Legal

Privacy Policy

Last updated: January 2025

Introduction

Winterfields Resources Limited ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website winterfieldsgroup.com.

Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site.

Information We Collect

We may collect information about you in a variety of ways. The information we may collect on the site includes:

  • Personal Data: Name, email address, company name, and inquiry details you provide when contacting us.
  • Usage Data: Information automatically collected when you visit our site, including IP address, browser type, and pages visited.

How We Use Your Information

We use the information we collect to:

  • Respond to your inquiries and provide information about our investment opportunities
  • Process NDA requests and share confidential documentation with qualified investors
  • Improve our website and user experience
  • Comply with legal obligations and protect our legal rights

Disclosure of Your Information

We do not sell, trade, or rent your personal information to third parties. We may share information in the following situations:

  • With our professional advisors (lawyers, accountants) under confidentiality obligations
  • To comply with legal requirements or respond to lawful requests
  • In connection with a merger, sale, or acquisition of our business

Data Security

We use administrative, technical, and physical security measures to protect your personal information. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

Security Measures We Implement

  • TLS/SSL encryption for all data transmissions
  • HTTP Security Headers (CSP, X-Frame-Options, X-Content-Type-Options)
  • Secure hosting with automated backups
  • Access controls and authentication for data systems

Cookie Policy

We use cookies and similar technologies to enhance your browsing experience and analyze site traffic. Cookies are small text files stored on your device.

Types of Cookies We Use

Essential Cookies

Required for basic site functionality. Cannot be disabled. Examples: session management, security tokens.

Analytics Cookies

Help us understand how visitors interact with our website. Examples: Google Analytics (opt-out available).

Marketing Cookies

Used to deliver relevant advertisements (opt-out available).

Managing Cookies: You can manage your cookie preferences through our cookie consent banner or your browser settings.

Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including:

  • Contact form submissions: Retained for 24 months
  • Investor inquiries: Retained for 7 years for regulatory compliance
  • NDA requests: Retained for 10 years
  • Analytics data: Anonymized after 26 months

After these periods, data is securely deleted or anonymized.

International Data Transfers

As an international trade finance company, data may be transferred to and processed in countries outside the UK/EEA. When we transfer data internationally, we ensure appropriate safeguards are in place, including:

  • Standard Contractual Clauses (SCCs) approved by the ICO
  • Adequacy decisions where available
  • Binding Corporate Rules for intra-group transfers

Third-Party Services

We use trusted third-party services. Each has their own privacy policy:

Web Hosting

Landingsite.ai - Data stored securely in AWS

Analytics

Google Analytics (opt-out available)

Email Delivery

AWS Lambda/SES for form submissions

Fonts

Google Fonts (privacy policy: google.com)

Children's Privacy

Our website is not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected personal data from a child without parental consent, we will take steps to delete that information promptly.

Data Protection Officer & Complaints

We have appointed a Data Protection Lead responsible for overseeing data protection matters.

If you have concerns about how we handle your data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Information Commissioner's Office (ICO)

Website: ico.org.uk
Address: Wycliffe House, Water Lane, Wilmslow, SK9 5AF
Phone: 0303 123 1113

Your Rights (UK GDPR)

Under UK data protection law (UK GDPR), you have the following rights:

Right of Access

Request a copy of your personal data

Right to Rectification

Correct inaccurate personal data

Right to Erasure

Request deletion of your data ("right to be forgotten")

Right to Object

Object to processing of your data

Right to Portability

Receive your data in a structured format

Right to Restrict

Request limited processing of your data

Exercising Your Rights: To exercise any of these rights, please contact us via our contact form. We will respond within 30 days.

Contact Us

If you have questions or concerns about this Privacy Policy, please contact us through our contact form or at:

Winterfields Resources Limited
United Kingdom

Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.