COPYWINS PRIVACY POLICY
This Privacy Policy explains how CopyWins, Inc. (“CopyWins,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information when you use the CopyWins website at copywins.com, our mobile applications, and our related services (collectively, the “Platform”). This Policy applies to creators, subscribers, free-tier users, and visitors. Please read this Policy carefully. By using the Platform, you agree to the practices described in this Policy. If you do not agree, do not use the Platform.
1. Quick Summary
This summary is for convenience only; the full Policy controls.
We collect information you provide (account, payment, content) and information about how you use the Platform.
We use information to operate the Platform, process payments, communicate with you, and comply with law.
We share information with service providers (such as Stripe, our payment processor), with creators or subscribers as required by the Platform's functionality, and where required by law.
We do not sell personal information for money. We may “share” personal information for cross-context behavioral advertising as defined under California law; you can opt out as described in Section 9.
If you are a resident of California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, or another state with comprehensive privacy law, you have specific rights described in Section 9.
To exercise privacy rights, contact us at [email protected].
2. Information We Collect
2.1 Information You Provide Directly
Account information: name, email address, username, password, date of birth (for age verification), country and state of residence.
Profile information: profile photo, biography, links, content categories.
Creator information: identity verification documentation submitted to Stripe (government-issued ID, tax identification number), bank account or payout information (held by Stripe, not by CopyWins), and tax forms (Form W-9 for U.S. persons or applicable Form W-8).
Payment information: card and billing information collected and stored by Stripe; CopyWins does not store full payment card numbers.
Content: posts, picks, comments, messages, and other material you submit.
Communications: emails, support requests, survey responses, and other communications you send to us.
2.2 Information We Collect Automatically
Device and connection data: IP address, device identifiers, browser type, operating system, language preferences, time zone.
Usage data: pages viewed, features used, time spent on the Platform, navigation paths, referring URLs, search terms entered.
Location data: approximate location derived from IP address. We do not collect precise GPS location unless you enable a Platform feature that requires it.
Cookies and similar technologies: see Section 4.
2.3 Information from Third Parties
Stripe (KYC verification, payment processing, payout administration).
Identity and fraud prevention vendors.
Analytics providers (such as the providers identified in our cookie disclosures).
Authentication providers, if you sign in through a third-party account.
Public sources, where reasonably necessary for fraud prevention, sanctions screening, or compliance.
2.4 Sensitive Personal Information
We may collect categories that some state laws define as sensitive personal information, including government-issued identifiers (for creator KYC), financial account information (for payouts), and precise geolocation (only where you affirmatively enable it). We use sensitive personal information only for the purposes described in Section 3 and only as permitted by law.
2.5 Information About Children
The Platform is intended for users 18 and older. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a person under 18, we will delete it. To request deletion, contact [email protected].
3. How We Use Information
We use personal information for the following business and commercial purposes:
Operating the Platform, including account creation, authentication, content delivery, and customer support.
Processing transactions, including subscriptions, tips, and creator payouts (in coordination with Stripe).
Communicating with you about your account, transactions, content, policy updates, and support requests.
Sending marketing communications about the Platform, where permitted by law and subject to your preferences.
Personalizing your experience, such as recommending creators or content.
Measuring and analyzing Platform performance and usage.
Detecting, preventing, and investigating fraud, abuse, security incidents, and violations of our Terms or policies.
Complying with legal obligations, including tax reporting (Form 1099-K), sanctions screening, and responding to lawful requests from authorities.
Establishing, exercising, or defending legal claims.
With your consent, for any other purpose disclosed at the time of collection.
4. Cookies and Similar Technologies
We use cookies, pixels, local storage, and similar technologies (collectively, “ookies”) to operate the Platform, remember your preferences, analyze usage, and (where applicable) deliver advertising. Specific categories include:
Strictly necessary Cookies, which are required for the Platform to function (such as authentication and load balancing).
Functional Cookies, which remember your preferences.
Analytics Cookies, which measure how the Platform is used.
Advertising and targeting Cookies, where applicable, which may be used for cross-context behavioral advertising.
You can manage your Cookie preferences through the Platform's cookie management tool, accessible from the cookie banner displayed on your first visit and from the “Cookie Preferences” link in the Platform footer. You can also control Cookies through your browser settings, and on the iOS App, through the App Tracking Transparency prompt.
