Privacy Policy

Win Elements LLC · Effective 1/25/2026 · Last Updated 7/22/2026

Win Elements LLC (“Win Elements,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains what information we collect through winelements.com (the “Site”) and our software services — MySafePouch (mysafepouch.com), SafePouchPass (safepouchpass.com), and Sleedu (sleedu.com) (the “Software Services”) — how we use it, and the choices you have.

01Information We Collect

On the winelements.com store

• Order information: name, billing and shipping address, email, phone number, and payment information when you make a purchase. Payment card details are processed by our payment processor and are not stored on our servers.
• Account information: if you create an account, your login credentials and order history.
• Contact and quote requests: information you submit through contact forms, quote requests, sample requests, or live chat.
• Email signups: your email address and any preferences you provide when subscribing to updates or downloading resources.

In the Software Services (school accounts)

• Staff account data: staff names, usernames, and encrypted passwords created by your school.
• Student roster data: student names and the school’s own student ID numbers — only if the school chooses to upload a roster. The services also work without a roster.
• Operational records: records created by school staff during the school day, such as pouch inventory entries, intervention logs, and hall pass records.
• What we do NOT collect in the Software Services: photos, home addresses, grades, test scores, disciplinary records outside the service’s own logs, or sensitive demographic data.

Collected automatically (all sites)

• Usage data: pages visited, links clicked, referring pages, and general interaction with our sites.
• Device data: IP address, browser type, device type, and operating system.
• Cookies and similar technologies: see Section 6.

02How We Use Information

• Process and fulfill orders, including shipping, receipts, and customer service
• Provide, operate, and secure the Software Services for your school
• Respond to inquiries, quote requests, and sample requests
• Send transactional emails (order confirmations, shipping notices, service notices)
• Send marketing emails if you have signed up or purchased from us, with an unsubscribe link in every message — we do not send marketing to student contacts
• Improve our sites, products, and services
• Prevent fraud and comply with legal obligations, including tax and accounting requirements

03How We Share Information

We do not sell your personal information. We share information only with:

• Service providers who help us operate: payment processing, shipping carriers, email and CRM services, website hosting (including Amazon Web Services, where Software Service data is stored in the United States, encrypted at rest), and analytics. These providers may access information only as needed to perform their services. AWS is the sole subprocessor for Software Service data.
• Legal compliance: when required by law, subpoena, or legal process, or to protect the rights, safety, or property of Win Elements or others.
• Business transfers: in connection with a merger, acquisition, or sale of assets, in which case this policy will continue to apply to your information and schools will be notified as required by applicable student privacy law.

04Email Marketing

If you subscribe to our emails or make a purchase, we may send you information about products, funding resources for schools, and company updates. You can unsubscribe at any time using the link in any email or by contacting us. Transactional emails related to your orders and services will still be sent.

05Data Retention

We retain order and transaction records as required for tax, accounting, and legal purposes. We retain marketing contact information until you unsubscribe or ask us to delete it. Software Service data is retained while your school’s account is active and deleted within thirty (30) days of cancellation, including from backups. You may request deletion as described in Section 8.

06Cookies

Our sites use cookies and similar technologies for:

• Essential functions: cart, checkout, login, and session security (these cannot be disabled without breaking the sites)
• Analytics: understanding how visitors use our sites so we can improve them
• Preferences: remembering your settings

You can control cookies through your browser settings. Disabling essential cookies may prevent purchases or logins from completing. The Software Services do not use advertising cookies or third-party ad trackers.

07Children’s Privacy

The winelements.com store is intended for adults — school officials, educators, and parents. It is not directed at children under 13, and we do not knowingly collect personal information from children under 13 through the store. If you believe a child has provided us personal information through the store, contact us and we will delete it.

The Software Services handle student information only at the direction of schools, under FERPA’s school-official framework, COPPA’s school-consent provisions, and applicable state student privacy laws (including California’s SOPIPA and AB 1584). Student accounts and records exist only where a school creates them; we do not permit students to create independent consumer accounts, and we do not knowingly collect student information outside a school relationship.

08Your Privacy Rights

California residents (CCPA/CPRA)

• Know what personal information we collect, use, and disclose
• Request deletion of personal information, subject to legal exceptions
• Correct inaccurate personal information
• Opt out of the sale or sharing of personal information — we do not sell or share personal information as those terms are defined under California law
• Non-discrimination for exercising these rights

To exercise these rights, contact us at hello@winelements.com. We will verify your request using the information associated with your account or orders. You may designate an authorized agent to make requests on your behalf.

Students, parents, and school records

Requests concerning student records in the Software Services should be directed to your school or district, which owns and controls that data. We support schools in fulfilling parent and eligible-student requests under FERPA, and will refer any request we receive directly to the appropriate school.

Other states

Residents of other states with comprehensive privacy laws may have similar rights. Contact us to exercise them, and we will honor requests as required by applicable law. We honor Global Privacy Control (GPC) signals where required by law.

09Data Security

We use commercially reasonable safeguards to protect your information, including HTTPS encryption on all pages, encryption at rest for Software Service databases (AES-256), PCI-compliant payment processing through our payment provider, and database-level isolation between school accounts. Within Win Elements, access to school data is limited to the founder for support and operations. No method of transmission or storage is completely secure, and we cannot guarantee absolute security; in the event of a breach affecting your data, we will notify affected schools and individuals as required by law.

10Third-Party Links

Our sites may link to third-party websites, including funding resources and government pages. We are not responsible for the privacy practices of those sites. Review their privacy policies separately.

11Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised “Last Updated” date. Material changes affecting school data will be communicated to school account holders directly, consistent with our data privacy agreements.

12Contact Us