WINNAR TRADING LLC

This Privacy Policy aims to clarify how we handle your personal data during your interactions with our Website, regardless of your location. It’s essential for you to understand your privacy rights and the legal safeguards in place. This document elaborates on the methods and reasons behind the collection, usage, sharing, transfer, and storage of your personal data. Furthermore, it provides information on your rights under relevant data protection laws and regulations.

Our Privacy Policy pertains to the personal data we gather from users (referred to as “you” or “your“) who engage with our Website, applications, and services.

Please take the time to read and comprehend our Privacy and Cookies Policy. It furnishes you with crucial information about how we manage your personal data and the ways in which you can exercise your privacy rights, including the utilization of cookies on our Website. If you continue to utilize our Website, applications, or services, you are signifying your agreement to the practices outlined in this Privacy and Cookies Policy.

We reserve the right to revise this Privacy and Cookies Policy from time to time and any changes will be communicated by posting the updated terms on our Website. Once these revised terms are published, they will be deemed effective immediately. Your continued use of our Website indicates your acceptance of these modifications and signifies your consent to abide by them.

In the context of our Website’s Privacy Policy, “Personal Data” refers to any data, details, or particulars that refer to an identifiable individual. This includes but is not limited to a person’s name, contact information, birth date, identification numbers, online identifiers, and any other data that, when combined or associated with other information, can lead to the identification of the individual. Personal Data encompasses any information that we collect from users, visitors, or customers that can be linked to a specific individual, directly or indirectly.

This Website is designed for individuals who are not considered children, and we do not intentionally gather information pertaining to children.

Any capitalized terms within this document hold the meanings described herein or as defined in other legal materials that we periodically publish or disseminate to you.

This Privacy and Cookies Policy is an integral part of the Terms & Conditions of this Website.

