1. Introduction
Wenwin ("we", "us" or "our") is committed to protecting and respecting your Personal Information (as defined in paragraph 2 below). In addition, we recognise that persons who use wenwin.com and any accompanying documentation (collectively the “Website”) value their privacy. This Privacy Policy, together with our Disclaimer, governs our collection, processing, and use of your Personal Information. By accessing the Website, you are consenting to the information collection, use, hold, and disclosure practices as described in this Privacy Policy.
Should we ask you to provide certain information by which you can be identified when using this website, then it will only be used in accordance with this Privacy Policy. This Privacy Policy applies to the operations of the Website in the European Economic Area (EEA). It gives you rights by operation of the EU GDPR. If you live outside the EEA, we will undertake best efforts to give you a similar degree of control over your privacy.
If you wish to know more about this policy, please contact us via email at contact@wenwin.com. By visiting the Website, using our services or otherwise providing us with your Personal Information (or authorising it to be provided to us by someone else), you agree to your Personal Information being handled by us as set out in this Privacy Policy.
2. Personal Information
Personal Information is information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not, and whether the information is recorded in a material form or not. The information includes but is not limited to:
  • Full legal name, address for service, e-mail address, phone number, date of birth, photographic identification, government-issued identification and other contact details.
  • We require the highest level of browser permissions that could potentially lead to procurement of more Personal Information than enclosed in the definition of Personal Information.
  • World Wide Web-related information, including but not limited to IP Addresses, operating system, the website you came from and browser type may be received by us as a result of your interactions with the Website.
  • Polygon blockchain and other public blockchains provide transparency into transactions and we are not responsible for preventing or managing information broadcasted on a blockchain.
  • We may use Google Analytics for purposes of monitoring web traffic. Any identifying information collected via Google Analytics is controlled by Google.
3. Purpose of Personal Information collection
Personal Information is collected in order to:
  • Provide our services efficiently and effectively;
  • Inform you about the Website’s features;
  • Develop, enhance, market, and deliver products and services to you;
  • Understand your needs and your eligibility for products and services;
  • Provide information to you about developments and new products, including changes and enhancements to the Website;
  • Conduct surveys and get feedback from you;
  • Establish and maintain a responsible commercial relationship with you;
  • Provide you with news and other matters of general interest to you as a user; and
  • Meet our legal and regulatory requirements (e.g. information required to verify your identity).
4. Security, Protection and Use of Personal Information
We are committed to protecting your privacy. Internally, only a specified number of team members have access to your Personal Information.
These team members have duties that reasonably require access to your Personal Information. We take the security of Personal Information very seriously and we take appropriate measures to ensure that Personal Information is not accessed or disclosed by anyone outside the terms of this Privacy Policy. We will also take appropriate measures to prevent unauthorised access or alteration of your Personal Information. These measures include internal reviews, storage and processing practices and security measures as well as physical measures to prevent unauthorised access to systems where we store Personal Information.
We reserve the right to retain and share certain Personal Information in order to meet our regulatory and statutory requirements. In addition, we reserve the right to retain and share certain Personal Information with our corporate partners, and third parties acting on behalf of us.
Personal Information and other related data may be exported outside of the jurisdiction in which you reside. Your Personal Information may be processed and stored in a foreign country or countries. Under those circumstances, the governments, courts, law enforcement or regulatory agencies of that country or those countries may be able to obtain access to your Personal Information through foreign laws. You need to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which you reside. You should note that you are not obliged to give your Personal Information to us, but if you choose not to do so, we may not be able to provide our services, or your access to our services may be limited.
5. Direct Marketing
From time to time, if you are a user or a potential user, we may contact you about our products as part of one of our campaigns, or to gain feedback on our services or marketing strategies. We may contact you via email. By signing up to our website you are consenting to this Privacy Policy and the receipt of our direct marketing messages. If you wish to no longer receive our direct marketing as outlined in this Privacy Policy, please unsubscribe from the emails via the link in their footer or send an email entitled “Unsubscribe” to the email address contact@wenwin.com.
