**Last Updated: 20 July 2024**

This Policy covers the Company's policies and practices regarding the User's collection, use and disclosure of information when using the Online Service. It also informs the User of their privacy rights and how the law protects them. The Company uses the Personal Information Users provide to provide and improve the Online Service. By using the Online Service, the User agrees to the collection and use of information in accordance with this Policy. The Policy complies with Articles 12, 13 and 14 of the GDPR and CCPA.

**I. DEFINITIONS**

According to this Policy:

• "User," It refers to any individual who has created an account on the Company's website and uses the Company's online service.

  
  

• "Device" means any device that can access the Website, such as a computer, mobile phone or digital tablet.

  
  

• "GDPR" refers to the general data protection standards concerning the processing of personal data and the free movement of personal data.

  
  

• "Website" refers to the Company's web platform for mobile devices or computers for users, accessible at www.winkoboost.com and is not associated with any other website, company, brand, organisation or similar named entity.

  
  

• "Empowerers" means the Company's employees, consultants, affiliates, subsidiaries and agents.

  
  

• "Online Service," refers to the Company's products and services and becomes accessible by creating an account on the Website. The User may receive the Online Service from both the Company and the Boosters.

  
  

• "Personal Data" refers to any information that can be used to identify a specific individual. This may include information such as a person's name, address, telephone number, e-mail address.

  
  

• "Processing" means any operation or set of operations performed on personal data or on sets of personal data, including collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, whether or not by automated means.

  
  

• "Company," Achievement Oriented Entertainment Pte. Ltd. - 7 TEMASEK BOULEVARD #12-07 SUNTEC TOWER ONE SINGAPORE (038987) refers to Registration Number 201820699H.

  
  

• "Usage Data," Refers to data collected automatically by the Online Service or its infrastructure (for example, visit duration, website paths and number of visits).

  **II. COLLECTION AND USE OF PERSONAL INFORMATION OF USERS AND/OR EMPOWEREES**

  
  

• Personal Data: When using the Company's website, the Company may ask both the User and the Boosters to provide personal information that can be used to contact or identify the User. Personal information may include, but is not limited to: Email address; first and last name of the User or Booster (when adding payment information); nationality of the User or Booster; identity card or passport (if required for identity verification); age of the User or Booster; billing address. The Company reserves the right, at any time and at its sole discretion, to ask Boosters or Users to verify their personal information, including identity verification documents.

  
  

  **III. DATA UTILISATION**

  
  

• Usage Data is collected automatically when the User visits the website. Usage Data may include information such as the pages the User or Boosters visit, the time and date of the visit, the time spent on those pages, unique device identifiers and other diagnostic data.

  When the User or Boosters access the website using a Device, the Company may automatically collect certain information: the type of device used; the unique identifier of the device; the operating system of the device; the type of internet browser used; and other diagnostic data.

  
  

  **IV. COOKIES AND TRACKING TECHNOLOGIES**

  
  

• The Company uses Cookies and other tracking technologies to monitor website traffic and store certain information. Beacons, tags and scripts are used as tracking technologies to collect and track information and to improve and analyse the website. The technology used by the Company may include: Browser Cookies or Cookies. A Cookie is a small file placed on the User's or Boosters Device. You can set the Browser to reject all Cookies or to warn when a Cookie is being sent. However, if the User or Boosters do not accept Cookies, they may not be able to access certain areas of the website. Cookies using Adobe Flash Player technology. Certain features of the website may use locally stored objects (or Flash Cookies) to collect and store the User's or Boosters' preferences or behaviour on the Online Service. Flash Cookies cannot be managed through the same browser settings as Browser Cookies. Web Beacon. Certain sections of the Website and the Company's emails may contain small electronic files (also known as clear gifs, pixel tags and single-pixel gifs) that allow the Company to perform actions such as counting users who have visited those pages or opened an email and other website statistics (for example, recording the popularity of a particular section and verifying system and server integrity). There are "Persistent" and "Session" cookies. Persistent Cookies remain on the User's or Boosters' personal Devices after they go offline, but Session Cookies are removed when the User or Booster closes the web browser. The Company uses both Session Cookies and Persistent Cookies for the following purposes:

  
  

  • Necessary/Basic Cookies: Session-based cookies are managed by the Company. These Cookies are necessary to provide the User and/or Boosters with the services accessible through the website and to enable the User and/or Boosters to use certain features. These

    Cookies help authenticate users and prevent the use of fake accounts. Without these Cookies, the services requested by the User cannot be provided and the Company uses these Cookies only to provide the User and/or Boosters with the requested services.

    
    

  • Cookie Policy / Notification Acceptance: Persistent Cookies are managed by the Company. These Cookies determine whether the user has accepted the use of cookies on the website.

    
    

  • Performance Cookies: Persistent Cookies are managed by the Company. These Cookies allow the User and/or Boosters to remember the preferences they made when using the website, for example the User's login details or preferred language. The purpose of these Cookies is to provide the User and/or Boosters with a more personalised experience and to prevent them from re-entering their preferences each time they use the website.

