Privacy Notice

Effective Date: August 2, 2024

WinTraders Limited (“WinTraders”) recognizes the importance of data privacy compliance and therefore take your privacy and information security very seriously. This Privacy Notice (“Notice”) describes the types of personal information we collect, how we use it, how and when we share it, and the rights you have with respect to your information. It also explains how we communicate with you and how you can make inquiries and requests to us about your information. As part of our continued commitment to maintaining your trust, we strive to help you understand how we use your information to improve our products, services, marketing, and interactions with you.

This Notice applies when you use or access the WinTraders website (“Site”) and its subdomains or portals; or otherwise provide Personal Information or interact with us online or in-person. For the purpose of this Notice, “Personal Information” is defined in accordance with the Data Protection Act, 2020 (Jamaica), as “information (however stored) relating to a living individual, or an individual who has been deceased for less than 30 years, who can be identified from that information alone or from that information and other information in the possession of, or likely to come into the possession of, the data controller, and which includes any expression of opinion about that individual and any indication of the intentions of the data controller or any other person in respect of that individual”. We refer to all of the above as “Services.”

Section 1: Personal Information We Collect
Section 2: How We Use Your Information
Section 3: Use of Cookies
Section 4: Your Privacy Choices
Section 5: How We Share Your Information
Section 6: International Transfers of Personal Information
Section 7: Security
Section 8: Third-Party Links
Section 9: Your Rights Under the Data Protection Act, 2020 (Jamaica)
Section 10: Legal Basis for Processing Personal Information
Section 11: Retention of Personal Information
Section 12: Exercising Your Rights Under The Act
Section 13: Children’s Privacy
Section 14: Changes to This Privacy Notice
Section 15: Contacting Us

Section 1: Personal Information We Collect

This section describes what information we may collect from you through our Site or Services. We may receive information (including Personal Information) in the following ways:

Information You Provide
As you interact with our Site or Services, we may collect the following Personal Information via the webforms or inputs/uploads on our Site, and through telephone calls, letters, emails, and other communications with you:

Contact and account information. We may collect information such as yourfirst and last name, email address, home or business address, telephone numbers, mobile numbers and password (where applicable).
Financial information. We may collect information such as your credit card or debit card number, bank account information and your payment, service and purchase history.
Social media information. We may collect information such as social media handles, content and other data shared with us through third-party features that you use on our Site or Services (such as tools, widgets and plug-ins offered by social media services like Facebook, Instagram, X (formerly Twitter) and YouTube) or posted on social media pages (such as our social media page or other pages accessible to us).
Employment information. If you apply for employment with us, we may collect information such as your current or past employment or educational information, as well as references and referrals provided to us; and/or
Other information. We may collect other information that could reasonably be used to identify you personally or identify your household or device.

Information Collected Automatically
Like many businesses, we and our service providers may automatically collect and/or store certain information when you visit or interact with the Site or Services (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Site. Usage Information may include:

Your IP address, IDFA, Android/Google Advertising ID, IMEI, or another unique identifier;
Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);
Referring and exit web pages and URLs;
The areas within the Site that you visit and your activities there, including remembering you and your preferences;
Your Device location or other location information, including the zip code (if applicable), parish, state or country from which you accessed the Site or Services;
Your Device characteristics (e.g. screen resolution, operating system, language, etc.);
Certain other Device data, including the time of day you visit our Site or other information used to provide analytics or other usage information;
Information about your engagement with our emails; and
Statistical information about how both unregistered and registered users, collectively, use the Site and Services. This aggregate information is derived from Personal Information but cannot be tied back to you or your web browser.

Information Collected from Third Parties
The Site may include functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of our Site from third parties. These third parties also use cookies and other tracking technologies to capture information about your interactions with WinTraders. WinTraders does not have control
over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

Section 2: How We Use Your Information

We may use the information we collect about you in a variety of ways, including:

To Provide Our Products and Services - We may use Personal Information to provide our products and services to you. As a part of this, we may process your purchases of, or requests for, our products and services.

To Improve Our Site or Services - We want to ensure that our Site and Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process Personal Information to perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others. We do this to help make our products better and to develop new products.

To Communicate with You - We may process certain Personal Information to communicate with you in relation to our services. We may send you emails about new product features or other news about us or on topics relevant to products or services you purchased or that you opted in to receive. You may opt out of these at any time.

To Comply with Applicable Laws - We may be required to process certain Personal Information under certain laws and regulations, such as tax laws. In addition, we may maintain appropriate records for internal administrative purposes, comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.

