Privacy Policy

WIN Human Resource Solutions (“WIN HR Solutions,” “we,” “us,” or “our”), a brand owned and operated by Waylus Management LTD, a company registered in Cyprus, is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, disclose, and protect information that identifies or can be used to identify you (“Personal Data”) when you use our website, services, programs, and content (collectively, “Services”).

We adhere to the principles of transparency, fairness, and lawfulness in all our data processing activities, particularly in compliance with the General Data Protection Regulation (GDPR) (EU) 2016/679.

1. Who We Are

WIN Human Resource Solutions is a provider of leadership training programs, executive coaching, HR consulting, and related services.

Legal Entity Name: Waylus Management LTD

Registered Address: 3 esperidon street. Mouttagiaka, 4527 limassol, Cyprus

Contact Email: [email protected]

2. Types of Personal Data We Collect

We may collect and process various types of Personal Data, including:

Identity Data: Name, title, job title, company name, professional affiliations.
Contact Data: Email address, postal address, telephone number.
Professional Data: Information related to your professional background, career interests, leadership experience, skills, qualifications, and performance, often provided during program enrollment or assessments.
Technical Data: Internet Protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Services.
Usage Data: Information about how you use our website, products, and services, including navigation paths, service access times, and interaction with content.
Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.
Payment Data: Details about payments to and from you for our Services (though we do not store full payment card details, which are processed by third-party payment processors).
I-Driven Tool Data : Data generated through your interaction with our AI tools, such as performance feedback, learning progress, communication patterns, and other insights relevant to your leadership development, which may contain personal elements.

3. How We Collect Your Personal Data

We collect Personal Data through various methods:

Direct Interactions: You provide data directly when you:
- Inquire about or purchase our Services.
- Register for an account or program.
- Participate in workshops, coaching, or assessments.
- Subscribe to our newsletter or other marketing communications.
- Provide feedback or contact us via email, phone, or online forms.
Automated Technologies or Interactions: As you interact with our website, we may automatically collect Technical Data and Usage Data using cookies, server logs, and other similar technologies.
Third Parties or Publicly Available Sources: We may receive Personal Data about you from third parties, such as analytics providers, payment processors, or publicly available sources like LinkedIn, where consistent with applicable data protection laws.

4. How We Use Your Personal Data

We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:

Purpose of Processing	Type of Data Used	Legal Basis for Processing
To provide and manage our Services	Identity, Contact, Professional, Payment, Usage, AI-Driven Tool Data	Performance of a contract with you or to take steps at your request before entering into a contract.
To personalize your experience	Professional, Usage, AI-Driven Tool Data	Legitimate interests (to improve our services and tailor content to you).
For billing and payment processing	Identity, Contact, Payment	Performance of a contract with you.
To communicate with you	Identity, Contact, Marketing & Communications	Performance of a contract, legitimate interests (responding to inquiries), or your consent.
For marketing and promotional purposes	Identity, Contact, Marketing & Communications, Usage	Your consent (for direct marketing) or legitimate interests (to promote relevant services to existing clients).
To improve our website and Services	Technical, Usage, AI-Driven Tool Data (anonymized/aggregated where possible)	Legitimate interests (to understand how our services are used and improve them).
For internal record keeping and administration	Identity, Contact, Payment, Usage	Legitimate interests (for business administration and compliance).
To comply with legal obligations	All relevant data	Compliance with a legal obligation.
For security and fraud prevention	Technical, Usage, Identity	Legitimate interests (to protect our business and users) or compliance with legal obligations.

5. Sharing Your Personal Data

We may share your Personal Data with the following categories of recipients:

Service Providers: Third-party vendors and service providers who perform services on our behalf, such as payment processing, website hosting, data analytics, email delivery, and customer support. These providers are bound by contractual obligations to keep your Personal Data confidential and use it only for the purposes for which we disclose it to them.
Business Partners: With your explicit consent, we may share relevant data with trusted business partners for collaborative programs or joint marketing efforts.
Professional Advisors: Lawyers, bankers, auditors, and insurers who provide professional services.
Law Enforcement & Legal Compliance: When required by law, court order, or governmental regulation, or if we believe it’s necessary to protect our rights, property, or safety, or the rights, property, or safety of others.
Corporate Transactions: In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

We will not sell or rent your Personal Data to third parties for their marketing purposes without your explicit consent.

6. International Transfers of Personal Data

As a company based in Cyprus (EU), we primarily process data within the European Economic Area (EEA). However, some of our service providers or partners may be located outside the EEA. When we transfer your Personal Data outside the EEA, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

Transferring Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
TUsing specific contracts approved by the European Commission that give Personal Data the same protection it has in Europe (Standard Contractual Clauses).
TWhere our providers are based in the US, if they are part of the EU-US Data Privacy Framework or similar certified mechanisms ensuring adequate protection.

7. Data Security

We have implemented appropriate technical and organizational security measures to prevent your Personal Data from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have procedures in place to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

We will retain your Personal Data only for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. Your Data Protection Rights (GDPR)

Under GDPR, you have the following rights regarding your Personal Data:

The right to be informed: About how your personal data is being used.
The right of access: To your personal data.
The right to rectification: To have inaccurate personal data corrected.
The right to erasure (the “right to be forgotten”): To have your personal data deleted in certain circumstances.
The right to restrict processing: To limit how we use your personal data.
The right to data portability: To obtain your personal data in a machine-readable format and transmit it to another controller.
The right to object: To certain types of processing, including direct marketing.
Rights in relation to automated decision-making and profiling: To object to decisions made solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
The right to withdraw consent: Where we are relying on consent to process your Personal Data, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us using the details provided in Section 11. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights).

You also have the right to lodge a complaint with the Cypriot Commissioner for Personal Data Protection or a relevant supervisory authority in your country of residence within the EU/EEA.

10. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyze site usage, and support our marketing efforts. Our Cookie Policy, available on our Website, provides detailed information about the types of cookies we use, their purpose, and how you can manage your preferences.

11. Links to Other Websites

Our Services may contain links to third-party websites that are not operated by us. This Privacy Policy applies only to our Services. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party websites or services. We encourage you to review the privacy policies of any third-party sites you visit.

12. Children’s Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect Personal Data from children. If we become aware that we have collected Personal Data from a child without parental consent, we will take steps to remove that information from our servers.

13. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Effective Date” at the top. We encourage you to review this Privacy Policy periodically for any changes.

14. Contact Us

If you have any questions about this Privacy Policy or our data protection practices, please contact us:

WIN Human Resource Solutions (Owned by Waylus Management LTD)
Email: [email protected]
Address: 3 Esperidon Str., Moutagiaka, 4527 Limassol, Cyprus
Website: winhrsolutions.com

Please consult with a legal professional to customize this Privacy Policy to your specific business needs and legal requirements, ensuring full compliance with GDPR and other applicable data protection laws.