Privacy and personal data protection policy
A. Collection and Use of Gathered Information
A.1. Personal Data
We will collect personally identifiable information (hereinafter “personal data”) about any user who signs up for a user account with WinnersFund (hereinafter “you” or “registered user” or “member”), including but not limited to your name, postal address, telephone number(s), e-mail address(es) etc, whether you provide such data to us when signing up for a user account, signing up for newsletters, participating in a survey, contacting our customer relations office or otherwise interacting with this website. Your personal data may be used for all legal purposes, which may include, but are not limited to, responding to your requests, processing your transactions, administrative purposes such as conducting contests, tracking which parts of the website are of interest to you, processing prizes, training of our customer relations department personnel, etc.
All information we collect is made clear to you if and when you fill-in data forms. Such information is not shared, unless you specifically choose to share all or part of it (e.g. sharing your Curriculum Vitae with your prospective funders).
If you are representing a business entity, we may also ask for extensive information about your business. Especially when raising money or investing money, we are obliged or may prefer to ask for documentation proving your address, identity and age (the so called “Know Your Customer” or “KYC” information).
A.2 Demographic Information
We may at any time collect and process demographic data, such as your date of birth, gender and postcode. Demographic data may be used to tailor your user experience, such as showing you content, including special events and campaign promotions, that you might be interested in, and displaying such content according to your postcode. On occasion, aggregate information that does not identify any particular user may be compiled and shared with our subsidiaries, affiliates, strategic partners, merchants and advertisers.
A.3 Passive Collection of non-Personal Information – Cookies
The website may use so-called "pixel tags", "web beacons", "clear GIFs" or similar means (collectively, "Pixel Tags") to compile aggregate statistics about website usage and response rates. Pixel Tags allow us to count users who have visited certain pages of the website, to deliver branded services and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can tell the sender whether and when the email has been opened.
WinnersFund may also collect "referrers" information, IP addresses and various environmental variables:
A "referrer" is information the web browser passes along to our web servers that references the URL from which you were directed to our website.
The "IP address" is a number used by computers on the network to identify your computer so that data can be transmitted to you.
"Environmental variables" include, among other things, the domain from which you access the Internet, the time you accessed this website, type of web browsers and operating system or platform being used in your computer, the internet address of the website you left to visit this website, the names of the pages you visit while at this website and the internet address of the website you then visit.
This information, when collected, is only used for WinnersFund’s internal operational and technical optimisations, such as to enhance website security, to detect broad demographic trends, to assist WinnersFund in providing content tailored to the users’ interests and to otherwise enhance their website experience. This information may also be shared with third parties on an aggregate and non-personally identifiable basis.
Also, this website often requires the use of encrypted or non-encrypted cookies. Cookies are data that a web server transfers to an individual's computer for recordkeeping purposes. Cookies are an industry standard used by most websites and help facilitate users' ongoing access to and use of a particular website, for example by providing information used to deliver content specific to the user’s interests and for other purposes, such as security and other account administrative functions, and which may track personal identifying information.
You should note, however, that declining cookies may make it difficult or impossible for you to use parts of our website.
B. Disclosure of Information to Private Third Parties
By default, we do not provide, share or otherwise transmit personal data to any private third party (meaning third-party businesses or other private entities or persons, not including our own personnel and our subsidiaries that provide us with back office and customer relations services as explained below), unless you are requested and you specifically agree to opt-in to a user experience programme that requires the use and transmission of your personal data to third parties.
When authorised by the user, WinnersFund may share personally identifiable information, including information that you provide on the website with third parties as described below. In such an occasion, we may transfer information to any country in the world, including the USA and other countries that do not offer the same level of data protection as the country where you reside, and that all data may be physically stored in several web and file servers around the world, since the website has been developed using cloud computing.
B.1. Affiliated Entities
We may share any information, including personally identifiable information that you provide on the website, with our subsidiaries and affiliates worldwide, only for the purposes described in Section I(A).
B.2. Strategic Partners
From time to time we may enter into special relationships with other business entities that are not owned by or affiliated with our Company to provide additional features on this website. These special relationships may include business partners, sponsors and co-branded or privately-branded websites (referred to here as "co-branded pages"). Any information, including personal data that you provide on one of these co-branded pages, will be shared with these third party partners. By participating in activities or providing your information on these co-branded pages, you also consent to our transmission of your personal data to those third parties. Since such third parties will use your information in accordance with their own privacy practices, you should check their website(s) for information regarding their privacy policies.
B.3. Service Providers
We may use third party service providers to help us operate our business and this website or administer activities on our behalf, such as sending emails, order fulfilment, back office operations and contest administration. We may share your information with these third parties for those limited purposes. For instance, if you participate in a contest, game or loyalty programme resulting in a prize or award, we will share your personal data with our games and merchandise fulfilment and advertising agencies.
