Welcome to Wincent Capital Management Limited (“we”, “us” or “Wincent”). Wincent is a global algorithmic market maker in digital assets, where we provide centralized trading platforms and off-exchange which can be used by our users (“you”). To provide our Services we need to collect and process some of your personal data when you are using https://www.wincent.co/ (our “Site”) or any of our other services or communicating with us (collectively our “Services”). This Privacy and Cookies Policy (the “Privacy Policy”) is intended to inform you about our practices regarding the collection and use of your data that you may submit to us through our website. This Privacy Policy should be read alongside, and in addition to the Terms & Conditions. Please read the Privacy Policy carefully!
(A) Unless otherwise defined in this Privacy Policy, terms used have the same meaning as in the Terms & Conditions.
(B) This Privacy Policy was last modified on 28/06/2022 and may be sporadically updated to reflect changes in legislation. You can always find the most recent version on our Site. If we make substantial changes, we will try to provide at least a 30-day notice prior to any changes taking effect. What constitutes a substantial change will be determined at our sole discretion. By continuing to access or use our Service after those revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, please stop using the Services.
(C) We process your data with due care, in accordance with all applicable laws and regulations, including the regulation (EU) 2016/679 of the European Parliament and of the Council, the General Data Protection Regulation (the “GDPR”).
(D) The Privacy Policy only covers data processing carried out by us. The Privacy Policy does not address, and we are not responsible for, the privacy practices of any other parties.
(E) We do not knowingly collect or ask for information from people under the age of 18. If you are such a person, please do not use our service or send us your information. We delete information that we learn is collected from a person under the age of 18 without verified parental consent.
1 Who processes your personal data?
1.1 Your personal data is being collected and processed by our company Wincent Capital Management Limited, a limited company incorporated in Gibraltar with a registered office at 6.20 World Trade Center, 6 Bayside Road, Gibraltar GX11 1AA and company number 118095 (the „Controller“, “we”, “us” or “our”).
1.2 The Controller is acting as an investment director to an Experienced Investor Fund managed by Wincent Capital Management Limited. We share personal data we collect with Wincent Capital Management Limited for the purposes of providing our Services.
1.3 To learn more about personal data management or if you have any other questions, you are welcome to contact us at gdpr@wincent.co.
2 What personal data is processed?
We may collect the following types of information about you:
2.1 Personal Data
We may collect and process your names, email address and any other data that identifies you, provided by you voluntarily when you use our Services.
2.2 Technical Information
We and/or our authorised external service providers (as stated in this Privacy Policy) may automatically collect technical data when you visit or interact with our website. Technical data may include, in particular, the URL of the website you visited before using our Service, the time and date of user visits, surfing habits, IP address, the browser name, the type of computer or device accessing our Service, time spent on the website and other similar technical information.
2.3 Cookies
2.3.1 What are cookies?
(a) To make this website work properly, we sometimes place small data files called cookies and similar technologies on your device.
(b) A cookie is a small text file that the website saves on your device when you visit it. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Permanent cookies last until you or your browser delete them or until they expire.
2.3.2 How do we use cookies?
(a) We use our session-based and also permanent functional cookies which enable the website to remember your actions and preferences (e.g., to remember that you are logged in) so you don’t have to keep re-entering them whenever you come back to the website or browse from one page to another.
(b) We also use third parties’ permanent cookies, specifically Google reCAPTCHA, which helps us to detect abusive traffic on our website without any user friction.
(c) Upon your consent, We use analytical cookies for the improvement of our Site and Platform. We may collect data such as device data, browsing data and interactions with the Site and Platform. You can withdraw your consent to analytical cookies at any time through your browser settings.
(d) Upon your consent, We use marketing cookies including social pixels, for retargeting you on other websites. You can withdraw your consent to marketing cookies at any time through your browser settings.
(e) Our Services and the communications generated from using our Services, such as promotional emails, may contain electronic images known as “web beacons”. Web beacons generally work in conjunction with cookies, and we may use them in the same way we use cookies.
2.3.3 How to control cookies?
(a) We inform you about the use of cookies on your device when you visit our website for the first time and, if applicable, we ask for your consent to use the cookies. The cookies will not be used for any purposes other than the ones stated above. Later, you may choose to accept or refuse cookies by selecting the appropriate settings in your browser.
(b) As mentioned above, in some cases we also may use cookies provided by third-parties (service providers). The list of such third-parties cookies of which you might encounter through our service is listed below. We are not responsible for third-party sites and their privacy practices. These companies collect and use this information under their own privacy policies and are responsible for their practices concerning cookies.
3 What are the purposes and legal basis for processing your personal data?
3.1 We process your personal data in order to:
3.1.1 carry out the agreement existing between us based on your decision to use our Service
This purpose includes mainly the following processing activities:
- creating and providing your account from personal data you provide upon registration;
- informing you about updates and new features of our Service;
- notifying you about updates of our Terms & Conditions and this Privacy Policy;
- responding to you in relation to any queries you may have with respect to our Services;
- resolving potential agreement-related troubleshoot problems and disputes.
