PRIVACY POLICY
Who we are
Winston Wolf Capital Management S.L. (“we”, “us”, “our”) is the data controller for personal data processed via this website. Registered address: Gran Via, 630, 4ª planta, 08007 Barcelona (Spain). Contact for privacy matters: privacy@winstonwolfcapital.com.
Personal data we collect
Data you provide directly
• Contact form: name, email, phone (optional), and your message.
• Newsletter (optional): name and email, only if you subscribe.
Data collected automatically
We collect minimal technical information necessary to operate and secure the site (e.g., IP address, timestamps, basic device/browser data). We currently use only strictly necessary cookies; we do not use analytics or advertising cookies.
Spam and bot protection (Cloudflare Turnstile)
We use Cloudflare Turnstile to protect our contact form from automated abuse. To determine whether a visitor is a human, Turnstile may collect certain technical and usage information such as IP address, device and browser characteristics, and interaction/behavioral signals. Cloudflare, Inc. (USA) processes this data to provide the service and may act as an independent controller for some processing activities. Data may be transferred outside the EEA; where applicable, we rely on the European Commission’s Standard Contractual Clauses and apply additional measures as appropriate. For details, please see Cloudflare’s Privacy Policy.
Purposes and legal bases
• Respond to inquiries (contact form): Art. 6(1)(b)/(f) GDPR.
• Newsletter / updates: consent (Art. 6(1)(a)), withdraw anytime.
• Security and compliance (incl. Turnstile): Art. 6(1)(f)/(c) GDPR.
Who we share data with
We do not sell your data. Access is limited to our team and essential service providers (e.g., hosting, email/newsletter delivery, spam/bot protection via Cloudflare Turnstile) acting under our instructions or, where applicable, as independent controllers for their own purposes. If any provider is located outside the EEA, we will use appropriate safeguards such as the European Commission’s Standard Contractual Clauses.
How long we keep your data
• Contact form correspondence: up to 12 months.
• Newsletter data: until you unsubscribe or withdraw consent (may retain email in suppression list).
• Security logs: typically up to 12 months unless needed longer for security or legal reasons.
Your rights
You may request access, rectification, erasure, restriction, and portability of your personal data, and object to processing in certain cases. Where processing relies on consent, you may withdraw it at any time without affecting prior lawful processing. Contact: privacy@winstonwolfcapital.com. You may also lodge a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es.
Cookies
We currently use only strictly necessary cookies and similar technologies for site operation and security. This includes technologies used by Cloudflare Turnstile to distinguish bots from humans. We do not use analytics or advertising cookies. If we later introduce optional cookies, we will request your consent and update this notice.
International transfers
If personal data is transferred outside the EEA, we will ensure an adequate level of protection using EU-recognized mechanisms and apply additional measures where appropriate. This may include transfers to Cloudflare, Inc. (USA) for the purposes of providing Turnstile.
Changes and contact
We may update this Privacy Policy to reflect legal, technical, or business developments. Effective date: 11 August 2025. Contact: Winston Wolf Capital Management S.L., Gran Via, 630, 4ª planta, 08007 Barcelona (Spain) — privacy@winstonwolfcapital.com.