Privacy Policy

1. Controller and privacy contact

No data protection officer has been appointed. Please send privacy enquiries directly to the email address above.

2. Website access and server logs

When this website is accessed, technically necessary data may be processed, including IP address, date and time, requested URL, amount of data transferred, referrer URL, browser type, operating system, and status or error data. Processing is necessary to provide the website securely and reliably, diagnose faults and prevent misuse.

Legal basis: Article 6(1)(f) GDPR. Our legitimate interest is the secure and functional operation of the website. Recipients may include hosting, platform, security and content-delivery providers engaged by us. Log data is deleted or anonymised when no longer needed, subject to legal obligations and security-related retention.

3. Knowledge guide, Zoho form and contact management

When you request the free guide “Trading Knowledge Compact”, we process the data you provide, currently your first name and email address, together with technical and evidentiary data relating to registration and confirmation.

The form is provided through Zoho services. When it loads and is submitted, data including IP address, device and browser information, time, page viewed and the contact information you enter may be transmitted to Zoho and processed on our behalf. We use Zoho Marketing Automation and related Zoho services for contact and email management.

Legal bases: Article 6(1)(a) GDPR where you consent to receive the email series, supplemented by Article 6(1)(f) GDPR for technical delivery, evidentiary purposes and abuse prevention.

4. Double opt-in and email series

We use a double-opt-in process to confirm your email address. We document registration, dispatch of the confirmation message and confirmation itself, where technically available including timestamps, source, wording/version and IP address.

After confirmation, you receive the requested guide and a short related email series with additional information on trading, time commitment, costs, risk, psychology and decision-making. Each message includes an unsubscribe option.

A later message may mention that you can actively request further information about other topics or projects if interested. This notice alone does not subscribe you to additional marketing communication.

5. Email open and click measurement

Where emails contain tracking pixels or individualised links, these may be used to measure opens and link visits. We associate such data with you and evaluate it according to individual interests only where separate consent has been given. Without that consent, we do not use personalised open or click analysis.

Legal basis for personalised analysis: Article 6(1)(a) GDPR. Consent is voluntary and may be withdrawn at any time with future effect.

6. Zoho services and international transfers

We use Zoho services for forms, CRM, marketing, email and bookings. When the form or booking page is opened or these functions are used, contact, communication, booking, usage, device and log data may be processed. Depending on the account configuration and Zoho entity involved, processing may occur outside the European Economic Area. In that event, the statutory requirements for international transfers must be met, particularly through an adequacy decision or safeguards such as the EU Standard Contractual Clauses.

Further information is available in Zoho’s Privacy Policy.

7. Guide download via Zoho WorkDrive

The guide is provided through a public sharing link in Zoho WorkDrive. When the link is opened, technically necessary access and log data such as IP address, time, browser and device information may be processed. A Zoho user account is not required to download the guide.

8. Recipients and retention

Within Win-Win Consult LTD, access is limited to persons who need the data to handle your enquiry and communications. Selected providers of IT, hosting, CRM, email, marketing, bookings and security services may also receive data where necessary to provide their services.

We retain data relating to the requested trading communication until the information series is complete or you unsubscribe earlier. Data used for additional marketing information that you expressly requested is generally retained until you withdraw consent. After that, data is erased or restricted unless still needed to document your request or consent, honour an objection to marketing, establish or defend legal claims, or comply with statutory retention obligations. Enquiry and booking data is erased once its purpose has ended and no legal reason for further retention remains.

9. Your rights

Subject to the GDPR, you have rights of access, rectification, erasure, restriction, data portability and objection. You may withdraw consent at any time with future effect; processing carried out before withdrawal remains lawful. You may object to direct marketing at any time.

You also have the right to lodge a complaint with a supervisory authority. Our competent authority is in particular the Information and Data Protection Commissioner, Malta. You may also contact the authority where you habitually live or work.

10. No automated decisions; adults only

We do not make solely automated suitability decisions and do not conduct profiling within the meaning of Article 22 GDPR. Any personal assessment is carried out manually. The offer and contact facility are intended exclusively for adults.

11. Provision of data and updates

You are generally under no legal obligation to provide personal data through this website. However, information marked as required is necessary to handle an enquiry or booking. We update this policy when website functions, service providers or legal requirements change.