Privacy Policy

Information you give us:

• Contact details — name, email address, phone number, shipping and billing address.
• Order information — what you bought, order history, subscription plan and status.
• Payment information — handled by our payment processors (such as Shopify Payments and the payment methods offered at checkout). We do not see or store your full card number.
• Account information — login details and subscription preferences.
• Communications — emails, texts, chat messages, contact-form submissions, and support conversations.
• Reviews and survey answers — if you choose to leave them.

Information collected automatically when you use the Site:

• Device and usage data — IP address, browser and device type, browser user agent, pages viewed, links clicked, actions taken (like adding to cart or purchasing), referring URLs, and general (city-level) location inferred from your IP address.
• Cookies, pixels, web beacons, and similar technologies — small files and code that keep your cart working, remember you, measure the Site, and support advertising. See Section 4.

Information from other sources:

• Our commerce and service platforms (for example Shopify and our subscription platform) share information with us to run your account and orders.
• Advertising and analytics partners may provide information about how you interacted with our ads.

We do not ask for, and ask that you do not submit, information about medical conditions or diagnoses. Please keep support messages to what we need to help you.

• To provide the service: process orders and payments, manage subscriptions and renewals, ship products, and run your account.
• To support you: answer questions, handle refunds and our guarantee, and keep records of support conversations.
• To communicate: send transactional messages (order confirmations, shipping updates, a reminder email before every recurring subscription charge, and required renewal notices) and, with your consent or as permitted by law, marketing email and text messages.
• To improve and protect: understand how the Site is used, test and improve pages and offers, prevent fraud and abuse, and keep the Site secure.
• To advertise: show you Winks ads on other platforms, reach people who may like Winks, and measure whether our ads work. See Section 4 for the specific tools.
• To comply with law: tax, accounting, consumer-protection, and other legal obligations, including keeping records of subscription consents.

The table below summarizes, in the categories used by the California Consumer Privacy Act, what we have collected in the last 12 months, whether we "sell" or "share" it (as those terms are defined in California law — "sharing" includes cross-context behavioral advertising through ad pixels), and who receives it.

• Category: Identifiers
  Examples: Name, email, phone, address, IP address, device IDs
  Sold or shared?: Yes — shared with advertising partners (including in hashed form for ad matching)
  Disclosed to (for business purposes): Commerce platform, subscription platform, email/SMS provider, support platform, shipping and fulfillment providers, advertising and analytics partners
• Category: Customer records
  Examples: Billing and shipping details; payment handled by processors
  Sold or shared?: No
  Disclosed to (for business purposes): Commerce platform, payment processors, fulfillment providers
• Category: Commercial information
  Examples: Products purchased, order value, order and subscription history
  Sold or shared?: Yes — purchase and order events are shared with advertising partners for ad measurement and targeting
  Disclosed to (for business purposes): Commerce platform, subscription platform, email/SMS provider, advertising and analytics partners
• Category: Internet or network activity
  Examples: Pages viewed, clicks, browsing behavior on the Site
  Sold or shared?: Yes — shared with advertising and analytics partners
  Disclosed to (for business purposes): Analytics and advertising partners, A/B testing tools
• Category: General geolocation
  Examples: City-level location from IP address
  Sold or shared?: Yes — shared with advertising and analytics partners
  Disclosed to (for business purposes): Analytics and advertising partners
• Category: Inferences
  Examples: Preferences we draw from your purchases and browsing
  Sold or shared?: No — we do not share our internal inferences (advertising platforms may draw their own inferences from the data shared with them, as described in Section 4)
  Disclosed to (for business purposes): Internal analytics
• Category: Audio/electronic communications
  Examples: Support emails, chats, texts
  Sold or shared?: No
  Disclosed to (for business purposes): Support platform, email/SMS provider
• Category: Sensitive personal information
  Examples: Account log-in credentials; consumer-health-related inferences (see Section 9)
  Sold or shared?: No — we do not sell sensitive personal information, and we do not use it beyond what the law permits without asking
  Disclosed to (for business purposes): Commerce platform (credentials); see Section 9

We do not collect biometric information, precise geolocation, or government identifiers, and we do not use or disclose sensitive personal information for purposes that require a "Limit the Use of My Sensitive Personal Information" link. Your text-message opt-in information is excluded from every sharing category above — see Section 5.

We use cookies, pixels, web beacons, and similar technologies to:

• keep the Site working (cart, checkout, log-in) — these are essential;
• measure and improve the Site (analytics and A/B testing); and
• advertise Winks (ad tools that help us reach you and people like you on other platforms).