To Enforce our Terms, Agreements, or Policies - To maintain a safe, secure, and trusted environment for you when you use our Site and Services, we may use Personal Information to ensure our terms, policies, and agreements with you and any third parties are enforced.

To Evaluate Your Application for Employment - We may use Personal Information to evaluate your application for employment or administer employment benefits.

With Your Consent - We may process Personal Information to fulfill any other business or commercial purposes at your direction or with your consent.

Section 3: Use of Cookies

We use cookies, which are small text files sent by your computer each time you visit our site, and other tracking technologies to personalize your experience, analyze user trends, and improve the Site and Services. These tracking technologies allow us to collect information such as your device type, browser type, interactions with our Site, geographic location, your web request, the date and time of your web request, your Internet Protocol address, the domain name of your Internet service provider and other data. If you can be identified from this information by combination with other pieces of information, then we will treat this information as Personal Information.

You can alter the configuration of your browser to refuse to accept cookies, but it is possible that doing so may cause limited functionality of the Site.

We may also use pixel tags, which are small graphic files that allow us and third parties to monitor the use of the Site and provide us with information based on your interaction with the Site. These tags may collect the IP address of the device from which you loaded the page and the browser type. Pixel tags are also used by our third parties to collect information when you visit our site, the links and other actions you take on our site, and we may use this information in combination with cookies to display targeted advertisements.

Other data technologies may be used that collect comparable information for security and fraud detection purposes.
If you have any questions about cookies or to generally find out more about cookies, visit this site.

Section 4: Your Privacy Choices

Cookies
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn them off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

Note, however, that if you reject our request to use cookies or turn cookies off, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site. To find out more about cookies and similar technologies, visit www.allaboutcookies.org, or www.youronlinechoices.com.

Do Not Track
Your browser may offer you a “Do Not Track” (“DNT”) option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites and platforms. There is no universally agreed-upon standard for what an organization should do when it detects a DNT signal. Currently, we monitor and take automatic action with respect to these signals. Your DNT preferences will be automatically honored when visiting the Site. You can learn more about Do Not Track here.

Communication Preferences
With your consent, WinTraders may communicate with you via a variety of digital media, including e-mail. To help us make e-mails more useful and interesting, we often receive a confirmation when you open e-mail from us if your computer supports such capabilities. You can opt out of receiving emails from us at any time. To manage your communications preferences with WinTraders, or to opt out of communications entirely, please unsubscribe at the bottom of our emails or contact us at information@wintradersltd.com.

Analytics
We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here. You can also opt-out of Google Analytics here.

Section 5: How We Share Your Information

Services Providers

We share your Personal Information with our third-party service providers who provide services such as website hosting, data analysis, information technology, customer service, email delivery, online advertising, auditing, and other services.

Third Party Advertising

We share information about your use of our Site and Services, and your interaction with our ads on other websites with our advertising partners to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s educational page here.

You can opt out of targeted advertising by visiting the following:

Other
Aside from the instances described above, we will only share your Personal Information:

to comply with the law;
to respond to claims or comply with legal process served on WinTraders (e.g., a lawful subpoena, warrant, or court order);
to enforce or apply our policies or agreements;
to protect and defend our rights or property or that of our customers, employees, visitors, or the public;
in connection with a business transfer, sale, liquidation, or merger;
if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure; and
with your consent.

Section 6: International Transfers of Personal Information

The Site is operated and hosted in Jamaica. If you are located in another jurisdiction, please know that your information will be transferred to, stored, and processed in the United States. By using the Site and providing us with information, you consent to this transfer, processing, and storage of your information in the United States. It is important to note that the privacy laws in the United States may not be as comprehensive as those in other countries such as those in the European Union (“EU”). Our service providers use appropriate safeguards to transfer your Personal Information to the United States.

Section 7: Security

We seek to use reasonable organizational, technical, and administrative measures, including data encryption and regular data backups, to protect Personal Information. However, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please contact us at information@wintradersltd.com.

Section 8: Third Party Links

Our Site may contain links to other websites such as social media platforms, other websites, and event and partner websites. These websites are not covered by this Privacy Notice. Please review the Privacy Notices or Policies of those websites to understand the privacy practices of these third parties.

Section 9: Your Rights Under the Data Protection Act, 2020 (Jamaica)

This section of our Privacy Notice applies if you are a data subject who resides or is located in Jamaica. We adopted this Policy to honor Jamaican privacy laws, including the Data Protection Act, 2020 (“The Act”). Any terms defined in The Act have the same meaning when used in this Section. In most instances, WinTraders is the data controller for processing Personal Information provided to us through the Site. The Act allows for personal data to be collected in keeping with the requisite protections afforded to persons under the Act whilst ensuring that their privacy rights are also protected.

