Privacy Policy

Last Updated: February 28, 2025

1. Introduction

1.1 CRD Holdings, LLC d/b/a Win It All ("Win It All," "we," "us") recognizes that people who use Win It All's Services ("you" or "users") value their privacy. This Privacy Policy details important information regarding the collection, use, and disclosure of user information collected on Win It All's website and related mobile applications (collectively, the "Services"). We provide this Privacy Policy to help you make an informed decision about whether to use or continue using our Services.

1.2 This Privacy Policy should be read in conjunction with our Terms of Use. By accessing the Services, you consent to the information collection and use practices described in this Privacy Policy.

1.3 Your use of the Services and any information you provide through the Services remains subject to the terms of this Privacy Policy and our Terms of Use, as each may be updated from time to time.

1.4 Any questions, comments, or complaints that you might have about this Privacy Policy should be emailed to privacy@winitall.com or forwarded in writing to:

CRD Holdings, LLC

6859 White Pine Dr

Bloomfield, Michigan 48301

For non-privacy inquiries or support needs, please visit our website at winitall.com/support.

2. Information We Collect

By using our Services and by submitting information to us through your use of our Services, this Privacy Policy will apply. You provide certain personal information to Win It All when choosing to participate in various activities on the Services, such as registering for an account, participating in contests, posting messages, taking advantage of promotions, responding to surveys, subscribing to newsletters or other mailing lists, or otherwise communicating with us or making a request on the Services. If you contact us by email, text message, phone call, or otherwise, in addition to any personal information we may receive, we may record and store the contents of those communications ourselves or using a third-party vendor. We may use the contents of these communications for training or other purposes and to satisfy our legal, auditing, and other obligations, or for any reason set forth in this Privacy Policy. Your communications with us might include requests, questions, and/or issues regarding your use of the Services or other topics you might raise.

The personal information we collect from you generally may include:

2.1.1 your name;

2.1.2 email address;

2.1.3 date of birth;

2.1.4 payment or billing information;

2.1.5 contacts you choose to submit;

2.1.6 profile photo;

2.1.7 username;

2.1.8 location;

2.1.9 your preferences;

2.1.10 submissions to various competitions and promotions;

2.1.11 responses to surveys;

2.1.12 communications sent to us by you;

2.1.13 your subscriptions to newsletters and services offered by us; and

2.1.14 any other information you submit to Win It All when choosing to participate in various activities on the Services.

2.2 In addition to the above, we may need to verify your identity in order for you to use some aspects of the Services. For verification purposes, we may also collect the following personal information from you (for compliance reasons, provision of this information, when requested, is a mandatory condition of using our Services):

2.2.1 passport information;

2.2.2 driver's license information;

2.2.3 other identification documents;

2.2.4 permanent and temporary address;

2.2.5 tax-related information; and

2.2.6 other information as may be required to verify you in accordance with applicable laws and regulations.

2.3 When you use our mobile apps, we may also collect mobile device information such as operating system, hardware type, unique device identifiers (such as IDFA or an Android Ad ID), device language, the location of your device (at a GPS level), and app usage information. This data may also be linked to your other information, including your location data. Our Services use precise location-based services (e.g., location collected through GPS technology) in order to locate you so we may verify your location, process payments, perform analytics, deliver relevant content and ads based on your location, share your location with our vendors as part of the location-based services we offer, and for purposes of legal and regulatory compliance. We also collect non-precise geolocation data (i.e., the city and state in which your device is located based on its IP address). This non-precise geolocation data allows us to customize your experience, give you access to content that varies based on your general location, and serve you ads that are relevant to you.

2.4 In addition, if you choose to log in, access, or otherwise connect to Win It All, or contact Win It All, through a social networking service (such as Facebook), we may collect your user ID and user name associated with that social networking service, as well as any information you make public using that social networking service. We may also collect information you have authorized the social networking service to share with us (such as your user ID, public profile information, email address, birthday, friends list, and pages you have "liked").

2.5 Cookies Information: When you visit our website, we may send one or more cookies—small files—to your computer or other device, which may enable us or others to uniquely identify your browser. Win It All uses both session cookies and persistent cookies. A persistent cookie remains after you close your browser and may be used on subsequent visits. Persistent cookies can be removed by following your web browser help file directions. Session cookies are temporary and typically disappear after you close your browser. You may be able to reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Services may not function properly if the ability to accept cookies is disabled.

2.6 Log File Information: When you use our Services, our servers may automatically record certain information that your device sends whenever you visit any website and use certain apps. These server logs may include information such as your web or app request, Internet Protocol ("IP") address, browser type, browser language, referring/exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that may uniquely identify your browser.