• CONTROLLER
  • For the purposes of applicable data protection law, the “Controller” processing your Personal Data is WINNAR TRADING LLC (referred to as we,” “us” or “our”).
• COLLECTION OF PERSONAL DATA
  • The Personal Data we gather from you can either be specific to your individual identity or of a general nature.
  • When you create an account on our Website, make updates to your information, make purchases of Products, or access our services, engage in promotions, or establish communication with us via email or alternate channels, you provide us with data that we store and subsequently process as needed. This information may include details such as your name, address, contact number, email addresses, payment card information, digital wallets, records of purchases and transactions, areas of interest, images, photographs, gender, age, geographical location, nationality, and other personal data.
  • We may collect and subsequently process general information that we consider necessary, which comes from your interactions with and from the use of our Website. This general information might include data received from or about you. It could further include information such as your IP address, the time period you access our Website, duration of your Website visit, your browsing history, the internet address of the site from which you directly linked to our Website, and analogous general details of this nature.
  • We refrain from collecting any special categories of Personal Data pertaining to you. These categories include information regarding your religious or philosophical beliefs, your sexual orientation and activities, your political opinions, membership in trade unions, details about your health, as well as genetic and biometric data.
• USAGE OF PERSONAL DATA
  • The Personal Data we collect from you in the course of rendering our services to you, will be process for the purposes set out below.
  • We collect your payment information, which encompasses details related to your credit or debit card and/or digital wallets. This collection serves the purpose of enabling you to carry out purchases of our Products through the Website. We are refrained from storing, selling, sharing, renting, or leasing any of your payment information or Personal Data to any third party.
  • We reserve the right to collect and utilize your image and voice with the intention of announcing and promoting you as the Winner of any Prize.
  • You may be able to use the Website without giving us any information about yourself. However, there are certain services that may involve the collection of information from you. This information serves the purpose of delivering the best possible service, primarily for maintaining internal records aimed at enhancing our Products and Services. Additionally, this data enables us to communicate with you concerning orders, purchases, or participation in raffle competitions hosted on our Website. We might also communicate with you for market research purposes and to provide details about new raffle competitions, new products, promotions, special offers, and other information we deem relevant to you. Any correspondence initiated by you through the Website or via email using the contact information provided on the Website might be recorded for future reference.
  • The collection of general information serves the purpose of making the Website more user-friendly. The subject collection helps us in evaluating the content of our Website and confirm its alignment with your interests and contributes to various objectives and for other purposes such as determining the Website’s technical design and specifications. Furthermore, it assists in identifying system performance or potential areas of concern, monitoring Website activity, generating reports, analyzing trends, and observing how the Website is utilized. The process of collecting general information as described in this Clause 3.5, is carried out in a manner that prevents personal identification of individual users.
  • This Website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and we are not responsible under any circumstances for their privacy statements. The information gathered by these third parties are not subject to this Privacy Policy and you should be aware and informed at all times, of the privacy policies that these third parties may have.
  • Certain advertisements displayed on the Website, originate from third parties, including ad networks, advertising agencies, advertisers, and audience segment providers. These third parties may gather information about you and your online activities, whether on the Website or other websites, employing technologies, like cookies, web beacons, and similar methods which aim to comprehend your preferences and provide you with advertisements that align with your interests. You hereby acknowledge and confirm that we lack access to, and control over, the information that these third parties may collect.
  • You hereby confirm that the Personal Data we hold about you is accurate and current. You acknowledge and agree to keep us at times informed if your Personal Data changes during your relationship with us.
• DISCLOSURE OF PERSONAL DATA
  • You confirm and agree that we may share your Personal Data within our group entities, subsidiaries, and partner companies.
  • We shall not share, sell, transfer, dispose of, or rent your Personal Data in any manner to any third parties outside of our group of companies, except when we have your consent under this Privacy Policy, or if we are required to do so by law or by any governing authority.
  • You confirm that we may share your Personal Data with our third-party service providers, with brands for advertising and marketing purposes, and with third parties for data storage or analytics purposes, including the sharing of such information within our group of companies, for all the permitted purposes.
  • Our intention is to retain your Personal Data within the boundaries of the United Arab Emirates (UAE). However, should circumstances necessitate such a transfer, we will ensure that the subject data receives a level of protection akin to that applicable in the UAE.
• DATA SECURITY
  • We want to ensure you that appropriate security measures are in place to safeguard your Personal Data.
  • We take all reasonable steps to protect your Personal Data from any unauthorized access, use, alteration, disclosure, or destruction.
  • Although we have implemented managerial, electronic, and physical measures to secure and protect your Personal Data, we cannot assume any responsibility whatsoever for any unauthorized access by third parties. We are unable to provide an absolute assurance that the Personal Data you provide or transmit through the Website or via email will be entirely secure and invulnerable to risks.
  • It is your absolute responsibility to keep any passwords you use strictly confidential and be careful from “phishing” scams where someone may send you a deceptive electronic message that appears to be from us asking you to provide your Personal Data.
  • Please be aware that we will never request your ID or password via electronic messages.
• DATA RETENTION
  • We will only retain your Personal Data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.
  • We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
  • To determine the appropriate retention period for Personal Data, we take into account factors such as the quantity, type, and sensitivity of the information, the potential risks associated with unauthorized access or disclosure of your Personal Data, the specific objectives for processing your Personal Data, the feasibility of achieving those goals through alternative methods, and the relevant legal, regulatory, tax, accounting, or other obligations.
• YOUR LEGAL RIGHTS
  • You have the right to:
    • Request access to your Personal Data;
    • Request correction of the Personal Data we possess about you;
    • Request erasure of your Personal Data;
    • Object to the processing of your Personal Data, particularly when our reliance on legitimate interests (your rights or those of a third party) you feel that infringe upon your fundamental rights and freedoms;
    • Request the restriction of processing your Personal Data;
    • Request the transfer of your Personal Data to either you or a third party; and
    • Withdraw consent at any time.
  • Accessing your Personal Data or exercising your rights does not entail any fees. Nevertheless, if your request is deemed clearly unfounded, repetitive, or excessive, we reserve the right to levy a reasonable fee. Alternatively, you acknowledge and consent that we may decline to fulfill your request under such circumstances.
  • For security purposes, we might ask you to provide specific information that aims in verifying your identity and substantiating your entitlement to access your Personal Data (or enact any of your rights). This step ensures that no Personal Data is disclosed to individuals without the proper authorization. In certain cases, we may also reach out to you for additional details relevant to your request, with the intention of expediting our response.
  • Should you have inquiries regarding the nature of the Personal Data we possess about you or if you intend to exercise any of your data subject rights, kindly submit a written request to [ ].
• COOKIES POLICY

