WIN BROKERS S.R.L. (hereinafter referred to as “WIN BROKERS”), with registered office in Bucharest, Sector 1, Strada Barajul Argeș no. 8A, Win Herăstrău, Office 1, registered with the Trade Register under no. J40/25245/2022, EUID ROONRC J40/25245/2022, having the Unique Registration Code 47385809, legally represented by administrator Mr. Pascu Cristian-Emil, as author, owner, user and administrator of the website www.win-brokers.ro, respects the confidentiality and security of personal data processing and places, uses and manages “cookies” in the context of users browsing this website.

I. PRIVACY POLICY

CONTACT DETAILS OF THE DATA PROTECTION OFFICER

WIN BROKERS S.R.L. has appointed a Data Protection Officer.
The Data Protection Officer may be contacted at the following email address: contact@win-brokers.ro.

DEFINITIONS

• “ANSPDCP” – the National Supervisory Authority for Personal Data Processing.

• “personal data” – any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or one or more specific elements of physical, physiological, genetic, mental, economic, cultural or social identity.
• “processing” – any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• “restriction of processing” – marking stored personal data with the aim of limiting their future processing.
• “controller” – the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of processing personal data.
• “processor” – a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
• “recipient” – a natural or legal person, public authority, agency or other body to whom personal data are disclosed, whether or not a third party. Public authorities receiving data in the context of a particular inquiry are not considered recipients.
• “consent” – any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which they signify agreement to the processing of personal data relating to them.

RIGHTS OF THE DATA SUBJECT

• Right of access – the right to obtain confirmation as to whether personal data are being processed and access to such data.
• Right to data portability – the right to receive personal data in a structured, commonly used and machine-readable format and to transmit them to another controller.
• Right to object – the right to object to processing based on public interest, legitimate interest, or direct marketing.
• Right to rectification – the right to obtain correction of inaccurate personal data without undue delay.
• Right to erasure (“right to be forgotten”) – the right to request deletion of personal data under certain conditions (no longer necessary, withdrawal of consent, unlawful processing, etc.).
• Right to restriction of processing – applicable in certain cases such as contesting accuracy, unlawful processing, or legal claims.

TYPES OF PERSONAL DATA COLLECTED

We generally collect personal data directly from you, giving you control over the information provided. For clarity, data may also be processed by companies within the group, including: PSC CONTRACTOR & DEVELOPER S.R.L., WIN ART GALLERY S.R.L., WIN TUREANU MOTORSPORT S.R.L.

For example, we receive:

When creating an account on WIN BROKERS:

• Email address
• First and last name
• Mobile phone number
• Age
• Position held
• Employer

We may also collect behavioural data during website usage in order to personalise the online experience, provide tailored offers, or inform you about our events.

Automatically collected information:

• Browser information
• Operating system
• Device information
• IP address
• Internet Service Provider
• Viewed content
• Geographic location
• Visit date and duration
• Traffic source

We do not collect or process data of minors under 16 years old.

PURPOSE AND LEGAL BASIS OF DATA COLLECTION

We process your personal data to comply with legal obligations and based on GDPR legal grounds.

1. To provide offers and information

• Account creation and administration
• Sending offers and updates about services and events

2. Marketing purposes

We may send emails about products, services, campaigns or events. Marketing is based on your prior consent, which can be withdrawn at any time.

3. Legitimate interests

We process data to protect our business, including cybersecurity and risk management.

RETENTION PERIOD

Personal data is stored for as long as the user account remains active. After account deletion, data may still be retained where required by law or legitimate interests (e.g., legal defence).

DISCLOSURE OF PERSONAL DATA

We may share personal data with:

• Courier service providers
• Payment/banking providers
• IT service providers
• Marketing service providers
• Companies within WIN ALLIANCE group

We do not sell personal data and ensure confidentiality and legal compliance.

DATA SECURITY

We implement technical and organisational measures to protect personal data against unauthorized access, alteration or destruction.

Employees and partners sign confidentiality agreements. Systems are protected by antivirus, anti-spam and firewall solutions.

CONTACT FOR DATA PROTECTION

Requests related to data protection will be answered within 30 days.

CONTACT DETAILS OF THE NATIONAL SUPERVISORY AUTHORITY (ANSPDCP)

Address: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, Bucharest, Romania
Email: anspdcp@dataprotection.ro
Phone: +0318.059.211 / +0318.059.212

II. COOKIE USAGE POLICY

This section explains how cookies are used on www.win-brokers.ro.

WHAT ARE COOKIES?

Cookies are small text files stored on your device when you visit a website. They do not contain software, viruses or spyware.

Cookies are used to:

• Provide a better browsing experience
• Analyse website traffic
• Improve website performance
• Remember user preferences

TYPES OF COOKIES USED

• Necessary cookies – essential for website functionality
• Analytical cookies – help analyse user behaviour
• Advertising cookies – used for personalised ads
• Geotargeting cookies – identify user location

COOKIE LIFETIME

• Session cookies – deleted when browser is closed
• Persistent cookies – stored until expiry or manual deletion

THIRD-PARTY COOKIES

Third-party cookies may be used by services such as Google Analytics, LinkedIn, Instagram, etc., and must comply with data protection regulations.

COOKIE MANAGEMENT

Users can disable cookies via browser settings, but this may affect website functionality.

POLICY UPDATES

This policy may be updated at any time. Changes will be indicated by updating the “Last updated” date.

Accessing the website after updates means acceptance of the revised policy.