2.7 Clear GIFs Information: When you use our Services, we may employ technology such as "clear GIFs" (a.k.a. Web Beacons) which are used to track the online usage patterns of our users. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by specific users.

2.8 Third-Party Information Collection: Win It All may also collect information about you from third parties, such as marketing partners, identity verification services, anti-fraud services, and other service providers. You authorize your wireless carrier to use or disclose information about your account and your wireless device, if available, to us or our service provider for the duration of your business relationship, solely to help us identify you or your wireless device and to prevent fraud.

3. The Way Win It All Uses Your Personal Information

3.1 We use your personal information to operate, maintain, and provide you with the features and functionality of the Services, including but not limited to the following:

3.1.1 providing you with our products and services, including promotions and contests;

3.1.2 processing and responding to inquiries;

3.1.3 personalizing your use of the Services;

3.1.4 alerting you to new features, special events, products, and services, or certain third-party products or services in which we think you will be interested;

3.1.5 enforcing the legal terms that govern your use of the Services; and

3.1.6 investigating and protecting the integrity of Win It All contests and promotions.

3.2 We may use your information (both personal and non-personal information) to send you marketing and advertising content, including through multiple channels such as direct mail, email, push notifications, display media, and personal text messages. However, we will not sell your mobile information to third parties or affiliates for marketing or promotional purposes.

3.3 We may use your information to communicate with you about:

3.3.1 our products and services in which you may be interested, provided that you have not requested otherwise; 3.3.2 newsletters and information for which you have signed up; and 3.3.3 non-marketing or administrative purposes (such as notifying you of major changes to the Services or for customer service purposes).

3.4 We use your information to improve the quality and design of our Services and to create new features, promotions, functionality, and services by storing, tracking, and analyzing user preferences and trends.

3.5 We also use cookies, clear GIFs, log file information, and mobile app information such as device identifiers for purposes such as (a) remembering information so that you will not have to re-enter it during your visit or the next time you visit our Services; (b) providing custom, personalized content and information; (c) monitoring the effectiveness of our marketing campaigns; (d) monitoring aggregate metrics such as total number of visitors, pages viewed, etc.; and (e) tracking your entries, submissions, and status in promotions, sweepstakes, and contests. You can learn more about how these technologies are used in the section below, Third Party Advertising and Analytics.

3.6 We may anonymize, de-identify, or aggregate your information for any legitimate business purposes, including for reporting, research, or advertising. Such anonymized and/or aggregated data does not personally identify you. Sometimes, this information may be used to target more relevant content or offers to you across different devices—for instance, we may provide you with offers and content on your mobile device based on your web-based activity.

3.7 We will retain personal information and the contents of our communications with you as long as necessary to fulfill these purposes unless the law requires us to keep it for a longer period. To provide security and business continuity for the activities described here, we make backups of certain data, which we may retain for longer than the original data.

4. When Win It All Discloses Information

4.1 We may disclose the information we collect or receive from you to our subsidiaries, affiliated companies, agents, or other businesses, or service providers who process your information on our behalf to provide or operate the Services. These entities may have access to your information for purposes including (but not limited to) billing and accounting, hosting, marketing, promotional and email services, customer and technical support, and facilitating communications with you. Our agreements with these service providers limit the kinds of information they can use or process and require them to use reasonable efforts to keep your personal information secure. Please note, if we use a vendor to facilitate or assist in communication with you, the vendor will receive your personal information (such as your name, email, or telephone number) and may record and store the content of your communications with us. However, we do not disclose mobile phone numbers to unaffiliated third parties for marketing purposes without your express consent.

4.2 When you choose to share information with social media services about your activities on Win It All, such as by connecting your social media account to our Services, Win It All may share your personal information and information about your use of the Services with such social media sites. Please make sure to read the terms and privacy statements of such sites prior to connecting to our Services in this way.

4.3 If you win a prize, we may use your personal information (such as your name and photo) in connection with publicity purposes.

4.4 If you win a promotion run by us, we may be required to either publish or make available upon request your name and county in accordance with applicable legislation.

4.5 We may publish a profile page that includes your username, the date you became a member, your stats from previous contests, and, if you uploaded one, your profile picture. Where you post personal information about yourself through our Services to public areas, you acknowledge and agree that this personal information will be publicly available.

4.6 When you participate in a contest or promotion, we may publish your username on a list of participants, along with a link to your profile page.

4.7 Where you have provided your consent, we may share your personal information with selected third parties for their commercial or marketing use in conjunction with your relationship with Win It All or as part of a specific program or feature.

4.8 We do not sell your personal information to third parties. However, we may disclose anonymized, de-identified, or aggregated data for research and analysis purposes.

