Privacy Policy

WinSocial, LLC (“WinSocial,” “we,” “us,” or “our”) is a marketing and social selling services company serving the mortgage and real estate industries. This Privacy Policy explains what personal information we collect, how we use and share it, how long we keep it, and the choices available to you.

This policy applies to our website, our newsletters and marketing communications, our training and cohort programs, and our business relationships with clients and prospective clients. It also describes, at a high level, how we handle information belonging to our clients when we deliver services to them.

This policy does not apply to the privacy practices of our clients, or to third-party platforms such as LinkedIn, whose own policies govern their handling of your information.

2.1 Information you provide to us

• Contact details, such as your name, email address, telephone number, company, and job title, when you contact us, request information, subscribe to a newsletter, or register for a program.

• Program and account information when you enroll in a cohort, course, or coaching program, including the information needed to deliver and support that program.

• Payment information when you purchase a program. Payments are processed by third-party payment providers; we receive confirmation of payment and limited transaction details, and we do not store full payment card numbers.

• Content and correspondence you send us, including emails, messages, survey responses, and materials you submit as part of a program.

2.2 Information collected automatically

When you visit our website, Lovable collects cookie-free visitor analytics for us, including technical and usage information described in Section 4. This analytics does not keep IP addresses or identify visitors.

2.3 Information we receive from clients

When we deliver services to a business client, that client may provide us with information needed to perform the work. For social media management engagements this may include account access credentials and materials the client wishes us to publish.

We handle this information on the client's behalf and in accordance with our agreement with that client. We do not use it for our own purposes, and we do not sell, rent, or disclose it. Our handling of client credentials and client confidential information is governed by our written Information Security Policy and by the confidentiality and information security agreements executed by every WinSocial worker.

We use personal information to:

• Provide, deliver, and support our services and programs;

• Respond to inquiries and communicate with you about your relationship with us;

• Send newsletters, educational content, and marketing communications, which you may opt out of at any time;

• Process transactions and maintain business and financial records;

• Operate, maintain, secure, and improve our website and services;

• Comply with legal obligations and enforce our agreements; and

• Protect the rights, property, and safety of WinSocial, our clients, and others. We do not use client-provided information, including account credentials, for marketing or for any purpose other than performing the contracted services.

Our website uses Lovable’s visitor analytics. It uses no cookies, stores nothing on your device, does not keep IP addresses, and does not identify visitors.

It records pages visited, where visitors came from, country, browser, operating system and device type, time on the site, page load speed, errors, and clicks on buttons and links. The site also reports technical errors to Lovable.

Clicks are recorded for every visitor without a consent banner. Page visits, time on page, page speed and errors are also recorded for every visitor, without cookies and without identifying anyone.

Lovable collects this data for us. Lovable's privacy policy explains how it handles it. Detailed data is kept for 90 days and daily summaries for a year.

The current website does not use sign-in, advertising pixels, embedded third-party media, or a cookie-preference banner. The enquiry form holds your entries in memory while you complete it, rather than saving them in browser storage.

When you submit an enquiry, your name, email address, selected service and message are processed through Lovable’s email delivery service and sent to hello@winsocial.com in our Google Workspace mailbox. If you choose the email-draft fallback, your email provider handles that message instead. These providers process and store correspondence in order to deliver and retain it.

The site loads fonts from Google Fonts. Your browser connects to Google to request those fonts, sharing technical request information such as your IP address and browser information with Google.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising.

We disclose personal information only as follows:

• Service providers. We use third-party providers to operate our business, including cloud productivity and file storage, customer relationship management, internal communication, project management, credential management, payment processing, email delivery, and course and program hosting. These providers may process personal information on our behalf and are permitted to use it only to provide services to us.

• Clients. Where we perform services for a business client, information relating to that engagement is shared with that client.

• Professional advisers. Accountants, attorneys, insurers, and similar advisers, bound by professional duties of confidentiality.

• Legal requirements. Where required by law, subpoena, court order, or to establish, exercise, or defend legal claims.

• Business transfers. In connection with a merger, acquisition, financing, or sale of all or part of our business, subject to this policy continuing to apply to the transferred information. We do not disclose client confidential information or client account credentials to any third party other than the service providers identified in our Information Security Policy as approved systems.

WinSocial engages independent contractors located outside the United States, including in the Philippines, who perform content production and design work. Contractors are engaged only on work for which they have been

specifically authorized, access is provisioned on a least-privilege basis and recorded per individual, and every contractor executes a written confidentiality and information security agreement before access is granted.

Contractors performing services outside the United States are contractually required to disclose their country of performance, may not transfer or store information in any other jurisdiction without our written consent, and may have access withdrawn at any time to comply with a client requirement regarding offshore access. We do not provide offshore contractors with access to client account credentials or to any nonpublic personal information.

We retain personal information for as long as needed for the purposes described in this policy, and thereafter as required to comply with legal, tax, accounting, and recordkeeping obligations or to resolve disputes.

Marketing contact information is retained until you unsubscribe or ask us to delete it. Program and customer records are retained for the duration of the relationship and for a reasonable period afterward. Client work product and client-provided information are retained in accordance with the client's contract and are deleted at the end of the engagement, or within the period that contract specifies.

WinSocial maintains a written Information Security Policy that applies to every worker and to every system used to conduct our business. It sets requirements for data classification, access provisioning and quarterly access review, multi-factor authentication, credential storage in a password manager, device encryption and endpoint protection, restrictions on third-party and artificial intelligence tools, retention and destruction, and security incident response with reporting required within 24 hours.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. We will notify affected clients and, where required, affected individuals and regulators, of a security incident in accordance with applicable law and our contractual obligations.

Depending on where you live, you may have the right to request access to the personal information we hold about you, to request correction of inaccurate information, to request deletion, to opt out of marketing communications, to opt out of the sale or sharing of personal information, and not to be discriminated against for exercising these rights.

9.1 California residents

If you are a California resident, you have the rights described above under the California Consumer Privacy Act as amended. We do not sell personal information and we do not share personal information for cross-context behavioral advertising. We do not knowingly collect or process sensitive personal information for purposes of inferring characteristics.

9.2 Residents of other states

Residents of other states with comprehensive privacy laws may have comparable rights. We honor verifiable requests from residents of those states on the same basis.

9.3 How to exercise your rights

To make a request, email dan@winsocial.com with the nature of your request. We will verify your identity before acting, which may require you to confirm information we already hold. We will respond within the period required by applicable law. You may designate an authorized agent to act on your behalf, subject to verification.

Where we process personal information on behalf of a business client as a service provider, requests relating to that information should be directed to the client. We will refer such requests to the client and support them in responding.

Our website and services are intended for business professionals. We do not knowingly collect personal information from children. If we learn that we have collected information from a child, we will delete it.

Our website and content may link to third-party websites and platforms, including LinkedIn and other social media services. We are not responsible for their privacy practices, and their own policies govern your use of them.

We may update this policy from time to time. The effective date at the top of this policy indicates when it was last revised. Material changes will be indicated by updating that date and, where appropriate, by additional notice.

Questions, requests, or complaints regarding this policy may be directed to:

WinSocial, LLC Email: dan@winsocial.com Attention: Dan Smokoska, Founder

This document is a starting template prepared for WinSocial, LLC. It is not legal advice. Have it reviewed by a licensed attorney before publication, particularly Sections 5, 6, and 9, and confirm that the service providers and data practices described match what the Company actually does. State privacy laws change frequently and vary by jurisdiction.