    
    

  • Advertising Cookies: Managed by the Company. The purpose of these cookies is to provide potential customers with the best advertising experience. They do not contain personal information and are based on the activity of the User and/or Boosters on the website.

    
    

    **V. PERSONAL DATA OF USERS AND/OR ENHANCERS

    
    

    USE OF**

    
    

• The Company may use Personal Data for the following purposes:

  
  

  • Providing and managing the website, including monitoring its use.

    
    

  • For the performance of a contract: The creation, fulfilment and execution of the product, service or any agreement purchased by the User and/or the Boosters.

    
    

  • To provide the User with news, special offers and general information about similar products, services and events that the User and/or Boosters have already purchased or enquired about, unless otherwise stated, unless they request to receive this information.

    
    

  • Manage user requests: Manage and respond to requests from Users and/or Boosters.

    
    

  • For business transfers: The Company may use the User's and/or Booster's information in a merger, assignment, restructuring, reorganisation, reorganisation, liquidation or other sale or transfer.

    
    

  • The Company may use the User and/or Booster's information for other purposes such as data analysis, identifying usage trends, determining the effectiveness of promotional campaigns, and evaluating and improving the website, products, services, marketing and User and/or Booster experience.

    
    

• The Company may share the Personal Information of the User and/or Booster in the following cases:

  • With service providers: The Company reserves the right to share the personal data of the User and/or Boosters with service providers for the purpose of monitoring and analysing the use of the website and communicating with the User and/or Boosters.

    
    

  • For business transfers: The Company may share or transfer the personal data of the User and/or the Booster in connection with or in the course of any merger, sale of the Company's assets, financing or acquisition of all or part of the Company's business by another company.

    
    

  • With affiliated organisations: The Company reserves the right to share the personal data of Users and/or Boosters with its affiliates, in which case it will require such affiliates to comply with this Privacy Policy. Affiliates consist of the Company's parent company and any subsidiaries, joint venture partners or other firms controlled by or under common control with the Company.

    
    

  • With business partners: The Company reserves the right to share personal data with its business partners for the purpose of providing certain products, services or promotions to the User and/or Booster.

    
    

  • With the User's Consent: The Company may share the personal information of the User and/or the Booster for any other purpose with the consent of the User and/or the Booster.

    
    

    **VI. STORAGE OF PERSONAL DATA OF USERS AND/OR ENHANCERS**

    
    

• The Company will retain the personal data of the User and/or the Booster only for as long as necessary to fulfil the purposes set out in this Privacy Statement. The Company will retain the User and/or Booster's personal data for as long as necessary to comply with the Company's legal obligations (for example, if we are required to retain the User and/or Booster's personal data under applicable law), resolve disputes and enforce our legal agreements and policies. Furthermore, the Company will retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, but this personal data may be retained when necessary to strengthen security or improve the functionality of our website, or when we are legally required to retain this data for a longer period of time.

  
  

  **VII. TRANSFER OF PERSONAL DATA OF USERS AND/OR ENHANCERS**

  
  

• The User and/or Booster's information, including personal data, is processed at the Company's operational offices and other locations where the parties involved in the transactions are located. This means that this information may be transferred to and stored on computers located outside the User and/or Booster's state, province, country or other government jurisdiction, where data protection rules may differ from those in the User and/or Booster's jurisdiction. The User and/or Booster's consent to this Privacy Policy means that they agree to such transfer after such information is provided. The Company will take all the steps reasonably necessary to ensure that User and/or Booster's personal data is treated securely and in accordance with this Privacy Policy and any transfer of User and/or Booster's personal data to any organisation or country will only take place where adequate controls are in place, which includes the security of User and/or Booster's personal data and other personal information.

  **VIII. DISCLOSURE OF PERSONAL DATA OF USERS AND/OR ENHANCERS**

  
  

• Business Transactions: The Company may transfer the personal data of the User and/or the Booster in connection with a merger, acquisition or asset sale. The Company will notify the User and/or the Booster before the personal data of the User and/or the Booster is transferred and subject to a different Privacy Policy.

  
  

• Law Enforcement: In certain circumstances, the Company may be required to disclose the User and/or Booster's personal data in response to legal requests (e.g., requests by a court or a government agency).

  
  

• Other Legal Requirements: The Company may disclose the personal data of the User and/or Booster in the following cases:

  
  

  • To comply with legal obligations.

    
    

  • To protect and defend the rights and property of the Company.

    
    

  • To prevent or investigate possible misbehaviour in relation to the Website.

    
    

  • To protect the safety of Users and/or Boosters of the Online Service and the general public.

    
    

  • Providing protection against legal liability.

    
    

    **IX. CHILDREN'S PRIVACY DATA**

    
    

• The Company's website is not designed for children under the age of 14. The Company does not knowingly collect personal information from children under the age of 14. If you are a parent or guardian and you become aware that your child has provided us with personal information, please contact us. If the Company learns that the Company has collected personal data from a child under the age of 14 without parental consent, the Company will take steps to delete such personal data from its servers and/or other storage media. Where the Company requires consent as a legal basis to process the User's and/or Booster's information and where the User's and/or Booster's country requires parental consent, the Company may seek the User's and/or Booster's parental consent before collecting and using such information.