  We value your experience on our Website and we wish to enhance it in every possible way. As is common practice across most professional websites, including our Website, we utilize cookies to optimize user interactions. This Cookies Policy seeks to clarify the nature of cookies, their purpose, the information they collect, and the reasons behind their storage.

  This Cookies Policy pertains to our website, its sub-domains (if any), related websites, and branded pages on third-party platforms or applications linked to or operated by us. By utilizing our website, you automatically consent to the use of cookies in accordance with this policy.

  If you do not agree with the use of cookies in this way, you should set your browser settings accordingly or not use our Website at all. Please kindly note that, as explained below further, if you disable the cookies we use, this may impact negatively your user experience while on our Website.

  • Cookies: Cookies are small text files, pieces of data or code placed on your device to collect information when you visit the Website. Each cookie is furnished with a distinctive identification number or value. We might also use other similar technologies such as web beacons, tags, pixels, scripts, local storage, etc., with the intention of helping us in delivering the services explained in the policies available on our Website.
  • Functionalities: Cookies facilitate the process of identifying account holders, tracking new users, preserving session details, and elevating your general browsing encounter. The primary function of cookies is to collect information concerning your personal preferences, interests, patterns, and behaviours. This data is typically gathered when you visit and navigate our Website, engage with our services and products, communicate with us via the Website, and when you undertake activities like applying to register as a customer or partner through the Website, including the sign-in process. Cookies collect this information and share it with us. They can be established either directly by us or through a third-party provider acting on our behalf.
  • Control: Most browsers automatically accept cookies, yet you have the option, to adjust your browser settings to decline all or some cookies, or to receive notifications when websites establish or access cookies.
  • Type of Cookies: There are two types of cookies utilized on our Website, namely (a) session cookies and (b) persistent cookies. Session cookies possess a temporary nature, existing solely on your device during the period of Website usage. Once you depart the Website or close your browser, these cookies are automatically deleted. In the contrary, persistent cookies maintain their presence on your device for an extended duration, depending on the “lifetime” span of the specific cookie and your browser settings (i.e., until expiration) or until you manually remove them. The following categories describe in detail the cookies available on our Website:
    • Strictly Necessary Cookies: These cookies are placed on our Website by default and cannot be deactivated, as they are absolutely necessary in order for our Website to function properly (including activities such as logging in, navigating the website, accessing secure sections, completing online forms, etc.). They also help us in detecting and swiftly resolving technical issues.
    • Session Cookies: Session cookies are used to enable the user to navigate the Website and use its features. It also used to retain the information the user provides us with while navigating through each section of our Website such as remembering previous actions. These cookies do not identify you as an individual. Declining these cookies might impact the Website’s performance or specific sections thereof.
    • Analytical Cookies: Analytical cookies supply us with anonymous, aggregated insights into how you interact with the Website, including which web pages you have visited, the duration of visits, the links clicked, and general activities across our Website. They may be set by us or by third-party providers to help us understand which pages are the most and least popular and see how visitors move around the Website. Analytical cookies do not divulge any identifying information specific to your person but they do help us improve how we provide you with our content.
    • Functional Cookies: These cookies allow our Website to remember and save the choices you make (such as your username or your preferred language) to provide a more personalized online experience across our Website. These cookies may collect personally identifiable information that you have voluntarily provided, like your username or profile picture. Opting not to accept these cookies may impede website performance and functionality, potentially limiting access to certain content.
