Privacy Policy

Winly Technologies Ltd (company number 17217900, registered in England and Wales, registered office at 2nd Floor, College House, 17 King Edwards Road, Ruislip, London, HA4 7AE, United Kingdom) is the controller of your personal data when you use the Winly platform at winlyonline.com.

We collect the following categories of personal data:

• Account data: your mobile phone number, name, optional email, language preference, and any profile photo you upload.
• Transaction data: the sales recorded against your phone number by Providers, including the amount, the Provider, the time, the cashback percentage applied, and the cashback amount earned.
• Game data: the picks you submit, when you submitted them, and the outcomes.
• Payout data: the cashback amounts you have been credited with, the payout phone number you provide so we can send your cashback to you, and the status of each payout.
• Identity verification data: where we are required to verify your identity before a payout, the documents and checks that our identity partner performs. We hold the outcome of the check and the minimum identity data needed to act on it; the documents themselves are held by our identity partner.
• Location data (optional): if you give your permission, we use your approximate location to surface nearby Providers. You can revoke this at any time in your device settings.
• Communications: when you contact support, we keep a record of the message and our reply.
• Technical data: device, browser, IP address, language, time of access, and operational logs needed to run and secure the service.

We do not knowingly collect data from children under 18. If you believe a minor has registered, tell us and we will close the account.

We use your data to:

• create and maintain your account;
• attribute sales recorded by Providers to the right account so you can earn cashback;
• run the prediction game and resolve outcomes fairly;
• send your cashback to you when your pick wins;
• send you notifications related to your account (sale confirmed, pick invitation, pick reminder, win notification, payout sent);
• detect, prevent, and investigate fraud and abuse of the platform;
• comply with our legal, regulatory, tax, and accounting obligations;
• improve the platform (aggregated and de-identified usage analysis).

Depending on the activity, we rely on one of the following: the performance of our contract with you (these Terms), our legitimate interests in running and protecting the platform, your consent (for example, for optional location use or marketing), and compliance with a legal obligation.

We share the minimum personal data needed with the following categories of partners, and only for the purposes set out here:

• Providers: when you make a purchase, the Provider sees your phone number, your name, and the sales recorded against you at their venue. They do not see your full transaction history elsewhere or your picks.
• Payout partners: to send your cashback to you, we share the minimum data needed (your name, the payout phone number you provided, and the amount) with the partner that delivers the payout.
• Messaging providers: Twilio (SMS and WhatsApp messages), Meta (WhatsApp delivery), and Postmark (email) deliver the notifications listed above.
• Identity verification partner: when an identity check is required, we use a regulated identity provider that processes your documents to confirm your identity.
• Hosting and infrastructure: Hetzner (servers), Cloudflare (CDN and file storage), and Neon (database) host the platform.
• Error and operational monitoring: Sentry helps us detect technical errors. We strip personal data from error reports where we reasonably can.
• Law enforcement and regulators: where we are legally required to disclose data, or where it is necessary to protect rights or the safety of users.
• Professional advisors and successors: lawyers, auditors, and (in the case of a merger, acquisition, or sale) the acquiring party, under appropriate confidentiality terms.

We do not sell your personal data. We do not allow our partners to use it for their own marketing.

Some of our partners process data outside Lebanon and the United Kingdom. Where we transfer personal data internationally, we rely on the safeguards permitted under applicable law, including standard contractual clauses with the partner.

We keep account, transaction, payout, and game data for as long as your account is active and for a reasonable period afterwards so we can meet legal obligations, resolve disputes, and enforce our agreements. Operational logs are kept for a shorter period (typically up to 12 months) and then deleted or aggregated. Identity-verification outcomes are kept for the period required by the laws that apply to us.

You have the right to access your personal data, to ask us to correct inaccurate data, to ask us to delete data we no longer have a reason to keep, to object to certain processing, and to ask for a copy of your data in a portable format. To exercise any of these rights, write to support@winlyonline.com from the email or phone we have on file. We may need to verify your identity before acting on a request.

If you are not happy with our response, you have the right to complain to your local data-protection authority.

We protect your data with the controls you would expect of a modern platform: encrypted connections, encrypted storage, tightly scoped access for our team, multi-factor authentication on administrative accounts, and continuous monitoring. No system is perfect; please tell us at once if you believe your account has been compromised.

We use a small number of cookies and local-storage entries that are needed to keep you signed in, remember your language and location, and run anti-abuse checks. We do not use third-party advertising cookies. You can clear cookies in your browser at any time; if you do, you may need to sign in again.

We may update this policy. If a change materially affects how we use your data, we will tell you in the app or by message. The "Last updated" date at the top of this page always reflects the current version.

Privacy questions go to support@winlyonline.com. Postal mail can be sent to our registered office in section 1.