Privacy Policy

PRIVACY POLICY

edition of 16.12.2021

Processing and protection of personal data of our website’s Users is of great importance to us, and we make every effort to ensure the protection and processing of such personal data in accordance with the law. This Privacy Policy explains how we process your personal data, based on the Law of Ukraine “On Personal Data Protection” of 01.06.2010 № 2297-VI and REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

By agreeing to the use of cookies on your first visit to our website, in accordance with the provisions of this Policy, you grant us full and unconditional permission to use cookies on each of your subsequent visits until you revoke such consent.

By ticking the checkbox for consent to the processing of your personal data, you provide us with voluntary, full and unconditional consent to the processing of your personal data, in the manner and terms specified in this Privacy Policy.

You can withdraw your consent to the processing of personal data by sending a notice to our e-mail address: info@winway.ua

PERSONAL DATA

We process the following types of personal data:

– Information about your computer, including your IP address, geographic location, browser type and version, and operating system.

– Information about your visits and use of this website, including referral sources, duration of visits, pages viewed and ways to navigate the website.

– Information about your e-mail address that you used to register on our website.

– The information you entered when filling out the contact form on our website – for example, your name, surname, telephone number, e-mail address.

– The information you provided when subscribing to our emails and / or mailings (your name, surname, company name and email address).

– Information you have entered while using the services of our website.

– Information generated when using our website, including information about the time, frequency, and conditions of its use.

– Information contained in any messages you send us by e-mail or through our website (contact form), including the content of the message and the metadata.

– Any other personal information you have sent or communicated to us, including, but not limited to, your mailing address, the name of the company in which you work, the title of your position.

Before disclosing personal information (personal data) of a third party to us, you must obtain the consent of that person to both disclose and process this information in accordance with this Privacy Policy.

Cookies. Our website uses cookies. A cookie is a file that contains an identifier (a line consisting of letters and numbers) that is sent by a web server to a web browser and stored by the browser. Subsequently, the identifier is sent back to the server each time the browser requests a web page from the server. Cookies can be either “permanent” or “session”: permanent will be stored by the browser and will be valid until the expiration date, unless they are deleted by the user in advance; “Session” on the contrary – will be deleted after the session with the website is over or after closing the browser. Cookies usually do not contain any personally identifiable information. However, the personal information we hold about you may be related to information stored and obtained from cookies. We use both persistent and session cookies on our website.

1.3.1.The names of the cookies we use on our website and the purposes for which they are used are listed below:

– On our website, we use Google Analytics and AdWords to identify your computer when you visit the website in order to track your navigation on the website, to improve the usability of the website (for example, to mention your language preferences when you visit the website again), to conduct website usage analysis, administer website, prevent fraud and improve website security, personalize website for each user, suggest advertising that on our point of view may be of interest to individual users;

You can set your browser to reject all cookies or specify when cookies should be sent to your computer. However, this may prevent our website or services from working properly. You can also configure your browser to delete cookies every time you close your browser. If you block or delete all cookies, you will not be able to use some features of our website.

PURPOSE OF PROCESSING
We process your personal data on the following basis:
2.1.1.your voluntary, complete, and unconditional consent to the processing of your personal data in accordance with the provisions of this Privacy Policy.
2.1.2.in the case of concluding and executing an agreement with our company to which you are a party, or which is concluded in your favor or for the implementation of measures prior to the conclusion of the agreement at your request.
2.1.3.to protect your vital interests.
2.1.4.to fulfill our duty as the processor of personal data, which is provided by law.
2.1.5.if it is necessary to protect our legitimate interests or legitimate interests of the third party to whom personal data is transferred, except when the need to protect your fundamental rights and freedoms in connection with the processing of your data outweighs such interests.

Personal information and personal data you provide to us through our website will be used for the purposes set out in this Privacy Policy. We may use your personal information (personal data) for the following purposes:

– administering our website and business (including, but not limited to quality control, staff training and analytics, systems administration and technology management, including optimizing our websites, maintaining accounting records, and auditing interactions with users of our website and our customers, including the keeping of logs and records that are part of transaction information).

– maintenance and inspection of security systems.

– personalization of our website for you.