Because our advertising tools involve disclosing identifiers, browsing activity, and purchase events to ad platforms, they count as "selling" or "sharing" personal information under some state laws. You can opt out at any time — see Your Privacy Choices and the opt-out links below. You can also block or delete cookies in your browser settings; essential cookies are required for checkout to work.

Meta (Facebook and Instagram) advertising

The Site uses cookies, pixels, web beacons, and similar technologies from third parties, including Meta Platforms, Inc. Specifically, we use:

• the Meta Pixel, which runs in your browser on the Site; and
• the Meta Conversions API, which sends information to Meta directly from our servers (server-side sharing your browser cannot show you — so we are telling you here).

Through these tools we share with Meta: identifiers and device information, your IP address and browser user agent, pages you view, and actions you take on the Site (such as add-to-cart and purchase events, including order value). To improve match quality ("advanced matching"), we may also share hashed versions of your email address, phone number, name, and address — hashing converts them into a code before they are sent. Meta uses this information to provide measurement services and to target and deliver ads, and we use it for advertising (including retargeting and reaching similar audiences), ad measurement, and attribution.

You can opt out of interest-based advertising from Meta and other participating companies at aboutads.info/choices, adjust your Meta ad preferences at facebook.com/adpreferences, or opt out of our sharing entirely via Your Privacy Choices.

Google analytics and advertising

We use Google Analytics 4 (GA4) to understand how visitors use the Site. GA4 sets cookies and collects device and usage information. You can read how Google uses information from sites that use its services at policies.google.com/technologies/partner-sites.

We also use Google Ads remarketing, and we have enabled GA4's Advertising Features — specifically remarketing with GA4 audiences, Google Signals (demographics and interests reporting), and conversion measurement integrations with Google Ads. That means:

• we use the data collected on the Site (including via cookies and device identifiers) to advertise Winks online;
• third-party vendors, including Google, show our ads on sites across the Internet; and
• third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie), third-party cookies (such as Google advertising cookies), and/or device identifiers together to serve ads to you based on your past visits to the Site and to measure how our ads perform.

You can opt out of Google's personalized advertising at Google Ads Settings, block Google Analytics with the GA opt-out browser add-on, or use the industry opt-out below. On mobile devices, you can also limit ad tracking in your device settings.

Industry-wide opt-outs

• Digital Advertising Alliance: aboutads.info/choices
• Network Advertising Initiative: optout.networkadvertising.org
• Google Ads Settings: adssettings.google.com
• Google Analytics opt-out add-on: tools.google.com/dlpage/gaoptout

Global Privacy Control and what happens when you opt out

If your browser sends a Global Privacy Control (GPC) signal, we treat it as a valid request to opt out of sale/sharing and targeted advertising for that browser, automatically. When you opt out (through GPC, our Site's privacy settings, or a request), we either stop sending your data to our advertising partners or send it flagged so it may only be used in the limited ways permitted for opted-out users — Meta's "Limited Data Use" and Google's "Restricted Data Processing."

If you opt in to Winks text messages, we collect your phone number, your name if you provide it, and information about the messages we exchange (message content, delivery, and engagement). We use this information to send the messages you signed up for — marketing texts (like offers and cart reminders, only with your consent), order and shipping updates, and support replies — and for nothing else. Consent to marketing texts is never a condition of purchase.

Your mobile information will not be sold or shared with third parties for promotional or marketing purposes. Information may be shared with subprocessors that support our services (such as our text messaging provider) only to enable delivery of the messages.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, excluding aggregators and providers of the text message services.

Opting out: reply STOP to any Winks text to stop receiving texts — or opt out by any other reasonable method, including emailing support@getwinks.com or using our contact form. Reply HELP to any message for help. Message and data rates may apply. See our SMS Terms for full program terms.

We disclose personal information to:

• Service providers who run parts of the business for us under contract: our commerce platform (Shopify), our subscription platform, email and SMS (Omnisend), customer support (Richpanel), payment processors, and fulfillment and shipping providers. They may use the information only to provide services to us.
• Advertising and analytics partners — including Meta and Google, as described in Sections 3 and 4. This is the "sale"/"sharing" you can opt out of. (Your text-message opt-in data is never part of this — see Section 5.)
• Professional advisors (lawyers, accountants, insurers) where needed.
• Authorities and others when required by law, to enforce our terms, or to protect rights, safety, and security.
• A successor business if we are involved in a merger, acquisition, financing, or sale of assets; we will require the successor to honor this policy or notify you.

We do not sell personal information for money.

