During the implementation of its activities, the Company may use your Personal Data in various ways,
when providing Services. That is why we have developed this document so that each Client has the opportunity
familiarize himself with the ways in which his Personal Data is used or to decide to refuse such use.
that may receive your data.
References to the words "you," "you," or "yours" (or similar words in meaning) mean our Client, depending
described in these conditions. WINDNFIRE is in no way responsible for Processing Personal Data by third
During the Processing of the Client's Personal Data, the Company is guided by the General Data Protection
Regulation (EU) 2016/679 of April 27, 2016, which is the most common and basic in the world.
We thank you for using the Services of our Company.
1.1. Client - an individual or legal entity that interacts with the Company to
receive the Services.
1.2. Controller means any natural or legal person, government agency,
or other body that independently determines the purposes and means of personal data Processing.
1.3. Cookies are a piece of information in the form of text or binary data is
transmitted to the browser from the site.
1.4. Client’s Consent (hereinafter "Consent") means a voluntary, specific,
and unequivocal expression of will, in which the Client using a statement or explicit affirmative action
to the Processing of his Personal Data.
1.5. Personal Data - means any information that directly or indirectly allows
identifying the Client. For example, name, surname, phone number, IP address.
1.6. Processing - means any actions with personal data, including but not
to: access, provision, distribution, collection, systematization, storage, accumulation, recording,
blocking, deletion, clarification, update and/or change, depersonalization, and other use of personal data,
carried out by the Company.
1.7. Processor is a natural or legal person, government agency, institution, or
other body that processes Personal Data on behalf of and behalf of the Controller.
1.8. Services - means the promotion of a company and/or a product and/or a page
social networks, complex of actions for using social services as channels for the promotion of a company
a product and/or a page and solution of other business tasks, with or without the involvement of third
1.9. Social Network - is a platform, online service and website designed to
reflect and organize social relationships on the Internet.
1.10. Third Party - means a natural or legal person, government agency,
or body other than the Client, Controller, Processor, and persons authorized by the Controller or Processor
under their direct supervision to process Personal Data.
1.11. WINDNFIRE (hereinafter referred to as "the Company" or "WINDNFIRE") - is a
company on the Internet that provides digital marketing services to the Client.
1.12. WINDNFIRE Site (hereinafter “Site”) - means a web page or group of web
on the Internet, which are located at: https://windnfire.com/
1.13. WINDNFIRE Application (hereinafter “App”) - is the application of the
with the help of which the Client can familiarize himself with and receive the Services of the Company,
to those indicated on the Site.
2.2. The Company acts as a Processor of Personal Data that it receives as a result of providing Services
2.3. The Company is not responsible for the Processing of Personal Data by third parties that are not
controlled or owned by WINDNFIRE.
control and shall not be responsible for any third-party sites to which the Client may access through the
available on the Site.
3. PERSONAL DATA
3.1. The Company receives the following Personal Data about the Client:
3.1.1. full name;
3.1.3. contact phone number;
3.1.4. address: country, city;
3.2. The Client may provide any of his Personal Data when filling
the feedback form ''GET IN TOUCH', in which case the Company Processes such data by the terms of this
3.3. The Company can obtain customer data through social networks: Facebook, Instagram and Twitter. In
case, the Personal Data received through Social Networks will be Processed by the terms of this Privacy
but the Company is not responsible for the Processing of Personal Data that the Client places on Social
3.4. If the Client is a legal entity, the Company has the right to collect and Process statistical data of
such Client, namely: name, legal and actual address, bank details, etc. The statistics obtained are stored
3.5. WINDNFIRE does not collect or Process sensitive Personal
Clients, such as race or ethnic origin, political views, religious or philosophical beliefs, union
genetic or biometric data, health information, sexual life or sexual orientation.
3.6. The Company collects and uses only Personal Data of users that are necessary for fulfilling their
order, and/or registering on the Site and/or in the App, in order to create an account.
3.7. When you visit the Site or receive the Services, WINDNFIRE
collect the following Personal Data automatically:
3.7.1. IP address;
3.7.2. time zone and language settings;
3.7.3. browser type and version;
3.7.4. operating system, device type and
3.7.5. location country;
3.7.6. information about your visit to
Site, including complete details on the URL, route to and from the Site (including date and time), page
time, data loading errors, length of stay on certain pages, activity on the page (such information such as
scrolling and mouse movements, clicks), methods used to exit the page, and phone numbers for contacting the
3.8. WINDNFIRE has the right to collect and receive the Personal
of the Client as follows:
3.8.1. when providing Services;
3.8.2. when placing an order with the
3.8.3. during the Client's description of
3.8.4. when interacting with employees of
Companies, by exchanging e-mails, messages on social networks and messengers, telephone calls;
3.8.5. use of log files, Cookies and
3.8.6. through the use of messengers and
3.8.7. when using a feedback form;
3.8.8. when signing any documents between
Client and the Company, including but not limited to: agreements, contracts, invoices, etc.