– providing you with the opportunity to use the services available on our website.

– fulfillment of the terms of agreements concluded with you, conducting pre-contractual agreements and negotiations.

– sending you notifications, invoices, and payment reminders, and receive payments from you, sending you products or samples at your request.

– sending you non-marketing commercial messages.

– sending you e-mails that you have specifically requested.

– sending you an e-mail within mailing process if you consented to it (you can notify us at any time that you no longer wish to receive e-mails from us by writing a letter to info@winway.ua).

– sending you marketing notices about our business or the activities of carefully selected third-party companies that we believe may be of interest to you, through publications or, if you have specifically agreed to do so, by sending an e-mail or using similar technologies (you can notify us at any time that you no longer wish to receive marketing communications by writing to info@winway.ua).

– providing third-party companies with statistical information about our users (however, these third-party companies will not be able to identify any individual user from this data).

– processing inquiries and complaints made by you or against you that relate to our website.

– to ensure the security of our website and prevent fraud.

– to verify compliance with the terms and conditions governing the use of our website (including the monitoring of private messages sent through the private messaging service of our website); and

– for other lawful purposes.

PROCEDURE FOR PROCESSING PERSONAL DATA

We collect your personal information in the following ways:

– when you provide your personal data by filling out the appropriate forms on our website (such as contact form) or provide personal data in any other way (for example, by sending it to our e-mail). This information may include, but is not limited to, your last name, first name, email address, telephone number, and any other information you have filled in in the appropriate field of the contact form.

– by using appropriate technologies. We may use technologies that automatically collect information when you visit our website, view our advertisements, or use our products or services. For example, we use cookies (small files stored on your computer) to know which browser and operating system you use, your IP address, the web pages you visit, the links you follow. 

– from partners or third parties with whom you interact. We may receive information that is shared with us or sold to us by other companies. For example, you could consent to another company sharing your personal data with us when subscribing to a telecommunications service or a reseller bonus program. We may also collect information from publicly available sources, such as online publications, blog entries, videos, or social media pages. We may also obtain information from other companies, such as consumer resellers who collect or aggregate data they obtain from publicly available databases (in accordance with local legal requirements) or with your consent to the use of your data by such companies and subsequently – us.

Storage limitation. Personal data that we process for a specific purpose is not stored by us for longer than necessary to achieve this purpose or these purposes set out in paragraph 2.2. of this Policy. Your personal data will be stored until the purpose of their processing is available and until you send a request to delete personal data or revoke your consent to its processing. If you do not submit such a request, the personal data will be deleted within the following period: after 48 months of inactivity on all communication channels. We determine inactivity by several internal criteria. Notwithstanding the other provisions of this paragraph, we will store documents (including electronic documents) that contain your personal information:

– in those cases where the law requires us to do so.

– if we believe that these documents may be relevant to any current or future litigation, arbitration, or administrative dispute.

– to establish, exercise or protect our legitimate rights and interests (including providing information to other parties to prevent fraud or reduce credit risks).

Modification, deletion, or destruction of personal data. We make changes to your personal data based on your written reasoned request, which is sent to info@winway.ua. We also make changes to your personal data at the request of other parties in the field of personal data protection, by your consent  or the change is made in accordance with the instructions of the Supreme Council Commissioner for Human Rights or a court decision that has entered into force. Deletion / destruction of your personal data is carried out in the following cases:

– expiration of the data retention period determined in accordance with clause 3.2. of this Policy.

– issuance of the relevant instruction of the Commissioner or officials of the Secretariat of the Commissioner appointed by him.

– entry into force of a court decision on the removal or destruction of personal data.

– on your written application sent to info@winway.ua. You have the right to withdraw consent to the processing of personal data without giving reasons, if the only reason for processing is your consent.

TRANSMISSION OF PERSONAL DATA

We do not distribute or sell your personal data; we only do this in certain situations where your privacy is securely protected.

You grant us the right to disclose your personal information (personal data) to any of our employees, managers, insurers, professional advisors (including lawyers, notaries, etc.), information technology and security companies, and other companies that provide us with services, agents, suppliers, contractors, or subcontractors, to the extent and for the purposes set forth in this Policy. We provide such companies with only the personal information they need to perform their tasks. We require them to protect your information in the same way that we do, and not to pass on or use it for any other purpose.

