Privacy Policy

PRIVACY POLICY

We are committed to protect your information.

We will only use your data to improve your experience.

You decide what and how you hear from us.

If we do not need it, we’ll delete it.

We know you care about your privacy, so we are committed to protect your information as though it is our own. This Policy aims to help you understand what kind of information we might collect about you when you visit www.winsysgroup.com (and any of its links and sub-domains), for what purpose, and how we intend to use such information.

For all our services, the data controller (the company that’s responsible for your privacy) is Win Newco Holdings US LLC, a private limited liability company registered under the laws of Delaware, USA with company number 38-4166006, with registered address located at 1209 Orange St., Wilmington, County of New Castle, Delaware 19801, USA, and principal business address located at 1910 NW  84TH Ave Doral FL 33126, U.S.

It is your right under EU law – the General Data Protection Regulation (GDPR) – that you are informed when your personal data is collected by any organization and why.

If you have any questions about our Privacy & Cookies Policy, contact us at web@winsysgroup.com

Last update: 27^th December 2018

CONTENTS

• The information we collect
• How & Why we use your information
• Marketing messages
• Cookies
• Children under 18
• Job applicants
• Your rights
• Disclosure of personal data
• Security of your personal data
• Changes to how we protect your data
• Links to other websites
• Severability
• Indemnity
• Waiver
• Entire policy
• Law and forum

THE INFORMATION WE COLLECT

Most of the personal information which we might collect about you is given to us only if you choose to give it to us. Such information may be requested from you when you fill in a field through Win Newco Holdings US LLC’s website.

The information we collect from you normally includes name + surname, company name, contact details (email address and telephone number), information about your device (phone or laptop) with which you use our website, and any other personal information on documents you may upload.

Some other information is given to us because you accessed this website. This is explained in the Cookies section below.

HOW & WHY WE USE YOUR INFORMATION

The table below sets out in detail how and why we may use your personal information.

Legal Basis for Processing

Under applicable data protection laws, there is a legal basis for us to use some of your personal data, sometimes, without having obtained your consent.

• This includes, for example, circumstances (such as we have described below) where we have a legitimate interest to use your data, provided that proper care is taken in relation to your rights and interests:
• to ensure that you know about any changes to the website or the terms of this Privacy Policy.
• to ensure that we organise our databases efficiently and understand how our clients may make purchases;
• to improve and ensure the security of the website (for example, for statistical, testing and analytical purposes, troubleshooting).

 Retention Periods

• We will hold on to your information for no longer than is necessary keeping in mind the purpose/s (or compatible purposes) for which we first collected the data.
• We may also keep hold of some of your information if it becomes necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.

MARKETING MESSAGES

We might communicate with you about products or services in which you have shown interest – we understand that you would be interested in receiving this information as it is of use with the product or service. But rest assured, you can ask us to stop.

Also, if you have said we can (i.e. you gave us your clear confirmation), we might send you marketing messages by email, WhatsApp or similar instant messaging system  to keep you aware of what we’re up to and to help you see and find our products.

You can stop receiving marketing messages from us at any time by contacting us at web@winsysgroup.com. Please note that it might take a few days for all our systems to be updated, so you might get messages from us while we process your request.

COOKIES

What are cookies?

A cookie is a small text file (typically numbers and letters) that is downloaded onto ‘terminal equipment’ (e.g. your computer or smartphone) when you (or someone else) access a website using that device. Cookies are then sent back to originating website on each subsequent visit – and they are useful because they allow a website to recognize a user’s device and store some information about your preferences or past actions.

Please note that the cookie will not identify you personally – only the browser that is installed on your computer, tablet or mobile that you use for the visit.

You can find our cookies policy here.

JOB APPLICANTS

Our website includes a JOIN US section at https://winsysgroup.com/en/employee-journey/ where you may submit your CV for vacancies we have.

All of the information you provide during the process will only be used for the purpose of progressing your application, or to fulfil legal or regulatory requirements if necessary. We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes. The information you provide will be held securely by us and/or our data processors whether the information is in electronic or physical format.

• We will use the contact details you provide to us to contact you to progress your application.
• We will use the other information you provide to assess your suitability for the role you have applied for.
• We do not collect more information than we need to fulfil our stated purposes and will not retain it for longer than is necessary. The information we ask for is used to assess your suitability for employment.

If you are shortlisted, or if we make a final offer, we will ask you to provide us with additional personal information, in which case we will inform you of the applicable retention periods and policy regarding disclosure.

