Privacy policy

WinningSpades Privacy and Cookies Policy

At Winning Spades (“Winning Spades “, “we”, “us”), we process personal data about our customers and visitors on our websites (“you”). We make efforts to handle your personal data with care, keep it secure and comply with data protection laws.

Winning Spades is engaged in performance marketing and lead generation online, with headquarters in Malta and subsidiaries in a number of other countries.

How this Policy Works

The purpose of this Policy is to explain when, why and how we process information which may relate to you (“personal data”). It also provides important information on your statutory rights. This Policy is not intended to override the terms of any contract you have with us, nor rights you might have under data protection laws.

Click on a topic in the list below to find out more on individual topics in more detail by following the various links. We have labelled sections of the Policy to make it easy for you to navigate to the information most relevant to you.

Content

3.         What do we use your personal data for and when do we process your personal data? 

4.         Who do we share your personal data with?

5.         International Transfers

6.         Direct Marketing

7.         How long do we keep your personal data?

8.         What are your rights?

9.         Cookie Policy

3.What do we use your personal data for and when do we process your personal data?

Winning Spades will collect information directly from you when you use our services or visit our websites.

We use your personal data to:

  • analyze information in our systems and databases to improve the way we run our business and websites according to user preferences, to provide a better service and user experience.
  • Improve and target advertisements that you receive from us.
  • meet or exercise any of our legal obligations or rights

We will only process your personal data for the purposes set out in this Section 3 and where we are satisfied that:

you have provided your consent to us using the data in that way, or
our use of your personal data is necessary to support ‘legitimate interests’ that we have as a business (for example, to improve our products, or to carry out analytics across our datasets), in a way that is proportionate and respects your privacy.

4.Who do we share your personal data with?

We work with many third parties, to help manage our business and deliver services. These third parties may from time to time need to have access to your personal data:

  • Our analytics service providers (such as Google, Hotjar and VWO), who process personal data for their own purposes as Data Controllers. Please refer to our Cookie Policy in the Appendix below in order to identify how you may prevent access to your personal data by analytics providers.
  • Service providers or data processors that handle your personal data on our instructions, for example cloud services.
  • If we are under a duty to disclose to comply with a legal obligation or protect our interests or security.

7.How long do we keep your personal data?

  • We will retain your personal data for as long as reasonably necessary.
  • In some circumstances we keep your personal data during a certain period to meet for example legal, tax or accounting requirements.
  • We maintain a data retention policy for personal data in our care. Where your personal data is no longer required we will ensure it is either securely deleted or made anonymous.

8.What are your rights?

You have a number of rights in relation to your personal data. More information about each of these rights can be found by referring to the table set out further below. To exercise your rights you may contact us as by sending an email.

You can ask us to:

  • confirm whether we are processing your personal data;
  • give you a copy of that data;
  • provide you with other information about your personal data, for example what data we have, what we use it for, who we disclose it to, whether we transfer it outside the EU and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any Automated Decision Making or Profiling, to the extent that information has not already been provided to you in this Policy.

9.Cookie Policy

We use Cookies

  • To offer you a full range of functions when you visit our website, recognize your preferences, and make the use of our website more comfortable and convenient, we use “cookies.”

What are Cookies?

  • A cookie, pixel or similar technology is a small file or information saved on your computer or device when you visit the website. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

Categories of cookies

We use cookies for different purposes and with different functions.

Some cookies are:

  • necessary in technical terms (technical necessity)
  • stored and used for a certain time period (storage duration)
  • placed and stored by us or a third party (cookie provider).