Privacy Policy

OVERVIEW

BEFORE USING OUR SITES OR PROVIDING US WITH PERSONAL INFORMATION, PLEASE READ THIS PRIVACY POLICY CAREFULLY.

This Privacy Policy applies to Windstone Capital and its affiliated companies. It explains how we collect, use, and disclose Personal Information through this site and our other sites (collectively, “Sites”), through communications with us, and in the course of otherwise conducting business with us. Windstone Capital is committed to providing secure websites for visitors of all ages and protecting any Personal Information (as defined below) provided to or collected by us. We have implemented this Privacy Policy to demonstrate our unwavering commitment to your privacy. This Privacy Statement explains how we collect, use, store, and safeguard your Personal Information, including:

• The definition of “Personal Information” and when it is collected.

• Which Personal Data we collect from you.

• The reasons we collect and use your Personal Information.

• The Internet technologies we may employ to collect and process your Personally Identifiable Information.

• Whom we may share your Personal Information with, and where we may store your Personal Information.

• How we safeguard your Personal Information and how long we keep it.

• Accessing, correcting, and updating your Personal Information.

• How to reach us regarding privacy concerns.

Please review this Privacy Statement before submitting any Personal Information to us. By using the Sites or otherwise submitting information to us, you consent to our collection, storage, transfer, and use of your Personal Information following this Privacy Statement.

If you do not concur with this Privacy Statement, kindly do not use our websites. Your continued use of the Sites indicates that you accept these terms and any modifications in effect at the time of service.

We reserve the right to modify this policy without prior notice at any time. When we modify this Privacy Policy, the “last updated” date will be updated at the top of the policy. You should check periodically to determine whether this Privacy Policy has been modified. If we make significant changes, we will, as appropriate, prominently post these changes on our website or directly notify registered users.

You may terminate your account and refrain from using our services or visiting the Sites if you disagree with any changes to the Privacy Statement. Continuing to use our services or visiting our Sites after we post or communicate a change indicates your acceptance of the revised Privacy Policy terms.

PERSONAL INFORMATION

For the purposes of this Privacy Policy and following applicable privacy laws, “Personal Information” refers to any information that may be used to identify you, including but not limited to your name, email address, mailing address, and telephone number, as well as information that may be generated using websites, such as your IP address (as described in greater detail below).

We collect the personal information you voluntarily provide by responding to non-anonymous surveys, questionnaires, feedback forms, and registration forms. We may also request additional information, such as your email address, if you wish to obtain other services or information or have complaints or concerns that need to be addressed. If you elect to invest with us, we will require additional information to establish your account and comply with applicable laws.

YOUR CONSENT

We only collect, use, and disclose your Personal Information for purposes directly related to our products and services, with your consent or as required by law. Your consent may be expressed in writing, verbally, electronically, or through your authorised representative(s). Your consent may also be implied or inferred from specific actions, such as visiting our websites, where this Privacy Statement is posted. If there are no legal or contractual reasons preventing you from doing so, you may withhold or withdraw your consent for us to collect, use, and share your Personal Information. However, depending on the circumstances, withdrawing your assent may affect our ability to continue providing you with the requested products and services.

HOW DO WE COLLECT PERSONAL INFORMATION, AND WHY

We collect information from and about you only with your consent or as required or permitted by law. In general, we will collect Personal Information such as your name, address, telephone number(s), Social Security Number (SSN) or date of birth. Financial information may be collected, which could include your place of employment, annual income, assets, and liabilities. For example, it could be investment or advice-related information about your financial objectives and retirement plans. We collect, use, and disclose your Personal Information to provide you with our products and services (collectively, the “Services”), including to:

• Confirm your identity and protect you and us from mistakes, fraud, and other misrepresentations.

• Evaluate your financial requirements and determine if our products and services are appropriate for you.

• Determine your product and service eligibility.

• Administer our products and services effectively.

• Comply with various legal and regulatory requirements, including securities law requirements, tax reporting obligations under the Income Tax Act, and specific anti-money laundering and terrorist financing regulations.

