintor Manager Web Platform and the Wintor AR apps.

Contents

1. What’s in this policy?
2. What does this policy cover?
3. How do you protect my personal information?
4. What types of personal information does the Wintor collect about me?
5. How long will Wintor keep my information?
6. How can Wintor use my personal information?
7. When will Wintor use my information to contact me?
8. Will I be contacted for marketing purposes?
9. When does Wintor share my personal information with others?
10. Can I delete my information?
11. What are my rights?
12. How does Wintor use cookies and similar tracking?
13. How will I find out about changes to this policy?
14. How can I contact Wintor?
15. Overview of Sub-Processors

Whats in this policy?

This policy tells you:

• What information we might collect about you
• how we might use that information
• when we might use your details to contact you
• what information of yours we might share with others
• your choices about the personal information you give us

What does this policy cover?

This policy covers the services that are offered by Wintor. What’s not covered in this policy? Our services sometimes link to services run by other companies. Those companies have their own privacy and cookies policies, so remember that the information you give them will follow their rules and not ours. We sometimes offer Wintor-branded services to other companies, like a Wintor YouTube page. Make sure to check their privacy policy so you know how they will use your information.

How do you protect my personal information?

We’re strongly committed to keeping your personal information safe. To do this we design our services with your safety in mind. At the same time, no service can be completely secure – if you have any concerns that your Wintor account or personal information has been put at risk, for example if someone could have found out your password, please get in touch straight away.

Where we store your information: All your information is stored in the EU. Some companies that provide services to us run their services from outside the European Economic Area. We only let that happen if we are satisfied with their levels of security. Keep in mind that when you give us personal information it could be being transferred, stored or processed in a location outside the EEA. Check out our list of sub-processors, the information exchanged and the reason at the bottom of this document.

What types of personal information does Wintor collect about me?

We collect as little personal information as possible by design. During sign up, you enter your full name and email address, this is used to log in and communicate. We also ask the general occupation for a better onboarding experiences, but this information is not stored. During the usage of the app or platform anonymized usage logs are gathered, that can not be linked to the user. In these anonymous logs we store some information on the type of device is being used and some identifiers for analysis.

Device Information

Devices are lots of things like:

• your computer
• your mobile
• your TV
• your tablet
• your voice-enabled device

We automatically collect some technical information from these devices and web browsers even when you’re not signed in to a Wintor account. This might include:

• IP (internet protocol) address
• device ID
• app ID
• vendor ID

How long will Wintor keep my information?

Personal information is stored indefinitely while your account is in use. After no activity is detected for a year, your account and related personal information will be removed. Before this happens, you will receive reminders to log back in to reactivate the account.

How can Wintor use my personal information?

We have to have a valid reason to use your personal information. It’s called the “lawful basis for processing”. Sometimes we might ask your permission to do things, like when you subscribe to an email. Other times, when you’d reasonably expect us to use your personal information, we don’t ask your permission, but only when:

• the law says it’s fine to use it, and
• it fits with the rights you have

We use your information for these types of things:

• to deliver our services and to provide you with information about them
• to deal with your requests, complaints and enquiries
• to check if you’re using Wintor and to keep the licensing database accurate and up to date

• to help us understand what kind of services you might use and sometimes how you might share things with other people
• to contact you about various things

When will wintor use my information to contact me?

We might use your information to contact you about different things, like:

• to update you on any changes to the Wintor’s policies, practices and Terms of Use
• to check with you about any service or activity you’ve signed up for. For example, we might tell you if your Wintor account has not been used in a long time.
• to contact you about a creation you sent us
• to answer you when you’ve contacted us, or to respond to a comment or complaint
• to invite you to take part in surveys about the Wintor services, which are always voluntary
• to send you notifications on your device if you’ve selected them in your settings

We’ll only contact you when we need to or when you’ve given us permission. We’ll never contact you to ask for your Wintor account password.

Will I be contacted for marketing purposes?

We’ll only send you marketing emails or contact you about Wintor services and your views on issues about Wintor if you’ve agreed to this. Keep in mind, even if you unsubscribe, we may still contact you, for other reasons then marketing.

When does Wintor share my personal information with others?

We’ll never sell your personal information. We do share it with others in these ways:

• When you publish a Tour, your full name will be shared..
• When we use other companies to power our services, In order for us to give you quality experiences and to understand how you’re using our services we often use other companies to process your personal information on our behalf. For example, sending you emails about things we think might interest you, or to ask you what you think about our services. We make sure that your personal information is looked after as if we were handling it directly. We carefully select these companies, only share with them what they need to do the work and we make sure they keep your information secure. See also the list of sub-processors at the end of the document.
• Sometimes by law we have to pass on your information to other organisations We might also share your information if we have to by law, or when we need to protect you or other people from harm.

Can I delete my information

You can delete your account. Your account information is immediately deleted.

Anonymous logs are not deleted, as we cannot link this back to the user requesting deletion.

What are my rights?

Remember, you’re in control of your personal information. You have the right to:

• request a copy of your information
• not let robots make big decisions about you
• to ask us to correct information that’s wrong, to delete it or to request that we only use it for certain purposes
• to change your mind, and ask us to stop using your information. For example, unsubscribing from any marketing emails or turning off personalisation. Bear in mind, sometimes we might not be able to help. Like if the law tells us we can’t.

How does Wintor use Cookies and similar tracking?

What are cookies and tracking technologies?

Cookies are bits of data which are stored in your computer or mobile when you visit a website or app. There are also similar pieces of tracking information we collect.

Why do we use cookies and other tracking?

To do a few different things:

• to remember information about you, so you don’t have to give it to us again. And again. And again
• to keep you signed in, even on different devices
• to help us understand how people are using our services, so we can make them better
• to help us personalise Wintor to you by remembering your preferences and settings. And your progress, so you can pause and pick up where you left off watching a space, even on a different device.
• to find out if our emails have been read and if you find them useful

A few things on our websites would not work without some cookies. Tech people call these “strictly necessary cookies”. They’re always on when you visit us. But we want to use others like functional, performance and advertising cookies to make your experience more enjoyable. We’ll only use them if you’ve agreed. You can always change your mind. Bear in mind there are some other cookies out there from other companies. These “third-party cookies” might track how you use different websites, including ours. For example, you might get a social media company’s cookie when you see the option to share something. You can turn them off, but not through us.

How long do cookies last?

Some are erased when you close the browser on your website or app. Others stay longer, sometimes forever, and are saved onto your device so that they’re there when you come back.

How do I control my cookies and tracking?

When you first visit us, we’ll tell you about our cookies and ask you to agree if we can use them. You can always change your mind by going to your settings. Stopping all cookies might mean you can’t access some Wintor services, or that some of them might not work properly for you. Another way to control some tracking is in the settings on your device.

How will I find out about changes to this policy?

We update this policy sometimes. If we make important changes, like how we use your personal information, we’ll let you know. It might be a notice, an email or a message in your app. If you don’t agree to the changes, then you can always stop using our services, delete your account and stop giving us any more personal information. We’d be sorry to see you go.

How can I contact Wintor?

Find out more and contact us about your rights.

• by email: support@wintor.com
• by post Wintor B.V., Keizergracht 520H, 1017EK, Amsterdam, The Netherlands

Sub-Processors of Wintor

There are a few instances, in which personal information is shared with third parties.

Mailerlite

Our email campaign provider receives email addresses of all users. This is used to contact users about new features or any other updates of the Wintor platform. When your account is deleted from the Wintor platform, your email address is also removed from Mailerlite. Mailerlite Data Processing Agreement