Privacy Policy
Effective date: July 30, 2026
This Privacy Policy describes how Winner's Circle Picks LLC ("Winner's Circle," "we," "us") collects, uses, and shares information when you use the Winner's Circle app and related services (the "Service"). The Service is for adults 18 and older; see Section 8.
1. Information we collect
Account information (you provide)
- Email address (used for sign-in via magic link and for service notices)
- Date of birth (used once to verify you are 18+; we store an over-18 flag and, where retained, the date itself)
- Username (public within the Service)
- If you sign in with Apple: the identifier and email (or Apple private relay email) Apple provides
Activity data (generated by your use)
- Pick history: selections, stakes in virtual units, odds at placement, results, performance statistics (win rates, unit returns). Picks also function as your entries in The Winner's Circle Daily Prize, a free-entry promotional skill contest (see its Official Rules), so this data doubles as contest-entry data used for qualification and winner determination. If you qualify for the Winner's Circle, your username, picks, and statistics are shown to paying pass holders; your settled pick history is visible to other users.
- Wallet and prize ledger: contest prizes credited, cashout requests and their status (amounts in US dollars)
Purchase data
- Pass purchase history (pass type, price, timestamps) and Stripe identifiers (customer ID, checkout session ID). We never see or store your card number — payment details are entered directly with Stripe on Stripe's checkout pages.
Payout identity data (only if you cash out)
- Cashouts require identity verification (KYC) and taxpayer identification (IRS Form W-9 information — name, address, SSN/TIN) with our payment partner Stripe (Stripe Connect); completing both is a precondition of any cashout, because contest prizes are reportable on IRS Form 1099-MISC once they exceed $2,000 in a calendar year. Identity documents, W-9/taxpayer information, and bank account details are collected directly by Stripe under Stripe's privacy policy; we store only your Stripe account identifier, verification status flags, and the verified state of residence (used to enforce the contest's state eligibility exclusions).
Device and technical data
- Basic device and app information needed to run the Service (device type/OS version, app version, IP address in server logs, authentication tokens)
- Push notification token, if you enable notifications (feature planned)
What we do NOT collect: precise location, contacts, photos, health data, advertising identifiers, or any data for third-party advertising. We do not use third-party advertising or analytics SDKs, and we do not track you across other companies' apps or websites.
2. How we use information
- Operate the Service: authentication, placing and settling picks, assigning pick-feed allocations, processing purchases and cashouts
- Administer The Winner's Circle Daily Prize contest: computing qualification, determining winners, paying and recording prizes, enforcing contest eligibility (age and state exclusions), and maintaining winner records per the Official Rules
- Enforce integrity: detecting multi-accounting, collusion, pick redistribution, and fraud (our anti-abuse rules depend on activity data)
- Age verification (18+ requirement)
- Legal compliance: tax information returns for prize recipients (IRS Form 1099-MISC, via Stripe; W-9/TIN collection at cashout), responding to lawful requests, unclaimed-property rules
- Service communications: sign-in links, receipts, material changes to terms. We do not send third-party marketing.
Legal bases (GDPR, where applicable): performance of contract (operating the Service), legitimate interests (integrity, security, fraud prevention), legal obligation (tax, age requirements), consent (push notifications).
3. Who we share information with (processors and partners)
We do not sell personal information, and we do not share it for cross-context behavioral advertising. We share information only with:
| Recipient | Role | What they receive |
|---|---|---|
| Supabase | Hosting, database, and authentication infrastructure | All account and activity data (stored in the US) |
| Stripe | Payment processing (purchases), payouts and identity verification (Stripe Connect), tax forms | Email, purchase data; for cashouts: identity/KYC and bank data you provide directly to Stripe |
| Expo (EAS) | App build/update infrastructure and push-notification delivery (when enabled) | Push tokens and device data needed for delivery |
| Apple | App distribution; Sign in with Apple; In-App Purchase (if offered) | Per Apple's own terms |
Odds and scores data flows into the Service from our sports-data provider (The Odds API); no user personal data is sent to it.
We may also disclose information if required by law, to protect the rights, safety, or property of users or the Service, or in connection with a merger, acquisition, or sale of assets (with notice).
4. Retention
- Account data: kept while your account is active.
- Economy and contest records (picks, prizes awarded, wallet ledger, winner records): the Service's money math runs on append-only ledgers. We retain transaction, prize, and tax-reporting records as required for tax, accounting, audit, contest-law, and dispute purposes (typically 7 years) even after account deletion, in de-identified or minimized form where feasible.
- Server logs: short-term rotation (typically ≤ 90 days).
5. Deletion and your choices
- In-app account deletion: you can delete your account from within the app (Settings → Delete Account). This permanently deletes your profile, email, and personal identifiers; residual economy records are retained only as described in Section 4 and are disassociated from your identity where legally permissible.
- You may also request deletion or a copy of your data by emailing support@winners-circle.co.
- Push notifications can be disabled in iOS Settings at any time.
6. Your rights (US state laws and GDPR)
Depending on where you live, you may have rights to access, correct, delete, or receive a copy of your personal information, and to opt out of "sale"/"sharing" (we do neither) — including under the California Consumer Privacy Act (CCPA/CPRA) and similar state laws, and the GDPR if you are in the EEA/UK. Exercise these rights in-app or via support@winners-circle.co. We will verify requests and respond within the legally required time. We do not discriminate against you for exercising privacy rights. California residents: we do not sell or share personal information as defined by the CCPA, and we honor deletion and access requests as described above.
7. Security
All traffic is encrypted in transit (TLS). Economy data is server-authoritative with row-level security; payment credentials and identity documents are held by Stripe, not by us. No system is perfectly secure; we will notify you of a breach affecting your personal data as required by law.
8. Children
The Service is strictly for users 18 and older. We do not knowingly collect information from anyone under 18 (and never from children under 13; the Service is not subject to COPPA because it is not directed to children and denies under-18 signups). If we learn an account belongs to someone under 18, we will terminate it and delete its data. Contact support@winners-circle.co to report an underage account.
9. International users
The Service is operated from the United States and data is stored in the United States. If you use the Service from elsewhere, you consent to processing in the US.
10. Changes to this policy
We will post updates here and, for material changes, notify you in the app or by email before they take effect.
11. Contact
Winner's Circle Picks LLC
137 E 38th St., New York, NY 10016
support@winners-circle.co — privacy requests, questions, and complaints
Last updated: July 16, 2026