WinRoulette, as the data controller of users' personal data, welcomes you to the information page regarding the protection of "Privacy and User Rights".

With reference to the provisions of Legislative Decree no. 196 of June 30, 2003, containing provisions for the protection of confidentiality in the processing of personal data, we hereby wish to inform you that:

• the personal data provided by you, or otherwise acquired within the scope of our activity, may be subject to processing using the Information System with or without the aid of electronic means in compliance with the aforementioned legislation for the institutional purposes of our company and in particular for:
  - executing a service or one or more contractually agreed operations
  - the fulfillment of obligations provided for by laws or regulations
  - the protection of our rights in court
• the provision of your data to our company (WinRoulette) is strictly functional to the execution of the contractual relationship
• in relation to the processing of data by us, you have the right to exercise the rights of Legislative Decree no. 196/03 reported below
• the data will be kept for the time prescribed by law
• the processing of data provided or otherwise acquired within the scope of our activity may also be carried out by subjects who are granted the right to access your personal data by law or secondary and/or EU regulations

Legislative Decree no. 196 of June 30, 2003, EU Regulation 2016/679 GDPR (General Data Protection Regulation) rights of the data subject:

• In relation to the processing of personal data, the data subject has the right:
  a) to know, through free access to the register referred to in Article 31, paragraph 1, letter a), the existence of data processing that may concern them;
  b) to be informed about what is indicated in Article 7, paragraph 4, letters a), b) and h);
  c) to obtain, from the controller or the processor, without delay:
  1. confirmation of the existence or non-existence of personal data concerning them, even if not yet registered, and the communication in an intelligible form of the same data and their origin, as well as the logic and purposes on which the processing is based; the request can be renewed, unless there are justified reasons, with an interval of no less than ninety days;
  2. the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those for which conservation is not necessary in relation to the purposes for which the data were collected or subsequently processed;
  3. the updating, rectification or, if interested, the integration of data;
  4. certification that the operations referred to in numbers 2) and 3) have been brought to the attention, also as regards their content, of those to whom the data were communicated or disseminated, except in the case where such fulfillment proves impossible or involves a use of means clearly disproportionate to the protected right;
  d) to object, in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of the collection; e) to object, in whole or in part, to the processing of personal data concerning them provided for the purpose of commercial information or the sending of advertising material or direct selling or for carrying out market research or interactive commercial communication and to be informed by the controller, no later than the moment in which the data are communicated or disseminated, of the possibility of exercising this right free of charge.
• For each request referred to in paragraph 1, letter c), number 1), the data subject may be asked, where the existence of data concerning them is not confirmed, for a fee contribution, not exceeding the costs actually incurred, according to the methods and within the limits established by the regulation referred to in Article 33, paragraph 3
• The rights referred to in paragraph 1) relating to personal data concerning deceased persons can be exercised by anyone who has an interest
• In exercising the rights referred to in paragraph 1), the data subject may grant, in writing, a proxy or power of attorney to individuals or associations
• The rules on professional secrecy of those practicing the profession of journalist remain firm, limited to the source of the news.

Processing Methods

The Controller (WinRoulette) processes Users' Personal Data by adopting appropriate security measures aimed at preventing unauthorized access, disclosure, modification, or destruction of Personal Data.

The processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Controller, in some cases, categories of appointees involved in the organization of the site (administrative, commercial, marketing, legal staff, system administrators) or external subjects (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Controller, may have access to the Data.

Purposes of Processing

User Data is collected to allow the Controller to provide its services, as well as for the following purposes: Statistics, Advertising, Hosting and backend infrastructure, Interaction with social networks and external platforms, and Displaying content from external platforms.

The types of Personal Data used for each purpose are indicated in the specific sections of this document.

In particular, Navigation Data is processed exclusively:

• for the operational management of navigation;
• for the processing of statistical data on access and consultation;
• for the management of Data security.

As for the Personal Data provided voluntarily by the User, they are processed for the following purposes, in addition to those indicated below:

• for the processing of anonymous and aggregate usage statistics;
• protection or defense of rights in court;
• fulfillment of obligations provided for by current laws or regulations, including accounting and tax matters;
• fulfillment of the specific purposes for which such Data were provided by the User (e.g. provision of a service, response to specific queries submitted via contact forms, assistance requests etc.);
• management of User registration and/or access to any restricted areas available on the site;

In order to pursue the processing purposes described above, WinRoulette uses the following services, listed by processing purpose.

