Privacy Policy

Last Update: September 22, 2021

This Privacy Policy explains the use of information, including yours, eventually collected due to the use of
Winnin Insights, customer service operations and other activities (collectively, "Service"), offered and operated
by Winnin Inc and others its subsidiaries (together "Winnin Inc."). This policy will help you understand what
information we collect, why we collect it, and how you can update, manage, export, and delete your
information.

This Privacy Policy is a complementary document to any other written agreement in place between Winnin Inc.
and our Users.

Our Service allows you to map culture in real time and helps understand what’s relevant to different audiences
and cultural niches. It empowers content creators through data. And in order to do so, our Service is integrated
with third-party sites.

If you have any questions about this Privacy Policy, you can contact us on dpo@winnin.com

We hereby inform you that we will process your data lawfully and fairly in full respect of your rights and, in
particular, your privacy, according to Laws 12.965/2014, 13.709/2018 and other applicable laws and regulations
(hereinafter collectively “Regulation”).

This Privacy Policy was structured based on the best privacy practices in the market, giving special attention to
Law 13.709/2018, the Brazilian General Data Protection Law (“LGPD”). Under the LGPD, you have the right to
access, rectify, port, erase, and confirm that we process your data. Our Privacy Policy provides information
about how we handle data that are provided to us.

To request more information about our data practices, you can contact the Data Protection Officer for Winnin
Inc., by sending an email to dpo@winnin.com. You also have the right to petition the Brazilian Data Protection
Authority (“DPA”) by contacting the DPA directly.

For the purposes of this document the following definitions shall apply to “User’s Information”:

(i) “Personal Information” means any information, manually provided to Winnin Inc., about one of
our Users which could, alone or together with other information, personally identify them or
otherwise be reasonably linked or connected with them. The collected information are full name,
country of access, company name and market, position, e-mail, login and password to access
Winnin Insights, phone number, type of user (full user or viewer) and any other data that may be
needed to use the Service, upon previous communication to User;

(ii) “Access Information” means any information collected automatically from the use of our Service,
that can be used to identify data about the User's account, his requests and activities on the Internet,
the interaction with a service, the messages sent or disclosed, the Address Internet Protocol ("IP"),
the URLs of the website of origin and the next website that User can be visiting, the type and language of the browser, one or more cookies that can identify the User’s browser or account,
general and specific information about User’s computer hardware, mobile phone or other device,
Internet connection, operating system and the number of the version in use.

By using the Service, User’s device used to access Winnin Insights platform automatically generates and
provides data to Winnin Inc. We collect and use such information to provide better service to all our Users.
Winnin Inc. may use the information collected to improve and customize the User's experience when using
Winnin Insights including, but not limited to keeping track of certain information aggregated to the User of its
use of the Winnin platform, operate and improve content made available on Winnin Insights platform, to
authenticate the identity of our Users and to allow them to access our Service, remember their preferences and
registration information, present and help measure and research the effectiveness of email communications from
Winnin Inc. and authorized third parties.

We also use the information we collect in existing services to help us develop new ones, for analytics and
measurement to understand how our services are used, as well as to interact with you directly, for example, we
may send you a notification if we detect suspicious activity in your account, or we may let you know about
upcoming changes or improvements to our Services. And if you contact us, we’ll keep a record of your request
in order to help solve any issues you might be facing.

Besides that, we use information to help improve the safety and reliability of our Service. This includes
detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm
Winnin Inc, our Users, public or partners. We also collect and storage information to comply with applicable
laws and regulations. Also, we use User’s Information to process and diffuse statistics and graphic
representations but only in aggregate and anonymous form, pursuing Winnin Inc’s legitimate interest.

The data activity we collect from you when using Winnin Insights may include:

●   Terms you search for;
●   Videos you watch;
●   Activity on third-party sites and apps that we use on our Service;
●   Location information through IP address

We collect information about you from our trusted partners, including data partners who provide us with
information about what people are watching online. For that, we may collect your username and thumb.

We use different technologies to process your information for these purposes. We use automated systems that
analyze your searches to provide you with things like customized search results, or other features tailored to how
you use our Service. We also use algorithms to recognize patterns in data.

We’ll ask for your consent before using your information for a purpose that isn’t covered in this Privacy Policy.

Winnin can use cookies, web beacons (web bugs) or similar technology for the purposes above mentioned, and
User can configure his browser to accept all cookies, reject them or notify when a cookie is set. However, if the
User rejects all cookies, the User may not be able to use Winnin Insights in its entirety. Winnin also uses local storage, such as browser web storage or applications data caches, databases and servers logs in the treatment of
the Personal Information.

By using the Service, the User expressly agrees and accepts that the User’s Information collected by Winnin Inc.
may be stored in its database, processed and transferred to third parties and territories for the purpose of
customizing the User experience and improving Winnin Insights platform, until the User cancels their
subscription to use the Service. In that case, Winnin Inc. may keep User’s Information for Three years from the
cancelation of the Winnin Insights subscription.

Winnin Inc collects technical information from customers, content and any other information received from
Users or any other third parties through interaction with Winnin Insights platform. The User can obtain a copy
of the content in your profile and change the Personal Information informed in its registration at any time by
requesting such change to dpo@winnin.com. Also, in order to delete the account, you must notify Winnin Inc.
by dpo@winnin.com, and the use and storage of User’s information will be discontinued and discarded from
Winnin Inc’s. proprietary systems, in compliance with applicable legislation and within three years.

