Privacy Policy WinningEdge Limited

When you use our services, we process personal data of our customers ("you", "your" or "Customer"). This Privacy Policy (the "Policy") provides you with information on how your data is processed.

This Privacy Policy includes information on the following points:

• Who is the controller of your personal data and how can you contact them?
• What information do we collect about you and how do we obtain it?
• How do we use your personal data?
• How do we store and secure your personal data?
• To whom do we disclose your personal data?
• Do we transfer your data to third countries or international organizations?
• What rights do you have and how can you exercise them?

1. Who is the Controller of Your Personal Data and How Can You Contact Them?

The controller responsible for processing your personal data is:

WinningEdge Limited
Andrea Tselepou 3A, Stefani Chaits Office 4
8201 Geroskipou, Cyprus
Commercial Register Number: HE 470530
Email: support@winningedge.io

If you have any questions or wish to exercise your rights regarding the processing of your personal data, please contact us using the details provided above.

2. What Information Do We Collect About You and How Do We Obtain It?

Below is general information on the personal data we collect and how we obtain it. Personal data includes any information that can directly or indirectly identify you or that relates to you.

Data Provided Directly by You

We collect data that you actively provide to us, for example:

• During registration and account creation: Your name, surname, telephone number, email address, postal address, date of birth, username, and password, as well as business-related details (e.g., VAT identification number) if applicable.
• While using our services: Payment information (e.g., bank account details), details about your betting activities, transaction data (such as stake, profit, and loss), and any other data you provide through customer support or via social media.

Automatically Collected Data

When you visit our website or use our services, we automatically collect technical information, including:

• Device Information: IP address, device type, operating system, browser, and connection provider.
• Usage Information: Date, time, duration of your visit, pages viewed, click behavior, and other interactions on our website.

Data from Third Parties

We may also receive data about you from third parties, such as platform providers through which you access our services.

3. How Do We Use Your Personal Data?

We process your personal data for the following purposes:

Registration and User Account Management

To open and manage your user account, we process your identification and contact data.

Legal Basis: Processing is necessary for the performance of the contract.

Provision of Services and Fulfilling Contractual Obligations

To enable you to access our betting and analysis services, tools, and support, we process not only your identification and contact data but also payment and usage data, as well as data regarding your betting activities.

Legal Basis: Processing is necessary for the performance of the contract or based on our legitimate interests. After service termination, we may retain your personal data for a limited period to protect our rights.

Marketing and Business Communications

If you are a current or former customer, we may occasionally send you marketing communications about our services, products, and events—provided you have consented to receive such communications or based on our legitimate interest. Every marketing email includes an easy unsubscribe option.

Legal Basis: Contract performance and legitimate interest (or consent, if provided).

Customer Support and Communication

When you contact our customer support, we process your data to address your inquiries and provide quality assistance.

Legal Basis: Legitimate interest.

Service Optimization

To develop, test, and enhance our services and improve security, we analyze data regarding your usage.

Legal Basis: Legitimate interest.

Analytics

We analyze user behavior on our website and within our services to understand user preferences and enhance our offerings.

Legal Basis: Legitimate interest.

4. How Do We Store and Secure Your Personal Data?

Your personal data is processed and stored in an encrypted database on our servers and other electronic storage devices. We have implemented extensive organizational and technical measures to protect your data against unauthorized access, alteration, disclosure, or destruction.

5. How Long Do We Process Your Data?

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Policy or as required by law. In particular:

• Contract Performance and Related Obligations: Your data will be stored during the contractual period and for an appropriate period thereafter (typically up to 10 years) to manage potential claims.
• Marketing Communications: Without your explicit consent, your data will be stored for business communications for a maximum of 5 years following the termination of the contract, unless you object.
• Service Optimization and Analytics: Data is generally stored for a maximum period of 6 months.
• Legal Requirements: Data will be stored as required by applicable laws (e.g., tax regulations may require storage for up to 10 years).

6. Data Sharing and Transfers to Third Countries

We only disclose or transfer your personal data to third parties who assist us in providing our services, including:

• Platform Providers: To enable your betting activities, we share relevant data with platform providers.
• Other Service Providers: This includes companies that support our website and services (such as hosting, cloud services, payment processors, customer support providers, IT service providers, marketing agencies, consultants, and postal services).
• Legal Obligations: We may also disclose your data when required by law or to enforce our legal rights.

Every third party receiving your personal data is contractually obligated to process your data in accordance with applicable data protection laws and strictly follow our instructions.

7. Your Rights

You have the following rights regarding the processing of your personal data:

Right of Access

You may request confirmation as to whether your personal data is being processed and, if so, obtain detailed information and a copy of the data (the first copy is free; subsequent copies may incur a fee).

Right to Rectification

If your personal data is inaccurate or incomplete, you can request its correction. If you have an account with us, you may update your data via your user settings.

Right to Erasure ("Right to be Forgotten")

You may request the deletion of your personal data if:

• It is no longer necessary for the purposes for which it was collected.
• You withdraw your consent and no other legal basis for processing exists.
• You object to the processing and no overriding legitimate grounds exist.
• The data is processed unlawfully.

Note: In some cases (e.g., for compliance with legal obligations or the defense of legal claims), deletion may not be possible.

Right to Restrict Processing

Under certain circumstances, you can request that we limit the processing of your personal data.

Right to Data Portability

Where data is processed based on your consent or for the performance of a contract, you have the right to receive your data in a structured, commonly used, and machine-readable format and to have it transferred to another controller.

Right to Object

If your data is processed based on our legitimate interest, you may object to such processing. If you object, we will cease processing your data unless we can demonstrate compelling legitimate grounds that override your interests or rights. In cases of direct marketing, the processing will be halted immediately upon receipt of your objection.

Right to Withdraw Consent

If processing is based on your consent, you can withdraw that consent at any time. This does not affect the lawfulness of the processing prior to the withdrawal.

Right Not to Be Subject to Automated Decision-Making

You have the right not to be subject to decisions based solely on automated processing (including profiling) that have legal or similarly significant effects on you.

Right to Lodge a Complaint

If you believe that we are processing your data in violation of applicable data protection laws, you can lodge a complaint with the competent supervisory authority in the jurisdiction where our company is located.

8. Final Provisions

We reserve the right to modify this Privacy Policy as necessary. Should any significant changes be made, we will notify you in advance. The latest version of this Policy can always be found in your client area on our website.

This Privacy Policy is effective as of the date of its publication on our website. If you have any questions or require further clarification, please do not hesitate to contact us.