Last updated: February 20, 2020
1. Introduction
When you use our services, you trust us with your information. Being aware of this responsibility, we work to protect the privacy of the people who use our platforms in order to ensure that our users can benefit from our services safely and without any problems.
The purpose of this Privacy Policy is to inform you about how we protect all your personal information, including the data you provide when you visit our site, register on our site, purchase a product or service from our site, or enter a contest, and to keep you informed about your privacy rights and how the law protects you.
This Privacy Policy was last updated on February 20, 2020, and you can obtain past versions by contacting us.
It is important that you read any privacy or data processing notices we provide to you so that you are fully aware of how and why we use your information.
This privacy policy supplements, but does not supersede, other statements.
Our users who continue to benefit from ONWIN services are deemed to have accepted the rules and practices we have explained in this Privacy Policy.
Users can withdraw this consent they have given at any time by contacting us.
It is important that all personal information we hold about you is accurate and up to date. If your data changes as long as your connection to our site continues, please inform us about the changes.
Contact information
Email address: [email protected]
Live support
2. Data We Collect About You
Your personal data or personal information refers to any information that makes it possible to identify a person.
We may collect, use, store and process different types of data about you as follows:
Identity Information: Contains name, maiden name, surname, username, marital status, title, date of birth, gender or similar identifying information.
Contact Information: Contains information such as phone numbers, e-mail address, billing address, residential address.
Financial Data: Contains bank account and payment card information.
Transaction Data: Contains information about payments you have made or made to you, and other details about products and services you have purchased from us.
Technical Data: Includes IP (Internet protocol) address, login information, browser type and version, time zone settings and your location, browser plug-in types and versions, operating system and platform, and other technologies on the devices you use to access this website.
Profile Data: Includes your username and password, your investments/payments within the framework of the services you receive, your interests, preferences, feedback and survey responses.
User Data: Contains information about how you use our website, products and services.
Marketing and Communication Data: It includes your e-bulletin, SMS sending and announcement preferences and communication preferences from us and third parties.
Request/Complaint Management Information: Includes requests and comments about our services and comments to other members.
We do not collect special categories of personal data about you, such as race, ethnicity, religion or philosophical belief, sexual life, sexual orientation, political views, union membership, your health, genetic and biometric data.
3. If You Do Not Provide Personal Data
Where we are required to collect personal data by law or the contract we have with you, and if you do not provide that data when requested, we may not be able to comply with the contractual requirements we have or are attempting to arrange with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us.
4. Third Party Links
This website may contain links, plug-ins and applications from third-party websites. Clicking or activating these links may result in data about you being collected or shared by these third parties. As we do not control third-party websites, we point out that we are not responsible for the privacy policies of these websites. For this reason, we recommend that you read the privacy policy (statement) of each website you visit.
5. How Is Your Personal Data Collected?
- We use different methods to collect data/information about you, including:
- direct interactions. You may provide us with your identification, contact or financial data by completing a form or by contacting us by post, e-mail, telephone, online applications or other means. This includes personal data you provide in the following ways:
- create an account on our website;
- refer to our products or services;
- Subscribing to our services or publications;
- To request the sending of marketing materials;
- Participate in any contest, promotion or survey;
- give us feedback.
- Cookies.
Cookies are small data files that are temporarily stored on your computer and mobile device by your browser and allow you to experience our website better. These files keep the session open by keeping the user’s login information, password and preferences, and make the site easier to use by recognizing the user on his next visit. Many browsers are designed to accept cookies, but users can change the settings so that they do not receive cookies or are warned when cookie files are sent. You can delete cookies by following the instructions you will find in the Settings menu of your internet browser.
6. Third Parties or Public Sources
- We may receive personal data about you from different third parties, as outlined below:
- Analytics service providers
- Marketing networks
- Search information providers
- From technical, payment and delivery service providers; communication, financial and transaction data
- From databases and resources; identity and contact data
- From public sources; identity and contact data.
7. How Do We Use Your Personal Data?
- We use your data to the extent permitted by law. In general, we use your personal data in the following situations:
- When we need to fulfill a contract that is about to be signed or that we have signed with you.
- Where it is necessary for our (or any third party’s) legitimate interests and your interests and fundamental rights do not override those interests.
- Where we are required to comply with an obligation under a law or regulation.
We generally do not obtain consent as a legal basis for processing your personal data, except to send you direct marketing communications via third parties via email or SMS. We would like to point out that you have the right to withdraw your marketing consent at any time by contacting us.
8. Our Purposes for Using Your Personal Data
We may process your data, which we use for a specific purpose, for more than one legitimate purpose. Please contact us if you need information about the specific legal bases we rely on to process your personal data.
Providing our services
Purpose/Action
data type
Legal basis for data processing, including legitimate interest
To register you as a new customer/member: Requesting your personal data for anti-money laundering purposes when an account is opened.
(a) Data type
(b) Communication
(a) Fulfillment of a contract between you and us.
(b) Fulfillment of a legal obligation.
To provide services to you and process payments for the products you have purchased.
(a) Managing payments, fees and expenses.
(b) Collecting and receiving money that is due to us.
(a) Data type
(b) Communication
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Fulfillment of a contract between you and us.
(b) Our legitimate interests are necessary (to collect the debt owed to us).
To manage our relationship with you, including:
(a) Notify you about our Terms and Conditions or changes to our Privacy Policy.
(b) Asking you to do a review or take a survey.
