Privacy Policy

WINNER’S CIRCLE ACADEMY, PRIVACY POLICY

(Effective January 1, 2023)

At Winner’s Circle Academy (“Winner’s Circle Academy”, “we”, “us”, “our”) we respect your privacy rights. We have created this privacy policy (“Privacy Policy”) to explain how we treat the information collected and received from your use of our services (“Services”) provided through (a) the website www.thewinnerscircleacademy.com and the URL extensions from such website, (b) Facebook®, Instagram®, and other social media pages controlled by us, and (c) any other websites or applications we own, operate, or control (the all of the foregoing collectively being the “Website(s)”). This Privacy Policy applies only to the Services, and we are not responsible for the practices of persons, companies, institutions or websites that Winner’s Circle Academy does not control, manage, or employ. Capitalized terms not defined herein have the meanings set forth in our “Terms & Conditions” located at www.thewinnerscircleacademy.com

Please read this Privacy Policy as well as our Terms & Conditions carefully, as they govern your use of the Website and our Services. If you do not agree to this Privacy Policy, please do not use the Website or our Services. By accessing or using our Website and Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of the Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Winner’s Circle Academy, is the data controller of your information. Please see the “Winner’s Circle Academy Contact Information” section below for additional details.

Important Information About Using Our Services

Please understand that by submitting any information to us, you acknowledge that we may collect, use, disclose and retain such information in accordance with this Privacy Policy and our Terms & Conditions, and as permitted or required by law. If you do not agree with these terms, then please do not provide any information to us.

Winner’s Circle Academy may offer social sharing features as part of its Services (“Social Sharing Services”). By electing to participate in any of our Social Sharing Services, you acknowledge that any information or materials you include in your profile (“Profile”) can be viewed by other persons accessing the Website(s), including potential or existing employers, as well as by others on applicable third-party websites. You also acknowledge that information you share through Social Sharing Services may remain accessible on third party websites and/or to those you have shared the information with in the event you make your Profile private after having made it public and/or ceasing to share your information and that Winner’s Circle Academy has no control over the access of or use of information provided to third parties via Social Sharing Services outside its Website(s). Information shared through our Social Sharing Services is posted and transmitted to others at your own risk, and you may assume that any other user can view your information unless the Website expressly indicates otherwise. We cannot control the actions of other users of the Website with whom you may choose to share your information. Therefore, we cannot and do not guarantee that your information will not be viewed by unauthorized persons.

What Information We Collect

Information You Provide Us

We collect a variety of information that you provide directly to us. In general, we collect information from you through:

Using our Website and any of our Services, including registering for a user account through the Website (“User Account”)
Making a purchase from us, including registering and enrolling in any online course (“Online Course”)
Signing up for email updates
Uploading or posting to public forums included through the Services
Submitting requests or questions to us via forms or email
Requesting customer support and technical assistance

The types of data we collect directly from you include:

Name, address, telephone number and email address
Log-in credentials, if you register a User Account with information about purchases or other transactions with us. Please note, however, that we do not collect, store, or transmit financial account information. Instead, we use a third- party payment processor to process our payments.
Information about your customer service and maintenance interactions with us
User-generated content you upload or post to public forums through the Services. Information needed in order to comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others
Any other information you choose to directly provide to us in connection with your use of the Services

Participation in Online Courses. If you desire to participate in an Online Course, you will be asked to provide us with certain information necessary to conduct such Online Course. This information may include, among other things, your name, phone number and email address.

Information We Collect Through Automated Means

Analytics Information

When you use our Website and Services, we and our service providers (which are third party companies that work on our behalf) may use cookies and similar technologies to track, collect and aggregate certain information including, among other things, which pages of our Website(s) were visited, the order in which they were visited, when they were visited, the URLs from which you linked to our Website(s), and which hyperlinks were “clicked.” Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Website. Through such information, we may be able to determine from an IP address a user’s internet service provider and the general geographic location (city/state) of his or her point of connectivity.

We also use or may use these technologies to help us determine and identify repeat visitors, the type of content and sites to which a user of our Website(s) links, the length of time each user spends at any particular area of our Website(s), and the specific functionalities that users choose to use.

We use third-party web analytics services (such as those of Google Analytics) on our Website(s) to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. We may also use third-party services, (including Slack), as a medium for communications, either through email, or through messages within our Service(s). The use of any such medium may be subject to the terms and conditions and privacy policy of those service providers and you should carefully review those terms and conditions. If you would like to opt out of having this information collected by or submitted to Slack or have questions about other third-party service providers’ collection of your information for this purpose, please contact us.

