Privacy Policy
Updated August 2022
Introduction
This Privacy Policy outlines the principles, guidelines, and practices concerning the collection, use, safeguarding, and disclosure of personal data obtained from traders participating in the proprietary trading product offered by Western Sahara Worldwide Services (WSWS), known as Willis Capital. It has been carefully created to provide proper insight into how Willis Capital and WSWS handle and protect the personal information of individuals involved in the trading program.
Purpose and Scope of the Policy
Purpose
The primary objective of this Privacy Policy is to inform individuals, particularly traders engaging with Willis Capital, about the nature, extent, and purpose of the collection, processing, and retention of their personal data. It emphasises the measures taken to protect their privacy rights, ensuring transparency in the handling of their information.
Scope
This policy applies to all individuals participating in the trading program provided by Willis Capital through WSWS. It encompasses the procedures and practices governing the acquisition, usage, storage, and sharing of personal data obtained from traders during their engagement with the platform. The policy also delineates the rights available to traders concerning their personal information.
Controller of Personal Data and Contact Information
The entity responsible for processing personal data within the context of Willis Capital's proprietary trading program is Western Sahara Worldwide Services (WSWS), headquartered at The Bay Gate, Business Bay, 2201, Dubai, U.A.E. WSWS oversees the management, storage, and processing of traders' personal information collected during their participation in the program. Individuals participating in any of Willis Capital trading programs or other concerned parties seeking clarification, making inquiries, or requesting information regarding the handling of personal data can contact WSWS using the provided email address or physical address.
Email Address: support@williscapitals.com
Physical Address: The Bay Gate, Business Bay, 2201, Dubai, U.A.E.
Collection of Personal Information
We gather personal data through various means:
Directly from Users
Participants in the Willis Capital proprietary trading program provide personal details during registration. This includes full names, contact information (email, phone), residential addresses, dates of birth, and unique usernames and passwords. However, we might also collect transaction records, communication details, and any warranty claims made during user interactions with the platform.
Automatically Collected Data
When users engage with our trading platform, we automatically gather device-specific information such as IP addresses, device types, operating systems, browser details, and connection provider data. Moreover, our systems track website usage, including the time, date, and duration of visits, geographical information (country), browsing history, login/logout information, account settings, fictitious capital value, account currency, and business strategy insights.
Information from Third Parties
We also obtain data from third-party trading platform providers, which may include simulated transaction data like instrument types, opening/closing times, investment amounts, and profit/loss details. If users opt to link their social media accounts to the Willis Capital platform, we also receive information like usernames, profile pictures, and associated email addresses.
Use of Personal Data
Account Registration and User Management
We process personal data to facilitate account creation and management on the Willis Capital platform. This includes identification, contact details, and user-specific setting required for registration
Provision of Services and Contractual Obligations
Personal data processing is necessary to provide services, offer appropriate access, tools, and support, and execute trades for users actively engaging with our platform. This involves handling identification, contact, payment, service usage data, simulated trades, and, if connected, social media data.
Marketing Communications and Events Participation
For current and past customers, occasional marketing communications related to our services are sent. Consent-based commercial communications may also be provided. These messages, marked as business communications, contain opt-out options. The processing of contact and identification data is involved in this context.
Customer Support and Communication
Engagement with customer support services involves the processing of identification, contact, other relevant data, and social media information when customers contact us through those channels. This is performed to ensure customer satisfaction and to aid in service utilisation.
Improving Services and Analytics
We process personal data to enhance, test, and secure our services, contributing to their development and improved security measures. This includes analysing customer behaviour, utilising various data such as identification, contact, device information, website usage data, service usage data, and simulated trade data.
Security and Storage of Personal Data
We implement stringent measures to ensure the security and confidentiality of personal data provided to Willis Capital. This includes the utilisation of industry-standard security protocols, encryption technologies, and access controls to safeguard against unauthorised access, disclosure, alteration, or destruction of data
Storage Practices and Data Security Measures Implemented
Personal data is securely stored in encrypted databases on secure servers and devices. We employ organisational and technical safeguards to protect against any unauthorised access, modification, disclosure, or destruction of the data collected and processed. Our commitment involves adherence to strict security protocols and best practices to maintain the integrity and confidentiality of all user information.