4.9 We may access, use, preserve, transfer, and disclose any of your information (including the content of your communications with us, device identifiers, and personal information) to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests, or legal process if in our good faith opinion such disclosure is required or permitted by law; (ii) to protect and/or defend the Services, its integrity, and our Terms and Conditions or other policies applicable to the Services, including investigating potential violations thereof; (iii) to protect the safety, rights, property, integrity, or security of the Services or any third party; and/or (iv) to detect, prevent, or otherwise address fraud, security, or technical issues.

4.10 In the event that Win It All is involved in a merger, acquisition, sale, bankruptcy, insolvency, reorganization, receivership, assignment for the benefit of creditors, or other change of control, your personal information may be disclosed to another entity related to such event.

4.11 Recipients of data disclosures described in this Privacy Policy may be located in the United States and elsewhere, including locations where privacy laws may not provide as much protection as your country.

5. Legal Bases for Processing Personal Data

5.1 Some laws require companies to disclose the legal grounds they rely on to process your personal information. To the extent those laws apply, we process your personal information under the following legal bases:

5.1.1 Legitimate Interests: In many cases, we handle personal data based on our legitimate interests in commercial activities, provided that these interests are not overridden by your fundamental rights and freedoms. These legitimate interests include: (a) Customer service (b) Marketing (subject to applicable laws and user preferences) (c) Protecting our users, personnel, and property (d) Analyzing and improving our business (e) Processing job applications (f) Managing legal and regulatory compliance

5.1.2 Business Partners and Affiliates: We may process personal data for the legitimate interests of our affiliates or business partners, such as to offer special events, promotions, or contests or to assist with marketing.

5.1.3 Contractual Necessity: Some personal data processing is necessary to fulfill our contractual obligations with our users.

5.1.4 Consent: Where required by law, and in some cases, we process personal data based on your express or implied consent. You may withdraw your consent at any time, subject to legal and contractual obligations.

5.1.5 Legal Compliance: We may use and disclose personal data to comply with our legal obligations, such as responding to regulatory requirements or law enforcement requests.

6. Third-Party Advertising and Analytics

6.1 We work with third-party companies that assist in marketing our services on external websites. These companies may collect information about online activities conducted on a particular computer, browser, or device over time and across different websites or online services for the purpose of delivering relevant advertising. Some ads on our Services may be delivered by third-party advertising partners who use cookies and similar technologies (e.g., unique identifiers, mobile device IDs) to collect data about your activities and interests. These advertising companies may track your interactions with advertisements to improve targeting and effectiveness.

6.2 To learn more about interest-based advertising and to opt out of third-party data collection on our website, you can visit www.aboutads.info/choices or www.youronlinechoices.com. The use of cookies and other tracking technologies by non-affiliated third parties is governed by their respective privacy policies. You can also opt out of tailored advertising through the Network Advertising Initiative's Consumer Opt-Out link or the Digital Advertising Alliance's Consumer Opt-Out link. For Google-based advertising, visit the Google Ads Settings page. Mobile users can use the DAA App Opt-Out Tool and the NAI App Opt-Out Tool to manage preferences.

6.3 We also work with third-party analytics providers to collect data through cookies and automated means. In some cases, these third parties may retain information in an identifiable form. These analytics services help us understand how users interact with our website and mobile apps so we can improve functionality and user experience.

We do not sell mobile information or personal data to third parties for marketing or promotional purposes.

7. Information Security

7.1 We are committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help safeguard your personal information from unauthorized access, use, or disclosure.

7.2 While no organization can guarantee the absolute security of information processed online, we implement appropriate security measures to protect your personal information. For example, we store the personal information you provide on computer systems with limited access, located in facilities with restricted entry.

7.3 To further protect your privacy and security, we reserve the right to take reasonable steps (such as requesting your password) to verify your identity before granting you profile access or making corrections.

7.4 You are responsible for maintaining the confidentiality of your password and account information. You should ensure that your password is kept secure at all times.

8. Your Rights and Choices

8.1 Win It All processes your personal information in accordance with this Privacy Policy. As part of this, we provide you with certain choices regarding how your personal information is processed. These choices are outlined below.

8.2 You can access and update certain personal information Win It All holds about you at any time by logging into your account via the Services.

8.3 We may occasionally send targeted advertising to you via web or mobile browsers or mobile applications. You may opt out of many third parties that support targeted advertising by visiting www.aboutads.info, and you may learn more about this type of advertising in Section 6: Third-Party Advertising and Analytics. You may also opt out of mobile advertising tracking through the settings on most smartphones via Google Ads Settings or Apple Privacy Settings.

8.4 We may send push notifications to your mobile device. You can turn off push notifications within the account settings of the Win It All mobile app or through your device’s notification settings on iOS or Android.

