Privacy Policy

Wintagen ("Wintagen," "we," "us") is responsible for the personal information described in this Policy. It applies to wintagen.com, inquiries, communications, and our administration of client services. Effective date: September 20, 2026. Contact: contact@wintagen.com.

For our website and business administration, we determine why and how personal information is used. When a client provides personal information solely for development, hosting, support, or another contracted task, we process it under that client's documented instructions and the applicable services agreement and data processing terms. The client's notice generally explains that processing. Direct requests about client-controlled data to the client; we assist as required by the contract and law.

Separate products and third-party sites

Products operated under the Wintagen portfolio may have distinct functions, audiences, and data practices. Their own privacy notices identify the operator and apply to those products. Links to external sites do not make their practices part of this Policy. A common brand does not mean all product data is pooled or shared.

Depending on the interaction, information may include your name, business name, role, email, phone number, correspondence, meeting arrangements, project requirements, website addresses, files you supply, service feedback, billing contact details, and records needed to administer an engagement.

Information from other sources

We may receive business contact details from a colleague referring you, a client's authorized representative, or a service provider facilitating a requested interaction. We do not infer that an introduction gives unlimited permission for marketing.

Our website infrastructure may process IP addresses, browser and device details, pages requested, timestamps, referring pages, diagnostic records, and security events. We do not ask you to submit passwords, government identifiers, payment card details, health records, or other sensitive personal information through a general inquiry form. Arrange an approved secure channel and appropriate agreement before sharing sensitive project data.

We use relevant information to answer requests; assess and scope projects; deliver agreed services; coordinate reviews and support; manage contracts, invoices, and payments; protect systems and investigate misuse; maintain necessary records; and meet legal obligations. We will provide an appropriate notice and obtain consent where required before materially incompatible new uses.

Cookies, local storage, pixels, and similar technologies can support functionality, preferences, measurement, or advertising. Necessary technologies support requested functions and security. Where prior consent is required, optional technologies will not activate until that consent is obtained.

Choices and privacy signals

You may manage optional technologies through your browser controls; disabling necessary storage can affect requested functions. Where applicable law requires it, we honor recognized opt-out preference signals such as Global Privacy Control for covered sale, sharing, or targeted advertising.

Where we send marketing emails, you may unsubscribe using the message link or by contacting contact@wintagen.com. We may keep limited suppression records to honor that choice. Necessary service, transaction, security, and legal messages may continue. Marketing consent, where needed, is separate from acceptance of service terms.

We disclose relevant information to providers performing authorized functions such as hosting, infrastructure, email, scheduling, customer management, support, payment processing, accounting, and professional advice. Access is limited to the work required and subject to appropriate obligations. A provider's role may differ by service; payment networks and professional advisers may have independent legal responsibilities.

Client projects and corporate events

We may share information with a client's authorized project participants as needed to carry out the engagement, with your direction or consent, or when reasonably necessary to comply with law, enforce rights, or protect people and systems. In a merger, financing, acquisition, or sale of assets, relevant information may be disclosed under appropriate protections; we will give any notice required by law. We do not treat routine portfolio ownership as permission for unrelated disclosure.

We do not sell personal information, share it for cross-context behavioral advertising, or use it for targeted advertising, as those terms are defined by applicable law.

We do not submit client confidential information or personal information to AI services except as authorized by the applicable agreement and privacy obligations. We do not use automated decisions that produce legal or similarly significant effects.

We maintain safeguards appropriate to the nature of the information and risks, and take steps to restrict access to authorized personnel and providers. No system or transmission is completely secure. If a security incident requires notice, we will notify affected parties or authorities as required.

We retain personal information only as needed for the purposes described, including necessary contract administration, accounting, legal compliance, dispute resolution, and security. Retention decisions consider the relationship, information sensitivity, applicable requirements, and whether the purpose can be met with less information. We delete or de-identify information when no longer needed, subject to legitimate holds and required records.

Backups and service data

Deleted information may remain in protected backups until scheduled expiry and is not used for ordinary business purposes. Client-controlled information is returned or deleted according to the applicable agreement and legal requirements. A deletion request does not automatically require removal of records that applicable law permits or requires us to retain; we explain relevant limitations where required.

Contact contact@wintagen.com to ask about your information or exercise rights available under applicable law. Describe your request and the relationship involved. We verify identity and authority using proportionate information and avoid collecting unnecessary identification. Authorized agents may need evidence of permission and identity verification where permitted. We respond within the deadline applicable to the request and explain permitted extensions or refusals.

Available rights

Depending on your location, our role, and the law's applicability, rights may include confirmation of processing; access; correction; deletion; a portable copy; restriction; objection; withdrawal of consent; and opt-outs from certain sale, sharing, targeted advertising, or qualifying profiling. Withdrawal does not undo lawful processing before withdrawal. We do not unlawfully discriminate for exercising privacy rights. Some exceptions may apply to security, legal duties, others' rights, and client-controlled information.

Appeals and complaints

If an applicable law provides an appeal, send it to contact@wintagen.com with the original request reference. We will explain our decision and available regulator complaint options within the applicable period. You may complain to the relevant supervisory or enforcement authority. This Policy does not reduce nonwaivable rights or condition their exercise on accepting arbitration or waiving claims.

Where applicable privacy law covers Wintagen and your information, the rights and request procedures above apply. Where required, we will provide any additional notices at collection rather than relying only on this general Policy.

Where relevant law applies, processing has an identified legal basis: requested contractual steps or performance, legal obligations, consent, or an identified legitimate interest balanced against your rights. Contact us to exercise applicable rights, withdraw consent, or request information about safeguards. You may complain to your local data protection authority.

Information may be processed in locations with different privacy protections. Where required, transfers use an appropriate legal mechanism and safeguards, such as an applicable adequacy determination or approved contractual measures, with supplementary measures when needed. Use of the website alone is not treated as blanket consent to restricted transfers.

The company website and client services are intended for adult business users and are not directed to children under 13. We do not knowingly collect personal information from children under 13 through these channels. If you believe a child supplied information, contact contact@wintagen.com so we can investigate and take required action.

We publish an updated Policy with a revised effective date when practices change. For material changes, we provide additional notice or request consent where required. Changes do not retroactively authorize incompatible uses. Questions and requests: Wintagen, contact@wintagen.com.