We process the email address and other data provided by you voluntarily when you use our Service.
Legal basis for such processing: the performance of a contract in accordance with Article 6 (1) (b) of GDPR.
3.1.2 market our Services
We may market current or future Services to You if you subscribe to our newsletter or consent to marketing cookies, as described above.
The Controller processes your email address on the following legal basis: your consent in accordance with Article 6 (1) (a) of GDPR (granted during submitting your email address to our newsletter bar) or legitimate interest in accordance with Article 6(1) (f) of GDPR (if you have an existing relationship with Us) .
You can stop direct marketing communications from us by:
- clicking the “Unsubscribe from newsletter” link in any email communication that we send you. We will then stop any further newsletter emails; or
- withdrawing your consent through gdpr@wincent.co.
3.1.3 improve our Services
This purpose includes the following processing activities using technical information:
- to influence current and future features;
- to prevent and detect security flaws and user interface issues.
The Controller processes technical information under the following legal basis: legitimate interest in accordance with Article 6(1)(f) of GDPR.
4 Who are recipients of your personal data?
4.1 We only share your personal data within the organisation of the Controller and the group of companies into which the Controller belongs.
4.2 We do not share your personal data with any recipients outside of the Controller and the group of companies into which the Controller belongs unless one of the following circumstances applies:
4.2.1 it is necessary for the performance and improvement of our Services
To the extent that our external service providers (sub-processors) need access to your personal data to help us perform our Services for you, we have taken the appropriate contractual and organisational measures to ensure that your personal data are processed in accordance with all applicable laws and regulations.
Below is a non-exclusive list of our sub-processors:
- Intuit Inc (Email marketing)
- Pipedrive, Inc. (Customer relationship manager)
- Ashby, Inc (Recruitment manager)
- Google LLC (Cloud service provider)
The list of external service providers we use may change from time to time as we change or remove some of the providers listed above and/or put in place other providers to assist us in providing the Services.
4.2.2 It is necessary for legal reasons
We may share your personal data with recipients outside the Controller if we have a good-faith belief that access to and use of your personal data is reasonably necessary to: (i) meet any applicable law, regulation, and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues; and/or (iii) protect the interests, properties or safety of the Controller, our users or the public as far as in accordance with the law. When possible, we will inform you about such processing.
5 Do we transfer your data to countries outside the EU/EEA?
5.1 The Controller may transfer your personal data to countries outside the European Union and the European Economic Area where we engage with external service providers. In such a case, we transfer your personal data only to a country that is considered to have an adequate level of protection in accordance with the EU Commission's decision or there are appropriate safeguards in place to protect your personal data, such as standard contract clauses or binding internal company rules. Regardless of the country in which your personal data is processed, the Controller takes reasonable technical, legal and organisational measures to ensure that the level of protection is the same as in the European Union and the European Economic Area.
5.2 If we are involved in a merger, acquisition or other reorganisation, your information may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.
6 What is the storage period?
6.1 The Controller stores your personal data only if it is legally permitted and necessary for the purposes for which the data were collected.
7 What are your rights?
7.1 Right of access - The Controller offers you access to your personal data we process. This means you can contact us and request from us a confirmation whether or not your personal data are being processed and if so, you have the right to request access to your data, which we will provide to you in the form of a so-called "registry" (stating, in particular, purposes, categories of personal data, categories of recipients of personal data, storage periods or criteria for determining storage periods).
7.2 Right to rectification - You have the right to have inaccurate personal data we have stored about you rectified.
7.3 Right to erasure - You may also ask us to erase your personal data from our systems. We will comply with such requests unless we have a legitimate ground to not delete your personal data.
7.4 Right to restriction of processing - You may request us to restrict certain processing of your personal data. If you restrict certain processing of your personal data, this may lead to fewer possibilities to use our Services and website.
7.5 Right to data portability - You have the right to receive your personal data from us in a structured, commonly used and machine-readable format in order to transmit the personal data to another controller.
7.6 How to use your rights - You may exercise your rights above, free of charge, in writing by sending a letter or email at gdpr@wincent.co. We may require confirmation of your identity depending on your request.
8 May you complain?
8.1 In case you consider our processing activities of your personal data to be inconsistent with the applicable data protection laws, you may lodge a complaint with the local supervisory authority for data protection.
9 Is your data secured?
9.1 We take all reasonable, appropriate security measures to protect the Controller and our customers from unauthorised access to or unauthorised alteration, disclosure or destruction of personal data we hold. Measures include, where appropriate, encryption, firewalls, secure facilities and access rights systems. Should despite the security measures, a security breach occur that is likely to have negative effects to your privacy, we will inform you about the breach as soon as reasonably possible. If you have any questions, feel free to contact us at gdpr@wincent.co.
