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. Information requests, Zoho form and CRM

When you request information through the embedded form, we process the data you enter—currently your name and email address—together with technical and evidentiary data relating to registration and confirmation. The information is automatically transferred to services within the Zoho group and processed there on our behalf. Services used include Zoho CRM, Zoho Campaigns or Zoho Marketing Automation, and Zoho Mail.

A specific request is processed under Article 6(1)(b) GDPR where it concerns pre-contractual steps, and otherwise under Article 6(1)(f) GDPR. Our legitimate interest is the proper handling of your enquiry. Where processing is based on express consent, the legal basis is Article 6(1)(a) GDPR.

Required information is necessary to handle your request or provide the requested email communication. Without it, the form cannot be used for that purpose.

4. Email information, marketing and double opt-in

If you give separate consent, we may email you information about the trading project and, where applicable, other products and offers from Win-Win Consult LTD. We use a double-opt-in procedure. We record the registration, dispatch of the confirmation message and confirmation itself, where technically available including timestamps, source, consent wording/version and IP address. This also enables us to demonstrate consent.

Legal basis: Article 6(1)(a) GDPR; evidence of consent and defence against unjustified claims may additionally rely on Article 6(1)(f) GDPR. You may withdraw your consent at any time with future effect by using the unsubscribe link in any email or contacting us.

5. Personalised open and click tracking

If covered by your separate consent, emails may contain tracking pixels and individualised links. These allow us to determine whether an email was opened and which links were clicked, and to associate this information with the relevant recipient. We use the data to measure effectiveness and adapt content to apparent interests.

Legal basis: Article 6(1)(a) GDPR. Consent is voluntary and may be withdrawn at any time with future effect. Personalised open and click tracking will not take place without the relevant consent.

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. Appointments via Zoho Bookings

If you open the link for booking an orientation call, you leave this website and access Zoho Bookings. Zoho processes the information required to provide and complete the booking. We use the booking and contact data you submit to prepare for and conduct the requested call.

Legal basis: Article 6(1)(b) GDPR where the booking relates to pre-contractual steps, and otherwise Article 6(1)(f) GDPR.

8. YouTube videos

The video preview images are loaded locally from our web server. Merely displaying a preview therefore does not establish a connection to YouTube. Only after you click the video preview is a connection made to YouTube through youtube-nocookie.com. Your IP address, device and browser information and video-use details may then be transferred to Google or YouTube.

Legal basis for loading the player: your consent under Article 6(1)(a) GDPR. Google provides its own mechanisms for international transfers. See Google’s Privacy Policy.

9. ProvenExpert

A ProvenExpert review widget is embedded on the website. Loading it may connect your device to ProvenExpert servers. This may involve processing your IP address, browser and device details, referrer, time and page viewed. Its purpose is to display external customer reviews.

Legal basis: Article 6(1)(a) GDPR where consent is requested; otherwise Article 6(1)(f) GDPR based on our interest in providing verifiable evidence of our services. See ProvenExpert’s privacy information.

10. Independent trading-project operator and referral fee

The trading project described on this website is operated by a legally independent third-party provider. Win-Win Consult LTD may receive a referral fee if an introduction results in a customer relationship with that provider. We do not automatically transmit your name or email address from the information form to the operator or other partners. If you wish to become a customer, you must independently create an account with the relevant provider. That provider is responsible for its own processing and will provide separate privacy information.

11. 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 generally retain contact details used for email information until you unsubscribe or withdraw consent. After that, data is erased or restricted unless still needed to document 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.

12. 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.

13. 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.

14. 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.