Privacy Policy

Date Last Modified: August 29, 2023

This Privacy Policy is an integral part of the Terms and Conditions of Our Website.

We respect your privacy and are committed to protecting Your personal data. This privacypolicy will inform You as to how we process Your personal data when You visit our Website(the “Website”) (regardless of where You visit from) and tell you about Your privacy rightsand how the law protects You.

Any information that is collected about Users of the Website by Marshalls Promo is referred to as “User Information”.

Controller

Win Pro Key LTD. a legal entity incorporated under the laws of the Republic of Cyprus underregistration number ΗΕ 450444 and with registered address at: Voukourestiou, 25, NEPTUNEHOUSE, Floor 1, Flat/Office 11, Zakaki, 3045, Limassol, Cyprus is the Controller and isresponsible for the operation of the Website.

If you have any questions about this Privacy Policy, including any requests to exercise yourlegal rights, please send us a request via email [email protected].

The types of User Information we collect:

We may collect and process categories of data as follows, however, this list is not exclusive:

Personal data:

Personally identifiable information (first and last name, email address, telephone number,date of birth) only if you choose to fill out a “Contact Us” form, found on the Website or emailus directly;

Any other personal data that the User decided to share with Us.

The above-mentioned data is collected on the base of a Users’ consent or other legal basispresented below and in compliance with applicable laws, along with required filings with dataprotection authorities, where required. Users can give consent to the processing of the personalinformation while submitting the form on Our Website or sending the consent via email [email protected].

Non-personal data:

Information on Your visit to the Website, including but not limited to, traffic data, locationdata, IP address, browser type, and version, screen resolution, browser language, time zone,operating system, and type of device;
Demographic information which indicates Your age, gender, and country;
Information from any research or surveys submitted by Website visitors within surveys (on avoluntary basis only) on various topics, including events and experiences, media consumptionpreferences, and how We can improve our Website;
Information from the content of messages you submit through any of the fillable forms on theWebsite;
Information from public postings, which is any information submitted to Us to be displayedon the Website, including any communication/material You provide to be posted or consent tobe posted to a publicly viewable area of the Website, such as a comment or a review. Pleaseacknowledge and understand that You shall have no expectation of privacy or confidentialitywith respect to the content you submit via the Website as a comment or review, whether or notyour submission includes personal information.

Win Pro Key LTD. does not collect and does not process any sensitive personal data (forexample, information related to racial or ethnic origin, political opinions, religion or otherbeliefs, health, biometrics or genetic characteristics, criminal background or trade unionmembership).

User Information may be collected:

When You provide information to Us by filling in form on the Website;
When You complete surveys that We use for research purposes;
When you decide to address us through email.

This Policy only addresses what happens if You visit the Website and this Policy does notapply to information collected by Win Pro Key LTD. offline or through any other means orany third party, including through any application or content that may link to or be accessiblefrom or on the Website.

Purpose of data processing:

We process the User Information for the following purposes:

To respond to Your inquiry/request;
To improve the contents of the Website and its operation;
To analyze information in order to improve the way we run our business and Websiteaccording to User preferences, to provide a better service and User experience;
To comply with regulatory obligations (if any);
To provide You with information in case you have signed up for any newsletter or to askyou/receive feedback;
For other reasons, to the extent permitted by the law.

Change of purpose

We will only use User Information for the purposes for which We collected it unless Wereasonably consider that We need to use it for another reason and that reason is compatiblewith the original purpose. Please note that We may process User Information without yourknowledge or consenting the limited situations only where this is required or permitted by law.

Third-party links

This Website may include links to third-party websites, plugins, and applications. Clicking onthose links or enabling those connections may allow third parties to collect or share UserInformation. We do not control these third-party websites and are not responsible for theirprivacy statements. When you leave our Website, we encourage You to read the privacy policyof every website You visit.

Retention of User Information

User Information will be deleted:

Once it is no longer needed to fulfill the purpose for which it was collected;
Once you request your Personal data to be deleted if Win Pro Key LTD. is not obligatedlegally to keep such data.

Sharing and Disclosing User Information

Win Pro Key LTD. may share your User Information with third parties located within theEuropean Economic Area if:

required by law;
to allow the proper operation of the Website (for the purposes of servicing the Website,including providing customer service and marketing assistance, performing business and salesanalysis, supporting the Website’s functionality, surveys, and other features offered throughthe Website);
in case there is another legitimate interest.

Although unlikely, in certain instances We may be required to provide User Information inresponse to a court order or government investigation. We may disclose certain UserInformation when We believe that such a release is reasonably necessary to enforce or applyour Privacy Policy, to abide by the laws, where applicable, or to protect the interests and/orsafety of Win Pro Key LTD. We may also share User Information in the event of a merger,restructuring, reorganization, dissolution, or other sale or transfer of some or all of Win ProKey’s assets, liquidation, or similar proceeding, where applicable.

The legal basis for this processing is Our legitimate interests, namely the protection andassertion of Our legal rights and proper protection of Our business against risks.

In case Win Pro Key LTD. shares User Information with third parties, such third parties will bebound to use it only for the purposes for which We disclose it to them and in line with theconsent that You have submitted with respect to your User Information and such third partieswill be bound by the obligations related to User Information processing of the same level ofdata protection.

User Information will be shared with those employees, agents, and third-party providers on aneed-to-know only basis and subject to a non-disclosure undertaking.

We reserve the right, and you hereby expressly authorize Us, to share User Information in thecases listed above.

Website Users’ legal rights

Win Pro Key LTD. wants to make sure you are fully aware of all of your data protection rights.Every Website User, consenting to the Terms and Conditions of the Website and this PrivacyPolicy, is entitled to the following:

The right to access;
The right to rectification;
The right to erasure;
The right to restrict processing;
The right to object to processing;
The right to data portability.

Cookies Notice

Win Pro Key LTD. uses a Web analytics service to analyze and monitor activity on theWebsite. Web analytics utilize cookies, which are files placed on the hard drive of Yourcomputer, tracking the way visitors use the Website.

We set the first-party cookies, which collect information like your language preference andlogin information, and third-party cookies, which are set by Web analytics and exist formarketing and advertising purposes.

Certain User Information is collected through enabling cookies, i.e. browser type, operatingsystem type, network location (domain), IP (Internet Protocol) address, and other similarinformation, as well as referrer data identifying the web pages You visited before and aftervisiting the Website and Your movement and activity within the Website, however, nopersonally identifiable information.

Win Pro Key LTD. uses aggregated User Information to analyze and improve the design, use,and content of the Website.

Win Pro Key LTD. may use other technologies such as Web beacons and flash cookies to trackthe efficiency and effectiveness of our communications and how the Website is used.

The Website incorporates security to allow You to disable/enable cookies. You can accept ordecline cookies by modifying the settings in Your browser. However, You may not be able touse all the interactive features of the Website if cookies are disabled.

Unless You have adjusted Your browser setting so that it will refuse cookies, Our system willissue cookies when you direct Your browser to the Website.

Modifications of Privacy Policy

To improve the services We can offer You, Win Pro Key LTD. may choose to expand itscapabilities for obtaining information about users in the future. If we modify this PrivacyPolicy, We will update the “Date Last Modified” and such changes will be effective uponposting.

Future Formation