Privacy Policy
Effective July 2022
1. Purpose
Welcome to our Privacy Policy! CLOUDNINE, s.r.o. and its affiliates (“CLOUDNINE,” “we,” “us,” or “our”) have adopted this Privacy Policy to let you know how we treat the information that we collect from you, the kinds of information we may collect, how that information is used, with whom we share it and how you can opt-out of a use or correct or change such information. Where permitted, by engaging with our Website, you accept and consent to the practices described in this notice, which may be updated from time to time. Therefore, please check this Privacy Policy periodically for updates.
This Privacy Policy supplements and forms a part of the Website’s Terms of Use (the “Terms”). Additionally, if you participate in an CLOUDNINE Experience, your participation is subject to the Website’s Official Rules, which include the Experience-specific rules stated on each Experience page under the section “Stuff Our Lawyers Want You To Know” (collectively, the “Rules”). If this Privacy Policy conflicts with or is inconsistent with the Rules, the Rules will control. Capitalized terms not defined in this Privacy Policy have the meaning given to them in the Terms or the Rules.
2. Scope
This Privacy Policy applies to all information collected and/or processed by CLOUDNINE as a result of your interaction(s) with us on www.epicwin360.com (the “Website”), via email, chat, telephone, video calls, social media, blogs, and/or other forums or offerings (collectively, with Website, the “Services”) or when you interact our with our advertising and applications on third-party websites and services.
This Privacy Policy does not apply to Personal Information we collect about our business partners, employees, applicants for employment, or contractors in the employment context.
3. What Information We Collect
We collect several types of information about our current and prospective customers, members, users, visitors, and guests (collectively, “Individuals”), directly from Individuals as well as from third-party sources. This includes:
Personal information that we could reasonably use to directly or indirectly identify an Individual, such as a name, mailing address, email, telephone number, or other similar identifiers (“Personal Information”).
Non-personal information that does not directly or indirectly reveal an Individual’s identity or directly relate to an identified Individual, such as de-identified and aggregated information (“Non-Personal Information”).
Statistical or aggregated information that does not identify a specific person, but we may derive non-personal statistical or aggregated data from Personal Information. For example, we may aggregate non-personal information to calculate the percentage of users accessing a specific Website feature.
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your CLOUDNINE account login information, browser type and version, device information, local time, or operating system and platform.
Non-personal details about an Individual’s interactions with the Website, including the full Uniform Resource Locators (“URLs”); clickstream to, though, and from our Website (including date and time); Experiences you viewed; pages for which you searched; page response times; download errors; length of visits to certain pages; button clicks; or methods used to browse away from the page.
If we combine or connect non-personal information with Personal Information so that it directly or indirectly identifies an Individual, we treat the combined information as Personal Information.
A. Anonymized Information.
We may use Personal Information and other information about you to create anonymized information and aggregate anonymized information. Examples of anonymized information include de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services or other analyses we create. Anonymized information is not Personal Information.
We may use anonymized and aggregated information for various functions, including research, internal analysis, analytics, and other legally permissible purposes. We may share this information within CLOUDNINE and with third parties in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
B. Types of Personal Information We Collect
We generally collect the types of Personal Information listed below.
Examples of information we may collect if you visit our website:
Technical and geolocation information, such as IP address, device type, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, operating system, referral URL, the date and time you used the Services, the amount of time you spend on each page, page views and site interactions, and location of your device.
Examples of information we may collect if you set-up an CLOUDNINE account, join our mailing list, communicate with us, or enter to win an Experience:
Identifiers, such as your name, email address, billing address, and phone number.
Geolocation information, such as city, county, and zip code.
Financial information, such as credit card and billing information if you make a donation (collected and processed by our third-party processor).
Commercial information, such as your entry history or donation history.
Other information you voluntarily provide to us on a public-facing portion of our site or in a communication to us.
Examples of information we may collect if you participate in a survey:
Demographic or other information that you submit voluntarily (such as your age, gender, education, and income).
