🔏Privacy Policy

This privacy notice provides you with details on how we collect and process your personal data through the use of our App https://app.win.investments/es.

By providing us with your data, you warrant to us that you are over 13 years of age.

WIN SPORTS MARKET, SA is the data controller and we are responsible for your personal data (referred to as “we”, “us”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer (DPO) who is responsible for privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details below.

Company Data

Full name of the legal entity: WIN SPORTS MARKET, SA

Name or title of Data Protection Officer: Gonzalo Busnadiego

E-mail address: [e-mail]

Postal Address: 28001

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at [e-mail].

User personal data

Personal data means any information capable of identifying an individual. It does not include anonymized data. We may process the following categories of personal data about you:

• Communication data which includes any communication you send to us, whether through the contact form on our website, the app, by email, text message, social media messaging, social media posts or any other communication you send to us. We process this data for the purpose of communicating with you, for registration and for the establishment, prosecution or defense of legal claims. Our legal basis for this processing is our legitimate interests which, in this case, are to respond to communications sent to us, to maintain records and to establish, pursue or defend legal claims.

• Customer data which includes data relating to any purchase of goods and/or services, such as your name, date of birth, ID card number, telephone number, qualified investor declaration, country of residence, city of residence, zip code, address, nationality, politically exposed person declaration, front photograph of ID card, reverse photograph of ID card, billing address, delivery address, email address, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our legal basis for this processing is to perform a contract between you and us and/or to take steps at your request to enter into such a contract.

• User data which includes data about how you use our website and any online services, together with any data you post for publication on our website or through other online services. We process this data to operate our website and ensure that relevant content is provided to you, ensure the security of our website, maintain backup copies of our website and/or databases and to enable the publication and administration of our website, other online services and business. Our lawful basis for this processing is our legitimate interests which, in this case, are to enable us to properly administer our website and business.

• IP address, login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our app, time zone settings and other technology on the devices you use to access our website. The source of this data is our analytics tracking system. We process this data to analyze your use of our website and other online services, administer and protect our business and website, deliver relevant content and advertisements on our website, and understand the effectiveness of our advertising. Our legal basis for this processing is our legitimate interests which, in this case, are to enable us to properly administer our app and our business and to develop our marketing strategy.

• Marketing data which includes data about your preferences for receiving marketing from us and our third parties, as well as your communication preferences. We process this data to enable you to participate in our promotions, such as contests, sweepstakes and free gifts, to deliver relevant content and advertisements to you on our website and to measure or understand the effectiveness of this advertising. Our legal basis for this processing is our legitimate interests which, in this case, are to study how customers use our products/services, develop them, grow our business and decide our marketing strategy. We may also use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant content and ads on our website (including Facebook ads or other display ads) and to measure or understand the effectiveness of the advertising we serve to you. Our lawful basis for this processing is legitimate interests in growing our business. We may also use such data to send other marketing communications to you. Our lawful basis for this processing is consent or legitimate interests (i.e. to grow our business).

• Sensitive data: We do not collect sensitive data about you. Sensitive data refers to data that includes details about your race or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, and genetic and biometric data. We do not collect information about criminal convictions and offenses. In the event that we are required to collect personal data by law, or under the contract between you and us, and you do not provide us with such data when requested to do so, we may not be able to perform the contract (e.g., deliver goods or services to you). If you do not provide us with the requested data, we may have to cancel a product or service you have ordered, but if we do so, we will notify you at that time.

  We will only use your personal data for the purpose for which it was collected or for a reasonably compatible purpose if necessary. For more information about this, please email us at [e-mail]. In the event that we need to use your data for a new and independent purpose, we will inform you and explain the legal basis for the processing. We may process your personal data without your knowledge or consent where this is required or permitted by law.

Personal data collection

We may collect data about you when you provide data directly to us (for example, by filling out forms on our website, app or by sending us emails). We may receive data from third parties, such as analytics providers such as Google based outside the European Union (EU), advertising networks such as Facebook based outside the EU, search information providers such as Google based outside the EU and technical, payment and delivery service providers such as data brokers or aggregators.

Marketing Communications

Our legal basis for processing your personal data to send you marketing communications is consent or our legitimate interests (i.e. to grow our business). Under the Privacy and Electronic Communications Regulations, we may send you marketing communications if you (i) made a purchase or requested information about our goods or services, or (ii) agreed to receive marketing communications and, in each case, have not since opted out of receiving such communications. Under these regulations, if you are a limited business, we may send you marketing emails without your consent. However, you may still opt out of receiving marketing emails at any time. Before we share your personal data with any third party for marketing purposes, we will obtain your express consent.

You may ask us to stop sending you marketing messages at any time by emailing us at [e-mail] at any time.

If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations, etc.

Disclosure of personal data

We may need to share your personal data with the parties listed below:

• Service providers providing IT systems management services.

• Professional advisors, including lawyers, bankers, auditors and insurers.

• Governmental agencies that require us to report on processing activities.

We require all third parties to whom we transfer your data to respect the security of your personal data and treat it in accordance with the law.

We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

Internationals Transfers

We share your personal data within our group of companies, which involves transferring your data outside the European Economic Area (EEA).

We are subject to the provisions of the General Data Protection Regulation which protects your personal data. Where we transfer your data to third parties outside the EEA, we will ensure that certain safeguards are implemented to ensure a similar level of security for your personal data. As such: We may transfer your personal data to countries that the European Commission has approved as offering an adequate level of protection for personal data; or When we use certain suppliers established outside the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission that provide the same protection for personal data as in Europe. If none of the above safeguards are available, we may request your explicit consent for the specific transfer. You will have the right to withdraw this consent at any time.

Data security

We have implemented security measures to prevent the loss, use, alteration, disclosure or unauthorized access to your personal data. In addition, we allow access to your personal data only to those employees and business partners who need to know such information for business reasons. They will only process your personal data on our instructions and must keep it confidential.

We have procedures in place to handle any suspected personal data breaches and will notify you and the appropriate regulator if we are legally required to do so.

Data retention

We will only retain your personal data for as long as necessary to fulfill the purposes for which we collect it, including legal, accounting or reporting requirements.

In deciding how long to retain data, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes of processing and whether it can be achieved by other means, and legal requirements.

For tax purposes, we are required by law to retain basic information about our customers (including contact, identity, financial and transaction data) for ten (10) years after they cease to be customers.

In some circumstances, we may anonymize your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Legal Rights

Under data protection laws, you have rights in relation to your personal data, including the right to request access, correction, erasure, restriction, transfer, objection to processing, data portability and, where the lawful basis for processing is consent, the right to withdraw your consent.

More information about these rights can be found at this link.

If you wish to exercise any of the above rights, please send an email to [e-mail]. You can consult the DATA CONTROLLER ACCESS REQUEST FORM here.

You will not have to pay a fee to access your personal data (or to exercise any other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or if we refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and secure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who is not entitled to receive it. We may also contact you to request further information in relation to your request to expedite our response.

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer if your request is particularly complex or if you have made several requests. In that case, we will inform you.

If you are dissatisfied with any aspect of how we collect and use your data, you have the right to lodge a complaint with the supervisory authority. We would appreciate it if you would contact us first if you have a complaint so that we can try to resolve it.

If you are dissatisfied with any aspect of how we collect and use your data, you have the right to lodge a complaint with the data protection authority in the country where you are located. We would be grateful if you could contact us first if you have a complaint so that we can try to resolve it.

Third-party links

This website may include links to third-party websites, plug-ins and applications. By clicking on those links or enabling those connections, the third parties may collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy statement of each website you visit.