• Hosting and backend infrastructure
  This type of service has the function of hosting data and files that allow WinRoulette to function, allow their distribution, and provide a ready-to-use infrastructure to deliver specific WinRoulette features.
• Interaction with social networks and external platforms
  This type of service allows interactions with social networks, or other external platforms, directly from the pages of WinRoulette.

Advertising
This type of service allows the use of User Data for commercial communication purposes in various forms of advertising, such as banners, videos, etc.  This does not mean that all Personal Data is used for this purpose. Data and terms of use are indicated below.

• Statistics
  The services contained in this section allow the Data Controller to monitor and analyze traffic data. WinRoulette uses this service to perform aggregate analyses on its Users in anonymous form and, thus, improve the performance of the WinRoulette site.
  All statistical services are used by WinRoulette through an integration that anonymizes the User's IP address.
• Displaying content from external platforms
  This type of service allows you to view content hosted on external platforms directly from the pages of WinRoulette and interact with them. In the event that a service of this type is installed, it is possible that, even if Users do not use the service, it may collect traffic data relating to the pages where it is installed.

Rights of the Data Subject

The User, as a data subject, may contact the Controller (WinRoulette) at any time, without any formality, to assert their rights, as provided for by Article 7 of the Privacy Code, which for the User's ease of reading is reported below in its entirety:

1. The data subject has the right to obtain confirmation of the existence or non-existence of personal data concerning them, even if not yet registered, and their communication in an intelligible form.

2. The data subject has the right to obtain indication of:

• the origin of the personal data;
• the purposes and methods of processing;
• the logic applied in case of processing carried out with the aid of electronic tools;
• the identification details of the controller, the processors and the designated representative pursuant to Article 5, paragraph 2 (of the Privacy Code);
• the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of it in their capacity as designated representative in the territory of the State, processors or persons in charge.

3. The data subject has the right to obtain:

• the updating, rectification or, when interested, integration of the data;
• the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those for which conservation is not necessary in relation to the purposes for which the data were collected or subsequently processed;
• certification that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data were communicated or disseminated, except in the case where such fulfillment proves impossible or involves a use of means clearly disproportionate to the protected right.

4. The data subject has the right to object, in whole or in part:

• for legitimate reasons to the processing of personal data concerning them, even if pertinent to the purpose of the collection;
• to the processing of personal data concerning them for the purpose of sending advertising material or direct selling or for carrying out market research or commercial communication.

Cookies

To make this site work well, we sometimes install small data files called "cookies" on your device. Most large sites do the same.

What are cookies?

A cookie is a small text file that sites save on your computer or mobile device while you visit them. Thanks to cookies, the site remembers your actions and preferences (e.g., login, language, font size, and other display settings) so that you don't have to re-enter them when you return to the site or navigate from one page to another.

How do we use cookies?

On some pages we use cookies to remember:

• display preferences, e.g., contrast settings or font size
• if you have already responded to a pop-up survey on the usefulness of the content found, to avoid proposing it again
• if you have authorized the use of cookies on the site.

In addition, some videos embedded in our pages use a cookie to process statistics, anonymously, on how you arrived at the page and what videos you watched.

It is not necessary to enable cookies for the site to work, but doing so improves navigation. It is possible to delete or block cookies, however, in this case, some functions of the site might not work correctly.

Information regarding cookies is not used to identify users and navigation data always remains under our control. These cookies are used exclusively for the purposes described here.

How to control cookies?

You can control and/or verify cookies as you wish—to find out more, go to aboutcookies.org. You can delete cookies already present on your computer and set most browsers to block their installation. If you choose this option, however, you will have to manually change some preferences every time you visit the site and it is possible that some services or certain functions may not be available.

In your browser, you can set privacy preferences so as not to store cookies, delete them after each visit or every time you close the browser, or even accept only cookies from WinRoulette.net and not those from third parties; there is also a service, Your Online Choices, which shows you which cookies are installed by various services and how you can deactivate them, one by one.

The data controller (you can find the references and contact details at the bottom of this page) will never give your email address to anyone else, for any reason (unless you give permission to do so).

That’s all for privacy on WinRoulette, we hope it was of interest to you. Personally, we prefer other pages on the sites, but obviously this one has its importance!

CONTACTS

In case of questions related to our Privacy Policy or in case of doubts about privacy or data use that we have not resolved satisfactorily, please contact our privacy team: info@winroulette.net