Examples of information we may collect if you win an Experience:
Audio or visual information, such as images and videos.
Demographic, employment, educational, or other background information included in a background check.
Government-issued ID, insurance information, tax information, or other information required to supply you with the prize.
4. How We Collect Information About You
The sources of the Personal Information we collect above include Personal Information that you directly provide to us (for example, on our Website or while interacting with our Services), Personal Information that we gather from the devices you use to access our Services (for example, our Website or mobile applications), Personal Information we receive from third-parties (e.g., marketing, research or survey partners), and Personal Information that we generate internally (for example, we may create identifiers internally that we associate with you).
A. Information You Provide Directly to Us.
When you use our Services, contact us directly, or engage in other activities we may ask for, and you may provide us with information about you (either directly to us or to third-parties acting on our behalf). This includes Personal Information you may provide when you make a donation, search our Website, enter to win an Experience, win an Experience, create an account, join our mailing list, communicate with us via email, telephone, or chat, interact with us on social media, participate in surveys or research, provide testimonials or reviews, report a problem with our Website.
If you post, publish or otherwise share content, or submit content for sharing, on a public forum (e.g., on our blogs, social media pages, product review pages, community forums, etc.), including via interaction with our Services or any third-party platform, such content is “public” and not be subject to the privacy protections provided in this Privacy Policy.
You share and/or submit content for public consumption at your own risk. Even if you set specific privacy settings for such public forums, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of any Website users or other third-parties. Therefore, we do not guarantee that unauthorized persons will not view the content that you may share or submit for publication on such public forums. Even if you delete the content, copies may remain viewable in cached and archived pages or might have been created or stored by others.
B. Automated Technologies or Interactions.
As you interact with our Services, we may automatically collect location-based information and technical information about your equipment, browsing actions, and Website interactions as specified above. We collect this information by using cookies and pixels (see Section 7, “Cookies and Automated Data Collection Technologies”).
C. Information from Third-Parties or Publicly Available Sources.
We may also receive information about you from other sources, including through third-party services and organizations. This includes Personal Information from a winner if they select you to be their guest for an Experience, from our vendors and business partners (including sub-contractors that help with technical, payment, or delivery services), advertising networks, analytics providers, or search information providers. In addition, for Potential Winners and Winners only, we may collect Personal Information from background check services (see the Website’s Official Rules, for more information).
5. How We Use Personal Information
We may use your Personal Information to fulfill requests for Services or information, to conduct our business operations and perform administrative purposes, to provide you with materials about non-profit partners, offers, products, or the Services, and/or to improve and personalize our Services, messaging, or your interactions with us.
Some examples include:
Present our Website; provide you with Experiences, Services, information, or support that you request from us; and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
Fulfill the purposes or the reason for which you provided the Information or that were described when it was collected, including through third-party payment processing.
Create, maintain, customize, and secure your account with us.
Process your requests, purchases, transactions, and payments, and provide related products or services or prevent transactional fraud.
Notify you about changes to our Website, products, or Services.
Provide, support, personalize, and develop our Website, products, and Services.
Provide and personalize our marketing messages to you and measure the effectiveness of those marketing messages.
Testing, research, analysis, and product development, including developing and improve our Website, products, and Services.
Processing any necessary paperwork or background checks for the potential winners and winners of each Experience.
In any other way we may describe when you provide the information.
For other legitimate interests, such as fraud protection or compliance with legal obligations.
6. When We May Share Your Personal Information
We may disclose Personal Information that we collect or that you provide as described in this Privacy Policy (e.g., with our third-party service providers; to comply with legal obligations; to enhance the Services; to protect and defend our rights and property) or with your permission. This includes disclosures:
To service providers, contractors, and other third parties we use to support our business, for at least the following business purposes: Performing services or servicing accounts; Serving advertising and marketing on our behalf; Maintaining or improving the quality of products or services we offer; and Detecting security incidents, protecting against malicious activity, and prosecuting those responsible. Our policy is only to make these business purpose disclosures to third-parties pursuant to written contracts specifying the purposes, requiring the recipient to keep the personal information disclosed confidential, and prohibiting the use of the disclosed information for any purpose except under the contract.
