Privacy Policy

Effective as of September 14, 2026 · last amended October 17, 2026 before public release

This Privacy Policy describes how Winner's Circle Picks, LLC, a Delaware limited liability company ("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 only to confirm that you are 18 or older; we keep the resulting over-18 flag on your profile and do not retain your date of birth after that check)
• 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 the identifiers needed to match a purchase to your account: Apple's transaction identifiers, the product bought, the price, currency and purchase date, the App Store country (storefront) of the purchase, and any refund notice Apple sends us, together with your Winner's Circle account identifier, which the app gives Apple as an "app account token" so Apple can tell us which account a purchase belongs to. We never see or store your card number, and we never see your Apple ID password — payment details are entered with Apple on Apple's payment sheet.

Payout identity data (only if you cash out)

• Cashouts require identity verification (KYC) with our payment partner Stripe (Stripe Connect); completing it is a precondition of any cashout. For a US individual, Stripe currently asks for your name, date of birth, and the last four digits of your Social Security number, and may request more (such as an identity document) if it cannot verify you. Because contest prizes are reportable on IRS Form 1099-MISC once they total $2,000 or more in a calendar year, we may also require full taxpayer identification information (IRS Form W-9 information), which Stripe would collect. Identity information, any taxpayer information, and bank account details are collected directly by Stripe under Stripe's privacy policy; we store only your Stripe account identifier and verification status flags.

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

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.

Do Not Track. We do not track users across third-party websites or apps over time and therefore do not respond to browser "Do Not Track" signals. No other parties collect personally identifiable information about your online activities over time and across different websites or apps when you use the Service.

2. How we use information

• Operate the Service: authentication, placing and settling picks, assigning pick-feed allocations, processing purchases and cashouts (including matching Apple purchase records to your account and applying refunds)
• 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, including collecting taxpayer identification information where required), 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:

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, and pass purchase records, including Apple transaction 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.
• Date of birth: not retained after the one-time 18+ check. Only the resulting over-18 flag is kept, for as long as your account exists.
• Server logs (including IP addresses): 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 for in-app purchases are held by Apple, and payment credentials and identity documents for cashouts 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. Where your information is stored and processed

Winner's Circle Picks, LLC operates the Service from the United States. Our primary database and authentication infrastructure (Supabase) is hosted in Canada. Our other service providers listed in Section 3 process information primarily in the United States, and some of them may process it in other countries. Our server functions may also run in other regions. Information stored or processed in another country is subject to that country's laws and may be accessible to its courts, law enforcement and national-security authorities. Our providers handle your information under their own data-protection terms and privacy commitments. By using the Service, you understand that your information will be stored and processed in Canada, the United States and those other locations.

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: October 17, 2026