We hope to ensure that the Personal Information we possess are always accurate and therefore we encourage you to update your information in your own account in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Information, subject to applicable law. We take every reasonable step to ensure that the Personal Information that we process are limited to the Personal Information that are reasonably required in connection with the purposes set out in this Privacy Notice.

If you are a resident of, or located within Jamaica, you have certain data protection rights. These rights include:

The Right to be Informed / The Right to Access: You have the right to be informed of whether your personal information is being processed by or on behalf of WinTraders, and if so, the right to be provided with:
- a description of the personal data;
- the purposes for which the data is being processed; and
- the recipients to whom any disclosures have been made.

The Right of Rectification / Erasure: You have the right to request that WinTraders rectify any inaccuracy in any personal data in our possession or control. For the purposes of the Act, the term 'rectify' means to amend, block, erase, or destroy and the term 'inaccuracy' includes any error or omission.

The Right to Object / Opt-Out: You have the right to object to our processing of your Personal Information:
- The Right to Prevent Processing (Object) – You have the right to prevent the processing of your personal data in specified circumstances such as:
  - where the processing is likely to cause substantial damage or substantial distress to you or to another person and that the damage or distress caused or likely to be caused (as the case may be) is unwarranted;
  - where the processing of the data is incomplete or irrelevant;
  - where the processing of the data is prohibited by law; or
  - where the data has been retained by WinTraders for a period longer than required by law;

The Right to Prevent Processing for Direct Marketing Purposes (Opt-Out) – You have the right to prevent the processing of your personal data for the purposes of direct marketing unless you have given consent, or you are a customer of WinTraders.

Section 10: Legal Basis for Processing Personal Information

We rely on the following legal bases for processing your Personal Information:

Processing of your Personal Information that you provide to us when you interact with our Services is necessary to respond to or implement your request prior to entering into a contract with us.

When you apply for employment through our Site, processing of your contact details and data about your employment history and education is necessary to respond to your request to process your application for employment.

We will send you information by email on our new products and services only with your consent or if you otherwise opt-in to receiving those communications. If you do not provide us with your consent to the processing of your Personal Information for this purpose, we will not send you this information. You have the right to withdraw your consent at any time.

Our use of data relating to your use of the Site or Services, described above, is necessary for our legitimate interests in understanding how the Site and Services are being used by you, to improve your experience on it and our Services offerings. We have also a legitimate interest in aggregating and/or anonymizing the information that we collect through our Site or Services and using this information for our business purposes, as described above. When we process your Personal Information for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your Personal Information for activities where our interests are overridden by the impact on you, unless we have your consent, or those activities are otherwise required or permitted to by law. You have the right to object to processing that is based on our legitimate interests, as further described below.

Section 11: Retention of Personal Information

WinTraders will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Notice. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations, resolve disputes and enforce our legal agreements and policies.

All information you provide to us is stored on our secure servers or those of our third-party data storage providers, with data encryption and regular data backups to ensure the highest level of protection.

Section 12: Exercising Your Rights Under The Act

If applicable, you may exercise any of your rights under The Act by submitting a verifiable data subject request to us by using the contact details below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of Jamaica by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in Jamaica in order to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.

Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.

Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us using the information in the Contact Us section below.

Section 13: Children’s Privacy

Our Site and Services are not directed at children under the age of 18, and we do not knowingly collect or receive Personal Information from them. If you believe that we have received Personal Information from a child under the age of 18, you may contact us at information@wintradersltd.com to request immediate deletion of that information.

Section 14: Changes to This Privacy Notice

We may change this Privacy Notice at any time. We will post all changes to this Privacy Notice on this page and will indicate at the top of the page the modified notice’s effective date. We encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy notice. If required by the applicable law, we will notify you of the changes. By continuing to use the Site or Services or providing us with information following such a replacement Notice being uploaded, you agree that you will be deemed to have agreed to be bound by the Privacy Notice as changed.

Section 15: Contact Us

If you have any questions or suggestions regarding this Privacy Notice, please contact us at:

Address: WinTraders Limited.
Suite #24, Ardenne Emirates.
7-9 Ardenne Road, Kingston 10. Jamaica. West Indies.

Email: information@wintradersltd.com

Telephone: 1-876-754-1351 or 1-876-754-1352.

Fax: 1-876-754-1500.