Retention Period for Personal Data
Personal information is retained only for the duration necessary to fulfil the purposes outlined in the Privacy Policy or as required by applicable laws and regulations. The retention period for collected data may vary based on the nature of the information and the purposes for which it was collected.
Guidelines for Data Retention and Deletion
We adhere to strict guidelines concerning the retention and deletion of personal data. Once the data is no longer necessary for the intended purposes or as required by law, we take appropriate measures to either securely delete or anonymize the information in a manner that prevents unauthorised access, use, or disclosure.
Sharing of Personal Information
We may share your personal data with specific entities or parties for the sole purpose of providing and improving our services. These parties may include but are not limited to:
Trusted Partners: Entities collaborating with Willis Capital to deliver services or assist in business operations.
Service Providers: Third-party service providers supporting our business functions such as IT services, analytics, and customer support.
Legal or Regulatory Authorities: If mandated by law or as necessary to protect the rights, property, or safety of Willis Capital, its users, or others, we may disclose personal data
Handling of Personal Data by Third Parties
Entities with access to personal data are contractually bound to ensure the confidentiality, security, and proper handling of the shared information. They are obligated to process the data only in accordance with our instructions and for the purposes agreed upon, as defined in our Privacy Policy.
Rights of Data Subjects
As a user of Willis Capital's services, you possess certain rights regarding your personal data. These rights include:
1. Right to Access Personal Data Users can request confirmation of whether their personal data is being processed and receive further details regarding such processing.
2. Right to Rectification: Users have the right to rectify inaccuracies or incomplete information in their personal data.
3. Right to Erasure ("Right to Be Forgotten"): Users can request the deletion of their personal data under specific circumstances, such as when the data is no longer necessary for the purposes it was collected or processed.
4. Right to Restriction of Processing: Under certain conditions, users can request the restriction of the processing of their personal data.
5. Right to Data Portability: Users can receive their personal data in a structured, commonly used, and machine-readable format and have the right to transmit this data to another controller.
6. Right to Object: Users have the right to object to the processing of their personal data, especially in cases where the processing is based on legitimate interests.
7. Right to Withdraw Consent: If the processing of personal data is based on consent, users have the right to withdraw their consent at any time.
8. Right Not to Be Subject to Automated Decision-Making: Users have the right not to be subject to decisions based solely on automated processing, including profiling.
9. Right to Lodge a Complaint with Supervisory Authority: Users have the right to lodge a complaint with the relevant supervisory authority if they believe that the processing of their personal data infringes data protection regulations.
Amendments and Policy Changes
At Willis Capital, we are committed to transparency and will inform users about any changes or updates made to the Privacy Policy.
Notification of Changes to the Privacy Policy
Process for Informing Users about Policy Updates Users will be notified of any changes to the Privacy Policy through:
- Email communication
- Notifications on the website or through the user account
- Notices in the Client Section or relevant service areas
Policy Review and Revision
Willis Capital periodically reviews and updates this policy to ensure compliance with regulatory requirements and best practices in data protection.
User Acknowledgment of Changes
Users are encouraged to review the Privacy Policy regularly to stay informed about how their personal information is being protected and used. Continued use of Willis Capital's services after the changes to the Privacy Policy will signify acceptance of the updated terms.
Willis Capital reaffirms its commitment to safeguarding user privacy and ensuring the confidentiality, integrity, and availability of personal data. Users are encouraged to read and understand this Privacy Policy to comprehend their rights and obligations regarding their personal data. For any queries, concerns, or requests regarding personal data or the Privacy Policy, users can reach out to Willis Capital via the provided contact details. However, by using Willis Capital's services, users acknowledge their understanding and acceptance of the Privacy Policy's terms and conditions. The Privacy Policy takes effect upon its publication and governs the use of personal data by Willis Capital.