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Privacy Policy



Welcome to This Privacy Policy is designed to tell you about our practices regarding collection, use, and disclosure of information that you may provide or Winnington Capital Limited ("we") may collect via this site. Please be sure to read this entire Privacy Policy before using or submitting information to this site.

Your Consent

By using this site, you agree with the terms of this Privacy Policy. Whenever you submit information via this site, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy. In the event that we transfer the business (in whole or in part) to another entity, you also agree that your data may be transferred to such new entity.

Active Information Collection

We collect information from qualified investors and allow these investors to become registered users of this site. To determine if an investor is qualified, we will (whether via this site or via other media) collect personally identifiable information online including [first and last name, email address, phone number, and the name of the potential investor's organization. The investor also has the option of providing his or her postal address] (collectively, "Personal Data"). We will also collect Personal Data online from those seeking general information or providing comments to us, and from those seeking employment with us.  If you have any general enquiries, please contact

You will be informed at each information collection point what information is required and what information is optional.


Passive Information Collection

As you navigate through a Website, certain information can be passively collected (that is, gathered without your actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, Internet tags, and navigational data collection.

This site may use Internet Protocol (IP) addresses. An IP Address is a number assigned to your computer by your Internet service provider so you can access the Internet and is generally considered to be non-personally identifiable information, because in most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user's computer). We use your IP address to diagnose problems with our server, report aggregate information, and administer and improve the site.

A "cookie" is a bit of information that a Website sends to your Web browser that helps the site remember information about you and your preferences. This site uses cookies.

"Session" cookies are temporary bits of information that are erased once you exit your Web browser window or otherwise turn your computer off. Session cookies are used to improve navigation on Websites and to collect aggregate statistical information. This site uses session cookies.

"Persistent" cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (e.g., passwords), helping to determine what areas of the Website visitors find most valuable, and customizing the Website based on your preferences. This site does not use persistent cookies.

"Internet tags" (also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) are smaller than cookies and tell the Website server information such as the IP address and browser type related to the visitor's computer. This site does not use Internet tags.

"Navigational data" ("log files", "server logs", and "clickstream" data) are used for system management, to improve the content of the site, market research purposes, and to communicate information to visitors. The information collected for these purposes is the IP address that requested the web page. This site uses navigational data.


Use And Disclosure Of Information

We use the information you provide, including Personal Data, to process your requests and may contact you by phone after you submit your requests such as to obtain further information. We may also use information provided to send you information about appropriate investment products or services, to invite you to participate in additional features or services, to evaluate what parts of the site are of interest to you or to generally improve our services. Please let us know if you wish to opt-out of your Personal Data being used for direct marketing purposes. If you do not opt-out within 30 days of providing information to us, you shall be deemed to have consented to your data being used for direct marketing. Even though such consent is deemed given, you may opt-out any time (even after the 30 days response period has lapsed). We shall cease using the Personal Data for direct marketing. We will disclose your Personal Data if (1)  in good faith, we believe it is required by law to do so, including but not limited to disclosure to law enforcement, other government officials or regulatory authorities in connection with an investigation of fraud, intellectual property infringement, or other activity that is illegal or may expose us to legal liability; and (2) in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, your Personal Data may be transferred to our successor. The Personal Data collected from you may be used by us and/or any company within the Winnington group of companies and/or any of its associated companies, within or outside Hong Kong, for such purposes noted above and in this connection, we may transfer or disclose such information to any of those other companies. We will cease to use the Personal Data if you request us to do so and accordingly the Personal Data will be erased or destroyed.

All recruitment applications will be handled in strict confidence by authorized personnel and will only be used for recruitment related purposes. Applicants who do not hear from us within three months from submission of the application may consider their applications as unsuccessful. All information on unsuccessful candidates will be destroyed after six months.

If you provide personally identifiable information to this site, we may combine such information with other actively collected information unless we specify otherwise at the point of collection. We will take reasonable measures to prevent personally identifiable information from being combined with passively collected information, unless you consent otherwise.

In addition, we will make full use of all information acquired through this site that is not in personally identifiable form.


Access And Correction

We are committed to protecting the privacy interests of individuals who provide us with information about themselves and to complying with the requirements of the Personal Data (Privacy) Ordinance (the "Privacy Ordinance") in Hong Kong. In doing so, we instruct our staff to comply with strict internal standards of security and confidentiality.

You are entitled under the Privacy Ordinance to be informed by us whether we hold Personal Data about you and to request access to and/or correction of any such Personal Data.

Any such request may be made to



We adhere to security measures to protect your personally identifiable information as you transmit your information from your computer to our site and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, you should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from this site may not be secure, and you should therefore take special care in deciding what information you send to us via email. Moreover, where you use passwords, ID numbers, or other special access features on this site, it is your responsibility to safeguard them.

You acknowledge and agree that we shall not be responsible for any unauthorized use, distribution, loss or damage of personal data.


Links To Other Websites

This site may contain links or references to other Websites. If you use such links or references you will leave this site. Please be aware that we do not control other Websites and that, in any case, this Privacy Policy does not apply to those Websites. We encourage you to read the privacy policy of every Website you visit.
Contact us if you have any queries about our privacy policy, the protection of personal data or wish to update or rectify the personal data that we hold about you.


Changes To Privacy Policy

We may amend this Privacy Policy at any time by posting a revised version on this site. The revised version will be effective at the time we post it.

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