Privacy Policy

1. Introduction

1.1 This Privacy Policy explains how Lege Nova Ltd ("Company", "we", "us", or "our") collects, uses, stores, and protects personal data when you access or use the Winlytics platform (the "Platform").

1.2 We are committed to protecting your privacy and processing personal data in accordance with Regulation (EU) 2016/679 (the "GDPR") and applicable Bulgarian and EU data protection laws.

1.3 Company details:

2. Scope of This Policy

2.1 This Privacy Policy applies to all users of the Platform and all personal data processed in connection with the Platform.

2.2 This Policy does not apply to third-party websites, bookmakers, or services that you may access via links from the Platform.

3. Categories of Personal Data

3.1 We may collect and process the following categories of personal data:

• (a) Account data, such as email address, username, and account credentials;
• (b) Contact data, including email correspondence with us;
• (c) Technical data, such as IP address, device type, browser type, operating system, and log data;
• (d) Usage data, including interaction with the Platform, preferences, and feature usage;
• (e) Payment-related metadata (excluding full payment card details), processed via third-party payment providers.

3.2 We do not knowingly collect special categories of personal data as defined under GDPR Article 9.

4. Sources of Personal Data

4.1 Personal data is collected directly from you when you register, use the Platform, or communicate with us.

4.2 Certain technical and usage data may be collected automatically through cookies and similar technologies.

5. Purposes and Legal Bases of Processing

5.1 We process personal data only where we have a lawful basis under GDPR, including:

• (a) Performance of a contract – to provide and operate the Platform;
• (b) Legitimate interests – to improve the Platform, ensure security, prevent abuse, and analyze usage;
• (c) Legal obligations – to comply with applicable laws and regulations;
• (d) Consent – where required, such as for marketing communications or non-essential cookies.

5.2 We do not use personal data for automated decision-making or profiling that produces legal or similarly significant effects.

6. Cookies and Tracking Technologies

6.1 The Platform uses cookies and similar technologies to ensure functionality, security, and performance.

6.2 Where required by law, non-essential cookies are used only with your consent.

6.3 You may manage or disable cookies through your browser settings, subject to potential impact on Platform functionality.

7. Data Sharing and Recipients

7.1 We may share personal data with:

• (a) Hosting, cloud, and infrastructure providers;
• (b) Analytics and security service providers;
• (c) Payment processors;
• (d) Professional advisers where necessary.

7.2 All third-party processors act under contractual obligations to process data only on our instructions and in compliance with GDPR.

7.3 We do not sell personal data.

8. International Data Transfers

8.1 Where personal data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards, such as adequacy decisions or standard contractual clauses.

9. Data Retention

9.1 Personal data is retained only for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting, or reporting obligations.

9.2 Retention periods are determined based on data type, purpose, and legal requirements.

10. Data Security

10.1 We implement appropriate technical and organisational measures to protect personal data against unauthorized access, loss, misuse, or disclosure.

10.2 No system is completely secure. We cannot guarantee absolute security of data transmitted or stored electronically.

11. User Rights

11.1 Under GDPR, you have the right to:

• (a) Access your personal data;
• (b) Rectify inaccurate or incomplete data;
• (c) Request erasure of personal data;
• (d) Restrict or object to processing;
• (e) Data portability;
• (f) Withdraw consent at any time where processing is based on consent;
• (g) Lodge a complaint with a supervisory authority.

11.2 Requests may be submitted to info@winlytics.ai. We may require verification of identity.

12. Marketing Communications

12.1 We may send service-related communications necessary for Platform operation.

12.2 Marketing communications are sent only where permitted by law or with your consent. You may opt out at any time.

13. Children's Data

13.1 The Platform is not intended for individuals under the age of 18.

13.2 We do not knowingly collect personal data from minors.

14. Third-Party Links

14.1 The Platform may contain links to third-party websites or services.

14.2 We are not responsible for the privacy practices of third parties. You should review their policies separately.

15. Changes to This Policy

15.1 We may update this Privacy Policy from time to time.

15.2 Material changes will be communicated where required by law. Continued use of the Platform constitutes acceptance of the updated Policy.

16. Complaints and Supervisory Authority

16.1 If you have concerns regarding data processing, please contact us at info@winlytics.ai.

16.2 You have the right to lodge a complaint with the competent data protection authority in your EU Member State, including the Bulgarian Commission for Personal Data Protection.