COOKIE POLICY
winari.com | Last updated: 2026-06-23
This Cookie Policy explains how 3-102-949565 SOCIEDAD DE RESPONSABILIDAD LIMITADA, a company registered in accordance with the Law of Costa Rica with the registered address at Province 01 San Jose, County 02 Escasu, San Rafael, Guachipelin, 400 Meters North of Construplaza, Latitud Norte Building, Third Floor, In the Offices of Quatro Legal, and company registration number 3-102-949565 (the “Company”, “we”, “us”, “our”), which is licensed by the Tobique Gaming Commission (the “Commission”) since 13 Feb 2026 to offer services under license number 0000146 according to the TGC Gaming Act 2023, uses cookies and similar technologies on winari.com (the “Website”).
This Cookie Policy forms part of, and should be read together with, our Terms and Conditions and our Privacy Policy. Capitalised terms not defined here have the meaning given to them in the Terms and Conditions. In the event of any conflict between this Cookie Policy and the Terms and Conditions, the Terms and Conditions shall prevail. This Cookie Policy is published in English, which is the official and governing language; in the event of any conflict between the English version and any translation, the English version shall prevail.
1. About this Cookie Policy
1.1 This Cookie Policy describes the cookies and similar technologies used on the Website, why we use them, the categories involved, the lawful basis for their use, and how you can manage your choices.
1.2 Cookies are one of the ways in which we collect the “electronic footprint” and customer device information that the Commission requires licensees to elicit, record and maintain. For that reason, certain cookies and identifiers are used for regulatory and compliance purposes and not merely for convenience.
1.3 The processing of any personal data collected through cookies is governed by our Privacy Policy. This Cookie Policy explains the technologies; the Privacy Policy explains your data-protection rights and how we handle personal data.
2. What are cookies and similar technologies
2.1 Cookies are small text files placed on your device when you visit a website. They may be “first-party” (set by us) or “third-party” (set by our service providers), and “session” (deleted when you close your browser) or “persistent” (remaining for a defined period).
2.2 “Similar technologies” include pixels and web beacons, local and session storage, software development kits (SDKs), device and browser identifiers, fingerprinting techniques and server log files. In this Cookie Policy, references to “cookies” include these similar technologies unless stated otherwise.
2.3 Together with data such as your IP address, device or computer identifier and other technical data, the information collected through cookies forms part of your electronic footprint, which we are required to record in connection with your registration and your gambling transaction history.
3. Why we use cookies
We use cookies for the following purposes:
• Operating the Website and delivering the Services, including page loading, navigation and core functionality.
• Account registration, secure login, authentication and session management.
• Identity and age verification and KYC/AML compliance, including detecting attempts to provide false or inconsistent information.
• Collecting and recording the electronic footprint and customer device details that we are required to maintain in our system audit log.
• Geolocation and enforcement of restricted jurisdictions, including detection of VPNs, proxies and IP-masking tools.
• Security, fraud prevention, payment integrity and transaction logging.
• Responsible gambling, including applying limits and reality checks, enforcing self-exclusion and operator-imposed exclusion, and identifying linked accounts.
• Remembering your preferences and settings (such as language, currency and display).
• Analytics and performance measurement to improve the Website.
• Marketing and campaign measurement, where you have consented.
• Regulatory reporting and record-keeping.
4. Categories of cookies we use
4.1 Strictly necessary (essential) cookies are required for the Website to function and for us to identify you, secure your Account, enforce jurisdiction and age restrictions, prevent fraud and comply with our regulatory obligations. These cannot be switched off in our systems. If you block them, we may be unable to register or verify you, secure your Account, or provide the Services.
4.2 Functional and preference cookies may be used to remember choices such as language, currency, display settings, device preferences and other settings that improve the usability of the Website. These cookies are not used to override age, identity, jurisdiction, responsible-gambling, AML/KYC or fraud-prevention controls.
4.3 Analytics and performance cookies may be used to understand how the Website is accessed and used, measure performance, identify technical issues, improve navigation and assess whether Website features operate correctly. Where analytics cookies are not strictly necessary, they are used only where we have a lawful basis and, where required, your consent.
4.4 Marketing and campaign-measurement cookies may be used to measure campaigns, understand whether promotional communications are effective and avoid showing irrelevant or repeated messages. These cookies are used only where permitted by applicable law and, where required, where you have consented. They must not be used to send marketing to customers who are self-excluded, operator-excluded or subject to responsible-gambling closure.
4.5 Compliance, security, geolocation, fraud-prevention and regulatory-record cookies and identifiers may be used to verify registration information, support age and identity checks, enforce restricted-jurisdiction rules, detect VPNs, proxies and IP-masking tools, identify linked or duplicate Accounts, protect payment integrity, support responsible-gambling controls and maintain the audit logs and transaction records required under the Tobique framework.
