Privacybeleid
We (also referred to as "We," "Us," or "Our") are committed to protecting your Personal Data and your privacy.
This Privacy Policy explains how we collect and store the information you provide through the website https://steenwinsthof.com (the Steen Winsthof).
The following principles apply:
We want you to make informed decisions about how your personal data is used and processed. To support this, we apply a range of methods and procedures to provide you with relevant information. Where we believe you need specific details, we deliver that information at the appropriate time. We are happy to answer any questions you may have about restrictions imposed by law.
1. De omvang?
This policy describes the types of Personal Data that Steen Winsthof collects about natural persons and how it processes, shares with third parties, secures, and otherwise handles such data.
This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be identified directly or through a combination of additional information we hold or have access to.
Under this Policy, "processing" means any operation that involves the use or collection of Personal Data. This includes managing, structuring, and storing Personal Data.
Our services are intended for use by a general audience and are not designed for persons under 18 years of age. We do not knowingly collect or request information from persons under 18. We do not knowingly permit such persons to use our services. We will delete any information we discover about children as soon as we become aware of it.
2. What personal data do we hold about you?
We collect Personal Data when you access the service and channels or visit our website. In some cases, we may ask you to provide your Personal Data directly. In others, we collect it by analyzing how you use our Services or service channels, or by receiving your data from our external partners.
3. Providing personal data to the company is not mandatory, along with the resulting consequences.
However, you are not required to provide Us with personal data. In certain circumstances, you may choose not to provide Us with Personal Data. This may prevent Us from delivering the Services or prevent users from accessing the website.
4. Welke soorten persoonsgegevens kunnen Wij verzamelen? Wanneer u onze website bezoekt, verzamelen wij de volgende persoonsgegevens van u:
This includes information about your online activity log, traffic data (including IP address, access date, access time, and access date), the language you used, software crash logs, the type of browser used, and information about the device you used. The information collected is not private data and cannot be used to identify you.
Personal data We receive from you: any personal data you choose to provide to Us when you connect to a third-party online trading platform through Us.
Personal information you provide specifically to third-party platforms to enable trading: this includes your full name, address, telephone number, and email address.
5. The legal basis and reasons for processing personal data
The company processes your personal data for the purposes described in this section and on the applicable legal basis.
Without a legal basis, the company cannot use any personal data about you. The legal grounds on which the company may process your personal data are:
- You have consented to the processing of your personal data for one or more purposes. This applies when you provide personal data through the Website so that we can transmit it to a third-party trading platform.
- The Company or a third party may need to process data to serve their legitimate interests. This applies, for example, when improving Our Services or defending against legal claims.
- De verwerking is noodzakelijk om te voldoen aan een wettelijke verplichting.
Contact us by email for more information about the processing required to protect legitimate interests.
Below is an overview of the reasons and legal grounds on which we may use the information you provide. Personal data.
Bereik, Rechtsgrondslag
1. To share your personal data with third parties at your request, giving you access to digital trading. At your request, we may collect personal data from you to forward to external companies.
You have given consent to the processing of your personal data for one or more specific purposes.
2. To respond to your requests, questions, or concerns. Personal data is necessary to help us address any questions you may have about the Services.
The legitimate interests of the Company or those of a third party must be processed.
3. Personal data is processed to meet applicable legal, administrative, judicial, or regulatory requirements.
Processing is required to ensure compliance with legal obligations.
4. To improve our services. We may use personal data to improve our services, including any crash or error reports we collect relating to the Services.
The legitimate interests of the Company or those of a third party must be processed.
5. To prevent fraud and misuse of Our Services
The legitimate interests of the Company or those of a third party must be processed.
6. Performing and managing operations that comply with the requirements of Our Services. Such activities include back-office functions, business development, strategic decision-making, oversight mechanisms, and similar processes.
The legitimate interests of the Company or those of a third party must be processed.
7. We use various analytical techniques, including statistical analysis, to inform decisions across a wide range of matters.
The legitimate interests of the Company or a third party must be processed.
8.
To protect our assets, rights, and interests, as well as those of third parties, and to establish and defend legal claims
We may process personal data to protect our rights, interests, and assets, or those of third parties, in accordance with all applicable laws, regulations, or agreements and any terms, conditions, or policies.
The legitimate interests of the Company or those of a third party must be processed.
6. Doorgifte van persoonsgegevens aan derden
The Company may share Personal Data with external companies that provide services to us, such as hosting and storage providers, IP address data, and user experience analytics.
You may also request that we provide specific Personal Data about you to external trading platforms. In that case, we will provide the Personal Data you supply to Us to third-party trading platforms. Their use of your Personal Data is governed by their own privacy policies. Your Personal Data may be shared with multiple trading platforms.
The Company may share Personal Data with affiliated entities or business partners. This can give the Company the resources needed to improve and optimize the products and services it offers its customers.
Where necessary to protect the rights or assets of third parties, the Company may disclose Personal Data to regulatory, local, or other official authorities.
We may also share Personal Data about you with potential investors or buyers, or with lenders to the Company or another company within the group, should such a transaction take place (including the transfer or sale of assets belonging to the Company or another company within the group) or as part of a merger, restructuring, consolidation, or bankruptcy of the Company or another company within the group.
7. Cookies and third-party services
Third-party services, such as those that display advertisements on our website or analytics providers, may be used. These companies may also use cookies or other technologies.
