1. General Information
We collect data about visitors of the website, subscribers, clients and job applicants.
The words ‘we,’ ‘us,’ ‘our,’ or ‘operator’ stand for Winfinity.
We will always treat your information with the utmost care and respect.
2. Information We Collect
2.1 When you contact us through the “Contact Us” form, we ask you to fill in the contact form with your name, email, phone number (optional). We process these data for the purpose of providing you with the support and information you have requested from us and in order to maintain accurate records of the information we have received from you, given our legitimate interest in conducting our business and improving the website and our users’ experience, and in some cases in order to take the first step for entering into a contract with you.
2.3. When you become a client of Winfinity, you will get access to your personal client account, where you will be required to fill in your name/surname/bank account details/contact information/address. We prosess these data for the purpose of complying with our legal obligations arising out of our contractual relationships and ensuring the proper and correct functioning of the back-office tools available to our clients in their client accounts. The legal basis for such collection and processing of personal data is our legitimate interest and your consent.
2.4. When you apply for a job at Winfinity through our website, we collect your contact information and the personal data contained in your CV and/or cover letter in order to manage and evaluate work applications on the basis of your consent.
3. How We Use the Information We Collect
We use, store, and process the information referred to in 2.1, to:
In such cases, we will process your personal information given our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest to you. The basis for the processing of such information is your consent. You can always withdraw your consent and opt-out of receiving marketing communications from us by following the instructions provided in each of our marketing communications.
We use, store, and process the information referred to in 2.3, to:
We use, store, and process the information referred to in 2.4, to:
Apart from the mentioned above, we use the data collected to establish, exercise and defend legal claims in the event of any dispute arising between you and Winfinity.
5. Sharing and Disclosure
In certain circumstances, we may share and disclose your personal data as described below.
5.1 Compliance with the Law, Responding to Legal Requests, Preventing Harm and Protection of Our Rights
We may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorised third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and respond to claims asserted against us, (iii) to respond to requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability.
The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights and proper protection of our business against risks.
5.2 Third-Party Service Providers
We can use third-party service providers to help us provide services related to the website, as well as payment services. Service providers may be located inside or outside the European Economic Area (“EEA”).
You can always contact us to receive the full list of our service providers which process your data.
5.3 Corporate Affiliate
We may share your information, including personal information, with any member of our group of companies (this includes our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. We have established an Intra Group Data Transfer Agreement which governs any transfer of Personal data within the group of companies.
5.4 Aggregated Data
We may also share aggregated information (information about our users that we combine so that it no longer identifies or references an individual user) and other anonymised information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
5.5 Business Transfers
6. Data Subject Rights
Under the General Data Protection Regulation, you have the right to access, rectify, port, and delete some of your data. You also have the right to object to and restrict certain processing of your data. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.
You may exercise any of the rights described in this section before your data controller by sending an email to [email protected] Please note that we may ask you to verify your identity before taking further action regarding your request.
Please be aware that, while we will try to accommodate any request you make in respect of your rights, they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.
6.1 Rectification of Inaccurate or Incomplete Information
You have the right to ask us to correct inaccurate or incomplete personal information concerning you.
6.2 Data Access and Portability
You have the right to access your personal data held by us and the right to receive certain personal data in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
6.3 Data Retention and Deletion
We will retain your personal data for the period necessary to perform the contract between you and us and to comply with our legal obligations. Where it is no longer necessary to process your personal data, it will be deleted. Please note, however, that we may be required by legal and regulatory requirements to keep personal data for a more extended period.
You have the right to have certain personal data erased where it is no longer necessary for us to process it, where you have withdrawn your consent pursuant to paragraph 6.4, where you have objected pursuant to paragraph 6.5, where your personal data has been unlawfully processed, or where erasing your personal data is required in accordance with a legal obligation.
However, there are exclusions of the right to erasure. The general exclusions include cases where processing is necessary: for exercising the right of freedom of expression and information, for compliance with a legal obligation, or for the establishment, exercise or defence of legal claims.
6.4 Withdrawing Consent and Restriction of Processing
Where we have specifically requested your consent to process your personal data and have no other lawful conditions to rely on, you have the right to withdraw this consent at any time by changing your account settings or by sending an email to [email protected], specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
Additionally, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to next section and pending verification regarding whether the legitimate grounds of the Data Controller override your own.
6.5 Objection to Processing
You have the right to object to processing where the lawful basis is in our legitimate interests, but please note that we may still process your personal data where there are other relevant lawful bases or where we have compelling grounds to continue processing your personal data in our interests which are not overridden by your rights, interests or freedoms;
You also have the right to object to direct marketing, which can be done by opting out of direct marketing by sending an email to [email protected] You also have the right to object to any profiling to the extent that it relates to direct marketing only.
6.6 Lodging Complaints
You have the right to lodge complaints about data processing activities carried out by the data controller before the competent data protection authorities. If you are not satisfied with how we manage your personal data, you also have the right to lodge a complaint with your local data protection authority.
7. Overseas Transfer of Your Information
You can always contact us to receive the full list of our service providers outside the EEA which process your data.
8. Term of data storage
We will ensure that the access to your data is accurately secured by applying appropriate safeguards, depending on the circumstances taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk. In support of this commitment, we have implemented appropriate technical, physical and organizational measures to protect your Personal data against: unauthorized or accidental destruction, alteration or disclosure; misuse; damage; theft or accidental loss; or unauthorized access.
10. Contact Us
If you have questions about this policy or our information handling practices, or if you are seeking to exercise any of your rights under Data Protection Laws, please contact our data protection officer at [email protected]