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WIT IT Solutions Ltd is a registered European Company and operates this website www.windsorbrokers.com which is used by the Windsor Group of Companies. More information regarding the above-mentioned entities can be found here.

Windsor Brokers has prepared this Privacy Policy (the “Policy”) which provides an overview and an explanation as to how we treat the personal information of individuals who are users of our website, www.windsorbrokers.com, and including but not limited to you using any of our products, services or applications in any manner, whether online or offline.

This Policy is directed to natural persons who are either current and/or potential clients or are authorized representatives/agents or beneficial owners of legal entities or of natural persons which/who are current or potential clients of Windsor Brokers.

Windsor Brokers will gather various types of information, which includes information identifying you as an individual,  this is known as “Personal data” and/or “data”. Windsor is committed to protecting your personal data and respects your privacy.

By continuing to use this Website, and/or any other services and products offered by and through Windsor Brokers, you confirm that you are of legal age, and expressly agree with this Privacy Policy and consent to Windsor processing the data, by manual and/or automated means.  This includes the collections, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, disclosure, dissemination or otherwise making available, alignment or combination, restriction, erasure and/or destruction of personal data.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGE

It is important that the personal data we hold about you is accurate, complete and true at all times, as such please do keep us informed if your personal data changes during your business relationship with any of the Windsor Brokers related entities.  In addition, you provide your implied consent for data processing/transmission/record keeping/ as between the said related entities, wherever such entities may be located, registered and/or operating.

THE DATA WE COLLECT ABOUT YOU

Personal Data, or Personal Information, means any information that related to an identified or identifiable living individual.  It does not include data where the identity has been removed (anonymous data).

Information can have various ways of being obtained, including but not limited to a) information you provide us with and/or b) information that we collect.

We may collect, use, store, process and transfer different kinds of personal data about you which we have or may obtain such as Identity Data, Contact Data, Financial Data, Transaction Data, Technical Data, Profile Data, Usage Data, Marketing and Communication Data.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.

We collect information about criminal convictions and offences, politically exposed person “PEP”.  Windsor may run client/potential client details through international databases.  Windsor may also collect and process personal data which is lawfully obtained not only from you but from within Windsor Brokers, or other third parties, e.g. credit reference agencies, public authorities, companies/persons that introduce you to us, companies that process card payments such as JCC Payment Systems Ltd.  We may also collect and process personal data from publicly available sources, e.g. the Department of Registrar of Companies, the Land Registry, commercial registrars, the Press, media and internet, which we lawfully obtain and are permitted to process.

PURPOSE OF DATA COLLECTION/PERSONAL INFORMATION COLLECTION

When using the website as an example, details of your data are automatically registered by our server, such as your IP address, browser, the content you have visited, and how you landed on our pages, personal identification information, etc. In addition, we collect and store information such as your name, address, e-mail address, phone number, date of birth, gender and other data transmitted to us through completion of online forms, inserting information through the portal, and/or any other newsletters, product demos, etc.

The main purpose of collecting data is:

• Compliance with national and international legal and regulatory/supervisory provisions;
• Identifying the client and suitability of the client in relation to the products and services offered and provided by Windsor Brokers;
• Improving the quality of services to natural/legal persons;
• Research and statistical analysis;
• Facilitation of technical administration;
• To take into consideration your online website behavior and trend;
• Improve the quality of services and develop new ones;
• Improve security by protecting against fraud and abuse;
• To provide you with the transaction and post transaction-related services;
• To inform you of products and/or services that may be of interest to you;
• Ensuring network and information security

All personal data is stored in accordance with the applicable laws on data protection.

DISCLOSURE OF DATA

Your personal data will be kept confidential and will be treated as such, it is to be noted that Windsor Brokers will only disclose website usage data and/or personal data, to third parties as permitted by laws, where and if Windsor Brokers is legally obliged to do so or if such disclosure becomes necessary to enforce Windsor’s rights in particular to enforce claims arising from a contractual relationship, or required to comply with any judicial, and/or other proceedings, court order, legal process or pursuant to any governmental, intergovernmental and/or other regulatory bodies, whereby such disclosure may be executed by Windsor without prior notice to you.

Windsor Brokers will not be liable for unlawful or unauthorized use of your personal information/passwords/username/login etc., due to misuse or misplacement of your passwords, negligent or malicious intervention and/or otherwise.

Your personal data may be shared within Windsor Brokers and may be also disclosed to (but not limited to) business introducers, affiliates, , or other third party service providers in order to process obligations arising from the agreement, financial institutions, banks, other similar organizations that we deal with in course of corporate business, external service providers and professional advisers, which may be located overseas, such as auditors, lawyers and accountants, any third parties where this is necessary to process a transaction or provide services which you have requested or for trade reporting purposes.

YOUR RIGHTS ON PERSONAL DATA

You shall have the following rights in relation to your Personal Data:

1. Right of access: The Client has the right to be informed whether the Company is processing his/her Data, and if so, to provide the Client with a copy of that Personal Data.
2. Right to rectification: The Client is entitled to request that the Company corrects or completes his/her Personal Data if it is inaccurate or incomplete.
3. Right to erasure: This enables the Client to ask the Company to erase or remove the Client’s Personal Data under certain circumstances, such as when the Client withdraws his consent.
4. Right to restrict processing: This enables the Client to ask the Company to restrict the processing of the Client’s Personal Data if:
   • it is not accurate.
   • it has been used unlawfully but the Client doesn’t want it to be deleted.
   • it is not relevant anymore, but the Client wants the Company to keep it for use in possible legal claims.
     • the Client has already asked the Company to stop using his Personal Data, but he is waiting for the Company to confirm if it has legitimate grounds to use such Personal Data.