3.9. The Company has the right to use Personal Data for the
3.9.1. to provide Services;
3.9.2. to ensure the security of the
3.9.3. contractual relations;
3.9.4. requests and other communications;
3.9.5. for marketing;
3.9.6. to administer the Site and conduct
internal operations, including troubleshooting, data analysis, testing and
3.9.7. improve the navigation of the Site
based on your preferences;
3.9.8. communication with the Client;
3.9.9. to respond to requests from law
3.9.10. to respond to lawsuits,
or resolve disputes with the Client.
3.10. The Company may use the Information received from you (for example, your email address) for
purposes. For example, by subscribing to our newsletter, you can receive publications and announcements
to your email. The Company can send you promotional materials about our services, and promotional offers
think you may be interested in.
3.11. You can unsubscribe from receiving our marketing emails (either in whole or in part) by clicking on the "unsubscribe" link in the emails you receive from us. You may also
contact us at any time to cancel your subscription by sending us an email to the email address listed in
3.12. The Company reserves the right to obtain additional information and/or Personal Data of the Client
the provision of Services. If the Client refuses to provide such information or Personal Data, the Company
the right to terminate any relationship with such Client.
4.1. Cookie is a small file that is placed on your computer, mobile device or tablet and contains an
identification code that allows us to recognize your computer, mobile device or tablet and provide you with
best possible experience on our Site. For example, it allows the Site to remember your actions and
(such as login information, language, font size and other display settings) for a certain period of time, so
do not need to re-enter them or re-adjust your preferences every time you return. to the Site or go from one
4.2. The pages of the Site may contain electronic images known as Web-beacons (sometimes also called
transparent gifs or pixel tags). Web-beacons are usually small images located on a web page or in emails
you view. The request that your internet-connected device makes to download such an image from a
is recorded and it provides us with information such as the IP address of the computer that downloads the
the time the image was viewed and the type of browser used for this is used.
4.3.1. Client authentication;
4.3.2. storing personal preferences and
settings of the Client;
4.3.3. tracking the User's access
4.3.4. storing statistics information
4.3.5. tracking the location of the User.
4.4. When providing the Services, we may use the following types of Cookies:
Cookies, also known as transient Cookies, exist only in temporary memory while the Client is on a
page. Browsers usually remove the session Cookie after the Client closes the browser window.
Cookies are deleted on a certain date or after a certain period. This means that information about
Cookie will be transmitted to the server every time the Client visits the Site to which these Cookies
are a type of files that appears when web pages contain content from external websites, such as links
other websites. For example, they may be used to track the history of Client visits to other websites.
4.5. Cookies do not transmit viruses and/or malicious software to your computer, as the data in the Cookie
does not change when moved and does not affect the operation of your computer in any way. Instead, they act
like logs (that is, they record user activity and remember state information) and are updated every time you
allow. You may also disable Cookies by changing the settings of your web browser. The information that
collect is in an anonymous form.
4.7. Some Cookies are necessary for the Site to function properly and some are not necessary, but they
improve the Site. Please note that you automatically accept the necessary Cookies from our Site for its
functioning when you visit it (unless you have disabled all Cookies in your browser settings).
be available to you. Cookies allow us to track the use of the Site by the Client, measure data and analyze
5. PERSONAL DATA TRANSFER
5.1. The Company has the right to transfer Personal Data to Third Parties for the implementation and
of the Services and/or protection of its legal interests:
employees. The Company may transfer Personal Data to other entities with which it will cooperate,
including legal and tax consultants and entities that provide accounting, marketing and IT services.
enforcement, and government agencies. The Company has the right to transfer Personal Data in the
of fulfilling any legal obligations, including in connection with a court ruling.
The Company has the right to disclose or transfer the Client's Personal Data during the following
transactions: acquisition or merger, financing, corporate reorganization, joint venture, including the sale
assets or in the event of bankruptcy.
6. CLIENT CONSENT
6.1. The following actions of the Client are considered to be the Consent of the Client to the terms of
Processing of Personal Data:
6.1.1. filling in the "GET IN TOUCH"
6.1.2. conclusion of any contract or
contractual document with the Company.
6.2. The Company reserves the right to obtain the Client's Consent through a pop-up form. The pop-up form
contain the Consent form in the flag submission.
7. PERSONAL DATA STORAGE AND PROTECTION
7.1. The Company uses all necessary security and protection measures for Personal Data to ensure its
confidentiality and prevents loss or misrepresentation.
