Privacy Policy

What Wins Inc. (“we”/”us”) provides a variety of resources relating to horse racing (the “Services”) available through the website, www.whatwins.com (the “Website”).  This Privacy Policy describes how we collect, store, use and distribute information about our users. 

Consent
By using the Website and/or the Services you consent to the use of your Personal Information (as defined below) in accordance with this Privacy Policy.  Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent.  You may withdraw your consent to our processing of your Personal Information at any time.  However, withdrawing consent may limit your ability to continue using some of the Website and Services.

Information We Collect
This Privacy Policy applies to Personal Information which we collect primarily through the registration process, communication with you, information downloads, product or service purchases, user support and surveys.  "Personal Information" means personally identifiable information, such as your name, address, e-mail address, credit card information, birth date and gender. 

This Privacy Policy does not extend to the collection, use or disclosure of the following information which is currently not limited by applicable privacy laws: (a) business information and information that is publicly available, such as names, addresses, telephone numbers and electronic address when listed in a directory or made available through directory assistance; or (b) Non-Personal Information.  "Non-Personal Information" is information of an anonymous nature, such as an Internet Protocol Address (IP Address), the domain used to access the Website, and the type and version of browser or operating system being used by visitors to the website.  Aggregate information, such as demographic statistics of our users (e.g. average age or geographical location of our users), number of visitors, what pages users access or visit, and average time spent on the Website.  Although the use of certain Non-Personal Information collected or derived by us in the course of operating the Website is not restricted, we provide information about the collection of such information for the sake of transparency.  For example, our web servers may automatically collect Non-Personal Information that is provided through your browser or stored in a cookie when you visit the Website.

Why We Collect Information
We aim to collect, use and disclose only such information as is required to enable us to manage your subscription and account, to provide the Services, to maintain our customer/visitor lists, to respond to your inquiries or provide feedback.  We also collect, use and disclose information for identification and authentication purposes, for billing, marketing and advertising, for service improvement, for monitoring of the Website, to notify users of things we consider would be meaningful and for the purpose of building Watch Lists.  We do not actively collect Personal Information for the purpose of sale or marketing in a way that specifically identifies the individual, in other words we do not sell customer lists. 

Use of Information
As outlined in Why We Collect Information, we collect and use information for various purposes and by different means and wish to highlight the following to you:

• Registration:  In order to make use of certain Services such as building watch lists or receiving particular feeds, you must create an account for the Website.  To create an account you are required to provide certain information, such as your name, email and mailing addresses.  You will also be asked to choose a user name and password.  During the registration process, you will be given an opportunity to provide certain optional information.  This optional information may include: your gender, date of birth and personal preferences.  In general, none of your account registration information (apart from your name or user name) will be shared with any other users of the Website by us and will used only for the purposes for which we have collected it (subject to the exclusions and disclosures we have listed below), unless you agree that we may disclose it to other third parties.  If we plan to use your Personal Information in future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy.  See further the section of this Privacy Policy entitled ‘Amendment of this Policy’.

• Transactional Notifications: We also provide notifications for the activities you engage in on the Website such as unsubscribing, registration confirmations, notifications of new private messages, confirmation of account setting changes and notification of new contacts.  Despite your indicated e-mail preferences, we may send you notices of any updates to our Website Terms and Conditions http://www.whatwins.com/index.php/site/terms_service/ or this Privacy Policy.

• Statistics: we also collect statistics about which products and services are purchased through the website and the content of watch lists.  This information will be kept confidential, however, aggregate statistics that do not personally identify an individual will be kept by us and such aggregate statistics may be made available to third parties. 

• Cookies: Cookies are used by us to track content usage and traffic on the Website.  A cookie is a feature of your web browser that consists of a text file that is placed on your hard disk by a web server.  The Website uses cookies to help it compile aggregate statistics about usage of the Website, such as how many users visit the Website, how long users spend viewing the Website, geographic information and what pages are viewed most often.  This information is used to improve the content of the Website and Services.  You can set your browser to notify you when you are sent a cookie.  This gives you the chance to decide whether or not to accept it.  If you disable cookies, you may not be able to take advantage of all the features of the Website.  We do not link any of the information we use in cookies to any Personal Information submitted by you when you are on the Website.

• IP Addresses: Your IP address is reported by your web browser whenever you visit a page on the Website.  This information is recorded together with your registration information on our databases.  We use this to: diagnose problems and any issues reported by other users that are related to the IP addresses controlled by specific parties; gauge how many users are visiting the Website from different regions; trace the source of any malicious or illegal use of the Website and/or Services so that we can more easily respond to such usage.

• Advertisements:  Any advertisements appearing on this Website may be delivered to visitors or members by us or one or more third-party advertisers. These advertisers may set cookies. These cookies allow the advertisement server operated by that third party to recognize your computer each time they send you an online advertisement. Accordingly, advertisement servers may compile information about where or whether you viewed their advertisements and which advertisements you clicked on. This information allows web advertisers to deliver targeted advertisements that they believe will be of most interest to you.  The Privacy Policy applies to cookies placed on your computer by us, but does not cover the use of cookies by any third-party web advertisers.  For the privacy practices of such third-party web advertisers, you should consult the applicable privacy policy for the relevant third-party web advertiser(s).

Disclosures & Transfers
We put in place contractual and other organizational safeguards with our agents to ensure a proper level of protection of your Personal Information.  From time to time we may employ third parties to help us improve the Website and/or the Services. These third parties may have limited access to databases of Website user information or registered member information solely for the purpose of helping us to improve the Website and/or the Services and they will be subject to contractual restrictions prohibiting them from using the information about our members for any other purpose.

Important Exceptions
We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Website members, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities.  We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law.

We may also disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information.

Security
The security of your Personal Information is important to us.  We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment.  We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us.  You are also responsible for helping to protect the security of your Personal Information.  For instance, never give out your password, and remember to log out of your account and close your browser window when you have finished using the Website, so that other people using the same computer will not have access to your Personal Information.

Retention
We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you.  We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained personal information will remain subject to the terms of this Privacy Policy.  If you request that your name be removed from our databases, it may not be possible to completely delete all your Personal Information due to technological and legal constraints.

Amendment of this Policy
We reserve the right to change this Privacy Policy at any time.  If we decide to change this Privacy Policy in the future, we will post an appropriate notice on the home page at www.whatwins.com/index.php/site/Privacy.   Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted and any material changes will become effective 30 days from their posting on the Website.  Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you and your account.  The date on which the latest update was made is indicated at the bottom of this document.  We recommend that you revisit this policy from time to time to ensure you are aware of any changes.  Your continued use of the Website signifies your acceptance of any changes.

Access and Accuracy
You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information.  Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant information available to you such as where that information also pertains to another user.  In such circumstances we will provide reasons for the denial to you upon request.  We will endeavor to deal with all requests for access and modifications in a timely manner.

We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate.  As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information.  Having accurate Personal Information about you enables us to give you the best possible service.

Contact Us
You can help by keeping us informed of any changes such as a change of address or telephone number.  If you would like to access your information, if you have any questions, comments or suggestions of if you find any errors in our information about you, please contact us at .     

Date:   March 2011