In connection with a merger, sale, divestiture, restructuring, reorganization, dissolution, or other transfer of some or all of CLOUDNINE’s assets.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.
To comply with any court order, law, or legal process, including responding to any government or regulatory request.
To enforce or apply any agreements between CLOUDNINE and you, if applicable.
As we believe necessary to protect the rights, property, or safety of CLOUDNINE, our users, partners, or others.
7. Cookies and Automatic Data Collection Technologies
We, as well as third parties that provide content, advertising, or other functionality on our Services, may use automatic data collection technologies (e.g., cookies, pixel tags/web beacons, social media widgets, local storage, etc.) to collect information about you, your equipment, browsing actions, and Website interactions. Similarly, if you sign up for our text messaging program, cookies may be used to personalize your experience (e.g., send you personalized text messages such as shopping cart reminders). We use technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our Website, Services, applications, messaging, and tools, and to recognize you across devices. We also may use these technologies to collect information about your online activities over time. For more information about your options, see Section 8 (“Your Rights and Choices”).
The information we collect automatically may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver better and more personalized Services, including by enabling us to:
Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your interests.
Speed up your searches.
Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Where available, you may refuse to accept certain cookies by adjusting the settings in our Cookie Preference Center. You may also refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Where applicable, unless you have adjusted your settings, our system will issue cookies when you direct your browser to our Website.
Pixel Tags. Pages of the Website and our emails may contain small electronic files known as pixels (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). For example, we use Google Analytics to measure and analyze our site traffic. Where available, you may refuse to accept certain beacons by adjusting the settings in our Cookie Preference Center.
8. Your Rights and Choices
CLOUDNINE understands that your Personal Information is important to you. Therefore, we strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
A. Tracking Technologies and Advertising
Where available, you can adjust your cookie settings in our Cookie Preference Center. You can also set your browser to refuse all or some browser cookies or alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. Learn how to manage the cookies in your browser below:
Chrome (desktop) (mobile)
Safari (desktop) (mobile)
Internet Explorer (desktop) (mobile)
Firefox (desktop) (Android)
Android Browser: Click on the top right corner of the app (labeled with “More” or three dots) -> Settings -> Privacy
Opera (desktop and mobile)
Silk (mobile)
To be clear, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device.
You may be able to opt-out of receiving certain personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. Please visit the Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page to opt-out directly from providers who participate in those programs. You may also be able to adjust your settings regarding personalized advertisements by adjusting the privacy settings in the applications and/or social media platforms you use. Please note that CLOUDNINE does not control or operate these tools or the choices that advertisers and others provide through these tools.
B. Marketing and Email
CLOUDNINE respects the rights of our users who receive our communications and enforces internal policies to preserve those rights. While we value our communications with you, if you do not want CLOUDNINE or CLOUDNINE’s representatives to contact you for marketing purposes.
9. Users From Outside the United States
This Website is hosted in the United States and is governed by US law. Accordingly, if you access the Website from the European Economic Area or any other regions with laws governing personal data collection and use, please note that your Personal Information will be processed in the United States and elsewhere outside the European Economic Area.
Personal Information collected by CLOUDNINE may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, Canada, the European Economic Area, in the cloud, on our servers, on the servers of our affiliates, or on the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities as described above.
10. Data Retention and Security
CLOUDNINE retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services, as necessary to fulfill the purpose(s) for which the Personal Information was collected, to provide our Services, to resolve disputes, to establish legal defenses, to conduct audits, to pursue legitimate business purposes, to enforce our agreements, and to comply with applicable laws. Unless we are otherwise required by law to retain specific information, once we no longer need to retain your Personal Information for the purposes described above, we will destroy, erase, or de-identify it per our data retention policies and applicable law. Legal requirements, however, may require us to retain some or all of the Personal Information we hold for a period of time that is longer than that for which we might otherwise hold it.