7.2. The Company protects and stores Personal Data from:
7.3.1. pseudonymization and encryption of
7.3.2. ability to ensure constant
confidentiality, integrity, availability and fault tolerance of Personal Data Processing systems;
7.3.3. regular testing, evaluation and
measurement of the effectiveness of technical and organizational measures to ensure the security of
7.4. The Company may delete a Client’s Personal Data upon receipt of a request from the Client and upon
termination of the relationship. By deleting Personal Data, we mean deleting all Personal Data from servers
and/or written media.
7.5. WINDNFIRE has the right to retain the Personal Data of Clients for 5 (five) years after the
of the relationship in the following cases:
7.5.1. for statistical accounting;
7.5.2. if the current legislation
7.5.3. if they are necessary for doing
7.6. The Company does not store the Client's Personal Data in the event of a request to delete Personal
on his behalf in accordance with the right to delete, as provided in Article 17 of the "Right to Erase" GDPR.
7.7. WINDNFIRE has the right not to delete Personal Data in the event of a reorganization of the company,
merger of WINDNFIRE with another company, or any other changes in the structure of WINDNFIRE, and in the
of a change of server.
8. BASIS FOR PROCESSING PERSONAL DATA
8.1. The Company collects and Processes Personal Data in accordance with the General Data Protection
8.2. The Company Processes Personal Data based on the following legal grounds:
8.2.1. Client's Consent;
8.2.2. Services provision to the Client;
8.2.3. contract conclusion;
8.2.4. to comply with applicable law, for
proper level of our business, to enter into and execute corporate transactions (sale of shares/stocks,
acquisitions), to fulfill its obligations to you and/or a Third Party.
8.3. In cases where the basis for the Processing of Personal Data is your Consent, you have the right to
revoke it at any time. In the event of withdrawal of your Consent, the Company has the right to terminate
provision of the Services and terminate all relations with you. If the Consent is revoked, your Personal
will be permanently deleted.
8.4. The Company undertakes to stop processing Personal Data within 10 (ten) business days from the date
receipt of the withdrawal of the Consent.
9. CLIENTS RIGHTS
9.1. The terms of this section apply to residents of the European Union and the European Economic Area. By
terms of this clause, the Client has the following rights:
access to the Personal Data we hold about them, as well as to any information in accordance with Article 15 of the General Data Protection Regulations.
rectification. The Client has access to Personal Data, which must be updated, corrected, and
supplemented at any time. The Client may also contact the Client support of the Company to access his
Data to correct, change, or delete it according to Article 16 of the General Data Protection Regulations.
9.2. The Client must provide sufficient information to confirm his identity, whose Personal Data are
by the Company. If the Client cannot confirm his/her identity, the Company has the right not to fulfill such
request until the confirmation of such identity.
9.3. The Client's request must contain accurate information on the requirements it places on the Company.
the request does not specify the exact requirements, the Company has the right to refuse to fulfill the
9.4. We will not be able to respond to your request or provide you
with Personal Data unless we are able to verify your identity or authority and confirm that the Personal
relates to you. In case of receiving a request with inaccurate information and/or in case of impossibility
verify the identity of the Client, the Company has the right not to Process the received request and apply
the Client for clarifications. If a request for clarification is received, the Client is obliged to submit a
corrected request or submit a new request.
9.5. The Company must respond to the request or fulfill the
outlined in the request within 21 (twenty-one) business days from the date of receipt.
10.1. The Company notifies the Client that its Personal Data may be used to provide the Services, and in
of disagreement, the Client must leave the Site and not use the Company Services.
10.2. The Company has the right to collect the Personal Data of the Client to obtain statistical data.
10.3. The Company is not responsible for:
10.3.1. loss of Personal Data in the
a hacker attack, hacking of the Site software, illegal actions of third parties, illegal actions of the
10.3.2. provision by the Client of
information and/or Personal Data.
10.4. The Company has the right to refuse the User to provide the Services and Process his Personal Data
is a resident of a jurisdiction that is prohibited, in accordance with the provisions of the AML/KYC Policy.
10.5. Unfortunately, the transmission of information via the
may not be completely secure. Although we make every effort to protect your Personal Data, we cannot
the secure Process of transferring your Personal Data to our Site. In this regard, you are solely
for possible failures in sharing your Personal Data with the Site. Upon receipt of your Personal Data, we
undertake the necessary technical and security measures to prevent unauthorized access to your Personal
11. ADULT POLICY
11.1. The Company Services are intended for adults Clients. The Company does not process the Personal Data
11.2. WINDNFIRE has the right to delete the Personal Data of a minor, without warning and any consequences
the Company, and to terminate the provision of such person to the Services.
11.3. If you have information about the use of the Services by a minor, please contact Company support by
sending an email to: firstname.lastname@example.org.
Data and in case of changes in the legislation governing the Processing of Personal Data.
Client uses the Services, then he agrees with the new rules for the processing of Personal Data.
13.1. The Client has the right to contact the support service of the Company at: email@example.com to ensure his rights, by the