In addition to the disclosures set out in Winton’s Privacy Notice, please refer to the below notice in relation to the collection and processing of your personal data pursuant to one or more agreements between Winton Capital Management and each firm whose employees, or affiliate entities’ employees, contribute trade ideas. You should read this notice together with Winton’s Privacy Notice in its entirety.

  • Winton will use trade ideas that you submit through the WINS idea portal or any other communications platform (such portal or platform being the “Idea Portal”, and each trade idea being a “Trade Idea”) in connection with its investment management and other activities, including the operation of its investment strategy or strategies.
  • In connection with such activities, Winton will collect certain personal data from or about you, which likely but not necessarily could include your name, email address, phone number, years of experience, areas of knowledge and expertise, trading style and coverage (“Biographical Information”).
  • When you submit a Trade Idea, Winton may use your Biographical Information to determine how and whether it is used within the data set that forms part of Winton’s operation of the relevant investment strategy. For example, a greater number of years of experience in trading a particular instrument in a particular sector could, but will not necessarily, result in a greater weighting for that Trade Idea within the broader data set.
  • Winton may also use your Biographical Information for other reasons including, among other purposes, the preparation and disclosure of hypothetical performance rankings or for operational reasons such as determining your access to Winton controlled communication and information services like Bloomberg terminals.
  • Where required, we may share your Biographical Information with legal or regulatory authorities to comply with applicable laws and regulations, and to service providers that perform software support functions for the Idea Portal and related infrastructure.
  • After you have submitted a Trade Idea, your Biographical Information will be kept for legal and compliance reasons.
  • In particular, please refer to the sections of Winton’s Privacy Notice entitled “Lawful basis”, “Sharing personal information”, “Security”, “International transfers” and “Retaining your personal information”.

If you have any questions or complaints regarding the processing of your Biographical Information, please refer to the contact described in the Winton Privacy Notice. For further information please contact your regular point of contact at Winton.