8.5 Marketing Communications. In accordance with applicable law, we or our vendors may send you marketing and promotional emails. If you wish to opt out of email marketing, you can do so by emailing us at privacy@winitall.com or following the unsubscribe instructions in the email. Even if you opt out of marketing emails, you may still receive important administrative and transactional messages (e.g., updates to our legal terms).

8.6 Rights Regarding Your Information. Depending on your jurisdiction, you may have the right to:

• Request information about the categories of personal information we collect, the sources of that information, and the business purposes for collecting it.
• Access and receive a copy of the personal information we hold about you.
• Correct or update inaccuracies in your personal information.
• Request deletion of certain personal information, subject to legal and contractual requirements.
• Restrict or object to certain uses of your personal information.
• Withdraw consent for processing personal information (where applicable).
• Opt out of direct marketing and targeted advertising.

Certain information may be exempt from these requests under applicable law. For instance, some data is required to provide our services to you. We may also require verification of your identity before processing your request.

8.7 Notice of Right to Opt Out of Sales and Targeted Advertising. Depending on your jurisdiction, you may have the right to opt out of the sale of your information or sharing/processing for targeted advertising purposes. Win It All does not sell personal information; however, some disclosures of personal data to third-party advertising partners may qualify as sharing for targeted advertising.

To opt out of targeted advertising, please visit Your Privacy Choices on our website. This must be done for each browser/device you use. If you clear your cookies, you may need to renew your choice.

If you are a California resident, additional rights may apply under the California Consumer Privacy Act (CCPA). We do not knowingly sell the personal information of minors under 16 years of age.

If you have any concerns or wish to exercise your rights, you may contact us at privacy@winitall.com. If you wish to designate an authorized agent to make a request on your behalf, we may require signed authorization and identity verification.

9. Notice to California Residents

9.1 California Consumer Privacy Act (CCPA). If you are a California resident, California law requires us to provide you with additional information regarding how we collect, use, and share your personal information (as defined in the California Consumer Privacy Act (CCPA)).

Categories of Personal Information We Collect: Throughout this Privacy Policy, we discuss in detail the specific pieces of personal information we collect from and about users. Under the CCPA, we are also required to provide you with the "categories" of personal information we collect. These categories may include:

• Identifiers (e.g., name, address, email address, driver’s license)
• Commercial information (e.g., purchase history, contest entry data)
• Financial data (e.g., payment details)
• Internet or device activity (e.g., browsing history, service usage)
• Geolocation data (e.g., city and state based on IP address)
• Professional or employment-related information (e.g., as part of your profile)
• Audio information (e.g., customer support call recordings, if applicable)
• Fraud prevention and risk management data (e.g., employment status, criminal history)
• Other information that identifies or can be reasonably associated with you

How We Use and Disclose Personal Information: We use and disclose the above categories of personal information in accordance with the purposes described in this Privacy Policy. Please refer to previous sections for further details.

9.2 Your Choices Regarding "Sharing" and "Selling"

We may disclose information to unaffiliated third parties that provide offers or services that we believe may be of value to you. We may also share information with third-party advertising providers for targeted advertising purposes or with analytics partners to better understand how users engage with our Services. Under applicable law, certain disclosures of your personal information may be considered “sales” or “sharing/processing for targeted advertising.”

If you would like to opt out of the disclosure of your personal information for purposes that could be considered “sales” or “sharing” for targeted advertising, please visit Your Privacy Choices on our website and follow the instructions. This opt-out must be performed on each browser and device you use. If you clear your cookies, you may need to renew your choice.

If you are a California resident, you may designate an authorized agent to submit such requests on your behalf. We do not knowingly sell or share the personal information of minors under 16 years of age without legally required affirmative authorization.

If you have a legally recognized browser-based opt-out preference signal enabled on your device, we recognize such preferences in accordance with applicable law.

9.3 Shine the Light Disclosures

If you are a California resident, you may request information regarding our disclosure of personal information during the past year to third parties for their direct marketing purposes. To submit such a request, please contact us at:

Win It All

6859 White Pine Dr

Bloomfield, Michigan 48301

Email: privacy@winitall.com

10. Changes and Updates

10.1 This Privacy Policy may be revised periodically. Updates will be reflected by the “Last Updated” date at the top of this page. We encourage you to revisit this page to stay informed about any changes. If we make material changes to this Privacy Policy, we will notify you via email or through a notice on our website.

10.2 Contact Information

For any questions or comments regarding this Privacy Policy, please contact us at:

Win It All

6859 White Pine Dr

Bloomfield, Michigan 48301

Email: privacy@winitall.com

For non-privacy inquiries or support needs, please visit our website at winitall.com/support.