In the United States, the Platform honors Global Privacy Control (GPC) signals as an opt-out preference signal under California, Colorado, Connecticut, and similar state laws. When we detect a GPC signal from your browser, we treat it as a request to opt out of “sales” and “sharing” for that browser.
5. How We Share Information
5.1 Service Providers
We share personal information with service providers that perform functions on our behalf, including:
Stripe (payment processing, KYC verification, payouts, tax form generation, fraud prevention).
Cloud hosting and infrastructure providers.
Email and communication providers.
Customer support and ticketing providers.
Analytics providers.
Identity and fraud prevention vendors.
Content moderation providers.
Professional advisors (lawyers, accountants, auditors).
Service providers are bound by contractual obligations to use personal information only as necessary to provide the contracted services and to maintain appropriate security measures.
5.2 Other Users
Information you choose to make public on the Platform (such as your profile, posts, picks, comments, and creator performance metrics calculated from your published Content) is visible to other users. Subscribers' identities are visible to creators they subscribe to as part of the subscription relationship.
5.3 Legal and Safety Disclosures
We may disclose personal information when we believe in good faith that disclosure is required by law or is necessary to:
Comply with applicable law, regulation, legal process, or governmental request.
Enforce our Terms, policies, or agreements.
Detect, prevent, or address fraud, security incidents, or illegal activity.
Protect the rights, property, or safety of CopyWins, our users, or others.
Respond to claims that user content violates the rights of third parties (including DMCA notices).
5.4 Business Transfers
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar transaction, personal information may be transferred as part of that transaction. We will notify you of any change in ownership or control of personal information.
5.5 With Your Consent
We may share personal information for any other purpose with your consent.
6. Sale and Sharing of Personal Information
California and certain other states distinguish between “sales” of personal information (broadly defined to include disclosures for monetary or other valuable consideration) and “sharing” of personal information for cross-context behavioral advertising.
We do not sell personal information for money. Depending on the advertising and analytics tools we use, certain disclosures may qualify as “sharing” for cross-context behavioral advertising under California law or as “targeted advertising” under similar laws in Colorado, Connecticut, Virginia, and other states. You may opt out of such disclosures as described in Section 9.4 and through the cookie management tool referenced in Section 4.
We do not knowingly sell or share the personal information of consumers under 16 years of age.
7. Retention
We retain personal information for as long as necessary to provide the Platform, comply with our legal obligations, resolve disputes, and enforce our agreements. Specifically:
Account information is retained for the life of the account and for a reasonable period after termination.
Transaction and tax records are retained for at least seven (7) years to comply with tax and financial recordkeeping obligations.
Content posted to the Platform may be retained after account termination to the extent it has been redistributed by other users or is necessary for moderation and historical performance display.
Records of moderation decisions and policy enforcement are retained for a reasonable period to support enforcement consistency and appeals.
Backups may persist for a limited period after deletion in accordance with our backup rotation.
When personal information is no longer needed, we delete or de-identify it in accordance with our retention schedule.
8. Security
We use reasonable technical, administrative, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, and destruction. These include encryption in transit, access controls, authentication requirements, and vendor due diligence. No method of transmission over the internet or electronic storage is fully secure, however, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.
If we become aware of a security incident affecting your personal information, we will notify you in accordance with applicable law.
9. Your Privacy Rights
Depending on your state of residence, you may have specific rights regarding your personal information. We honor verifiable consumer requests as described below.
9.1 Rights Under California Law (CCPA/CPRA)
If you are a California resident, you have the right to:
Know what personal information we collect, use, disclose, sell, or share, including the categories of sources, the purposes for collection, and the categories of third parties with whom we share.
Access a copy of the specific pieces of personal information we have collected about you.
Delete personal information we have collected, subject to applicable exceptions.
Correct inaccurate personal information.
Opt out of the “sale” or “sharing” of personal information.
Limit the use and disclosure of sensitive personal information to purposes permitted by law.
Be free from discrimination or retaliation for exercising your privacy rights.
To exercise these rights, contact us at [email protected] or call our toll-free number listed at the bottom of this Policy. We will verify your identity before responding to a request. You may designate an authorized agent to make a request on your behalf; we may require the agent to provide proof of authority and may verify your identity directly.
