Privacy Policy

This Privacy Policy explains how Ninth Holdings LLC (“Company,” “we,” “us,” or “our”) collects, uses, and shares information about you when you use the Winner, Baby website, applications, and related services (the “Service”). By using the Service, you agree to the practices described in this Policy.

1. Information We Collect

We collect the following categories of information:

• Information you provide. Account details such as your email address and password, a display name or nickname you choose, an optional email address you provide when joining an event, and any content you create within the Service (such as questions, choices, and answers).
• Information collected automatically. Log and usage data such as your IP address, browser type, device information, pages viewed, and the dates and times of your interactions.
• Cookies and similar technologies. We use cookies and similar technologies to keep you signed in, remember your preferences, and understand how the Service is used.

2. How We Use Information

We use the information we collect to:

• Provide, operate, maintain, and improve the Service;
• Create and manage accounts and authenticate users;
• Communicate with you, including sending service-related and transactional messages;
• Monitor and analyze usage and trends to improve user experience;
• Detect, prevent, and address security incidents, fraud, and abuse;
• Comply with legal obligations and enforce our terms.

3. Legal Bases for Processing

Where applicable law (such as the GDPR) requires it, we process personal data on the following legal bases: performance of a contract with you, our legitimate interests in operating and improving the Service, your consent (which you may withdraw at any time), and compliance with legal obligations.

4. How We Share Information

We do not sell your personal information. We may share information:

• With service providers who perform services on our behalf, such as hosting, analytics, and email delivery, under obligations of confidentiality;
• With other participants in an event you join, to the extent necessary to operate the event (for example, your display name and score may appear on a leaderboard);
• To comply with the law, a legal process, or a lawful government request;
• To protect the rights, property, or safety of the Company, our users, or others;
• In connection with a merger, acquisition, or sale of assets, subject to this Policy.

5. Data Retention

We retain personal information for as long as necessary to provide the Service and for legitimate business or legal purposes, after which we delete or anonymize it. The specific retention period depends on the nature of the information and the reasons it was collected.

6. Security

We implement reasonable administrative, technical, and physical safeguards designed to protect your information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7. Your Rights and Choices

Depending on where you live, you may have the right to access, correct, delete, or port your personal information, to object to or restrict certain processing, and to withdraw consent. Residents of California (under the CCPA/CPRA) and the European Economic Area or United Kingdom (under the GDPR) may have additional rights. To exercise any of these rights, contact us using the details below. We will not discriminate against you for exercising your rights.

8. Children’s Privacy

The Service is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided us with personal information, please contact us and we will take appropriate steps to delete it.

9. International Data Transfers

We may process and store information in the United States and other countries that may have data-protection laws different from those in your jurisdiction. Where required, we take steps to ensure your information receives an adequate level of protection.

10. Third-Party Links

The Service may contain links to third-party websites or services that we do not operate. This Policy does not apply to those third parties, and we encourage you to review their privacy policies.

11. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will provide notice through the Service or by other reasonable means and update the “Last updated” date above.

12. Contact

If you have questions about this Policy or our privacy practices, contact us at [email protected].