1. Who We Are
This Privacy Policy explains how Vincitore Group S.A., a corporation organized under the laws of the Republic of Panama, registered with the Public Registry of Panama, Mercantile Section, under Folio No. 155788320, with Registered Agent Gerli & Co., Global Bank Tower, 18th Floor, Suite 1801, 50th Street, Panama City, Republic of Panama ("Vincitore Group," "we," "us"), collects, uses, and protects personal data when you visit vincitoregroup.site (the "Site") or contact us through it.
Vincitore Group S.A. is the data controller for personal data collected via the Site.
2. What We Collect
Through the Site's contact form, we collect the information you voluntarily provide, which may include your name, email address, and the content of your message. The Site does not use cookies, analytics, or other tracking technology beyond what is strictly necessary for its technical operation, and does not build profiles of visitors.
Personal data collected in connection with an actual trading relationship (counterparty due diligence, identity verification via our KYC provider, sanctions/PEP screening, source-of-funds documentation) is governed separately by our AML/CFT Compliance Program and is not the subject of this website Privacy Policy, which covers only data collected through the Site itself.
3. How We Use Your Data
We use the information you submit through the contact form solely to respond to your inquiry and to correspond with you. We do not sell your personal data to third parties.
4. Legal Basis
We process your data on the basis of your consent (by voluntarily submitting the contact form) and our legitimate interest in responding to inquiries directed to the Company.
5. Data Sharing
We do not share personal data submitted through the Site with third parties, except: (a) service providers who host or operate the Site on our behalf, under confidentiality obligations; or (b) where required by applicable law or a valid request from a competent authority.
6. Data Retention
Personal data submitted through the contact form is retained only for as long as necessary to address your inquiry, after which it is deleted or anonymized, unless a longer retention period is required by applicable law. Corporate and compliance records related to the Company's business activity (as distinct from website contact-form data) are retained in accordance with Panamanian record-keeping requirements (Law 52 of 2016), generally for a minimum of five years.
7. Your Rights
If applicable to you under Panama's Law No. 81 of 2019 on Personal Data Protection, or another data protection law that applies to you, you may have the right to: access the personal data we hold about you; request correction of inaccurate data; request deletion of your data; object to or restrict certain processing; and, where applicable, request portability of your data. To exercise any of these rights, contact us using the details in Section 11 below.
8. International Transfers
Because the Site may be accessed from outside Panama, your data may be processed in Panama or in the location of our Site hosting/service providers. We take reasonable steps to ensure such transfers are protected consistent with this Policy.
9. Security
We use reasonable technical and organizational measures to protect personal data submitted through the Site against unauthorized access, loss, or misuse. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
10. Children's Privacy
The Site is not directed at, and we do not knowingly collect personal data from, individuals under the age of 18.
11. Contact
For questions about this Privacy Policy or to exercise your data protection rights, please contact us through the contact form on the Site.
12. Changes to This Policy
We may update this Privacy Policy from time to time. The "Last updated" date above reflects the most recent revision.