  
  

  **X. SECURITY OF PERSONAL DATA OF USERS AND/OR ENHANCERS**

  
  

• The Company takes reasonable measures to protect the information received from the User and/or the Booster against accidental or unlawful destruction, loss, alteration, disclosure or access. The Company has implemented the necessary physical, technical and administrative measures and used privacy-enhancing technologies such as encryption to protect and secure the User and/or Booster's information. If you have any questions regarding the protection of your personal information, you may contact us at contact@winkoboost.com

  you can contact us.

  
  

  **XI. HYPERLINKS TO OTHER WEBSITES**

  
  

• The Company's website may contain links to third party websites. When the User and/or Boosters click on a link to a third party website, they will be directed to that website. The Company strongly advises Users and/or Boosters to review the Privacy Policies of each website they visit. The Company has no control over, and assumes no responsibility for, the content, privacy policies or practices of any third party websites or services.

  
  

  **XII. AMENDMENTS TO THIS CONFIDENTIALITY POLICY**

  
  

• The Company may change this Policy periodically. The Company will notify the User, Boosters and other third parties of any changes by posting them on this website. The Company has the right to change the Policy. The Company will notify the User, Boosters and other third parties by changing the "Last Updated" date at the top of this Policy. The User, Boosters and other third parties are encouraged to review this Policy frequently. Once posted on this page, changes to this Privacy Policy will become effective.

  
  

  **XIII. GDPR NOTIFICATION**

  
  

• The legal basis for the processing of personal data of the User and/or Boosters is Article 6, paragraph 1, points a), b), f) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR). The legitimate interest of the Company is to provide the Website to the User. Personal Data will be processed until the data processing objection or termination application is made or for a maximum period of ten (10) years. The User and/or the Boosters have the right to access, rectify, delete or restrict the processing of their personal data or the right to object to processing and the right to data portability and the right to lodge a complaint with the supervisory authority. The User and/or the Boosters have the right to withdraw their consent at any time when the collection and processing of their data is in accordance with Article 6(1)(a) of the GDPR. The Company is the data controller of the personal data of all categories of data subjects collected from the User and/or Booster. The Company acts as a data processor for all content except user logs, administrative user logs and some account settings information. If the Company acts as a data processor, it processes data in accordance with the User's data processing instructions.

  
  

  **XIV. INFORMATION FOR RESIDENTS OF CALIFORNIA**

  
  

• This section contains additional disclosures required by the California Consumer Privacy Act (CCPA). Please see "Categories of Personal Data Collected" in this Policy.

  table. For a list of personal information that the Company has been authorised to collect from California consumers in the past twelve months and for the Company's business and commercial purposes and categories of third parties with whom this information may be shared. For more information about the types of personal data the Company collects and uses, please see the "Collection and Use of Personal Data" section.

  
  

  • Categories of Personal Data Collected: Internet or other electronic network activities, browsing behaviour and information related to the User's and/or Boosters' use and interaction with the Company's website.

    
    

  • Parties with whom data may be shared: Third parties providing services to the Company, such as customer support, subscription and order fulfilment, advertising measurement, communications and surveys, data analysis, fraud prevention, cloud storage, error correction management and logging and payment processing. The Company's advertising and marketing partners, partners that assist in determining the popularity of content, sending advertisements and materials tailored to the User's and/or Boosters' interests, and better understanding the User's and/or Boosters' online activities.

    
    

  • The CCPA gives California users the right, with certain limitations and exceptions, to request more information about the categories of personal information collected and their specific information, to delete their personal information, to opt out of any "sale" of their personal information, and to not be discriminated against for exercising these rights. We do not "sell" the personal information we collect (and will not sell such information in the future) (and will not sell it in the future) (and will not sell it in the future). The Company permits its advertising partners to collect certain device identifiers and electronic network activity through the Company's Online Service in order to display advertisements targeted to the User's and/or Boosters' interests. The User and/or Boosters may opt-out by limiting ad tracking on the website by adjusting their Device settings. Users from California may make a claim by emailing contact@winkoboost.com. The Company will verify the User's and/or Booster's claim by asking the User and/or Booster to verify the information it has about the User and/or Booster to verify the User's and/or Booster's claim. Users and/or Boosters may appoint a representative to exercise these rights on their behalf. Authorised representatives must submit requests in the same manner, but the Company may require the representative to verify that the representative is authorised to act on the User's and/or Booster's behalf and also to verify the User's and/or Booster's identity directly with the Company.

    
    

    **XV. DISPUTE RESOLUTION**

    
    

• If you have an unresolved complaint regarding the company, privacy or data usage, please contact us at contact@winkoboost.com.

  
  

  **XVI. CONTACT**

  
  

• If you have any questions about our policy, please contact us by

  
  

  • By e-mail: contact@winkoboost.com