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Windsor Solutions and Windsor Group of Companies, (collectively as “Windsor”, “Windsor Group”, “we” and “us”) has prepared this privacy policy which provides overview and 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 Privacy Policy is directed to natural persons who are either current and/or potential clients of Windsor or are authorized representatives/agents or beneficial owners of legal entities or of natural persons which/who are current or potential clients of Windsor, whereby Windsor 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 the Windsor website, and/or any other services and products offered by and through Windsor, 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 CHANGES
The new data protection law in Cyprus is in effect as of 25 May 2018, better known as the General Data Protection Regulation (“GDPR”).  This Privacy Policy sets out the rights and duties within the new legislation related to GDPR, and Windsor are hre to service your request(s) related to personal data, subject to the systems being ready for such request(s), and we undertake to provide you with the service required the soonest for request made by you for your data.

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 entities within the Group of Companies.  In addition you provide your implied consent for data processing/transmission/record keeping/ as between the Group of Companies, 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 other entities within the Windsor Group, 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;
  • Improving the quality of services to natural/legal persons;
  • Research and statistic 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 will only disclose website usage data and/or personal data, to third parties as permitted by law(s), where and if Windsor 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 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.

Windsor may disclose your personal data to but not limited to business introducers, affiliates, any of the entities within the Windsor Group of Companies, (who might process data on behalf of Windsor and who may only use it for the same purposes as Windsor), 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.

MONITORING AND RECORDING
Windsor 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 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 is protected against any unauthorized access, misuse, loss and/or destruction.

Windsor uses physical and electronic security measures, including but not limited to the use of firewalls, personal passwords, encryption and authentication technologies. Windsor’s 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 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 adheres to strict security standards using the most up to date security technologies.

COOKIES
Windsor’s 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’s 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 Cyprus and/or the applicable law of the entity in which the User proceeds to open account with based on written agreement.

RECORD KEEPING
Windsor 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 the Group.

Windsor 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 keeps your personal data for as long as legally entitled to, unless you have officially requested deletion from the records.

HOW TO CONTACT US
To exercise you rights you can contact the Company in which you have executed agreement or intend to form agreement or are interested in and the relevant Company will take action based on request.

Copyright © 2019 Windsor Solutions Ltd for the Windsor Group of Companies

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