9.2 Rights Under Other State Laws
Residents of Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, Delaware, Iowa, New Hampshire, New Jersey, Maryland, Minnesota, Tennessee, Indiana, Nebraska, Kentucky, and other states with comprehensive privacy laws have substantially similar rights, with some variations. To exercise these rights, contact us at [email protected]. We will verify your identity and respond as required by your state's law (typically within 45 days, with extensions where permitted).
9.3 Verification and Response
We will respond to verifiable consumer requests within the timeframes required by applicable law (generally 45 days under most state laws, with one extension of an additional 45 days where reasonably necessary). If we cannot verify your identity to the standard required by law, we will not be able to respond. There is no fee for these requests in most circumstances.
9.4 Right to Appeal
If we deny your request, you may appeal by contacting [email protected] with the subject line “Privacy Request Appeal.” We will respond within the timeframe required by your state's law (typically 45 to 60 days). If your appeal is denied, you may contact your state attorney general.
9.5 Opting Out of Sale and Sharing
You may opt out of the “sale” or “sharing” of your personal information by:
Clicking the “Do Not Sell or Share My Personal Information” link at the bottom of any page of the Platform.
Adjusting your preferences in our cookie management tool.
Sending a Global Privacy Control (GPC) signal from your browser.
Emailing [email protected].
9.6 Limit Use of Sensitive Personal Information
California residents may direct us to limit the use and disclosure of sensitive personal information to purposes specified in the CCPA. To make this request, click “Limit the Use of My Sensitive Personal Information” in the Platform footer or email [email protected].
10. Categories of Information We Collect, Disclose, and Share
This Section provides the categorical disclosures required by California and similar state laws. The following table summarizes the categories of personal information we collect, the sources, and the categories of third parties with whom we disclose.
Category | Source | Disclosed To |
Identifiers (name, email, username, IP address, device ID) | Directly from you; automatically; third parties | Service providers; other users (limited); legal authorities; advertising partners (for sharing) |
Customer records (account, billing, contact) | Directly from you | Service providers; legal authorities |
Commercial information (transactions, subscriptions) | Directly from you; Stripe | Service providers; legal authorities |
Internet/electronic activity (usage, browsing) | Automatically | Service providers; analytics partners; advertising partners (for sharing) |
Geolocation (approximate, from IP) | Automatically | Service providers; analytics partners |
Audio/visual (profile photos, content) | Directly from you | Other users; service providers |
Professional information (creator credentials) | Directly from you | Service providers; legal authorities |
Inferences (preferences, interests) | Derived from collected data | Service providers; analytics partners |
Sensitive personal information (gov ID, financial account, precise geo when enabled) | Directly from you; Stripe | Stripe; legal authorities |
We have collected the categories above in the twelve months preceding the date of this Policy. We have disclosed these categories to the categories of third parties listed above for the business purposes described in Section 3. We have not sold personal information for money. Depending on advertising and analytics tools in use, certain Cookies may constitute “sharing” of identifiers and internet activity for cross-context behavioral advertising.
11. Marketing Communications
We may send marketing communications about the Platform. You can opt out of marketing emails by clicking “unsubscribe” in any marketing email or by updating your preferences in your account settings. Even if you opt out of marketing, we may continue to send you transactional and operational messages (such as receipts, security alerts, and policy notices).
12. Third-Party Services and Links
The Platform may contain links to third-party websites or services, including brokerages, sportsbooks, and exchanges where users execute their own transactions. We are not responsible for the privacy practices of any third party. Your use of any third-party service is governed by that third party's privacy policy.
13. International Users
The Platform is operated from the United States and is intended for U.S. users. If you access the Platform from outside the United States, your personal information will be processed in the United States, where data protection laws may be different from those of your jurisdiction. By using the Platform, you consent to this processing.
14. California Shine the Light
California Civil Code Section 1798.83 permits California residents to request information about disclosures of personal information to third parties for direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes. To make a Shine the Light request, contact [email protected].
15. Notice to Nevada Residents
Nevada residents have the right to direct us not to sell certain covered personal information to third parties. We do not sell covered personal information as defined under Nevada law. To submit a request, contact [email protected].
16. Changes to This Policy
We may update this Policy from time to time. We will post any changes on this page and update the “Last Updated” date. If we make material changes, we will provide additional notice (such as by email or in-Platform notification). Continued use of the Platform after the effective date of an update constitutes acceptance.
17. Contact Us
To exercise your privacy rights, ask questions about this Policy, or report a privacy concern, contact us at:
CopyWins, Inc.
Attention: Privacy
Email: [email protected]