Online Advertising

We may allow third party companies, including advertising companies (such as Facebook, Google, Twitter and Instagram), to place cookies on our website (“Cookies”). Cookies enable such companies to track your activity across various sites where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the internet. These Cookies store information about the content you are browsing together with an identifier linked to your device or IP address.

These Cookies also allow us and third parties to know whether you’ve seen an ad or a type of ad, and how long it has been since you’ve last seen it. This information is used for frequency capping purposes, to help tailor the ads you see, and to measure the effectiveness of ads.

Do Not Track Signals

Currently, we do not monitor or take any action with respect to web browser signals or other mechanisms for the expression of choice regarding collection of information about an individual over time and across third-party web sites or online services (e.g., web browser “do not track” signals).

Information We Collect From Social Media And Other Content Platforms

If you log-in to, or connect to, a third-party network (e.g., through a social network), or log-in to our Services, through a social network site (e.g., Facebook), you may allow us to have access to and store certain information from your social network profile. This includes your name, gender, profile picture, depending on your settings on such services. If you do not wish to have this information shared, do not use a social networking connection to access the Website or Services. For a description of how social networking sites handle your information, please refer to their privacy policies and terms of use, which may permit you to modify your privacy settings.

Referral Programs

We may offer certain users (“Referrers”) the opportunity to refer their friends (“Referees”) to the Website through a third-party referral program whereby both Referrers and Referees may obtain credits or other rewards through such referrals. To the extent we offer such programs, the Referrers may share information about the Referees, including email addresses for the purpose of sharing the referral offer. We may also share the Referrer’s email and name with the Referee as well as provide the Referrer the confirmation of the Referee’s acceptance of the referral which may include Referee’s email in connection with providing any such referral program.

How We Use The Information We Collect

We use your information for various purposes depending on the types of information we have collected from and about you and the specific services you use, in order to:

Send you information in connection with the Services
Respond to your communications and requests
Manage and process Online Courses, including but not limited to tracking attendance, progress and completion
Provide Services to you, such as services that you request in conjunction with the Online Courses
Contact you by email, postal mail, or phone (including via SMS messages) regarding Winner’s Circle Academy and third-party products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you
Customize the content we provide through the Services
Help us better understand your interests and needs, and improve the Services
Engage in analysis, research, and reports regarding use of the Services
Secure the Services
Comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others
Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others

Combined Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.

Aggregate/Anonymous Data We may aggregate and/or anonymize any information collected through the Website so that such information can no longer be linked to you or your device (“Aggregate/Anonymous Information”). We may use Aggregate/Anonymous Information for any purpose, including without limitation for research and marketing purposes, statistical analyses of Website(s) usage, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.

How We Share And Disclose Your Information

Winner’s Circle Academy will share your information in the following ways:

Service Providers. We provide access to or share your information with operations and maintenance contractors and other third parties who perform services on our behalf. They have access to perform these services but are prohibited from using your information for other purposes. They provide a variety of services to us, including billing, sales, marketing, product content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, payment processing, and legal services.

Protection of Winner’s Circle Academy and Others. By using the Website, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order) or law; (b) enforce our Terms & Conditions, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of Winner’s Circle Academy™, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, compliance with applicable law, and spam/malware prevention, and similar purposes.

Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions) user information may be among the transferred assets. If a portion or all of Winner’s Circle Academy’s assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, Winner’s Circle Academy will comply with such restrictions.

Advertising. We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria

Aggregate/Anonymous Information. From time to time, Winner’s Circle Academy may share Aggregate/Anonymous Information about use of the Services, such as, but not limited to, publishing a report on usage trends or survey results. The sharing of such data is unrestricted.

Data Subject Rights And Your Choices

You may have certain rights with respect to your information as further described in this section.

Your Legal Rights

If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Winner’s Circle Academy Contact Information” section below at any time. Your local laws, such as in the European Union, may permit you to request that we:

provide access to and/or a copy of certain information we hold about you
prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)
update information which is out of date or incorrect
delete certain information which we are holding about you
restrict the way that we process and disclose certain of your information
transfer your information to a third-party provider of services
revoke your consent for the processing of your information

We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation.

To the extent that you make such a request, we require certain information to help verify your request and prevent fraudulent information and removal requests. Specifically, we ask that you provide the following pieces of information:

Username and email address associated with your Winner’s Circle Academy User Account;
Online Courses currently or previously enrolled in;
Approximate date of User Account registration;
Information you want to view and/or request removed;
Country of residence; and
A statement under penalty of perjury that all information in your request is truthful and that this is your User Account or that you have the authorization to make the request on behalf of the owner of the User Account.