You grant us the right to disclose your personal information (personal data) to any member of our group of companies (this includes our partners, subsidiaries, our ultimate holding company and all its subsidiaries) to the extent and for the purposes set out in this Policy. In particular, but not exclusively: WIN-WAY COMPANY LLC).

The information (data) we collect may be stored, processed, and transmitted between any of the countries in which we operate or where our employees, managers, insurers, professional advisers (including lawyers, notaries, etc.), agents, suppliers, contractors or subcontractors are located in order to enable us to use this information in accordance with this Policy. The information we collect may be transferred to the following countries where there are no data protection laws similar to those in the European Economic Area: The United States, Russia, Japan, China and India.

By agreeing to this Privacy Policy, you consent to the transfer of your personal data in accordance with the provisions of this section, and you agree that we will not notify you of any transfer of your personal data to third parties unless you have submitted a request to do so.

PERSONAL DATA PROTECTION

We respect your personal data and take all necessary measures to protect it from loss, misuse or alteration. Where appropriate, these can be technical measures: firewalls, intrusion detection and prevention systems, unique and complex passwords, and encryption. We also take organizational and physical measures, such as training staff in data processing, identifying data incidents and risks, restricting staff access to your personal data and ensuring physical security, including proper protection of documents when not in use. 

You verify acknowledgement that the transmission of information over the Internet is not completely secure, and we cannot guarantee the complete protection of data transmitted over the Internet. You are solely responsible for keeping your password for access to our website confidential.

YOUR RIGHTS REGARDING THE PROCESSING OF PERSONAL DATA

You have the right to:

– know about the sources of collection, location of your personal data, the purpose of it processing, the location of our company or give the appropriate instructions to obtain this information to your authorized persons, except as provided by law.

– receive information about the conditions for granting access to personal data, in particular information about third parties to whom your personal data is transferred.

– access to your personal data.

– receive no later than thirty calendar days from the date of receiving the request, except as provided by law, an answer as to whether your personal data is processed, as well as receive the content of such personal data.

– make a reasoned request to the processor of personal data with an objection to the processing of your personal data.

– make a reasoned request to change or destroy your personal data by any processor and controller of personal data if this data is processed illegally or is inaccurate.

– to protection your personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, non-provision or untimely provision, as well as to protection against the provision of information that is inaccurate or discredits the honor, dignity and business reputation of the physical persons.

– file complaints with the Parliamentary Commissioner for Human Rights or the courts about the processing of your personal data; apply legal remedies in case of violation of the legislation on personal data protection.

– make reservations regarding the restriction of the right to the processing of your personal data when giving the consent.

– withdraw consent to the processing of personal data at any time without consequences for the legality of processing, which was based on consent to its withdrawal.

– know the mechanism of automatic processing of personal data.

– to protection against an automated decision that has legal consequences for you, within the meaning of Art. 22 of the General Data Protection Regulation

– “be forgotten” – the right to erase your personal data.

– make request to our company regarding access to and correction of your personal data, erasure, restriction of processing or objections to processing, as well as the right to data mobility.

– correct your incorrect or inaccurate personal data; to limit the processing of personal data in the cases provided for in Art. 18 of the General Data Protection Regulation.

– object to the processing of personal data for direct marketing purposes, including profiling.

– other rights provided by applicable law.

CHANGES AND ADDITIONS

We reserve the right to periodically make changes and additions to this Privacy Policy and publish its new version on our website. You should periodically check this website to ensure that you have up-to-date information about the processing of your personal data. We may also notify you of changes to this Privacy Policy by sending an email or through our website’s private messaging system.

If you have any questions or concerns regarding this Privacy Policy and our data protection policies, please contact us. If your request is addressed to our data protection specialist, for example, if you suspect a data breach, please indicate this in your message.

Controller of personal data: LLC “WIN-GROUP COMPANY”, registration code: 41012274, address: 04074, Kyiv city, Avtozavodska street, building 2, sub building 66, Ukraine, info@winway.ua; +38 066 379 33 31