# Security Compliance Policy

#### Last updated 10/4/2023

This privacy notice describes how we, B601 Labs Inc. dba Winware, and our subsidiaries and affiliates, from time to time ("Winware," "we," "us," "our"), process, maintain, use and share information about individuals (each a "User," "you," "your") who use our website (www.winware.ai) and related features (collectively, the "Site") or who we communicate or interact with. Winware complies with various privacy laws globally, including, but not limited to, the European Union General Data Protection Regulation ("GDPR") and the California Consumer Privacy Act ("CCPA").

This notice sets out:

01. Information we collect about you  
02. Cookies and other technologies  
03. How we use your information  
04. Our promotional updates and communications  
05. Who we give your information to  
06. Where we store your information  
07. How we protect your information  
08. How long we keep your information  
09. Child Safety  
10. Your rights  
11. Changes to this notice  
12. Contact us

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

By engaging with our Site, you acknowledge you have read and understood this privacy notice.

For the purposes of the applicable data protection law, the **Data Protection Officer** is:

Steven Cohn,  
CEO  
privacy@winware.ai

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## 1. INFORMATION WE COLLECT ABOUT YOU

We will collect and process the following personal data from you:

### Information you give us

- This is information about you that you give us directly when you interact with us. It includes information you provide when you use our site, subscribe to our service, search for a product, submit a query, and when you report a problem with our site.
- The information you give us may include demographic information, such as your name, job title, company name, country, e-mail address, and phone number.
- If you register for an event we organize, you may submit additional information, including your interest in compliance topics and products.
- If you respond to an advertised job vacancy or make a general inquiry regarding employment opportunities with us, you may submit various employment details about yourself, including a CV, resume, or other details of your educational and employment history.

### Information we collect about you from your use of our site:

We will automatically collect technical information each time you visit our site. This includes:

- The Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- Product usage behaviors.

### Information we receive from other sources:

This is the information we receive about you if you use any other websites or Apps we operate or our other services.

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## 2. COOKIES AND OTHER TECHNOLOGIES

Our site uses cookies and/or other similar technologies to collect and store certain information. Cookies and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services. They can manage various features and content, store searches, and present personalized content.

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## 3. HOW WE USE YOUR INFORMATION

We use the information we hold about you in the following ways:

### Information you give to us:

- We will use this information to:
- Take steps to enter any contract or carry out our obligations arising from any existing contract between you and us.
- Ensure in our legitimate interests that content from our site is presented most effectively for you and your computer.

### Information we collect about you from your use of our site

- We will use this information in our legitimate interests, including:
- To administer our site and for internal operations, including troubleshooting, data analysis, and testing.
- To keep our site safe and secure.
- To understand the effectiveness of advertising we serve to you.

### Information we receive from other sources

- We may combine this information with information you give us and information we collect about you.

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## 4. OUR PROMOTIONAL UPDATES AND COMMUNICATIONS

Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications.

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## 5. WHO WE GIVE YOUR INFORMATION TO

We may give your information to any member of our group and to selected third parties. This may include:

- Organizations who process your personal data on our behalf.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.

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## 6. WHERE WE STORE YOUR INFORMATION

We are headquartered in the United States of America. Suppose we transfer personal information outside of the European Union (EU) or the United Kingdom (UK). In that case, we will ensure that your data is treated securely and in accordance with this privacy notice.

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## 7. HOW WE PROTECT YOUR INFORMATION

Winware will use appropriate technical and organizational security measures to protect your personal data from loss, misuse, alteration, or destruction.

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## 8. HOW LONG WE KEEP YOUR INFORMATION

Winware will retain personal data reasonably, considering legitimate business needs.

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## 9. CHILD SAFETY

We do not knowingly collect personally identifiable information from anyone under 13. If you are a parent or guardian and know your child has provided us with Personal Data, please contact us.

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## 10. YOUR RIGHTS

You may have the following rights under European laws and similar rights under other countries laws:

- Right of subject access.
- Right to rectification.
- Right to erasure.
- Right to restriction of processing.
- Right to object.
- Right to data portability.
- Right to withdraw consent.

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## 11. CHANGES TO THIS NOTICE

Winware keeps this notice under regular review and may modify it occasionally at our discretion.

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## 12. CONTACT US

Suppose you have questions, comments, or complaints about this privacy notice. In that case, you may contact our Data Protection Officer:

Steven Cohn,  
CEO  
privacy@winware.ai