YOUR RIGHTS

You enjoy several rights relating to your personal information:

• The right to be informed about how your personal information is being used; We need to be clear with you about how we process your personal data. We do this through this Privacy Policy, which we will keep as up to date as possible.
• The right to access the personal information we hold about you; You can access the personal data we hold on by contacting us at web@winsysgroup.com. To process your request, we will ask you to send us proof of identity so that we can be sure we are releasing your personal data to the right person. We will carry out our best efforts to process your request within one month, and we can provide you with a copy of your personal data in electronic format. If we consider the frequency of your requests as being unreasonable, we may refuse to comply with your request. In those circumstances, if you disagree, you can complain to the data protection authority (in Malta, the Information and Data Protection Commissioner).
• The right to request the correction of inaccurate personal information we hold about you; We appreciate feedback from you to ensure our records are accurate and up-to-date. If you think that the information we hold about you is inaccurate or incomplete please ask us to correct it by contacting us at web@winsysgroup.com
• The right to request that we delete your data, or stop processing it or collecting it; You can ask us to delete your personal data; however, this is not an absolute right. In spite of a request for erasure, we may be justified to keep personal data which we need to keep, e.g. (i) to comply with a legal obligation; and (ii) in relation to the exercise or defence of any legal claims.
• The right to stop direct marketing messages;
• The right to object to certain processing based on legitimate interest; You have a right to object to our use of your personal information including where we use it for our legitimate interests or where we use your personal information to carry out profiling using automated means.
• The right to request human intervention if automated processing without human intervention is used to make decisions having legal or similar effects on you;
• The right to withdraw consent for other consent-based processing at any time;
• The right to request that we transfer or port elements of your data either to you or another service provider; You have the right to move, copy or transfer your personal data from one organisation to another. If you do wish to transfer your personal data we would be happy to help. If you ask for a data transfer, we will give you a copy of your personal data in a structured, commonly used and machine-readable form (e.g. a CSV file format). We can provide the personal data to you directly or, if you request, to another organisation. Please note that we are not required to adopt processing systems that are compatible with another organisation, so it may be that the recipient organisation cannot automatically use the personal data we provide. When making a transfer request, it would be helpful if you can identify exactly what personal data you wish us to transfer.
• The right to complain to your data protection regulator (in Malta, the Information and Data Protection Commissioner – IDPC).

If you want to exercise your rights, have a complaint, or just have questions, please contact us at web@winsysgroup.com.

Please appreciate that the rights must be exercised within some limitation – for example, if you ask us for information we can only give you what relates to you and not what relates to other persons. When we receive requests, we may also request that you identify yourself and provide documentation or information for verification (we would not want to disclose information to the wrong person).

DISCLOSURE OF PERSONAL DATA

We do not, and will not, sell any of your personal data to any third party. It is not our business to do so – and we want to earn your trust and confidence.

However, we might share your data with professional service providers who operate our business or companies in the group to which Win Newco Holdings US LLC belongs, as sometimes different companies within our group are responsible for different activities. This includes all related entities and members of the Win Systems Group. Related entities and subsidiaries use the information collected to help us improve the content and functionality of our websites; to better understand our customers and markets; and to improve our products and services. Members of the group vary from time to time.

We will not normally disclose personal data, but circumstances where we might be required to disclose personal information without your consent include where there is a court order, to comply with legal requirements and satisfy a legal request, for the proper administration of justice, to protect your vital interests, to fulfil your requests, to safeguard the integrity of the relevant websites operated by us or by such related entities or subsidiaries, or in the event of a corporate sale, merger, reorganisation, dissolution or similar event involving us and/or the other entities within our group.

When we do share data, we do so on an understanding with the other entities that the data is to be used only for the purposes for which we originally intended.

If we ever share data with entities that are outside of the EEA, we will be sure to do so in a manner that complies with the requirements set out in EU regulations.

SECURITY OF YOUR PERSONAL DATA

Security of your personal data is very important to us, so we do our best to keep the information you disclose to us secure. However, please understand no data transmission over the Internet is totally secure and no system can guarantee that unauthorised access or theft will not occur.

CHANGES TO HOW WE PROTECT YOUR PRIVACY

Our website is continually under review – new functions and features are periodically added and improved to interface, thus changes to our privacy policy may be required from time to time. We therefore encourage you to check our privacy policy on a frequent basis.

LINKS TO OTHER WEBSITES

This privacy notice does not cover the links within this site linking to other websites which are not controlled by us. We are not responsible for the collection or use of your personal information from these third-party websites. Therefore, we encourage you to read the privacy statements on the other websites you visit.

SEVERABILITY

In the event that any of these terms, conditions or provisions shall be determined by any competent authority to be invalid, unlawful or unenforceable to any extent, such term, condition or provision shall to that extent be severed from the remaining terms, conditions and provisions which shall continue to be valid to the fullest extent permitted by law.

INDEMNITY

If there’s ever any claims against us, or any losses, damages or demands, which arise out of your use and access of the website or the services it provides, you shall indemnify us in full.

WAIVER

Any failure or neglect on our part, at any time, to enforce any of the provisions above, shall not be construed nor be deemed to be a waiver of our rights herein, nor in any way affect the validity of the whole or any part of this policy, nor prejudice our rights to take subsequent action.

ENTIRE POLICY

This Policy represents the entire agreement between us in relation to the subject matter of Privacy, and supersedes and voids all prior agreements between us relating to this subject matter.

LAW AND FORUM

This Policy, together with any other documents with which this Policy forms an integral part, shall be governed by and construed in accordance with the laws of Malta, and shall be subject to the jurisdiction of the Courts of Malta.