Privacy Policy

Last updated: January 2025

1. Introduction

Winsclose AS ("we", "our", "us") respects your privacy and is committed to protecting your personal data. This policy explains how we collect, use, and protect your information in compliance with the EU General Data Protection Regulation (GDPR) and the Norwegian Personal Data Act.

2. Data Controller

Winsclose AS
Postboks 1234, 0116 Oslo, Norway
Email: privacy@winsclose.com

3. Data We Collect

3.1 Information You Provide

• Contact information (name, email) when contacting us
• Communication content when you message us
• Age verification responses

3.2 Technical Information

• IP address and location data
• Browser type and version
• Device information
• Usage data and analytics (with consent)
• Cookie data (with consent)

4. Legal Basis for Processing

• Legitimate Interest: Age verification, security, basic functionality
• Consent: Analytics, marketing, non-essential cookies
• Contract: Service delivery and support
• Legal Obligation: Compliance with Norwegian regulations

5. How We Use Your Data

• Provide and maintain our entertainment services
• Ensure compliance with age restrictions (18+)
• Respond to inquiries and provide support
• Analyze usage to improve our service (with consent)
• Prevent fraud and ensure security
• Comply with Norwegian legal obligations

6. Consent Management

We implement granular consent management for non-essential data processing:

• Analytics: Opt-in consent required
• Marketing: Opt-in consent required
• Non-essential cookies: Opt-in consent required

Analytics and marketing scripts load only after explicit consent. You can withdraw consent at any time through our Cookie Settings.

7. Data Sharing

We do not sell your personal data. We may share data with:

• Service providers (hosting, analytics) under strict data processing agreements
• Legal authorities when required by Norwegian or EU law
• Professional advisors under confidentiality obligations

8. Data Retention

• Age verification: Stored locally until consent withdrawn
• Contact inquiries: 3 years or until resolved
• Analytics data: 26 months maximum (Google Analytics)
• Cookies: As specified in our Cookie Policy

9. Your Rights Under GDPR

You have the following rights regarding your personal data:

• Access: Request copies of your data
• Rectification: Correct inaccurate data
• Erasure: Request deletion of your data
• Restriction: Limit processing of your data
• Portability: Receive data in portable format
• Objection: Object to processing based on legitimate interest
• Withdraw consent: For consent-based processing

To exercise these rights, contact us at privacy@winsclose.com. We will respond within 30 days.

10. Data Security

We implement appropriate technical and organizational measures to protect your data, including:

• Encryption in transit and at rest
• Access controls and authentication
• Regular security assessments
• Staff training on data protection

11. International Transfers

Some data may be processed outside the EU/EEA by service providers with adequate safeguards (Standard Contractual Clauses, adequacy decisions).

12. Updates

We may update this policy periodically. Material changes will be communicated through our website.

13. Complaints

You have the right to lodge a complaint with the Norwegian Data Protection Authority (Datatilsynet) if you believe we have mishandled your personal data.

14. Contact Information

For privacy-related questions, contact our Data Protection Officer:
Email: privacy@winsclose.com