Privacy Policy_

Privacy Policy for

Wintermute

Last updated: May 28, 2020


This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.


We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.


Interpretation and Definitions


Interpretation


The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.


Definitions


For the purposes of this Privacy Policy:



  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

  • Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Wintermute Trading LTD, 2 Eastbourne Terrace, Paddington.

  • For the purpose of the GDPR, the Company is the Data Controller.

  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

  • Account means a unique account created for You to access our Service or parts of our Service.

  • Website refers to Wintermute, accessible from https://www.wintermute.com/

  • Service refers to the Website.

  • Country refers to: United Kingdom

  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

  • Personal Data is any information that relates to an identified or identifiable individual.

  • For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

  •  Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.


Collecting and Using Your Personal Data


Types of Data Collected


Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:



  • Email address

  • First name and last name

  • Usage Data


Usage Data


Usage Data is collected automatically when using the Service.


Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.


When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.


We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.


Tracking Technologies and Cookies


We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.


You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service.


Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser. Learn more about cookies: All About Cookies.


We use both session and persistent Cookies for the purposes set out below:



  • Necessary / Essential CookiesType: Session CookiesAdministered by: UsPurpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.Cookies Policy / Notice Acceptance Cookies

  • Type: Persistent CookiesAdministered by: UsPurpose: These Cookies identify if users have accepted the use of cookies on the Website.Functionality Cookies

  • Type: Persistent CookiesAdministered by: UsPurpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.Tracking and Performance Cookies

  • Type: Persistent CookiesAdministered by: Third-PartiesPurpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them.


Your California Privacy Rights


(California’s Shine the Light law)


Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.


If you’d like to request more information under the California Shine the Light law, and if you are a California resident, You can contact Us using the contact information provided below.


 


California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)


California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.


To request removal of such data, and if you are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.


Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.


 


Links to Other Websites


Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.


We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.


 


Changes to this Privacy Policy


We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.


We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.


You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.