Depending on the circumstances and the information you request, we may require additional methods of verification in our discretion.

Communications & Notification Preferences And Opting Out

We provide our users with the opportunity to update their information or to opt out of having their contact information used for purposes not directly related to payment or servicing of your account.

If you are a student and wish to opt out of any of the communications offered by Winner’s Circle Academy, you may do so at any time by sending a notice as shown below.

You may opt out as follows:

Contact us by email at [email protected]
Contact us via postal mail at Winner’s Circle Academy, Please identify the communication methods (e.g., phone, email, or SMS text message) by which you desire to stop receiving messages.

You may unsubscribe from our commercial or marketing email communications at any time by following the unsubscribe instructions located at the bottom of such emails. If you have opted in to receive marketing text message communications from Winner’s Circle Academy, you can opt out of those messages by following the instructions in those messages or by contacting us at the information provided above. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

Retention Of Your Information

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

Third Party Links And Features

The Services contain links to third-party websites such as social media sites, and also contain third-party integrations (such as the Facebook “like” button, Slack & WebEx integrations, or YouTube) and functionalities. If you choose to use these sites or features, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function. Winner’s Circle Academy is not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this Privacy Policy. We urge you to read the privacy and security policies of these third-parties.

Children’s Privacy

Winner’s Circle Academy is intended for general adult audiences and not for children under the age of 18. No one under age 18 may provide any personal information to or on the Website or otherwise use our Services. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we become aware that we have inadvertently collected “personal information” (as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 18 without legally-valid parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws. If you believe we might have any information from or about a child under 18, please contact us using the information in the “Winner’s Circle Academy Contact Information” section below.

International Users

Winner’s Circle Academy stores information about visitors to our Website and users on servers located in the United States. By using our services, you consent to the storage of your information inside the United States. If you are using the services from outside the United States and the European Union, please know the information you submit will be transferred to and stored in servers in the United States or other countries. The data protection and other laws of the United States and/or other countries might not be as comprehensive as those in your country. By submitting your data and/or using our services, you acknowledge the transfer, storing, and processing of your information in and to the United States.

As described above, Winner’s Circle Academy also may subcontract the processing of your data to, or otherwise share your data with, service providers and others in countries other than your country of residence, including the United States, in accordance with applicable law. Such third parties may be engaged in, among other things, the provision of services to you, the processing of transactions and/or the provision of support services. By providing us with your information, you acknowledge any such transfer, storage or use.

If we provide any information about you to any such non-European Union entities, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy. These measures include signing Standard Contractual Clauses in accordance with European Union and other data protection laws to govern the transfers of such data. For more information about these transfer mechanisms, please contact us as detailed in the “Winner’s Circle Academy Contact Information” section below.

We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your data within 45 days of receiving your complaint. If you are unsatisfied with the resolution of your complaint, you may contact the data protection supervisory authority in the country where you are based for further information and assistance.

Binding Arbitration. You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with Winner’s Circle Academy and provided us the opportunity to resolve the issue; and (2) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you.

How We Protect Your Information

We consider the confidentiality and security of your information to be of the most importance. Winner’s Circle Academy takes a variety of technical, administrative, and physical measures to protect your information from disclosure to or access by third parties. Please note that we do not guarantee the security of information, as no method of internet transmission or storage is completely secure. Also note that we may retain and store your information in our databases and systems even after your Winner’s Circle Academy account is deactivated as long as we have a legitimate purpose to do so and in accordance with applicable law.

California Privacy Rights

California residents have the right to receive, once a year from Winner’s Circle Academy: (a) information identifying any third-party company(ies) to whom we may have disclosed (within the previous calendar year) “personal information” (as defined by California law) for that company’s direct marketing purposes; and (b) a description of the categories of personal information disclosed. If you are a California resident and wish to obtain such information, submit a request [email protected]; when you request the information, use the phrase “California Shine the Light Request” to help us appropriately identify your question, and include your mailing address, state of residence and email address so we can provide a response.

Changes To Our Privacy Policy

Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Website(s). You can know if the Privacy Policy has changed since the last time you reviewed it by checking the effective date at the beginning of the Privacy Policy. If we make a material change to the Privacy Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy. Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

Winner’s Circle Academy Contact Information

If you have any questions, comments or complaints about this Privacy Policy, please contact us: [email protected]

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