Windsor Solutions Ltd is a registered European company and operates this Website www.windsorbrokers.com and the mobile app which is used by both Seldon Investments Ltd/Jordan registered and licensed by the JSC in Jordan and Windsor Brokers (BZ) Ltd, an investment firm licensed under the IFSC in Belize (hereinafter collectively referred to as “Windsor Brokers”)
This Policy is directed to natural persons who are either current and/or potential clients or are authorized representatives/agents or beneficial owners of legal entities or of natural persons which/who are current or potential clients of Windsor Brokers.
Windsor Brokers will gather various types of information, which includes information identifying you as an individual, this is known as “Personal data” and/or “data”. Windsor is committed to protecting your personal data and respects your privacy.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGE
It is important that the personal data we hold about you is accurate, complete and true at all times, as such please do keep us informed if your personal data changes during your business relationship with any of the Windsor Brokers related entities. In addition, you provide your implied consent for data processing/transmission/record keeping/ as between the said related entities, wherever such entities may be located, registered and/or operating.
THE DATA WE COLLECT ABOUT YOU
Personal Data, or Personal Information, means any information that related to an identified or identifiable living individual. It does not include data where the identity has been removed (anonymous data).
Information can have various ways of being obtained, including but not limited to a) information you provide us with and/or b) information that we collect;
We may collect, use, store, process and transfer different kinds of personal data about you which we have or may obtain such as Identity Data, Contact Data, Financial Data, Transaction Data, Technical Data, Profile Data, Usage Data, Marketing and Communication Data.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.
We collect information about criminal convictions and offences and politically exposed persons (PEPs). Windsor may run client/potential client details through international databases. Windsor may also collect and process personal data which is lawfully obtained not only from you but from within Windsor Brokers , or other third parties, e.g. credit reference agencies, public authorities, companies/persons that introduce you to us, companies that process card payments such as JCC Payment Systems Ltd. We may also collect and process personal data from publicly available sources, e.g. the Department of Registrar of Companies, the Land Registry, commercial registrars, the Press, media and internet, which we lawfully obtain and are permitted to process.
PURPOSE OF DATA COLLECTION/PERSONAL INFORMATION COLLECTION
When using the website as an example, details of your data are automatically registered by our server, such as your IP address, browser, the content you have visited, and how you landed on our pages, personal identification information, etc). In addition, we collect and store information such as your name, address, e-mail address, phone number, date of birth, gender and other data transmitted to us through completion of online forms, inserting information through the portal, using the mobile app and/or any other newsletters, product demos, etc.
The main purpose of collecting data is:
- Compliance with national and international legal and regulatory/supervisory provisions;
- Identifying the client and suitability of the client in relation to the products and services offered and provided by Windsor Brokers;
- Improving the quality of services to natural/legal persons;
- Research and statistic analysis;
- Facilitation of technical administration;
- To take into consideration your online website behavior and trend;
- To take into consideration your mobile app behavior and trend;
- Improve the quality of services and develop new ones;
- Improve security by protecting against fraud and abuse;
- To provide you with the transaction and post transaction-related services;
- To inform you of products and/or services that may be of interest to you;
- Ensuring network and information security;
All personal data is stored in accordance with the applicable laws on data protection.
DISCLOSURE OF DATA
Your personal data will be kept confidential and will be treated as such, it is to be noted that Windsor Brokers will only disclose website usage data and/or mobile app usage data and/or personal data, to third parties as permitted by law(s), where and if Windsor Brokers is legally obliged to do so or if such disclosure becomes necessary to enforce Windsor’s rights in particular to enforce claims arising from a contractual relationship, or required to comply with any judicial, and/or other proceedings, court order, legal process or pursuant to any governmental, intergovernmental and/or other regulatory bodies, whereby such disclosure may be executed by Windsor without prior notice to you.
Windsor Brokers will not be liable for unlawful or unauthorized use of your personal information/passwords/username/login, etc due to misuse or misplacement of your passwords, negligent or malicious intervention and/or otherwise.
Your personal data may be shared within Windsor Brokers and may be also disclosed to (but not limited to) business introducers, affiliates, , or other third party service providers in order to process obligations arising from the agreement, financial institutions, banks, other similar organizations that we deal with in course of corporate business, external service providers and professional advisers, which may be located overseas, such as auditors, lawyers and accountants, any third parties where this is necessary to process a transaction or provide services which you have requested or for trade reporting purposes.
MONITORING AND RECORDING
Windsor Brokers will as required by the Law, monitor and record any communication you have with us whether in writing, by phone or by electronic mail.
Windsor Brokers takes all appropriate security measures to ensure that the personal data/data collected and stored in connection with your visit to the website and/or usage of the mobile app and/or in relation to the services and products provided by Windsor Brokers is protected against any unauthorized access, misuse, loss and/or destruction.
Windsor Brokers uses physical and electronic security measures, including but not limited to the use of firewalls, personal passwords, encryption and authentication technologies. Windsor Brokers’ employees and service providers are bound by professional secrecy and must comply with all data protection provisions.
It is to be noted, that access to personal data is restricted to specific employees, contractors and third-party service providers who require this access in order to process the agreement between Windsor Brokers and you, all on a “need to know” basis and to be able to execute all obligations emanating from the agreements in place.
It should be noted that data transmitted via an open network like the Internet cannot be fully protected from third-party access, although we take the best possible precautions to avoid any leakage of information/data.
Any transmission of data via the internet is at your own risk, although we will exercise all ways in order to protect your personal data. Please note that all your actions while using this website and/or the mobile app may be recorded and analyzed for various purposes, including security, marketing and system monitoring purposes.
Windsor Brokers adheres to strict security standards using the most up to date security technologies.
If you do not wish to receive cookies, you may be able to change the settings of your browser to refuse all cookies or to have your device notify you each time a cookie is sent to it, and thereby the choice to accept it or not.
It is strongly recommended that you allow cookies on our website to ensure you have best possible experience. Disabling the cookies may result in reduced performance of the website and trading platform and may also impair the quality of the services that we provide you in relation to your account with us.
THIRD PARTY LINKS
The use of this website and/or the mobile app shall be governed by the laws of Cyprus and/or the applicable law of the entity in which the User proceeds to open account with based on written agreement.
Windsor Brokers will keep your personal data/data for as long as we have a business relationship with you (as an individual or in respect of our dealings with a legal entity you are authorized to represent or are a beneficial owner), and in accordance with the minimum period of retainment of personal data depending on the agreement executed by the User and the legal entity within Windsor Brokers.
Windsor Brokers shall not be required to delete data made pursuant to automatic archiving and back-up procedures in its IT systems, where a deletion is not possible or not possible without commercially unreasonable efforts.
For prospective clients’ personal data (or authorized representative/agents/or beneficial owners of a legal entity prospective client), Windsor Brokers keeps your personal data for as long as legally entitled to, unless you have officially requested deletion from the records.