Information pursuant to Articles 13 and 14 GDPR
Privacy Policy
This policy applies exclusively to the German- and English-language trading information website operated by Win-Win Consult LTD.
1. Controller and privacy contact
Win-Win Consult LTD
86A Triq Leli Falzon
Naxxar, NXR 2609, Malta
Director: Michael Rehberger
Email: mrehberger@win-win-consult.de
Telephone: +49 (0)177 6960650
No data protection officer has been appointed. Please direct privacy enquiries to the email address stated above.
2. Accessing the website and server log data
When you access the website, technically necessary data is processed. This may include your IP address, date and time of access, requested address, amount of data transferred, referrer URL, browser type, operating system, and status or error information. Processing is carried out to provide the website securely and reliably, analyse errors and prevent misuse.
Legal basis: Article 6(1)(f) GDPR. Our legitimate interest is the secure and functional operation of this website. Recipients may include hosting, platform, security and content-delivery service providers engaged by us. Log data is deleted or anonymised when it is no longer required for these purposes, subject to statutory obligations and security-related retention requirements.
3. Information requests, Zoho form and CRM
If you request information using the embedded form, we process the information you provide, currently your first name and email address, together with verification and technical data relating to registration and confirmation. The form is embedded as third-party content supplied by Zoho. Therefore, when the form loads, your browser may establish a direct connection to Zoho and transmit, in particular, your IP address, device and browser information, the time of access and the page viewed.
The information entered is automatically transferred to services of the Zoho group and processed there on our behalf. In particular, we use Zoho CRM, Zoho Marketing Automation and Zoho Mail.
Your specific request and the delivery of the information you requested are processed on the basis of Article 6(1)(b) GDPR where this concerns pre-contractual measures, and otherwise on the basis of Article 6(1)(f) GDPR. Our legitimate interest is the proper handling of your request. Where processing is based on consent expressly given by you, the legal basis is Article 6(1)(a) GDPR.
Required information is necessary for us to handle your request and provide the requested information. Without it, the request cannot be processed via the form. We do not use Zoho website analytics or website automation tracking code on this website. Under the current technical configuration, we do not intend to use optional Zoho tracking cookies for general website analytics.
4. Requested email information, other projects and double opt-in
After registration, we send you only the information you requested and the associated email series relating to the trading project. We use a double opt-in procedure to confirm your email address. We record the registration, dispatch of the confirmation message and the confirmation itself, where technically available including timestamps, source, version of the consent text and IP address. This also serves as evidence of your request.
In the final message of this series, we may point out that you can actively request further information about other projects if you are interested. This notice alone does not sign you up for general advertising. You will receive further or recurring information about other projects and offers only if you expressly request or consent to it. You may withdraw such consent at any time with effect for the future via the unsubscribe link or by contacting us.
Legal bases: Article 6(1)(b) or (f) GDPR for the requested trading information; Article 6(1)(a) GDPR for voluntarily requested additional marketing information. We also rely on Article 6(1)(f) GDPR for documenting requests and consent and for defending against unjustified claims.
5. Email open and click measurement
Where emails contain technical tracking pixels or personalised links, these may be used to measure email opens and link clicks. Such data is linked to you personally and evaluated based on your interests only where separate consent has been obtained. Without such consent, we do not carry out person-related open or click tracking.
Legal basis for person-related evaluation: Article 6(1)(a) GDPR. Consent is voluntary and may be withdrawn at any time with effect for the future.
6. Zoho services, processing on our behalf and international transfers
We use services provided by the Zoho group, including form, CRM, marketing, email and booking functions. For the processing of personal data on our behalf, we have entered into a Data Processing Addendum with Zoho Corporation B.V., Beneluxlaan 4B, 3527 HT Utrecht, the Netherlands, in accordance with Article 28 GDPR.
Under this agreement, personal data is generally stored in Zoho data centres within the European Economic Area (EEA). In the course of providing the services, however, data may also be processed by or accessed from Zoho group companies, sub-processors or other service providers outside the EEA. Zoho undertakes to ensure a valid transfer mechanism as required by the GDPR for such transfers.
When the form or booking page is accessed and when these functions are used, contact, communication, booking, usage, device and log data may in particular be processed. Further information is available in Zoho's Privacy Policy.
7. Appointment booking via Zoho Bookings
If you open the link to book an introductory meeting, you leave this website and access Zoho Bookings. Zoho processes the data required to provide the booking service and complete the booking. We use the booking and contact details you enter to prepare for and conduct the requested meeting.
Legal basis: Article 6(1)(b) GDPR where the booking concerns pre-contractual measures; otherwise Article 6(1)(f) GDPR.
8. YouTube videos
Video preview images are loaded locally from our web server. Merely displaying the preview therefore does not establish a connection to YouTube. Only when you click the video preview is a connection established with YouTube via the youtube-nocookie.com domain. Your IP address, device and browser information and information about your use of the video may then be transmitted to Google or YouTube.
Legal basis for loading the player: your consent pursuant to Article 6(1)(a) GDPR. Google's transfer mechanisms apply to international data transfers. Further information is available in Google's Privacy Policy.
9. ProvenExpert
A ProvenExpert review widget is embedded on the website. When the widget loads, a connection to ProvenExpert servers may be established. In particular, your IP address, browser and device information, referrer, time and page viewed may be processed. The 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 presenting our services in a transparent and verifiable manner. Further information is available from ProvenExpert.
10. External operator of the trading project and referral remuneration
The trading project described on this website is operated by a legally independent third-party provider. Win-Win Consult LTD may receive referral remuneration if a referral 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 there, you must independently create a customer account with the relevant provider.
The respective provider is responsible for its own processing and will provide you with separate information about it.
11. Recipients and retention periods
Within Win-Win Consult LTD, access is limited to persons who need the data to process your request and communicate with you. In addition, carefully selected IT, hosting, CRM, email, marketing, booking and security service providers may receive data where necessary to provide their services.
Data relating to the requested trading communications is retained until the information series has been completed or until you unsubscribe earlier. Data used for additional marketing information expressly requested by you is generally retained until you withdraw your consent.
We then delete or restrict the data unless it is still required to document your request or consent, comply with an objection to marketing, defend legal claims or satisfy statutory retention obligations. Request and booking data is deleted once the purpose no longer applies and there are no statutory or legal reasons for further retention.
12. Your rights
Subject to the GDPR, you have the right of access, rectification, erasure, restriction of processing, data portability and objection. You may withdraw consent at any time with effect for the future. 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 data protection supervisory authority. The Information and Data Protection Commissioner, Malta, is in particular the supervisory authority responsible for us. You may also contact the supervisory authority at your habitual residence or place of work.
13. No automated decision-making and no minors
There is no decision about your suitability based solely on automated processing and no profiling within the meaning of Article 22 GDPR. Any personal assessment is carried out manually. The offer and contact options are intended exclusively for adults.
14. Requirement to provide data and updates
As a general rule, you are not legally required to provide personal data to us via this website. However, information marked as required is necessary for us to process a request or booking. We update this policy if functions, service providers or legal requirements change.