• To personalise the user experience and enhance our services by analysing how our customers utilise our products and services and the resources on our websites.

• To provide, market, and/or provide services, products, and/or special offers.

• To conduct, finalise, and process transactions with you.

• Create, modify, and personalise services and offers that appeal to our customers.

SECONDARY USES

As permitted by law, we may use some of your Personal Information for purposes unrelated to your use of the Services, as described below. You may refrain from participating in certain activities or providing us with your Personal Information. In all other cases, you may opt out of our use of your Personal Information for secondary purposes by contacting us using the information provided below under “Contact.” In the interest of completeness, we also list several practices that only collect and utilise aggregated data.

Windstone Capital may use information submitted during registration or submission for marketing and promotional purposes with the consent of online visitors. If visitors object to such use for any reason, they can prevent it by sending an email or modifying the registration information provided.

We may also use services provided by third-party platforms (such as social networking platforms, search engines, and other third-party websites) to serve demographically targeted advertisements to users of such platforms based on user data collected by the operators of such platforms. In general, your exposure to advertising on these platforms is governed by the privacy policy, terms of service, and preference settings provided by the platform’s provider.

Occasionally, we may also use third-party platforms to serve users of those platforms with more individually targeted advertising based on both the platform’s user data and your interactions with Windstone Capital outside of the platform. To accomplish this, we provide the platform provider with a “hashed version” of your email address or other potentially identifying information that could be matched to your profile on that platform. Hashing is a mathematical operation that uses an equation to generate an encrypted value that cannot be reversed to disclose the original data. Windstone Capital and the platform execute the same one-way hash function on identical data elements, such as email addresses. Therefore, when Windstone Capital provides the platform with the hashed email addresses of a selected group of individuals, the platform is able to match the hashed value against the corresponding hashed value for users of the platform, enabling the platform to target users of that platform who are also connected with Windstone Capital with relevant advertising based on the demographic factors chosen by Windstone Capital. Windstone Capital provides the platform with only the hashed value and no other information about you. The social media platforms that you use may provide additional information about this process (see, for example, the “ads” icon in Facebook’s user Privacy Settings and Tools), and you may exercise the preferences provided by these social media platforms regarding your viewing of advertising on those platforms. To opt out of Windstone Capital’s use of your Personal Information for these purposes, don’t hesitate to get in touch with us using the information below under Contact.

If you do not want us to use your Personal Information for secondary purposes, or if you would like to manage your communication preferences, including opting out of future correspondence from Windstone Capital, don’t hesitate to get in touch with our team at the addresses listed below. Note that you can opt out of receiving marketing and promotional emails at any time by selecting the “unsubscribe” link in any of these emails.

Windstone Capital, like many other website owners, may use the standard technology known as “cookies” on its Sites. When you access a website, cookies are minuscule data files downloaded to your computer. Cookies identify your browser/IP address, but not you personally, to our computers whenever you visit our website.

We may use cookies to construct a profile of Site users, including their stated and inferred preferences, to effectuate a more personalised web browsing experience, such as by offering more personalised products and services tailored to your requirements. Additionally, we may use cookies to collect aggregated statistical information regarding the use of our website and its features.

The majority of web browsers allow you to block or delete cookies (typically through privacy settings) or to be notified when a request is made to establish one. You are not required to enable cookies in order to view our website; however, certain features of our website and services rely on cookies. Consequently, if you choose to disable cookies, you may not be able to use these features, or you may lose your cookie-based preferences.

PROTECTION AND RETENTION OF PERSONAL INFORMATION

We will only retain your Personal Information as long as necessary to fulfil the purposes for which it was collected or as required or permitted by law. Personal information that is no longer required will be securely obliterated, permanently deleted, or de-identified so that it can no longer be associated with you as an individual.