5. Cookies, your electronic footprint and record-keeping
5.1 As a licensee, we are required to elicit and record background information (your electronic footprint) at registration – such as IP address, computer/device identifier, internet cookies and other relevant technical data – and to log customer device details as part of your gambling transaction history.
5.2 Because of this, some cookies and identifiers are collected and retained for compliance, fraud-prevention and audit purposes. Where information collected through cookies forms part of records we are required to keep, it is retained in accordance with our record-keeping obligations, which require customer transactional information to be kept for at least five years from the date of your last activity, and KYC/CDD records to be kept for at least five years after the business relationship ends.
5.3 Such records are maintained securely with an adequate audit trail and protected against unauthorised access, use, disclosure, alteration or destruction.
6. Third-party cookies and recipients
6.1 Some cookies are set by trusted third parties that provide services to us, which may include payment and cryptocurrency providers, game and content providers, KYC/AML and fraud-prevention providers, identity-verification and geolocation providers, analytics providers, hosting and content-delivery networks, and our consent-management platform.
6.2 These third parties process information under their own policies and may use cookies for their own purposes. We recommend you review their cookie and privacy notices.
6.3 Information collected through cookies may be disclosed to the recipients described in Section 6 (Recipients and Access to Data) of our Privacy Policy, including hosting, IT and security providers, game providers, payment providers, crypto PSPs, data analytics providers, KYC/AML/sanctions and fraud-prevention providers, customer support providers, marketing partners where permitted, group companies and professional advisers. It may also be disclosed to the Tobique Gaming Commission, the Direct Licensee, financial intelligence units, law enforcement, courts, tax authorities, payment schemes, fraud-prevention networks, sports-integrity bodies and approved alternative dispute resolution entities, where permitted or required.
7. Legal basis and your consent
7.1 Strictly necessary cookies are used because they are required to provide the Services you request, to protect the security and integrity of the Website, and to comply with our legal and regulatory obligations. They do not require your consent.
7.2 Analytics, marketing and other non-essential cookies are used only where we have a lawful basis and, where required by applicable law, your consent. Where the Website provides a cookie notice or other consent mechanism, your choices will be recorded and applied. Where an on-site preference centre or purpose-by-purpose cookie settings are not available, you can control or withdraw permission for non-essential cookies through your browser or device settings, or by contacting Customer Support where your request relates to cookies or identifiers that we can reasonably control.
7.3 Withdrawing consent to non-essential or marketing cookies will not be used as a ground to refuse to provide the core Services to you, subject to applicable legal and regulatory requirements.
7.4 Withdrawing consent does not affect cookies already used while consent was in place, and does not remove strictly necessary cookies.
8. How to manage cookies
8.1 When you first visit the Website, any cookie notice or banner made available on the Website will explain the available choices for non-essential cookies. The Website may not provide purpose-by-purpose customisation or an on-site preference centre. In that case, browser and device settings are the main way to block, delete or restrict non-essential cookies and similar technologies.
8.2 Most browsers also allow you to block or delete cookies through their settings. Because controls differ between browsers and devices, please refer to your browser’s help function. You can also manage mobile identifiers through your device settings.
8.3 Blocking or deleting strictly necessary cookies will affect how the Website works. In particular, it may prevent registration, secure login, identity and age verification, geolocation and jurisdiction checks, and may make it impossible for us to provide the Services or to meet our regulatory obligations.
8.4 We honour recognised browser-level signals where required by applicable law.
9. Data protection, security and retention
9.1 Personal data collected through cookies is processed as described in our Privacy Policy.
10. International transfers
10.1 Where information collected through cookies is transferred to, or accessed from, a country other than the one in which you are located, including transfers outside the European Economic Area, we protect it consistently with our Privacy Policy and applicable data-protection requirements. Where required by applicable law, safeguards may include adequacy decisions, standard contractual clauses, data-processing agreements, contractual confidentiality obligations, supplier due diligence, access controls, encryption and other technical and organisational security measures.
11. Changes to this Cookie Policy
11.1 We may update this Cookie Policy from time to time. The current version will always be published on the Website. Where changes are significant, we will notify customers and keep records of how and when the notification was given.
12. Contact and complaints
12.1 If you have questions about this Cookie Policy or how we use cookies, you can contact Customer Support through the channels shown on the Website, which are available 24/7. [email protected]
12.2 If a complaint about the use of cookies or your data remains unresolved to your satisfaction within two months, it may be referred to an approved alternative dispute resolution (ADR) entity, such as Egis (via egis-adr.com), in accordance with our Terms and Conditions and Tobique rules.