Privacy Statement of WHOOSHING TRADING LIMITED

Introduction

We take your privacy seriously. This privacy statement is designed to explain how WHOOSHING TRADING LIMITED (collectively referred to as “we,” “us,” or “our”) collects, uses, shares, and processes your information.

1. Collection and Use of Personal Data

1.1 Definition of Personal Data

Personal data refers to information that can directly or indirectly identify you. It also encompasses anonymous data that is linked to information enabling direct or indirect identification. However, data that has been irreversibly anonymized or aggregated to the point where it can no longer be used, in combination with other information or otherwise, to identify you is not considered personal data.

1.2 Promoting Safety and Security

We adhere to the principles of legality, legitimacy, and transparency. We use and process the minimum amount of data within a limited scope of purposes and implement technical and administrative measures to safeguard data security. Personal data is utilized to verify accounts and user activities, as well as to promote safety and security. This includes monitoring fraud, investigating suspicious or potentially illegal activities, and addressing violations of our terms or policies. Such processing is based on our legitimate interest in ensuring the safety of our products and services.

1.3 Types of Personal Data We Collect and Their Uses

1.3.1 Data You Provide

When you use our products and services or interact with us in other ways, such as creating an account, contacting us, participating in an online survey, using our online help or chat tool, or making a purchase, we collect the personal data you provide. This data includes payment information (e.g., credit or debit card number and other card details), account and authentication information, as well as billing, shipping, and contact details.

1.3.2 Data About the Use of Our Services and Products

When you visit our websites, we may collect the following information from or about the devices (computers, phones, etc.) on which you install or access our products or services:

• Device type and unique identifier
• IP address
• Operating system
• Internet browser type
• Usage and diagnostic information
• Location information (where available, we may use GPS, IP address, and other technologies to determine the approximate location of the device to improve our products and services)

1.4 How We Use Your Personal Data

1.4.1 Providing, Improving, and Developing Our Products and Services

We use personal data to provide, improve, and develop our products, services, and advertising. This involves data analysis, research, and audits, all based on our legitimate interest in offering you quality products and services and ensuring business continuity. If you participate in a contest or other promotion, we may use the personal data you provide to administer these programs. Some activities may have additional rules that contain further details on how we use personal data, so we encourage you to read them carefully before participating.

1.4.2 Communicating with You

With your prior express consent, we may use personal data to:

• Send you marketing communications related to our own products and services.
• Communicate with you about your account or transactions.
• Inform you about our policies and terms.

If you no longer wish to receive marketing emails, please contact us to opt-out. We also use your data to process and respond to your requests when you contact us. With your prior express consent, we may share your personal data with third-party partners who may send you marketing communications about their products and services. Additionally, we may use personal data to personalize your experience with our products and services, as well as on third-party websites and applications, and to evaluate the effectiveness of our promotional campaigns.

Note: For any use of your data that requires your prior express consent, you have the right to withdraw your consent by contacting us.

2. Definition and Use of Cookies

2.1 Definition of Cookies

Cookies are small text files used to store information on web browsers. They are widely used to store and receive identifiers and other information on computers, phones, and other devices. In this statement, we refer to cookies as encompassing all technologies used for similar purposes, including data stored on your web browser or device, identifiers associated with your device, and other software.

2.2 Use of Cookies

We use cookies to provide, protect, and improve our products and services. This includes personalizing content, offering and measuring advertisements, understanding user behavior, and providing a safer experience. The specific cookies we use may vary depending on the websites and services you utilize.

3. Disclosure of Personal Data

We make certain personal data available to strategic partners who collaborate with us to provide our products and services or assist in marketing to customers. Personal data will only be shared with these companies to provide or enhance our products, services, and advertising. It will not be shared with third parties for their own marketing purposes without your prior express consent.

4. Data Disclosure, Storage, Transfer, and Processing

4.1 Fulfillment of Legal Obligations

Due to mandatory laws in the European Economic Area (EEA) or the country where the user resides, certain legal acts may require us to fulfill specific legal obligations. For residents of the EEA, our processing of your personal data will be legitimized as follows: Whenever we require your consent for processing personal data, such processing will be justified under Article 6(1) of the General Data Protection Regulation (EU) (GDPR).

4.2 Reasonable Implementation or Application of This Article

We may share personal data with all our affiliated companies. In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer, or sale or disposition of all or any portion of our business, including in connection with bankruptcy or similar proceedings, we may transfer any and all personal data to the relevant third party. We may also disclose personal data if we believe in good faith that such disclosure is reasonably necessary to protect our rights, pursue available remedies, enforce our terms and conditions, investigate fraud, or safeguard our operations or users.

4.3 Legal Compliance and Security or Protection of Other Rights

We may be required by law, legal process, litigation, or requests from public and governmental authorities within or outside your country of residence to disclose personal data. We may also disclose personal data if we determine that such disclosure is necessary or appropriate for purposes of national security, law enforcement, or other issues of public importance.

5. Children's Privacy

Our products and services are intended for adults. We do not knowingly collect, use, or disclose data from children under 16 (or the equivalent minimum age depending on the jurisdiction). If we learn that we have collected the personal data of a child under 16, we will take steps to delete the data as soon as possible. If you become aware that a child under 16 has provided us with personal data, please contact us immediately.

6. Your Rights

We take reasonable steps to ensure that your personal data is accurate, complete, and up to date. You have the following rights regarding your personal data:

• Access, correct, or delete the personal data we collect.
• Restrict or object, at any time, to the further processing of your personal data.
• Receive your personal data in a structured and standard format.
• Lodge a complaint with the competent data protection authority regarding the processing of your personal data.

To protect the privacy and security of your personal data, we may request information from you to confirm your identity and right to access such data, as well as to search for and provide you with the personal data we maintain. There may be instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal data we maintain. You may contact us to exercise your rights, and we will respond to your request within a reasonable timeframe, and in any event, within less than 30 days.

7. Third-Party Websites and Services

When you access a third-party website through a link on our website, we are not responsible for the privacy policy of that third party. Our websites, products, and services may contain links to or provide access to third-party websites, products, and services. We are not responsible for the privacy practices employed by these third parties, nor for the information or content contained in their products and services. This privacy statement applies solely to data collected by us through our products and services. We encourage you to read the privacy policies of any third party before using their websites, products, or services.

8. Data Security, Integrity, and Retention

We use reasonable technical, administrative, and physical security measures to safeguard and prevent unauthorized access to your data and to ensure the correct use of the data we collect. We will retain your personal data for as long as necessary to fulfill the purposes outlined in this privacy statement, unless a longer retention period is required or permitted by law.

9. Changes to This Privacy Statement

We may periodically update this privacy statement to keep pace with new technologies, industry practices, and regulatory requirements. Your continued use of our products and services after the effective date of the updated privacy statement indicates your acceptance of the revised statement. If you do not agree to the revised privacy statement, please refrain from using our products or services and contact us to close any account you may have created.

10. Minors' Privacy (Reiterated)

We are committed to protecting the privacy of individuals under the age of 18. We do not knowingly collect, use, or disclose personal information from anyone under the age of 18. If we become aware that we have inadvertently collected personal data from a minor, we will take reasonable steps to delete such information from our records. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us so that we can address the matter promptly.