WINONA, INC. PRIVACY POLICY

Changes to This Privacy Policy

We may occasionally update this Privacy Policy. When we do, we will revise the "last updated" date at the top of the Privacy Policy. Any revised Privacy Policy will be effective when posted. We recommend that you periodically review our Privacy Policy for updates.

Children's Privacy

The Winona website and Services are not intended for children under the age of 18 years, and Winona does not knowingly collect any information from children under 18 years old through its website. If the parent or guardian of a child under 18 believes that the child has provided us with any information, the parent or guardian of that child should contact us if they want this information deleted from our files. If Winona obtains knowledge from any source that it has information about a child under 18 in retrievable form in its files, we will delete that information from our existing files.

Sources of Personal Information

We may collect Personal information about you from the following sources:

• Directly from you. We may collect personal information you provide to us directly, such as when you contact us through our website; sign up for offers or newsletters; communicate with us; place or customize orders; or sign up for an account or other services.
• Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you; such as through cookies and other tracking technologies, when you interact with our Services. This may include information about how you use and interact with our Services, information about your device, and internet usage information. For more information about cookies and other tracking technologies, please see the "Our Use of Cookies and Analytical Tools" below.
• From third parties. We may collect personal information from third parties, such as service and content providers, our affiliated companies and subsidiaries, business partners, data brokers, social media companies or other parties who interact with us.
• From publicly available sources. We may collect personal information about you from publicly available sources, such as public profiles and websites.

Personal Information We Collect

We may collect the following types of personal information:

• Identifiers, such as your name, email address, physical address, telephone number, other business contact information, and device identifiers (e.g., cookie IDs and IP address).
• Records about you, such as signatures; physical characteristics or a description of you; the content, timing, and method of communications you have with us, such as online chats, calls, and emails; and information you share with or upload to our Services.
• Demographic information, such as age (including birthdates) and gender.
• Commercial information, such as information related to your transactions; products or services purchased, obtained, or considered; subscription information; or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information, such as your browsing history, search history, preference information (including marketing and purchasing preferences), account settings (including any default preferences), and other information regarding your interactions with and use of the Services. For more information about cookies and other device data, please see the "Cookies and Other Tracking Technologies" section of this Privacy Policy.
• Non-precise geolocation data, such as your approximate location based on your IP address.
• Audio, electronic, visual, or other sensory information, such as photographs taken at events, call recordings, and video recordings of our premises.
• Inferences drawn from any of the information we collect to create a profile about you reflecting your preferences or behavior, including to assess the level of interest in our products and services based on frequency of visits and contact and determine your preferred frequency for receiving offers.
• Sensitive personal information, including the following:
  • Account log-in information.
  • Information about your health.
  • Racial or ethnic origin
  • Information concerning your sexual orientation.

How we use your information

We may use personal information for the following purposes:

• To provide you or your company with products and services, such as making our Services, products, and services available to you; registering, verifying, and maintaining your account with us; providing and delivering you the goods and services you or the company that you represent requests; providing customer service; processing or fulfilling orders and transactions (including processing payments); verifying customer information and eligibility for certain programs or benefits; communicating with you (including soliciting feedback and responding to requests, complaints, and inquiries); hosting informational sessions; and providing similar services or otherwise facilitating your relationship with us.
• For our internal business purposes, such as day-to-day operation of our business; maintaining internal business records, such as accounting, document management, and similar activities; enforcing our policies and rules; management reporting; auditing; and IT security and administration.
• For our internal research and product improvement purposes, such as verifying and maintaining the quality and safety of our products and services; improving our products and services; designing new products and services; evaluating the effectiveness of our advertising and marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
• For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers', and other third parties' safety, property or rights; detecting, preventing, and responding to security incidents and health and safety issues (including managing the spread of communicable diseases); and protecting against malicious, deceptive, fraudulent, or illegal activity.
• In connection with a corporate transaction, such as if we acquire assets of another business or sell or transfer all or a portion of our business or assets, including through a sale in connection with bankruptcy and other forms of corporate change.
• For marketing, such as marketing our products or services or those of our affiliates, business partners, or other third parties. For example, we may use personal information we collect to personalize advertising to you (including by developing product, brand, or services audiences and identifying you across devices/sites); to analyze interactions with us or our Services, or to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars. You can unsubscribe to our email marketing via the link in the email or by contacting us using the contact information at the end of this Privacy Policy.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

How We Disclose Your Personal Information

We may disclose personal information to third parties, including the categories of recipients described below:

• Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.
• Medical professionals and pharmacies that provide services to you via the Services
• Service providers that work on our behalf to provide the products and services you request or support our relationship with you, such as IT providers, internet service providers, web hosting providers, data analytics providers, and companies that provide business support services, financial administration services, marketing, advertising, and communications services, security services, fraud prevention and detection services, legal services, and other professional services.
• Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
• Vendors necessary to complete transactions you request, such as payment processors and shipping companies.
• Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, including to respond to law enforcement requests; as required by applicable law, court order, or government regulations; and when we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Winona, our users, or others.
• In connection with a corporate transaction, such as if we acquire assets of another business or sell or transfer all or a portion of our business or assets, including through a sale in connection with bankruptcy and other forms of corporate change.
• Entities to which you have consented to the disclosure.