6. Consent
Consent is required for the collection of Personal Information and the subsequent use or disclosure of Personal Information. The form of consent may vary depending upon the circumstances and the type of Personal information obtained. You consent to the collection and use of Personal Information as described in this Privacy Policy. We reserve the right to use and disclose Personal Information without your knowledge or consent as permitted by applicable law.
7. Disclosure of Personal Information
We use the Personal Information for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy and/or as otherwise permitted by law. We may make available the Personal Information that you provide to us to our affiliates, agents, representatives, service providers and contractors for these purposes. We also reserve the right to disclose Personal information that we believe, in good faith, is appropriate or necessary to enforce the terms in our Disclaimer, take precautions against liability or harm, to investigate and respond to third-party claims or allegations, to respond to a court order or official requests, to protect our security, integrity, rights, property or safety, and our uses or others.
We may share users' Personal Information with any financial dispute resolution scheme to which we subscribe, and other law enforcement bodies, regulatory agencies, courts, arbitration bodies and dispute resolution schemes, as may be required by law.
If you request in writing, we may share your Personal Information with your nominated advisers. Except where disclosure of your Personal Information is required by law or requested by you, we will generally require any third party which receives or has access to Personal Information to protect such Personal Information and to use it only to carry out the services they are performing for you or for us unless otherwise required or permitted by law. We will ensure that any such third party is aware of our obligations under this Privacy Policy and we will take reasonable steps to ensure that contracts we enter with such third parties bind them to terms no less protective of any Personal Information disclosed to them than the obligations we undertake to you under this Privacy Policy or which are imposed on us under applicable data protection laws.
In the event that we are involved in a merger, acquisition, sale, bankruptcy, insolvency, reorganisation, receivership, assignment or the application of laws or change of control, there may be a disclosure of your information to another entity related to such an event.
8. Access and Changing of Personal Information
We take all reasonable steps to ensure your Personal Information is accurate and up to date. If we believe that it is not accurate, we may contact you to update your Personal Information. If you believe the Personal Information that we have stored about you is inaccurate you may contact us via contact@wenwin.com to change the Personal Information we have stored. Where we do receive unsolicited Personal Information, we will determine whether or not it would have been permissible to collect that Personal Information if it had been solicited. If we determine that it would not have been permissible by law to collect the Personal Information, we will destroy or de-identify that Personal Information as soon as practicable. You may also ask us to send you the Personal Information we have about you. If you would like to access this Personal Information, please contact us via contact@wenwin.com. You may also request the deletion or destruction of your Personal Information by sending an email to us. We will act on your request only when it is not inconsistent with our legal and regulatory obligations and compliance procedures. Upon your written request, we will inform you of the use and general disclosure of your Personal Information. Depending on the nature of your request, there may be a minimal charge for accessing your Personal Information.
9. Overseas Disclosure
Some of our providers may be located, or have some of their business functions located in countries outside of the EU. As part of our business, we will be required to disclose your Personal Information to these companies. We will take such steps as are reasonable in the circumstances to ensure that these companies do not breach EU privacy legislation in relation to your Personal Information. Please contact us if you have any questions regarding our Privacy Policy or would like us to send you a copy of this policy. Our Privacy Policy may be amended from time to time. The current version will be posted on our website.
10. Retention of Personal Information
We will hold your Personal Information only for as long as it is necessary for us to do so, having regard to the purposes described in this Privacy Policy and our own legal and regulatory requirements.
11. Users Under Age of 13
We do not knowingly collect or store any Personal Information about children under 13 without verifiable prior parental consent. If you believe such information has been inadvertently collected, we will take the necessary steps in order to remove such information from our database. Users under 13 must seek and obtain parental consent to use the Website.
12. Links
There may be links to other sites and resources provided by third parties. This Privacy Policy applies only to the Website. Accessing those third-party sites or sources requires you to leave our Website. We do not control those third-party sites or any of the content contained therein and you agree that we are in no way responsible or liable for any of those third-party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those sites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each site that you visit.
13. Changes
Our policies, content, information, promotions, disclosures, disclaimers and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at our sole and absolute discretion. Users will be able to check the last date when the Privacy Policy is updated.
14. Contact Us
If you have any questions, comments, or concerns regarding our Privacy Policy and/or practices, please contact us at contact@wenwin.com. We will get back to you if required as soon as possible and within 14 days.