Winger

Privacy Policy

OVERVIEW

This Privacy Policy describes the policies governing the collection, use, and disclosure of information that Winger Trading, Inc. (“Winger Trading”), collects and receives from you, including information relating to your past use of the Winger Trading website and services (collectively, the “Site”).

Winger Trading may update this Privacy Policy at any time by posting the amended Privacy Policy on the Site and/or by sending a notice to the email address you provided. Your continued use of the Site shall constitute your consent to such changes and you will be subject to the then-current Privacy Policy.

COLLECTION AND USE OF INFORMATION

Winger Trading receives and may store any information you enter in on the Site or provide us in any other way. This may include personal information by which users are identified, including your username, email address, first and last name, street address, and telephone number.

Personal information may be used for general purposes including, but not limited to, sending you Winger Trading’s newsletters, notifying you of updates and other products or services that may be of interest to you, requesting your voluntary opinion/feedback, communicating with you in general, and/or other services.

Some of your private information may be disclosed to third parties (i.e. accrediting bodies) in order to provide the information and services that you request, and may be used by both Winger Trading and third parties to provide that information and/or perform those services. In addition, Winger Trading and third parties may use your private information to offer you additional information, products, or services that match your areas of interest.

If you have voluntarily provided information, you consent to the collection and use of your personally identifiable information as described in this Privacy Policy. We do not sell or rent personally identifiable information collected through the Site to anyone, although we may provide aggregate statistics about visitors to the Site such as volume, traffic patterns, and related site information to reputable third parties. These statistics will not include any personally identifiable information.

Winger Trading may also disclose information in special cases when we have a good faith belief that such action is necessary to:

  • (a) conform to legal requirements or comply with legal process;
  • (b) protect and enforce our rights or property;
  • (c) enforce the website Terms of Service or this Privacy Policy;
  • (d) act to protect the interests of our users or others;
  • (e) resolve disputes, or
  • (f) troubleshoot website problems.

Winger Trading also may receive and store information on our server logs about your browser and/or computer, including, but not limited to, IP address, pages viewed and requested, referring website and web browser software (e.g. Internet Explorer, Mozilla, etc.).

When you visit the Site, Winger Trading may collect information from you automatically through “cookies” or similar technology. Web cookies are small-unique identifier text files that allow a web server to recognize that you are a user that accessed the server on previous occasions.

Winger Trading does not sell, rent or share the information with other people or nonaffiliated companies except when we have your permission or under the following instances:

  • (1) To send marketing and other communications to our visitors about Winger Trading products or services;
  • (2) To third party vendors that provide business services to Winger Trading, including customer service, marketing, etc.;
  • (3) In response to court order, subpoena, other legal process, or as otherwise required by law;
  • (4) To exercise or establish our legal rights and/or defend against claims;
  • (5) When Winger Trading believes it to be reasonably necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of Winger Trading’s Terms of Service or as otherwise required by law;
  • (6) In connection with a corporate transaction (e.g. consolidation, merger, sale of assets, etc.); or
  • (7) Providing anonymous or aggregate information (i.e. non-personal and non-billing information) to third parties (e.g. investors, advertisers, business partners and clients) to the extent necessary to allow them to understand the kinds and number of visitors to the Site and how those visitors use the Site.

You have the right to access, correct, or request deletion of the personal information that we collect, subject to certain exceptions. To protect the privacy and the security of your personal information, we may request information from you to enable us to verify your identity and your right to access such data, as well as to search for and provide you with the personal information we maintain. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes. Please note that there may be instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain. Below are the rights that every user is entitled to:

  • The Right to Access – You have the right to request copies of your personal data held by Winger Trading. We may charge you a small fee for this service.
  • The Right to Rectification – You have the right to request that Winger Trading correct any information you believe is inaccurate. You also have the right to request Winger Trading to complete any information you believe is incomplete.
  • The Right to Erasure – You have the right to request that Winger Trading erase your personal data, under certain conditions.
  • The Right to Restrict Processing – You have the right to request that Winger Trading restrict the processing of your personal data, under certain conditions.
  • The Right to Object to Processing – You have the right to object to Winger Trading’s processing of your personal data, under certain conditions.
  • The Right to Data Portability – You have the right to request that Winger Trading transfer the data that we have collected to another organization, or directly to you, under certain conditions.

To exercise any of the rights set forth above, please contact us by email at cs@wingertrading.com.

COLLECTION AND USE OF INFORMATION THROUGH HOST SITES

Winger Trading may collaborate with other companies to make Winger Trading’s content and/or services available via their websites (“Host Sites”) or vice versa. Personal and/or demographic information you provided to Host Sites may be included in Winger Trading’s database, and we will handle such information received or gathered via Host Sites subject to this Privacy Policy.

On the other hand, information gathered via Host Sites or a website co-sponsored by Winger Trading and another company may become the property of the other company as well as of Winger Trading. The use of such information by the other company will be subject to the privacy policy of that company. Winger Trading is not responsible for that company’s use of your personal or demographic information and suggests that you to examine their privacy policy and terms of service before deciding to provide any personal, billing, and/or other information.

SECURITY MEASURES

Winger Trading has employed appropriate physical, procedural, and technological measures to help protect your personal and/or other information from unauthorized access or disclosure. We exercise great care to protect your personally identifiable information, including, among other things, using commercially reasonable and industry standard security practices. However, we CANNOT guarantee that unauthorized third parties will never be able to defeat those measures or use your information for improper purposes. We are not responsible for the retention, use, or privacy of personal and/or other information saved to the Site.

CHILDREN’S PRIVACY AND SITE AGE LIMITATIONS

The Site is intended for use by persons aged 13 or older, and by your use of this Site you affirm that you are at least 13 years of age. In addition, if you are under the age of 18, you are only permitted to use this Site with the consent of your parents or an adult guardian. Winger Trading does not knowingly allow registration of an account for any person that Winger Trading believes to be younger than 13. We also do not collect any personally identifiable information from any persons under the age of 13 and if we discover that we have been provided any such information, we will delete this information from our records.

OWNERSHIP CHANGES

In the event that Winger Trading, its business, or this Site becomes owned or controlled by other individuals or entities, the information we have collected about you through this Site or otherwise may be transferred to such other individuals or entities. In such an event, this Privacy Policy will continue to apply to the information gathered online about you through this Site until you are notified otherwise or a change is made to this Privacy Policy and posted or notified as provided above.

HOW TO CONTACT US

If you have any questions about this Privacy Policy or the personal information we have collected from you, or if you would like to exercise one of your data protection rights, please do not hesitate to contact us at cs@wingertrading.com.

Last updated: 6/26/2023