Privacy Policy

Effective date: February 27, 2026

We collect only the information needed to operate CWYN, process transactions, deliver digital products, provide support, and maintain security/compliance.

1) Data categories, purposes, recipients, and retention

Category	Examples	Primary purposes	Recipient types	Retention baseline
Identifiers & contact	Name, email, support identifiers	Account/order communication, support	Hosting, customer support tools, communications vendors	Active customer lifecycle + legal/operational need
Commercial/order data	Products purchased, order ID, entitlement status, timestamps	Fulfillment, accounting, dispute handling, fraud review	Payments processors, hosting/database vendors	Accounting/dispute/legal retention periods
Payment metadata	Processor IDs, payment status, risk outcomes	Payment processing, chargeback handling, abuse prevention	Payment processors and anti-fraud services	As required for financial controls and legal recordkeeping
Security/device telemetry	IP/country signals, request logs, abuse events	Security monitoring, rate limiting, incident response	Hosting/security tooling providers	Limited-duration operational/security windows unless needed for investigation
Support communications	Messages, troubleshooting details, attachments	Resolve support issues and improve service quality	Support/communications vendors	Until resolution + reasonable service-quality review period

2) Sources of personal information

Directly from you (checkout, support, forms)
Payment/service providers (transaction state and risk events)
Automated telemetry from site interactions (security + reliability)

3) Sensitive data handling

CWYN does not intentionally collect highly sensitive personal information categories unless required for legal or fraud-prevention reasons. CWYN does not store full card numbers or CVV. If sensitive data is received unintentionally (e.g., in support messages), access is restricted and the data is deleted or minimized where feasible.

4) Sale/share/targeted ads + GPC

CWYN does not sell personal information for money and does not share personal information for cross-context behavioral advertising. Global Privacy Control (GPC) and similar universal opt-out signals are honored where legally required.

5) U.S. state rights and operational process

Depending on your state, you may have rights to access, correction, deletion, portability, opt-out (where applicable), and appeal.

Submit requests: privacy@cwyn.com with subject “Privacy Request.”
Verification: We may request identity/authority proof before acting.
Response target: within applicable legal timelines.
Appeals: Send “Privacy Appeal” to privacy@cwyn.com if a request is denied.
Authorized agents: accepted where lawful with proof of authority.
Nondiscrimination: CWYN does not discriminate for exercising applicable privacy rights.

6) International transfers

Data may be processed in multiple countries. Where required, we apply contractual and technical safeguards for cross-border transfers and enforce least-privilege access controls.

7) Children

This site is not intended for children under 13, and we do not knowingly collect data from children.

8) Security

We use administrative and technical safeguards (including access controls and logging). No method of transmission or storage is 100% secure.

9) Changes

We may update this policy from time to time. Changes are effective when posted with a revised effective date.

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