B.4. Other Disclosures
Personal data of any individual user may be shared with other business entities outside our Company without the specific consent of the user: (i) as required or permitted by law, (ii) in the event of a transfer of ownership, assets or bankruptcy, (iii) where we determine that disclosure of specific information is necessary to comply with the request of a law enforcement or regulatory agency or other legal process, or (iv) to protect the interests or safety of WinnersFund or other visitors to this website.
B.5. User Generated Content
C. Links and Third-Party Privacy Practices
WinnersFund has security measures in place to help protect against the loss, misuse and alteration of all personal data under its control. WinnersFund employs security measures consistent with standard industry practices to help protect against public access to any personal data and account activity information collected on and used by WinnersFund. For instance, access to our databases containing personal data is logged for security purposes and access is limited to key personnel. Certain specific activities are protected using a secure communications encryption technology called SSL. SSL (standing for Secure Sockets Layer) is a method for hiding information to prevent others from intercepting and reading the data sent between the client (your computer) and the server (our website). Personal data and account activity are also protected through the use of user names and passwords. In order to help maintain the security of your information, you should protect the confidentiality of your user name, password and email address you use to access WinnersFund restricted sections.
E. Opt-in Choice
WinnersFund may provide you with the opportunity to opt-in to receive marketing communications from WinnersFund or our business partners. If you do not opt-in WinnersFund will not send you such promotional offers and will not transmit your personal data to any third parties. However, regardless of your opt-in preferences, WinnersFund may still at times need to send e-mails for administrative reasons. If you opt-in in order to receive communications and then change your election, your opt-out preference may not be effective in certain instances where you agreed to receive brand-specific communications.
WinnersFund gives you several options for reviewing, correcting, updating or otherwise modifying personal data you have previously provided, such as making changes and updates on the account profile page, or contacting WinnersFund Customer Service and requesting such changes and updates.
Please note that changes may not be effective immediately. In each event, you must clearly indicate the information that you wish to have changed or clearly indicate that you wish to have your personal data removed from our database. We will endeavour to comply with your request as soon as reasonably possible. Note that, despite any request for removal of or change to personally identifiable information, we may need to retain certain information for recordkeeping and regulatory purposes and there may also be residual information that will remain within our databases and other records, which will not be removed or changed. We also reserve the right, from time to time, to re-contact former users of the website for important administrative purposes. Finally, we are not responsible for informing third parties (including without limitation our third party service providers or strategic partners) with whom we have already shared your personally identifiable information of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such entities.
F. Disclosure of Information to the Authorities
By using WinnersFund you specifically and unconditionally agree your personal data to be announced, without a notice or your consent, to any state authorities, judicial courts, hearing committees, the Police or any public administration bodies whatsoever, of any European Economic Area country or the country of your residence, that may require the disclosure of your personal data for the protection of Intellectual Property, dispute resolution and the suppression or prevention of criminal activities, especially in the fields of patent breach, intellectual property misuse / unauthorised use, fraud prevention, tax evasion and money laundering / terrorist financing activities.
G. Use of the Website by Younger Persons
This website is not directed at people with age of less than 18 years old and we request parents to ensure that children do not provide any personal data through the website, otherwise they may be held accountable for any such activity of their children.
I. Special conditions for Project Owners
For transparency reasons and protection of the general public, following the release of funds, all Funders of successful Campaigns are requested by WinnersFund to verify that the funds receivers ("successful Project Owners") have fulfilled their promises. A publicly available "Project Owner profile" is created for each one, based on all such Funder feedback, listing all Funders' evaluation together with each Project Owner's replies. WinnersFund Clients (Project Owners), as specified in our Terms of Service, expressly agree and irrevocably and unconditionally accept that all relevant information is openly available to the public, with or without restricted access, as WinnersFund will freely decide under its unquestionable discretion, and they irrevocably waive any rights against the Company owning WinnersFund for rectification in general of any damage, moral, material or otherwise, due to the publication of these data, as well as any right to ban, whether by judicial or extrajudicial means, the public disclosure of such information.
J. Governing Law – Jurisdiction
This agreement and all other agreements are governed by the exclusive jurisdiction of the courts of London, United Kingdom.
K. Contact WinnersFund
You can see some of the Personal Data we hold about you in the "Profile" section of your WinnersFund account (if you are a registered user of WinnersFund). In the event that you wish to receive a copy of all of your Personal Data held by us, please write to:
Anametron UK Ltd
24 Holborn Viaduct
City of London
London EC1A 2BN
PRIVACY Version 1.1 EN, May 15-05-2015, 06:00' UTC