Privacy Policy

This Privacy Policy describes how Winkly ("we," "us," or "our") collects, uses, and protects information when you use our website at getwinkly.com and our learning platform (collectively, the "Service").

We take privacy seriously — especially when it comes to children. Please read this policy carefully.

1. Who We Are

Winkly is an AI literacy education platform for children ages 6–14, operated by Tristan Hakert, a sole proprietor doing business as "Winkly," based in Dallas, Texas, United States. Tristan Hakert is the data controller responsible for personal information processed through the Service.

Our online reseller Paddle.com is the Merchant of Record for all purchases made through the Service and acts as an independent data controller for payment, billing, tax, and fraud-prevention data it collects directly from buyers.

For privacy questions, contact us at: winklyhelp@gmail.com

2. COPPA Compliance — Children's Privacy

Winkly is designed for use by children under the age of 13 under the direct supervision and with the explicit consent of a parent or legal guardian. We comply with the Children's Online Privacy Protection Act (COPPA).

What this means:

• Accounts are created by parents or legal guardians, not by children directly
• We do not knowingly collect personal information from children under 13 without verifiable parental consent
• Parents provide consent during the account creation process on behalf of their child
• Parents may review, update, or request deletion of their child's information at any time by contacting us at winklyhelp@gmail.com
• We do not use children's data for behavioral advertising
• We do not allow children to make their personal information publicly available

If you believe we have inadvertently collected personal information from a child under 13 without proper parental consent, please contact us immediately at winklyhelp@gmail.com and we will delete that information promptly.

3. Information We Collect

A. Information You Provide

When a parent or guardian creates an account, we collect:

• Parent or guardian full name
• Parent or guardian email address
• Password (stored securely and encrypted)
• Child's first name
• Child's age
• Selected learning track (Explorer, Builder, or Creator)
• Payment information (processed securely by Paddle — we do not store full card details)

When you contact our support team, we collect your name, email address, and the content of your message.

B. Information Collected Automatically

• Device type and operating system
• Browser type and version
• IP address
• Pages visited and time spent on the Service
• Lesson progress and completion data
• XP earned and streak information

We use cookies and similar tracking technologies to maintain your session and remember your preferences. You can disable cookies in your browser settings, but this may affect the functionality of the Service.

C. Information We Do Not Collect

• Social Security numbers or government IDs
• Precise geolocation data
• Biometric data
• Sensitive personal information beyond what is listed above

4. How We Use Your Information

• Create and manage your account
• Provide access to the Winkly learning platform
• Track and display your child's lesson progress and achievements
• Process payments and manage your subscription
• Send transactional emails such as account confirmation and password reset
• Respond to support requests
• Improve and develop the Service
• Comply with legal obligations

We do not sell your personal information to third parties. We do not use your information for targeted advertising.

5. How We Share Your Information

A. Service Providers

We share information with trusted third-party service providers who help us operate the Service, including:

• Supabase — database and authentication infrastructure
• Paddle — payment processing and subscription management
• Anthropic — AI API powering the Wink chatbot (conversation content is processed to generate responses)
• Lovable — hosting and deployment infrastructure

These providers are contractually required to use your information only to provide services to us and to protect your information appropriately.

B. Legal Requirements

We may disclose your information if required to do so by law, court order, or governmental authority, or if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or investigate fraud.

C. Business Transfers

If Winkly is acquired by or merged with another company, your information may be transferred as part of that transaction. We will notify you before your information is transferred and becomes subject to a different privacy policy.

We do not sell, rent, or trade your personal information to any third party for their own marketing purposes.

6. Data Retention

We retain your account information for as long as your account is active or as needed to provide the Service.

If you cancel your subscription, we retain your account data for 90 days in case you choose to reactivate. After 90 days, your personal data is deleted from our active systems.

Lesson progress data and XP records are retained as long as your account exists.

You may request deletion of your account and all associated data at any time by contacting winklyhelp@gmail.com.

7. Data Security

• Encrypted connections (HTTPS/TLS) for all data transmission
• Encrypted password storage
• Secure authentication through Supabase
• Payment processing through Paddle, which is PCI DSS compliant

No method of transmission over the internet or electronic storage is 100% secure. While we use commercially reasonable means to protect your information, we cannot guarantee absolute security.

8. Your Rights and Choices

You have the right to:

• Access the personal information we hold about you
• Correct inaccurate information
• Request deletion of your account and personal data
• Opt out of non-essential communications
• Withdraw consent for your child's data at any time

Parents and guardians have the additional right to review all personal information collected about their child, request deletion of their child's information, and refuse further collection or use of their child's information.

To exercise any of these rights, contact us at winklyhelp@gmail.com. We will respond within 30 days.

9. Third-Party Links

The Service may contain links to third-party websites or resources. We are not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party sites you visit.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by sending an email to the address associated with your account and by updating the "Last Updated" date at the top of this page.

Your continued use of the Service after any changes constitutes your acceptance of the updated policy.

11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Tristan Hakert (dba Winkly)
Dallas, Texas, United States
Email: winklyhelp@gmail.com
Website: getwinkly.com

For COPPA-related inquiries or to exercise parental rights regarding your child's data, please email winklyhelp@gmail.com with the subject line "COPPA Request."