At Winson Capital, we are committed to maintaining the trust and confidence of our clients and potential client’s private information. As a result, we do not share or sell your information for marketing purposes. On top of that we take great care in how we handle and process your information in a secure and professional manner. We have outlined below when and why we collect your personal information, how we use it, the steps we have taken to secure it, and under which limited conditions we disclose your information to others.

We collect personal information on you including your name, date of birth, address, contact details, employment, financial information, forms of identification and other financial information. We may require further information depending on requirements that will help us carry out our duties to you, our product providers, and regulators

When someone visits www.winsoncapital.com we use a third-party service, Google Analytics, to track visitor numbers social shares made at our website. Google automatically collect and store certain information in their server logs which includes device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL, cookies that may uniquely identify your browser or your Google Account, in accordance with their data privacy policy: https://policies.google.com/privacy

We embed a Facebook widget to allow you to see number of likes/shares/recommends and “like/share/recommend” our webpages. This widget may collect your IP address, your web browser User Agent, store and retrieve cookies on your browser, embed additional tracking, and monitor your interaction with the widget, including correlating your Facebook account with whatever action you take within the widget (such as “liking/sharing/recommending” our webpage), if you are logged in to Facebook. For more information about how this data may be used, please see Facebook’s data privacy policy: https://www.facebook.com/about/privacy/update

We use a Twitter Tweet widget at our website. As a result, our website makes requests to Twitter’s servers for you to be able to tweet our webpages using your Twitter account. These requests make your IP address visible to Twitter, who may use it in accordance with their data privacy policy: https://twitter.com/en/privacy#update

We use a Linkedin Share widget at our website to allow you to share our webpages on Linkedin. These requests may track your IP address in accordance with their data privacy policy: https://www.linkedin.com/legal/privacy-policy

Additionally, we allow you to social share via email and whatsapp to your chosen audience. In this regard, we recommend that you respect individual’s rights afforded under the GDPR with any share.

If we do want to collect personally identifiable information in person, through our website, social media marketing channels, or other digital means we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it and allow you to opt-in or out of the service.

The purposes of collecting the above-mentioned information is to enable us to provide you with a comprehensive service and real value in your financial journey. This service includes holistic financial planning, relationship services, as well as information that you might find useful such as seminars, market updates and newsletters. This comprehensive service shall be subject to your opt-in agreement at initial engagement around our services.

We shall process and control your information such that we can fulfil our contractual obligations to you, or such that it satisfies a legitimate interest which does not override the rights afforded to you. An example of legitimate interest, not limited to, is where your product provider requests information about you, in order to update their files and systems for your benefit.

Considering our role in the financial services industry, we take our responsibilities to the stability of the financial system seriously. As a result, we collect information that enables us to combat money laundering, to comply with our regulatory requirements and international best practice. With this said, where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions.

At Winson Capital we are committed to the protection of the personal data that you have provided us with in order to preserve their confidentiality and prevent any unauthorized access, use, alteration or destruction of your personal data.

We apply high ethical standards through our internal policies, as a result our employees who are given access to your personal data for the purposes set out above in this privacy policy are bound by a strict confidentiality obligation, whose breach can be sanctioned by disciplinary action and/or other sanctions in accordance with applicable labour laws.

As part of the information security policy implemented by us for the protection of our own sensitive information and our clients’ information, we apply organisational and technical measures to ensure appropriate security of the personal data we collect, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, and to ensure that your private information is only used for the above reasons.

Though we believe we apply appropriate measures, in particular, for the protection of the information system environment on which the data we collect are stored, it remains that no transfer of data via the Internet can be fully protected from unlawful access by third parties. Communications via the Internet may potentially be intercepted, lost or modified and such risks remain beyond Winson Capitals reasonable control. In the event of this occurrence, we shall notify the appropriate regulator of any breach within 72 hours.

Accordingly, you acknowledge and accept that Winson Capital may not be held liable, for any reason whatsoever, for any damage of whatever nature resulting from the transmission of personal data, and that all communication is at your own risk.

Through our file keeping system we are obliged to keep all correspondence, contracts and transactions carried out on behalf of our clients for an indefinite term due to the lack of statute of limitations clause for financial advice. These files must also be kept, and made available to Regulator’s examiners and law enforcement authorities, regarding criminalisation of money laundering, upon request at any given time in the future.

If you are not yet a client, or do not intend to engage with us in a business relationship, we will only retain your information for a period of 24 months after the point of becoming inactive, unless you have given us an instruction to delete your personal information.

Under the GDPR, European individuals and individuals within the European Economic Area are entitled to these rights. However, we believe in a universal right to privacy and this rings true with our values as a company. We intend to extend these rights to all, where appropriate.

• The right to be informed: By providing you with this privacy note, we commit to and emphasise the need for transparency over how personal data is used.

• The right to rectification: You are entitled to have personal data rectified if it is inaccurate or incomplete.

• The right to erasure: The right to erasure enables you to request the deletion or removal of personal data when there is no compelling reason for its continued processing.

• The right to restrict processing: When processing is restricted, it is permitted to store personal data, but not to further process it.

• The right to data portability: The right to data portability allows you to obtain and reuse your personal data for your own purposes across different services

• The right to object: You have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority, direct marketing, or for purposes of scientific/historical research and statistics.

• The right not to be subject to automated decision-making, including profiling: The GDPR provides safeguards for individuals against the risk that a potentially damaging decision is taken without human intervention.

This privacy notice/policy was updated on 17/09/2018, and we shall review and update it accordingly from time to time on our website.

If you have any questions, queries or would like more information/detail about the above mentioned, your private data, and rights, please feel free to contact us on privacy@winsoncapital.com and we will do our best to get back to you in a timely and professional manner.

If we feel we have a legal right not to deal with your request, or to action, it in different way to how you have requested, we will inform you of this at the time.

You should also make contact with us as soon as possible on you becoming aware of any unauthorised disclosure of Your Personal Data, so that we may investigate and fulfil our own regulatory obligations.