The security of your Personal Information is very important to us. CLOUDNINE uses physical, electronic, and administrative safeguards designed to protect your Personal Information from loss, misuse, and unauthorized access, use, alteration, or disclosure.
The safety and security of your Personal Information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. Do not share your password.
By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues.
11. CLOUDNINE’s Privacy Team Contact Information
If you have any questions about our privacy practices, this Privacy Policy, or how to submit a complaint with the appropriate authority, please contact
CLOUDNINE by Mail: CLOUDNINE, s.r.o.
Zámostní 1155/27,
Slezská Ostrava,
710 00 Ostrava
Czech Republic
Attn: Privacy Agent
This Privacy Policy may change from time to time. We may revise this Privacy Policy at our sole discretion, so please review it periodically. If you continue to visit the Website and use the Services after such changes have been made, you thereby provide your consent to the changes.
You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Website and Services after the revised Privacy Policy is posted (as reflected in the above Effective Date). Accordingly, if you do not agree to any portion of the Privacy Policy, you must immediately stop using the Website and Services.
14. EEA and UK Rights
A. Your Rights in the EEA and UK
Users from the European Economic Area and the UK have the following rights regarding their Personal Information:
The right to access. You have the right to request CLOUDNINE provide you a copy of your personal data. This includes the right to request that CLOUDNINE provide you with a copy of your data structured, machine-readable format, and to ask us to share (port) this data to another controller.
Right to correct, delete, or restrict (stop any active) processing of your personal data.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we do not have to process the data to meet contractual or other legal requirements or where we are using the data for direct marketing).
These rights may be limited, for example, if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
B. Legal Basis for Processing Data for Users From the EU and European Economic Area.
We process Personal Information as detailed in the sections above. Under the privacy laws applicable to Users in the EEA and UK, we additionally provide the legal basis for which we process and share such Personal Information:
To fulfill a contract or take steps linked to a contract (e.g., when you enter to win an Experience);
To verify your identity;
To take payments;
To communicate with you, including sending you automated service messages;
To provide customer service;
To draw winners; and
To arrange the delivery or other provision of prizes for the winners of the Experience.
As required by CLOUDNINE to conduct our business and pursue our legitimate interests, we will use your information:
To provide products and services you have requested;
To help us monitor, improve, and protect our products, content, Services, and Website;
To investigate and respond to any complaints received from you or others about our Website; products, or Services;
To send you direct marketing about our current activities, future events, and Experiences, where permitted by law;
To personalize our Website and Services for you;
To provide targeted advertising about CLOUDNINE on our sites and selected partner sites and social networks;
To process credit or debit card payments (which is processed by our third-party payment processors);
To prevent, investigate, and/or report fraud, terrorism, misrepresentation, security incidents, or crime, in accordance with applicable law;
In connection with legal claims, compliance, regulatory, and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation);
In connection with those cookies and other technologies that are strictly necessary to make our Website function; and
To invite some individuals to take part in market research where they choose to do so.
Where you give us permission, we will use your information:
To send EEA and UK residents direct marketing about our current activities, future events, and Experiences;
In connection with surveys, where you choose to participate in those surveys and choose to provide us any information;
In connection with cookies, web beacons, and other storage technologies that are not otherwise strictly necessary for the Website to function, which technologies we may use to collect or receive information from the Website and elsewhere on the Internet and use that information to provide measurement services and target ads about CLOUDNINE;
In connection with photographs, video recordings, and information about winners; and
On other occasions where we ask you for consent, we will use the data for the purpose that we explain at that time.
For purposes required by law, we may use your information:
In response to requests by government or law enforcement authorities conducting an investigation.
