This Privacy Policy describes SmartWinnr’s practices regarding the collection, use and disclosure of the information we collect from and about you when you use SmartWinnr’s web-based and mobile applications (the “Service”). We take our obligations regarding your privacy seriously and have made every effort to draft this Privacy Policy in a manner that is clear and easy for you to understand. By accessing or using the Service, you agree to this Privacy Policy

1. Our Collection and Use of Information

1.1 Information You Provide to Us

We collect personal information, such as your name and email address, when you register for an account on the Service. You may also provide us with optional information such as a photograph. Your user name, email address and any optional profile information that you elect to associate with your account is referred to herein as your “Profile Information.” If you are a user of our paid premium service, we will utilize a third party credit card payment processing company to collect payment information, including your credit card number, billing address and phone number. We will share this payment information with the third party processing company as detailed below in “How We Share Your Information: With Trusted Service Providers and Business Partners.” We do not store your payment information. We may use your email address to send you Service-related notices (including any notices required by law, in lieu of communication by postal mail). We may also use your email address to send you announcements and information about other products or services (including third party services) that you may be interested in (together, the “Marketing Messages”). You may opt-out of receiving Marketing Messages at any time by following the instructions provided in the Marketing Message. Through your account interface, you may also opt-out of receiving categories of Service-related notices that are not deemed by SmartWinnr to be integral to your use of the Service. Even if you are not a registered user of our Service, if you email us we may retain a record of such email communication, including your email address, the content of your email, and our response.

1.2 Your Content

Your use of the Service will involve you uploading or inputting various content into the Service; including but not limited to: questions, quizzes, smartfeeds and knowledge categories (together, the “Content”). You control how your Content is shared with others via your settings on the Service. SmartWinnr may view your Content only as necessary (i) to maintain, provide and improve the Service; (ii) to resolve a support request from you; (iii) if we have a good faith belief, or have received a complaint alleging, that such Content is in violation of our Acceptable Use Guidelines; (iv) as reasonably necessary to allow SmartWinnr to comply with or avoid the violation of applicable law or regulation; or (v) to comply with a valid legal subpoena or request that meets the requirements of our Law Enforcement Guidelines.

1.3 Information We Collect Automatically

Log Files
When you use the Service, our servers automatically record certain information in server logs. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type and settings, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, date and time stamp information and other such information. Log files help us to monitor, analyze, improve and maintain the Service and to diagnose and fix any Service-related issues.
Device Token
When you access the Service using a mobile device and opt for push notification services, we collect the device token which is required to properly maintain push notification services.

1.4 Our Cookie Policy

SmartWinnr uses technologies like cookies to provide the Service. For example, a cookie is used to remember your user name when you return to the Service and to improve our understanding of how you interact with the Service. You can block cookies on your web browser; however please be aware that some features of the Service may not function properly if the ability to accept cookies is disabled.

2. How We Share Your Information

We may share the information we collect from you with third parties as detailed below.

2.1 As Directed By You

We will display your Profile information on your profile page and elsewhere on the Service in accordance with the preferences you set in your account. You can review and revise your Profile information at any time. We will display your Content within the Service as directed by you. If you elect to use a third party application to access the Service, then we may share or disclose your account and Profile information and your Content with that third party application as directed by you. Please remember that we are not responsible for the privacy practices of such third parties so you should make sure you trust the application and that it has a privacy policy acceptable to you.

2.2 With Trusted Service Providers and Business Partners

We may utilize trusted third party service providers to assist us in delivering and hosting our Service. For example, we use AWS to help host our Service, send out email updates. These service providers may have access to your information for the limited purpose of providing the service we have contracted with them to provide. They are required to have a privacy policy and security standards in place that are at least as protective of your information as is this Privacy Policy (including those provisions related to compliance with the EU-US and Swiss-US Privacy Shield).

2.3 With Law Enforcement or In Order to Protect Our Rights

We may disclose your information (including your personally identifiable information) in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. We may also disclose your information to our legal counsel, governmental authorities or law enforcement if we believe that it is reasonably necessary to do so in order to comply with a law or regulation; to protect the safety of any person; to address fraud, security or technical issues; or to protect SmartWinnr’s rights or property.

2.4 In Connection with a Sale or Change of Control

If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Service can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Privacy Policy until such time as this Privacy Policy is updated or amended by the acquiring party upon notice to you.

3. How We Protect Your Information

The security of your information is important to us. When you enter sensitive information as part of our service, we encrypt the transmission of that information using industry-standard encryption. SmartWinnr uses commercially reasonable and industry-standard physical, managerial, and technical safeguards to preserve the integrity and security of your information. For example, we continuously and regularly back up your data to help prevent data loss and aid in data recovery. We also guard against common web attack vectors, host data in secure SAS 70 audited data centers, and implement firewalls and access restrictions on our servers to secure our network and better protect your information.

4. Risks Inherent in Sharing Information

Although we allow you control over where you share your Content and what information is included in your Profile and take reasonable steps to maintain the security if the information associated with your account, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you share your Content and we are not responsible for third party circumvention of any privacy settings or security measures on the Service.

5. Your Choices About Your Information

You may, of course, decline to submit personally identifiable information through the Service, in which case SmartWinnr may not be able to provide certain services to you. You have a right to access information we hold about you. You may update or correct your account information at any time by logging in to your account. For questions or inquiries regarding the correction or deletion of your personally identifiable information on the Service you may contact us at

6. SmartWinnr Blogs

Information you provide in comments to our blogs are public and may be read, collected, and used by others who view those blogs. Your posts will remain even after you cancel your Service account.

7. Children’s Privacy

Our Service is not directed to persons under 13. SmartWinnr does not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register for an account on the Service. If we become aware that we have collected personal information from a child under age 13 without verification of parental consent, we take steps to remove that information. If you believe that we might have any information from or about a child under 13, please contact us at

8. Links to Other Web Sites

We are not responsible for the practices employed by websites linked to from within the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy is no longer in effect and your activities on that third party website is subject to such third party website’s own rules and policies.

9. Changes to Our Privacy Policy

If we change our Privacy Policy, we will post those changes on SmartWinnr Privacy Policy page to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page.