    • Performance Cookies: These cookies help us understand how visitors interact with our Website by providing information about the areas visited, the time spent on the website, and any issues encountered, such as error messages. This helps us improve the performance of our Website. It may also count visits and traffic to help us understand which pages are most and least popular. These cookies do not identify you as an individual. All information and data are collected and aggregated anonymously.
    • Advertising Cookies: These cookies are used to customize the Website’s content according to what is more relevant to your preferences and your interests. They may be used to deliver targeted advertising or to limit the number of times you see an advertisement. They also help us measure the effectiveness of advertising campaigns on the Website. We may use these cookies to remember websites you have visited and we may share this information with other parties, including advertisers and our agencies. Targeting cookies could also be set through to our Website by our advertising partners, business partners, and associates and/or present ads to you which are not owned or operated by us. These cookies may gather limited personally identifiable information, such as a user’s IP address.
  • Managing Cookies: Please be aware that if you opt to disable or decline cookies, specific parts of this Website might become inaccessible or experience impaired functionality. You can change your browser settings to adjust, modify, prevent or block cookies; or to alert you when cookies are being sent to your computer or device (see your browser Help for how to do this). You can also manage your preferences by changing your browser settings on your device to refuse the use of some or all cookies. Please note however that by disabling cookies it may have a negative impact on your browsing experience while on the Website and any other websites that you visit. Disabling cookies will usually result in also disabling certain functionalities and features of the Website or you may be unable to visit or use certain areas of the Website. Considering these implications, we recommend refraining from disabling such cookies for an optimized browsing experience.
  • Third-Party Cookies: On occasion, cookies may originate from companies engaged in advertising on our behalf or on behalf of our group of companies. It is important to note that we lack control over these cookies, and these cookies are not subject to this Privacy Policy.
  • Google Analytics: Our Website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies and/or text files to analyze website traffic. The information generated by cookies, including your details (including your IP address), is transmitted to a Google server located in the United States of America.
  • Google Data Processing: Google processes this information to assess your interaction with the Website, generate reports about the Website’s activities on our behalf, and offer other associated services related to website and internet usage.
  • Third Parties Sharing: Google may also share this information with third parties as required or if these third parties are processing the data on Google’s behalf.
  • Agreement to Processing: By using this Website, you explicitly consent to Google’s processing of the information as described herein, and in alignment with the provisions of this Privacy and Cookies Policy.
  • Limitation of Liability: Neither we, our respective suppliers, nor any of our shareholders, group companies, subsidiaries, partner companies, nor their officers, directors, partners, agents, managers, members or employees bear responsibility for any direct or indirect, punitive, incidental, special, or consequential damages or losses (including, but not limited to, incidental and consequential damages, lost profits, or damages arising from lost data or business interruption) linked to the usage of the information outlined herein.
  • Digital Tracking: We utilize Instagram, Facebook and Google tracking pixels on the Website and consequently, third parties may use cookies, web beacons and comparable technologies to gather or obtain information from both the Website and other online locations. They use this information to supply measurement services and deliver targeted advertisements. In case you wish to abstain from the use of these tracking pixels, you are urged to modify your browser settings accordingly.
• LEGAL INFORMATION
  • This Privacy and Cookies Policy as well as your access to our Website is subject to and governed by the laws of the United Arab Emirates as applied in the Emirate of Dubai without giving effect to conflicts of law principles thereof.
  • Any dispute regarding this Privacy and Cookies Policy or our handling of your Personal Information, General Information, and Cookies utilized by our Website is subject to the exclusive jurisdiction of the Courts in Dubai.
  • The Privacy Policy has been prepared based on provisions of multiple legislations, including Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data, as amended from time to time.
  • This Privacy and Cookies Policy relates solely to this Website, if not explicitly stated otherwise herein.