Your Privacy Rights

Depending on where you live, you may have certain rights regarding your Personal Data ("Personal Data" or "Personal Information"). This section describes your rights and how you may exercise them.

A. Rights Available to All Users

You may have the following rights:

• Right to Know. You may have the right to request that we disclose to you the Personal Data we collect, use, disclose, or sell about you.
• Right to Access. You may have the right to request access to your Personal Data.
• Right to Delete. You may have the right to request that we delete Personal Data that we have collected from you.
• Right to Correct. You may have the right to request that we correct inaccurate Personal Data that we maintain about you.
• Right to Opt Out of Sales and Sharing for Targeted Advertising. You may have the right to opt out of (i) the sale or sharing of your Personal Data and (ii) targeted advertising.
• Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to limit the use and disclosure of Sensitive Personal Information.

You may exercise any of the rights available to you via our webform https://bywinona.com/contact/, or by emailing us at hello@bywinona.com.

In order to fully exercise the Right to Opt Out of Sales/Sharing/Targeted Advertising you must undertake both of the following steps:

1. Submit an Opt Out of Sales/Sharing/Targeted Advertising request through our webform https://bywinona.com/contact/.
2. Disable the use of advertising cookies and other tracking technologies in the preference center here. You must complete this step on each of our websites from each browser and on each device that you use. These steps are necessary so that we can place a first-party cookie signaling that you have opted out on each browser and each device you use. Please note:
   • If you block cookies, we will be unable to comply with your request to opt out of sales/sharing/targeting with respect to device data that we automatically collect and disclose to third parties online using cookies, pixels, and other tracking technologies.
   • If you clear cookies, you will need to disable the use of all advertising cookies and tracking technologies in the preference center again on each browser on each device where you have cleared cookies.

To the extent required by law, we will honor opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object. We will process opt-out preference signals at the browser level.

We will not discriminate against you for exercising your privacy rights.

Nevada residents: Individuals may contact us at hello@bywinona.com to inquire about your right to opt out of the sale of your Personal Data.

Verification: In order to process rights requests, we may need to obtain information to locate you in our records or verify your identity depending on the nature of the request. In most cases we will collect some or all of the following data elements: first and last name, email address, and telephone number. In some cases, we may request different or additional information, including a signed declaration that you are who you say you are, and will inform you if we need such information.

Authorized Agents: Authorized agents may exercise rights on behalf of you by submitting a request by email at hello@bywinona.com and indicating that they are submitting the request as an agent. We may require the agent to demonstrate authority to act on behalf of you by providing signed permission from you. We may also require you to verify your own identity directly with us or to directly confirm with us that you provided the authorized agent permission to submit the request.

Appeal: If we deny your rights request, you may have the right to appeal. To submit an appeal, contact us by email at hello@bywinona.com. We will inform you in writing our response to your appeal.

B. Additional Data Processing Disclosures for California Residents

In addition to the disclosures above, this section provides supplemental information about how we process Personal Data. These additional disclosures apply only to individuals who reside in California as required by the California Consumer Privacy Act ("CCPA").

Disclosure of Personal Data

Although we have not "sold" Personal Data for money in the past 12 months, we engage in routine practices with our Digital Properties involving third parties that could be considered a "sale" or "sharing" as defined under California law. We do not knowingly sell or share any Personal Data of minors under the age of 16.

Below please find a chart detailing the categories of Personal Data we collected and with whom it was sold, shared, or disclosed for a business purpose in the past 12 months.

California Shine the Light: If you are a California resident, you may opt out of sharing your Personal Data subject to California Civil Code §1798.83 (the "Shine the Light law") with third parties for those third parties' direct marketing purposes by emailing us at hello@bywinona.com.

Links to Third-Party Websites

The Services may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Contact Us

If you have questions regarding this Privacy Policy, our handling of your personal information, or would like to request more information or exercise a data right, please contact us using the webpage at hello@bywinona.com or by telephone at (844) 929-1586