Last Revised: September, 2020

Introduction

Wind Trust Ltd. (the “Company“, “Wind Trust” or “we“) respect the Privacy of its users (“user“, “you“, “your”), and therefore we encourage you to read this privacy policy (“Policy“) carefully prior to accessing or using our website or Services (as defined under our Terms of Use (“Terms“)).

The Policy is an integral part of the company’s website Terms and it governs the data collection, process and transfer regarding your use of the website or Services. The definitions used in this Policy, which are not defined in the Policy, shall have the meaning ascribed to them in our Terms.

This Policy details the types of information Wind Trust may collect from you during your visit of the website, how such information may be used or shared with third parties, how we safeguards it and how you may exercise your rights related to your Personal Data (as this term is defined below).

Under the applicable law (included the GDPR), the legal basis for processing Personal Data is as follows:
(i) Wind Trust will process your online identifiers for the following purposes: operation, functionality and security;
(ii) When you choose to contact Wind Trust, we will process your contact details.

The “Last Revised” date of the Policy is indicated above. The Company has the right to amend or revise this Policy at any time and at its sole discretion. Please review this Privacy Policy often as it may be updated from time to time. We will make best efforts to post a notice where we add material changes that will adversely affect your rights.

What types of information we collect?

If you access Wind Trust’s website or interact with our Services, we may collect the following information about you as described below:

(I) Non-Personal Data: Non-Personal Data is a non-identifiable aggregated data, such as technical data which is transferred from the user’s device. Non personal data is not used to identify individuals;
(ii) Personal Data: Personal Data is data which identifies or may with reasonable effort identify an individual, including online identifiers, for example IP address.

The types of data that will be collected their use:

I. Wind Trust may collect technical data when you access or interact with our website. The data may include information regarding date and time stamp, device’s type, operating system, language preference estimated location, traffic source that lead the user to the website and other actions in the website. The company may use the data to administer internal statistics and for operation purposes.

II. If you choose to contact Wind Trust, Wind Trust will ask you to add contact details such as name, or email address (“contact details”). Wind Trust may use the information regarding communicated in order to respond, and provide you with the service you may request. Moreover, the information regarding your communication with us may be stored if the company finds it is required to provide you with any assistance needed, improve the services or for any future claim to.

III. Wind Trust or our service providers may collect your IP addresses or other special online identifiers through your use of the website. We collect such data in order to provide and operate the website, improve the content therein, for internal statistics, analyze traffic flow and security related purposes.

The Data we share

Wind Trust does not share with third parties any Personal Data collected from you, except as follows:

I. Service Providers: in order to perform certain services on your behalf, Wind Trust may share your information with third parties. We prohibit our providers from using your information for any purposes which are not performing our instructions.
II. Corporate Transactions and Affiliated Companies: Wind Trust may share your information with its parent company, any of its subsidiaries, joint ventures, or any other companies that are under common control with us (“Affiliated Companies”) only if and when applicable or necessary for the purposes described in this Policy, or in the event of a corporate transaction (e.g. purchase of a substantial part of our business, merger, consolidation or asset sale). In such an event, we will make our best efforts to ensure that the acquiring company or our Affiliated Companies will assume our obligations as described in this Policy.
III. Comply with Applicable Law: Wind Trust may share your information in this situation, only if it will required to do so in order to comply with any legal requirements, for example, to comply with a court injunction ;
IV. Consent: Wind Trust may share your information, subject to your consent. If the company does so, your information will be subject to such third party’s privacy policy.

Data Security

We deploy industry standards and better technical and administrative security measures in order to secure your Personal Data. However, it is very important for you to remember, we cannot guarantee the security of data transmitted via the internet, which can’t be one hundred percent secure and we cannot be responsible for the acts of those who gain unauthorized access or abuse our website. Wind Trust makes no warranty, express, implied or otherwise, that it will be able to prevent such access. Please contact us at: support@windtrustltd.com in the event you think that a third party attempted to gain unauthorized access to your Personal Data, your privacy was not dealt with properly or your privacy was dealt with in a manner that was in breach of our Policy.

Data Transfer

Wind Trust may store or process your Personal Data in various territories, including in the US. If you are a resident of the EEA we will take appropriate measures to ensure that the Personal Data receives an adequate level of protection according to applicable law.

The rights of our users

Privacy and data protection laws and regulations may provide specific rights (depending on applicable jurisdiction) regarding Personal Information, as follows:
I. The right to amend Personal Data (by adding, correcting, or deleting information);
II. The right to access Personal Data;
III. The right to file a complaint with a supervisory authority in the user jurisdiction;
IV. The right to ensure that Personal Data is accurate, complete and up to date;
V. The right to withdraw your consent, according to legal or contractual restrictions and reasonable notice;
VI. The right to object to the processing of Personal Data;
VII. The right to send or “port” Personal Data;

In the event that you contact Wind Trust regarding the exercise of rights detailed above, we may request you to provide us certain information in order to verify your identity and locate such data. Such a process may take some time, subject to applicable privacy laws. In the event the user does not provide us the required information, or under the applicable law, Wind Trust may reject your request.

Subject to privacy protections laws in your jurisdiction, you may have different rights than the rights listed above. For filing file a request to exercise any of the above rights, you may contact our privacy team at: support@windtrustltd.com

Children

The website and Services of Wind Trust are not intended for use of children under the age of 16 (or as defined by applicable). The company does not knowingly process a child’s information. Wind Trust will discard any information that it receives from a user that is considered a “children” immediately upon its discovery. If you have reason to believe that a child has shared any information with us Please contact us at: support@windtrustltd.com.

Data retention

Subject to applicable laws, unless you instruct us otherwise, we retain the collected information for as long as necessary to provide our services as described above, enforce our agreements (if applicable) and to any lawful needs. Please note, that this Policy shall not be interpreted as an obligation to record information, and we may, at our own discretion, avoid from any recording and storing or delete any and all kind information.

Do Not Track Disclosure

Our website does not respond to Do Not Track signals. In order to receive additional information regarding Do Not Track, please visit: http://www.allaboutdnt.com/.

Contact information

If you have any questions regarding our Policy, you are welcome to contact us as follows:

WIND TRUST LTD

support@windtrustltd.com