We have implemented physical, electronic, and managerial procedures and safeguards to prevent unauthorised access, use, and disclosure of your Personal Information. Windstone Capital employs security measures commensurate with the sensitivity of the information, such as storing information in secure facilities and restricting access to Personal Information to a small number of authorised Windstone Capital employees on a need-to-know basis. In instances where we may engage a third party to provide Windstone Capital with services that assist us in providing you services, such as customer relationship management customisation or information technology support, and where such a third party requires specific access to Personal Information in order to provide the service in question, we take appropriate contractual and other measures to ensure that the third party has access only to the Personal Information required to provide the service in question.

While Windstone Capital uses these advanced techniques when interacting with its clients, representatives, and third-party service providers, you should be aware that transmitting any data electronically carries a residual risk. This danger is inherent to all Internet transactions. We assume no responsibility for any interception, misuse, or alteration of Internet-transmitted data.

Please note that this Privacy Statement applies solely to our Sites and not to the websites of other companies or organisations that may be linked to our Sites. You may wish to evaluate the privacy policies of any sites linked to the Windstone Capital Sites and/or contact the site’s operator with any questions regarding those privacy policies. These links to third-party websites are provided solely for your convenience and information. Windstone Capital does not endorse and is not responsible for the linked websites or any Personal Information collected by them.

SHARING OF PERSONAL INFORMATION

Windstone Capital will not share any Personal Information that you provide on its Sites with any third parties except i) following the terms of this Privacy Policy and/or ii) to comply with legal requirements such as a law, regulation, warrant, subpoena or court order that requires Windstone Capital to disclose such information to bodies including, but not limited to, American and/or international regulatory authorities.

Windstone Capital may, on occasion, share Personal Information with third-party service providers, such as customer relationship management specialists and information technology consultants. We will only share with these service providers the Personal Information that is reasonably required for the purpose or service for which they are engaged. We will also use contractual and other means to provide a comparable level of protection. At the same time, the information is being processed by these service providers, including requiring that any Personal Information we share be used solely to provide the service for which they were hired and for no other purpose. You can obtain additional information about our policies and practises regarding using Personal Information by third-party service providers by contacting us as described in the “ Contact “ section below.

Please be aware that the sharing of Personal Information with these service providers may result in the storage or processing of Personal Information outside of the United States, where it may be subject to the laws of the country in which it is stored, including laws that require the disclosure of Personal Information to governmental authorities under circumstances that differ from those in the United States.

The disclosure of your Personal Information will generally be limited to those who need the information and the legal right to access it. Only the following individuals may have access to your Personal Information:

• Our personnel and representatives who require the information to fulfil their responsibilities for us.

• Service providers who require the information to carry out their responsibilities for us and fulfil their obligations to us.

• Any individual or entity to whom you have granted Windstone Capital access to your Personal Information.

• Any individual who is otherwise permitted by law.

In the context of a sale, merger, or amalgamation of all or a portion of our business or the insurance or securitisation of our assets, we may share or transfer your Personal Information where it is reasonable to do so. In such instances, the recipient parties will be contractually bound to maintain the information’s confidentiality and use it only for the transaction or proposed transaction at hand. Unless additional consent is obtained, assignees or successors of Windstone Capital or our business or assets may only use and disclose Personal Information for the purposes outlined in this Privacy Statement in the event of a business transaction.

ACCESSING AND MODIFYING YOUR PERSONAL DATA

We will make every effort to ensure that the Personal Information we collect and maintain is as accurate, complete, and up-to-date as necessary for the identified purposes. To accomplish this, we will rely on you to provide us with accurate information and to notify us of any changes, such as your contact information. You have the right to access and verify your Personal Information maintained in our files and to request that any factually inaccurate Personal Information be corrected, subject to certain legal restrictions. If we receive a request to disclose your Personal Information, we will comply only if the requestor can provide adequate identification and confirmation of entitlement or if required or permitted by law. To access or amend the Personal Information we maintain about you, please submit a written request to our Privacy Officer at the addresses listed below.

PLEASE CONTACT US

If you would like more information about our privacy policies, have any questions, or would like to file a complaint, don’t hesitate to get in touch with us via e-mail at [email protected] or by mail at the address listed below:

Windstone Capital, Corp, 4445 Corporation Ln Ste 264, Virginia Beach, Virginia 23462-3262, United States.

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