Depending on where you live, you may have some or all of these rights. Comprehensive state privacy laws currently active include those of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. We extend the rights below to all US customers regardless of state:

• Know / access — get a copy of the personal information we have about you, including the categories collected, the sources, and the purposes.
• Delete — ask us to delete your personal information (with legal exceptions, like completed-order records we must keep).
• Correct — fix inaccurate personal information.
• Portability — receive your information in a usable format.
• Opt out of the sale or sharing of personal information and of targeted advertising — see Your Privacy Choices. We honor Global Privacy Control signals automatically as an opt-out.
• Non-discrimination — we will never penalize you, deny you service, or change your price for exercising a privacy right.

How to exercise your rights (two ways)

1. Online: submit a request through our contact form — include the words "Privacy request" in your message — or start from Your Privacy Choices.
2. Email: write to support@getwinks.com with "Privacy Request" in the subject line.

We will confirm receipt and respond within 45 days (we may extend once by 45 days for complex requests, and we will tell you if we do). To protect your information, we verify requests by matching details you provide (such as your email address and a recent order) against our records; we may ask a follow-up question. You may use an authorized agent to submit a request — we will ask for proof of the agent's authority and may still verify your identity directly.

Appeals: if we decline a request, we will explain why, and you may appeal by replying to our decision or emailing support@getwinks.com with "Privacy Appeal" in the subject. We respond to appeals within the time required by your state's law. If you are unsatisfied after an appeal, you may contact your state Attorney General.

You can opt out of the "sale" and "sharing" of your personal information and out of targeted advertising:

• Visit Your Privacy Choices and follow the steps there;
• Turn on Global Privacy Control in your browser — we honor it automatically; or
• Email support@getwinks.com with "Do Not Sell or Share" in the subject line.

Opting out stops our disclosure of your data to advertising partners from that point forward — we either stop sending it or flag it for restricted, non-advertising processing (Section 4). You may still see Winks ads — they just will not be targeted using your data from us.

Winks is a sleep-supportive supplement, so some information we handle — like the fact that you bought a sleep product — could be considered "consumer health data" under laws such as Washington's My Health My Data Act and Nevada's consumer health data law, because it might support an inference about your health.

Here is our honest posture:

• We do not collect sensitive health details. We do not ask about medical conditions, symptoms, or diagnoses, and we ask that you not include them in messages to us. The only health-adjacent information we handle is what is inherent in selling you our product: your orders, your subscription, and your messages to us.
• We use this information to run the store — processing orders, subscriptions, support, and legally required records.
• We treat purchase data as potentially health-inferable, and we are transparent that some of it is shared for advertising. As described in Sections 3 and 4, order and purchase events (the fact and value of a purchase) are shared with our advertising and analytics partners for ad measurement and targeting. We do not share your support messages, survey answers, or any health details with advertising platforms.
• You can stop that sharing. Opt out any time via Your Privacy Choices or a Global Privacy Control signal, which we honor automatically. We do not sell consumer health data for money, and where a law requires consent before a use of consumer health data, we will ask first.
• Washington and Nevada residents may exercise the rights in Section 7 (access, deletion, withdrawal of consent) for consumer health data using the same two request methods, and may appeal as described there.

The Site is intended for adults and is directed to people 18 and older. We do not knowingly collect personal information from anyone under 13, and we do not knowingly sell or share the personal information of anyone under 16. If you believe a child has provided us personal information, contact us at support@getwinks.com and we will delete it.

Every marketing email includes an unsubscribe link. Unsubscribing stops marketing email; we will still send transactional messages about your orders and subscription (including a reminder email before every recurring charge and legally required renewal notices). For text-message choices, see Section 5.

We keep personal information only as long as we need it for the purposes described in this policy: account and order records for as long as you have an account plus the period our legal obligations require (tax, accounting, and subscription-consent records); support conversations for as long as needed to help you and improve support; and marketing data until you opt out or it is no longer needed. When information is no longer needed, we delete or de-identify it.

We use reasonable administrative, technical, and physical safeguards appropriate to the nature of the data — including encryption in transit, access controls, and vetted service providers. No method of transmission or storage is 100% secure, so we cannot guarantee absolute security; if a breach affects you, we will notify you as required by law.

We may update this policy from time to time. We will post the updated version here with a new "Last updated" date, and if the changes are material, we will tell you by email or by a notice on the Site before they take effect. We review this policy at least once every 12 months.

Questions, requests, or concerns about privacy:

Winks Sleep, Inc. Attn: Privacy 9321 East Willis Road, Suite 125 Building 2 Mesa, Arizona 85212 Email: support@getwinks.com Or use our contact form.