Cookies are small text files placed on your device each time you visit or open the website. They collect information about your preferences and browsing behaviour to improve your experience, remember your settings, and tailor the products and services you may value. Cookies are also used for statistics and analytics.
Some cookies we use are session cookies. These are temporarily downloaded to your device and remain active only for a short time, until you close your browser. Others are persistent cookies. Persistent cookies stay on your device for a set period after you close your browser. They help the website recognise you as a returning user and allow users to return to the website.
Soorten cookies:
We may use them depending on their purpose:
1. Cookies that are strictly necessary
These cookies are necessary to access the features you request and to navigate our website. They are used to deliver the information, products, and services you have asked us to provide.
They are required to download and stream data to your device, allowing you to move through the website, use its features, and return to pages you have previously visited.
Cookies collect personal data, such as your username and the date of your last login, to confirm that you are logged in to the site. They are deleted as soon as you close your web browser (session cookies).
2. Functionaliteitscookies
Cookies allow us to recognise you each time you visit our site and to store your preferences.
Cookies collect personal data, such as your username and the date of your last login, to confirm that you are signed in to the site. They are deleted as soon as you close your web browser (session cookies).
3. Cookies voor prestaties
Cookies collect statistical data on site performance to help us improve it. They also enable us to carry out analytics on our website.
Cookies store anonymous data that is not linked to an identified or identifiable natural person. Some cookies are deleted when you close your browser, while others remain valid indefinitely.
Cookies have been blocked or deleted
To block or delete cookies, you will need to adjust your browser settings. Below are links to help you do this in some of the most popular browsers.
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
However, please note that if this happens, some or all of the website's functions and features may not work as expected.
ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retaining personal data about you
The Company retains your Personal Data for as long as necessary to fulfil the purpose of processing described in this Policy, or for longer periods where permitted by laws, regulations, policy rules, and applicable decisions.
We share your data with third-party trading platforms for a period of 12 months. With your consent, we continue sharing your data for a further 12 months.
We regularly review the Personal Data we hold to confirm whether it is still required.
9. Transfer of personal data to a third country or to an international organisation
Your personal data may be transferred to another country (that is, to a third country — a country other than the one in which you reside) or to international organisations or jurisdictions. The Company takes all necessary measures to protect the personal data you provide and to ensure that users can exercise their rights and access effective legal remedies.
These protections and safeguards are available to anyone residing in the EEA (European Economic Area).
- Transfer to a third country or international organisation that the European Commission has determined provides an adequate level of protection for the personal data transferred there, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR").
- The transfer is made under a legally binding and enforceable agreement between public bodies or authorities within the meaning of Article 46(2)(a).
- The transfer was carried out in accordance with the Standard Contractual Clauses adopted by the European Commission under Article 46(2)(c) of the GDPR. The clauses adopted by the European Commission are available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
Upon request, the Company can provide details of the safeguards it applies to protect your Personal Data transferred to third countries or international organisations. Send an email to the following address: info@steenwinsthof.com
10. Beveiliging van persoonsgegevens
We have implemented appropriate organizational and technical measures to protect Personal Data. This includes safeguards against the accidental or unlawful destruction, loss, or alteration of Personal Data.
We cannot guarantee or warrant that the security of your Personal Data will be maintained without error. Nor can we be held liable for any non-material, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, the disclosure of Personal Data resulting from transmission errors, unauthorized access by a third party, or any other cause beyond our control.
Where required by law or by other obligations beyond our control, we may be compelled to disclose Personal Data about you to third parties, such as government authorities. We cannot control the security applied to your Personal Data by third parties in such situations.
Personal Data cannot be transmitted over the web in a fully secure manner. The Company cannot guarantee the security of Personal Data you transmit to Us via the internet.
11. Hyperlinks to third-party websites
This website contains links to third-party websites and applications. These applications and websites are not controlled by the Company. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to actions carried out through such sites or apps.
Before opening or using any of these third-party websites or apps, we recommend that you read their privacy policy. We also advise caution before providing any Personal Data to them.
12. Changes to this policy
When visiting any third-party website or app, we recommend reviewing their privacy policy before deciding to open or use it. We also advise caution before providing them with any Personal Data.
13. Your rights regarding your personal data
You have the right to ask us to verify the accuracy of the Personal Data collected about you, to correct any errors, and to delete any Personal Data we do not need. You may also restrict the scope of how your personal information is processed.
If you are a resident of the EEA, please consult this page:
These rights apply to the information you provide in connection with your Personal Data. To exercise the rights available to you, send an email to the address below.
Right of access
The Company can verify whether the Personal Data processed about you is accurate. Where this is the case, you may access your Personal Data.
The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be made available electronically if you request it.
The right to access Personal Data must not conflict with the rights and freedoms of others. If the request harms the rights and freedoms of another person, the Company may refuse to comply with it or limit its ability to do so.
Right to rectification
The Company has the right to correct inaccurate Personal Data. You have the right to require that incomplete Personal Data about you be corrected, taking into account the purpose of the processing.
Right to erasure
The following reasons apply: (a) the Personal Data is no longer needed for the purpose for which it was collected or processed; (b) you withdraw your consent and there is no legal basis for processing; (c) you object at any time, on grounds specific to your situation, to the processing of Personal Data about you that is based on legitimate interests pursued by Us or by a third party; (e) the Personal Data is processed unlawfully; or (f) the Personal Data must be deleted to comply with the Company's legal obligation.