Privacy Policy

1. Introduction

Welcome to the Privacy Policy of "The Winners" (thewinners.ae). We respect your privacy and are committed to protecting your personal information.

2. Information We Collect

• Technical information: IP address, browser type, device, operating system.
• Usage information: Pages viewed, links clicked.
• Cookies: Small files to improve your experience.
• Tracking parameters: gclid and fbclid for tracking traffic sources.

3. Use of Information

• Improving user experience
• Traffic analysis
• Marketing effectiveness tracking
• Affiliate commission calculation

4. Cookies

The site uses essential cookies, analytics (Google Analytics), and marketing cookies. You can manage your preferences through your browser settings.

5. Third Parties

We may share information with Google Analytics, Google Tag Manager, Vercel (our hosting provider, with edge servers globally), Supabase (our database provider), and Amazon Associates business partners across multiple regional Amazon storefronts (amazon.ae, amazon.sa, amazon.com, amazon.co.uk, amazon.de, amazon.fr, amazon.it, amazon.es, amazon.ca, amazon.com.au, amazon.sg, amazon.com.br, amazon.pl, amazon.se, amazon.ie, amazon.com.be, amazon.nl). We do not sell your personal information.

6. Security

We take reasonable security measures to protect your information.

7. Your Rights & Applicable Law

The Site is operated from the United Arab Emirates and primarily serves UAE residents under the UAE Personal Data Protection Law (PDPL). However, visitors from outside the UAE may be entitled to additional rights under their local laws, which we honor where applicable.

Wherever you live, you can ask us to access, correct, delete or export your personal data, object to its use, or withdraw your consent, and you can complain to the data-protection authority of your country.

UAE Residents (PDPL)

Under PDPL you have the right to request access, correction, or deletion of your personal data, and to withdraw consent.

European Economic Area & United Kingdom (GDPR / UK GDPR)

If you are located in the EEA or the UK, you have the right to:

• access the personal data we hold about you;
• request rectification or erasure of your personal data;
• restrict or object to processing;
• data portability;
• withdraw consent at any time (where processing is based on consent);
• lodge a complaint with your local supervisory authority.

Legal basis for processing (GDPR Article 6): (a) your consent for analytics and marketing cookies, which you can withdraw at any time via the cookie settings, and (b) our legitimate interest in operating the Site, securing it, and improving user experience.

California Residents (CCPA / CPRA)

If you are a California resident, you have the right to:

• know what personal information we collect, sell, or share;
• delete personal information we hold about you;
• opt out of the "sale" or "sharing" of personal information (including the use of affiliate-tracking cookies for cross-context advertising);
• non-discrimination for exercising these rights.

Brazil (LGPD — Lei Geral de Proteção de Dados, Law 13,709/2018)

If you are located in Brazil, you have the right to:

• confirmation that we process your personal data, and access to it;
• correction of incomplete, inaccurate or outdated data;
• anonymization, blocking or deletion of unnecessary or excessive data;
• data portability;
• deletion of data processed with your consent, and to withdraw consent at any time;
• information about the parties we share data with, and about the consequences of not giving consent;
• lodge a complaint with the Brazilian National Data Protection Authority (ANPD).

Legal basis (LGPD Art. 7): your consent for analytics and marketing cookies, and our legitimate interest in operating, securing and improving the Site.

Other countries

If you are located elsewhere — including Saudi Arabia (PDPL), Japan (APPI), Canada (PIPEDA), Australia (Privacy Act 1988) and Singapore (PDPA) — you have the rights your local law gives you. Contact us and we will honor them.

Data retention

Session and click-tracking data is retained for up to 24 months for analytics and affiliate attribution purposes; longer where required by legal compliance.

International data transfers

Your data may be transferred to and processed in countries other than your own, including the United States and the European Union, by our service providers (Vercel, Supabase, Google, Amazon). Where applicable, such transfers rely on the safeguards required by the law of your region, such as standard contractual clauses approved for that region (for example the EU/UK clauses, or the clauses approved by Brazil's ANPD) or equivalent mechanisms.

Exercising your rights

Email us at thewinners@atomicmail.io. We will respond within 15 days — the shortest deadline among the laws we follow (for example Brazil's LGPD), so it covers every visitor. Please include enough information for us to verify your identity (e.g., approximate dates of visits, country, browser/device).

Where local mandatory consumer-protection or data-protection laws conflict with this Privacy Policy, the local mandatory law prevails.

8. External Links

Our site contains links to external sites (including the various regional Amazon storefronts we partner with — amazon.ae, amazon.com, amazon.co.uk, amazon.de, and others depending on your country). We are not responsible for the privacy practices of these sites; please consult their privacy policies directly.

9. Changes to Policy

We may update this policy from time to time. Changes will be posted on this page.

10. Contact

For questions about our privacy policy, contact us at thewinners@atomicmail.io.