5. Right to data portability: The Client has the right to obtain his/her Personal Data provided to the Company in a structured, commonly used, and machine-readable format.
6. Right to object: The Client may ask the Company at any time to stop processing his/her Personal Data, and the Company will do so:
   • If the Company is relying on a legitimate interest to process the Client’s Personal Data and the Company cannot demonstrate compelling legitimate grounds for the processing, or
   • If the Company is processing the Client’s Personal Data for direct marketing.
7. Rights in relation to automated decision-making and profiling: The Client has the right to be free from decisions based solely on automated processing of his/her Personal Data, including profiling, that affect him/her, unless such profiling is necessary for entering into, or the performance of, a contract between Client and the Company or the Client provides explicit consent.
8. Right to withdraw consent: If the Company relies on the Client’s consent to process his/her Personal Data, the Client has the right to withdraw that consent at any time. This will not affect the lawfulness of the processing that took place on the basis of the Client’s prior consent.
9. Right to lodge a complaint with the data protection authority: If the Client has a concern about the Company’s privacy practices, including the way in which the Company handled his/her Personal Data, the Client can report it to the relevant data protection authority.

 

Any queries regarding data protection, including subject access requests and complaints, can be directed to the Company’s Data Protection Officer at: compliance@windsorbrokers.com

For further information on how to exercise any of the aforementioned rights, please refer to your Client Account Agreement with the Company. Windsor is committed to promptly addressing all inquiries and requests regarding the handling of your Personal Data. It is noted that Windsor may not always comply with the requests in accordance with the applicable laws and regulations.

PERSONAL DATA TRANSFERS

Windsor is committed to protecting your personal data, particularly when it involves transferring it outside your residing jurisdiction. Such transfers are only undertaken if suitable safeguards are implemented to ensure the security and protection of your personal information. Windsor may disclose or transfer your personal data outside your residing jurisdiction, to entities within the Windsor Group and third-party providers engaged on our behalf. These transfers are carried out in compliance with this policy, ensuring that appropriate confidentiality and security measures or arrangements are in place.

MONITORING AND RECORDING

Windsor Brokers will, as required by the Law, monitor and record any communication you have with us whether in writing, by phone or by electronic mail.

SECURITY MEASURES

Windsor Brokers takes all appropriate security measures to ensure that the personal data/data collected and stored in connection with your visit to the website and/or in relation to the services and products provided by Windsor Brokers is protected against any unauthorized access, misuse, loss and/or destruction.

Windsor Brokers uses physical and electronic security measures, including but not limited to the use of firewalls, personal passwords, encryption and authentication technologies. Windsor Brokers’ employees and service providers are bound by professional secrecy and must comply with all data protection provisions.

It is to be noted, that access to personal data is restricted to specific employees, contractors and third party service providers who require this access in order to process the agreement between Windsor Brokers and you, all on a “need to know” basis and to be able to execute all obligations emanating from the agreements in place.

It should be noted that data transmitted via an open network like the Internet cannot be fully protected from third-party access, although we take the best possible precautions to avoid any leakage of information/data.

Any transmission of data via the internet is at your own risk, although we will exercise all ways in order to protect your personal data. Please note that all your actions while using this website may be recorded and analyzed for various purposes, including security, marketing and system monitoring purposes.

Windsor Brokers adheres to strict security standards using the most up to date security technologies.

COOKIES
Windsor Brokers website uses cookies for statistical purposes and in order to improve the quality of services to the user. Cookies are small files that are placed on your device via your web browser when you visit Windsor Brokers website. Information is stored, such as the specific preferences when using the website. It is to be noted that you can configure your browser not to save any or only certain cookies on your device. There are different types of cookies such as ID cookies which do not expire when you close your browser, and persistent cookies with remains on your hard drive for a period of time.

If you do not wish to receive cookies, you may be able to change the settings of your browser to refuse all cookies or to have your device notify you each time a cookie is sent to it, and thereby the choice to accept it or not.

It is strongly recommended that you allow cookies on our website to ensure you have best possible experience. Disabling the cookies may result in reduced performance of the website and trading platform and may also impair the quality of the services that we provide you in relation to your account with us.

THIRD PARTY LINKS

Links may appear on the website that are not operated or monitored by us, known as “third-party websites”, whereby such third party websites are not bound by this privacy policy and we are not responsible for their content. No warranties or liability related to the contents of such third party websites are made. Using links to third-party websites are at your own sole risk and discretion.

GOVERNING LAW

The use of this website shall be governed by the laws of the jurisdiction of the entity in which the User proceeds to open account with based on written agreement.

RECORD KEEPING

Windsor Brokers will keep your personal data/data for as long as we have a business relationship with you (as an individual or in respect of our dealings with a legal entity you are authorized to represent or are a beneficial owner), and in accordance with the minimum period of retainment of personal data depending on the agreement executed by the User and the legal entity within Windsor Brokers.

Windsor Brokers shall not be required to delete data made pursuant to automatic archiving and back-up procedures in its IT systems, where a deletion is not possible or not possible without commercially unreasonable efforts.

For prospective clients, personal data (or authorized representative/agents/or beneficial owners of a legal entity prospective client), Windsor Brokers keeps your personal data for as long as legally entitled to, unless you have officially requested deletion from the records.