Winnin shares Personal Information with third-party service providers, who work on our behalf for the purposes
described in this Privacy Policy, and with User’s consent or as necessary to comply with the laws or respond to
lawful requests and legal process. These third-party service providers are listed below:

●   Amazon Web Services - Cloud computing web services that help Winnin Inc. strengthen the security of
Winnin Insights with encryption.
●   Hubspot - Platform that helps Winnin Inc. with e-mail flows and with regard to marketing and sales
teams.
●   Google Drive - Cloud computing web service that allows Winnin Inc to save files online and access
them anywhere;
●   Mixpanel - Helps Winnin Inc. to group all events performed by users, allowing the visualization of the
timeline related to each one of them, individually;
●   D4sing – Website that helps managing documents and signatures;
●   Slack – Business communication platform;
●   Hotjar – Data analysis tool that provides infor`mation about user behavior on the site.
●   Monday – Task organization and management platform.
●   Intercom – Platform that helps Winnin Inc. communicate with its customers on Winnin Insights.

Where User have consented to Winnin Inc’s processing of his or her data, User may withdraw that consent at
any time by contacting dpo@winnin.com with the subject “Withdraw Consent”, informing the specific consent
that the User would like to withdraw. Please note that if User decides not to provide Winnin Inc. with User’s
Information, User may not be able to access the Service or certain features of Winnin Insights.

Winnin Inc. may take certain steps to verify requests submitted using information available to us, including
User’s email address and any information associated with User’s account. Personal Information provided to
Winnin for verification will only be used to verify and maintain records regarding User’s request.

Information provided by Users and collected will be protected in accordance with strict confidentiality
standards. The security of your Personal Information is very important to us, and we do our best to protect it in
several ways, including the use of commercially acceptable means. While we strive to take due care using best practices and recommendations, we cannot guarantee that all technologies involved are free of security flaws due
to the technologies’ constant evolution.

Winnin Inc. will not disclose, sell or rent the User’s Information collected to third parties, except as provided in
this Privacy Policy. Winnin Inc. may send User’s Information capable of identifying the User to third parties in
the following cases: (i) with your consent; (ii) when necessary to provide the product or service requested or
authorized by User; (iii) Winnin Inc. trusted businesses or persons for any of the purposes described above; and
(iv) to third parties to comply with any applicable law, Court order, governmental request, or to detect, prevent
or address any form of technical, fraud or security issues, protect rights, the property or the security of the
Winnin Inc., Winnin Insights , its Users or third parties, as requested or permitted by law, as well as to enforce
applicable Terms of Service, including investigation of potential violations.

The User’s Information eventually collected by Winnin Inc. is limited to staff, agents, employees and service
providers (“Staff”) under contract with Winnin Inc., who need to be aware of these User’s Information in order
to process it on behalf of Winnin Inc. and help with our business operations. That means we limit the amount of
people that have access and we make sure that User’s Information can only be read, copied, modified or
removed by properly authorized Staff. We monitor internal activity to ensure the safety and accuracy of User’s
Information. Winnin Inc. Staff is required to conduct themselves in a manner consistent with the company’s
guidelines regarding confidentiality, ethics, and appropriate usage of User’s Information, including being
subjected to confidentiality agreements.

Unless otherwise stated, the third parties indicated by Winnin Inc. will not be entitled to use User’s Information
submitted beyond what is necessary to fulfill the needs of Winnin Inc, and will be subjected and in compliance
to our Privacy Policy, instructions and any other appropriate confidentiality and security measures.

The User acknowledges and agrees that the Service may provide links to other sites which may collect
personally identifiable information from the User. The User acknowledges and agrees that Winnin Inc. is not
responsible for the privacy practices of other websites and encourages the User to carefully read the privacy
statements of each and every website that collects personally identifiable information, as listed below:

YouTube
Facebook
Instagram
Twitch

This Privacy Policy applies only to information collected and processed by Winnin Inc. This Privacy Policy
doesn’t apply to services that have separate privacy policies that do not incorporate this Privacy Policy.

If Winnin is involved in a merge, acquisition, sale of assets, or if all or substantial portions of our assets are
acquired by another company, your information will likely be disclosed to our advisers and any other
prospective purchaser’s advisers and will be one of the assets that is transferred to the new owner. Nonetheless,
we’ll continue to ensure the confidentiality of your User’s Information and give affected Users notice before
User’s Information is transferred or becomes subject to a different privacy policy.

We maintain servers around the world and your information may be processed on servers located outside of the
country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this
policy.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We
work with the appropriate regulatory authorities, including local data protection authorities, to resolve
complaints regarding the transfer of your data that we cannot resolve with you directly.

In attention to privacy regulations, User’s Information may be deleted, if requested by the User. However, it may
happen that the data needs to be kept for a longer period, due to law, court order, fraud prevention, credit
protection and other legitimate interests. After the legal term required, the data will be excluded using safe
disposal methods.

This Privacy Policy can be modified from time to time by Winnin Inc. We will not reduce your rights under this
Privacy Policy without your explicit consent. The changes will be in force automatically on the date of
publication of the new version on Winnin Insights. If changes are significant, we’ll provide a more prominent
notice (including, for certain services, email notification of Privacy Policy changes). In order to continue the
access to Winnin Insights after the changes come into effect, the User must agree and accept the Privacy Policy
last version.