WINSTON RETAIL SOLUTIONS, LLC/THE APPLICATION PRIVACY POLICY

This Privacy Policy describes the policies and procedures of Winton Retail Solutions, LLC (“Winston”, "we", "our" or "us") on the collection, use and disclosure of your information via the use of the WinTell mobile application provided by Winston (the "Application"), and the photo sharing and enhancement services, features, content or applications we offer (the "Services"). We receive information about you from various sources, including: (i) if you register for the Services or download the Application, through your user account on the Services (your "Account"); and (ii) your use of the Services generally. When you use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy.

What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of personally identifiable information ("Personal Information") gathered when you are using or accessing the Services. This Privacy Policy also covers our treatment of any Personal Information that our business partners share with us or that we share with our business partners.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications ("Third Party Services") that you elect to access through the Service or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

What Information Do We Collect?

The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Information. We may collect the following types of information from our users.

Account Information:

When you create an Account, you will provide information that could be Personal Information, such as your name, username, password, date of birth, and email address. You acknowledge that this information may be personal to you, and by creating an account on the Services and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you information about our Services..

User Content:

The Services are intended to allow you to provide content to the Services, such as photos, reports, and questions. All content submitted by you to the Services may be retained by us indefinitely, even after you terminate your account. We may continue to disclose such content to our clients and other third parties in a manner that may reveal certain Personal Information, as described in this Privacy Policy.

Financial Information:

We do not currently collect any financial information.

IP Address Information and Other Information Collected Automatically:

• We may automatically receive and record information from your web browser when you interact with the Services, including your IP address and cookie information. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Services (e.g., what links you have clicked on).
• Generally, the Services automatically collect usage information, such as the number and frequency of visitors and/or user of the Application. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.

Email Communications:

We may receive a confirmation when you open an email from us.

Information Collected Using Cookies:

• Cookies are pieces of text that may be provided to your computer or mobile device through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit and use the Application and otherwise use the Services through the Internet.
• Our cookies do not, by themselves, contain Personal Information, and we do not combine the general information collected through cookies with other Personal Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your Account if you have one.
• Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave cookies active, because they enable you to take advantage of the most attractive features of the Services.
• This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.

Use of Web Beacons:

We collect certain information from your mobile device, including but not limited to the following:

• Location Information that allows us to periodically determine your location, including your location relative to certain dates and times and within third party merchant locations. Among other things, we may use and share precise location data to confirm your presence and time spent at certain locations.
• Device and Usage Information that may include (i) information specific to your mobile device (e.g., make, model, operating system, device identifier and similar information); (ii) information about your use of features, functions, or notifications on the device; and (iii) signal strength relating to WiFi or Bluetooth functionality, temperature, battery level, and similar technical data.

We may collect this information even if you are not logged in to the application.

You should be able to adjust the settings on your iOS mobile device to prevent our collection of Location Information by disabling the location services feature on your device. You should be able to adjust your settings on your Android mobile device to prevent our collection of Location Information by disabling Bluetooth and Location.

How, and With Whom, Is My Information Shared?

The Services are designed to help you share information with Winston others. As a result, some of the information generated through the Services is shared publicly or with third parties. Other than Personal Information, you should not have any expectation of privacy with respect to User Content that you provide to or through the Services.

Your Activity on the Services:

Registered users may have some of this information associated with their Accounts. Unregistered users will not have this association, but information concerning their use of the Services (such as what pages they have visited) may be tracked anonymously through the use of cookies and stored by us.

Please also remember that if you choose to provide Personal Information using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.

IP Address Information:

While we may collect and store IP address information, that information is not made public. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.

Information You Elect to Share:

You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within the Application. We are not responsible for the privacy policies and/or practices of these Third Party Services, and you are responsible for reading and understanding those Third Party Services' privacy policies. This Privacy Policy only governs information collected on the Services.

Email Communications with Us:

As part of the Services, you may occasionally receive email and other communications from us, such as communications relating to your Account. Communications relating to your Account will only be sent for purposes important to the Services, such as password recovery.

User Profile Information:

User profile information including your username and other information you enter may be displayed to other users to facilitate user interaction within the Services.

Information Shared with Our Agents:

We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our "Agents"). We may need to share Personal Information with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents.

Information Disclosed Pursuant to Business Transfers:

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

Information Disclosed for Our Protection and the Protection of Others:

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce the applicable Terms of Service, including investigation of potential violations thereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect the rights, property or safety, of us, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Ways We Disclose and Share the Information We Collect:

We share the information we collect with third-party business partners who commit to comply with applicable laws concerning their usage of the information. Our third-party business partners may use the information either for themselves or on behalf of their own business partners to:

• Operate and improve their services; and
• Carry out other purposes that are disclosed to you and to which you consent.

Is Information About Me Secure?

Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer, mobile device and browsers by signing off after you have finished accessing your Account.

We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

We otherwise store all of our information, including your IP address information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Information or otherwise.

What Information of Mine Can I Access?

If you are a registered user, you can access information associated with your Account by logging into the Services. Registered and unregistered users can access and delete cookies through their web browser settings.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 22 W. 38^th Street, 12^th Floor, New York, NY 10018..

How Can I Delete My Account?

Should you ever decide to delete your Account, you may do so by emailing support@winstonretail.com. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to us and our business partners.

What Choices Do I Have Regarding My Information?

• Most of the features of the Services require you to register and thus require you to provide certain information with respect to those features. Should you prefer to not provide any information, you do not have to register for these Services.
• You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features.
• You can delete your Account. Please note that we will need to verify that you have the authority to delete the Account, and activity generated prior to deletion will remain stored by us and may be publicly accessible.

What Happens When There Are Changes to this Privacy Policy?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email. A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.

What If I Have Questions or Concerns?

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to support@winstonretail.com. We will make every effort to resolve your concerns.

Effective Date: May 1, 2018