Privacy Policy

Last updated: April 16, 2026

This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use the Service and explains Your privacy rights and how the law protects You.

By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

Words with the first letter capitalized have meanings defined under the following conditions. These definitions apply whether they appear in singular or plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service.

Affiliate means an entity that controls, is controlled by, or is under common control with a party.

Company (referred to as “the Company”, “We”, “Us”, or “Our”) refers to TOD Enterprise S.R.L, Str. Marchian 2, Botoșani, Romania.

Cookies are small files placed on Your device that store certain browsing or usage information.

Country refers to: Romania.

Device means any device that can access the Service such as a computer, mobile phone, or tablet.

Personal Data means any information relating to an identified or identifiable individual.

Service refers to the WINNR mobile application and related websites.

Service Provider means any natural or legal person who processes data on behalf of the Company.

Usage Data refers to data collected automatically when using the Service.

You means the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may collect personally identifiable information, which may include:

Email address

First and last name

Information You choose to provide while using the Service

Preferences and settings

This may include information related to Your activities, habits, or personal goals, depending on how You use the Service.

Some information You provide may be considered sensitive. We only collect and process such data as necessary to provide the Service.

Usage Data

Internet Protocol (IP) address

Device type and operating system

App usage data, session duration, and interactions

Crash logs and diagnostic data

Unique device identifiers

Tracking Technologies and Cookies

We may use Cookies and similar tracking technologies to:

Store user preferences

Analyze usage and improve performance

Ensure security and prevent fraud

You can manage cookie preferences through Your device settings. Disabling cookies may affect certain functionality.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide, operate, and maintain the Service

To personalize Your experience

To manage Your Account

To communicate with You, including notifications and updates

To monitor usage and improve the Service

To ensure security and prevent misuse

To comply with legal obligations

Sharing of Your Personal Data

We may share Your information in the following situations:

With Service Providers: to operate, host, analyze, and support the Service

For Business Transfers: in connection with a merger, sale, or acquisition

With Affiliates: under common ownership and subject to this Privacy Policy

With Authorities: when required by law or legal process

With Your Consent: for any other purpose You explicitly approve

Retention of Your Personal Data

We retain Personal Data only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required by law.

Transfer of Your Personal Data

Your information may be processed outside Your country of residence. We take reasonable steps to ensure that Your data is treated securely and in accordance with this Privacy Policy.

Your Privacy Rights

Depending on Your location, You may have the right to:

Access Your Personal Data

Request correction of inaccurate data

Request deletion of Your data

Restrict or object to processing

Request data portability

To exercise these rights, contact us at the email below.

Delete Your Personal Data

You have the right to request deletion of Your Personal Data.

You may do so by:

Using available in-app features (if applicable), or

Contacting us directly

You have the right to request deletion of Your Personal Data.

Security of Your Personal Data

We implement appropriate technical and organizational measures to protect Your Personal Data. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.

Children’s Privacy

The Service is intended only for individuals aged 18 or older. We do not knowingly collect Personal Data from individuals under 18. If we become aware that such data has been collected, we will delete it.

Links to Third-Party Websites

The Service may contain links to third-party websites. We are not responsible for their content or privacy practices.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes are effective when posted on this page with an updated “Last updated” date.

Contact Us

If You have any questions about this Privacy Policy, You can contact us:

Email: support@appwinnr.com