(a) Data type
(b) Communication
(c) Profile
(d) Marketing and Communications
(a) Fulfillment of a contract between you and us.
(b) The need to comply with a legal obligation.
(c) Necessary for our legitimate interests (keeping our records up to date and researching how customers use our products/services).
To enable you to enter a sweepstakes or contest or complete a survey
(a) Data type
(b) Communication
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Pursuant to a contract between you and us.
(b) Necessary for our legitimate interests (to research how customers use our products/services, develop them and grow our business).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and data hosting).
We also use your information to ensure that our services work as intended.
(a) Data type
(b) Communication
(c) Technical
(a) Necessary for our legitimate interests (to continue our business, provide management and IT services, network security, fraud prevention, and as part of company reorganization or group restructuring).
(b) The need to comply with a legal obligation.
To deliver relevant website content and advertisements to you, and to measure and understand the effectiveness of the advertisements we deliver.
(a) Data type
(b) Communication
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to research how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy).
Using data analytics to improve our website, products/services, marketing activities, customer relationships and experiences.
(a) Technical
(b) Use
Necessary for our legitimate interests (to identify types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations about products and services that may be of interest to you.
We use the information we collect from existing services to develop new services.
(a) Data type
(b) Communication
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to improve our products/services and grow our business).
Forwarding your personal information to any relevant competent authority in accordance with license obligations.
(a) Data type
(b) Communication
(c) Technical
(d) Usage
(e) Profile
Fulfillment of a legal obligation.
9. Marketing
We try to offer you different options for certain personal data uses in terms of marketing and advertising. Accordingly, the following personal data control system has been established:
Promotional Marketing Sourced by Us
We may use your identity, contact, usage and profile data to create an insight into what kind of services you might want or need. This is how we decide which products, services and offers might be of interest to you.
You will receive marketing messages from us if you have requested information from us or purchased [products or services] [or provided your information by registering an account] and have not revoked your consent to receive marketing messages.
Third Party Marketing
We will obtain your explicit consent before sharing your personal data with any company outside of our company.
Cancellation of Approval
You can request that we or third parties stop sending you marketing messages at any time by checking or unchecking the relevant boxes after logging in to the web page to adjust your marketing preferences, or by contacting us. Your opt-out of receiving these marketing messages will not apply to personal data provided to us as a result of a product/service purchase, product/service experience, or other transaction.
10. Change of Use
We will only use your personal data for the purpose for which it was collected, unless we reasonably believe that we need to use your data for another purpose and that purpose is compatible with the original purpose.
Where we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows this.
Please note that we may use your personal data without your knowledge or consent, in accordance with the above rules, if required and appropriate by law.
11. Sharing Your Information
We may have to share your personal data with the parties listed below for the purposes stated above.
Internal Third Parties as set forth in the Rules.
External Third Parties as set forth in the Rules.
[listed above] specified third parties
Third parties to whom we decide to sell, transfer or merge parts of our company or assets. Alternatively, we may acquire or seek to merge with other companies. In case of any change in our company, the new owners can use your personal data as stated in this privacy statement.
We require all third parties to respect the security of your personal data and to process it lawfully. We do not allow our third-party service providers to use your personal data for their own purposes, and we only allow them to process your personal data for specified purposes in accordance with our instructions.
12. Data Security
- The ONWIN site and its products have high-security features that constantly protect your information. If we detect a risky situation that we think you should be aware of, we’ll let you know and assist you with steps to take to ensure you’re better protected. Accordingly, we offer a number of security features such as Security Check and 2-Step Verification.
- We have established appropriate security measures to prevent your personal data from being accidentally lost, used or subject to unauthorized access, modification or disclosure. In addition, we limit communications to your personal data to employees, agents, contractors and other third parties who need to know for their job. These persons will only process your personal data in accordance with our instructions and are under the obligation of confidentiality.
- We limit access to personal information to ONWIN employees, subcontractors and agents who need it to process that information. Anyone with this access is subject to strict contractual confidentiality obligations and may face disciplinary action or termination if they fail to meet these obligations.
- In some cases, you can ask us to delete your data: see [Deletion request] below for more information.
- We try to make sure that our services prevent information from being accidentally or maliciously deleted. Therefore, after you delete something, it may take some time for the copies to be deleted from our active and backup systems.
- In some cases, we may anonymize your personal data (so that they cannot be associated with you) for research or statistical purposes and continue to use this information indefinitely without further notice to you.
13. Your Legal Rights
- In certain circumstances, you have the following rights in relation to your personal data under data protection laws:
- Requesting access to your personal data
- Request correction of your personal data
- To request the deletion of your personal data
- Object to the processing of your personal data
- Requesting the restriction of the processing of your personal data
- Requesting the transfer of your personal data
- Right to withdraw consent.
For more information or to enforce any of your rights above, please contact us.
We may ask you for certain information to help us verify your identity and access to your personal data. The purpose of this is to ensure that your personal data is not disclosed to any person who does not have the right to access this data. We may also contact you to request additional information regarding your request to expedite our response.
14. Changes to the Privacy Policy
We may make changes to this Privacy Policy from time to time.
When we make these changes, we will provide you with prominent notice as appropriate in the terms, for example by sending you a notification via email and/or on the site. We can inform you about this in advance.
15. How to contact us
Thank you for reading our Privacy Policy. If you have any questions about this Policy, please contact us using the Live Support line or by sending an e-mail to support@onwin.