Privacy policy

Last Updated on 28th August 2022

This Privacy Policy describes how Numinous Holdings Ltd. (“Winda”) and its affiliates (“we,” “us”), process personal information in relation to your use of the Winda Platform.


Undefined terms in this Privacy Policy have the same definition as in our



2.1 Information needed to use the Winda Platform.

We collect personal information about you when you use the Winda Platform. Without it, we may not be able to provide all services requested. This information includes:

Contact Information, Account, and Profile Information such as your first name, last name, phone number, email address, and date of birth, some of which will depend on the features you use.

Identity Verification and Payment Information. Passport or other travel document or Card information for the purpose of Bank account or payment account information.

2.2 Information you choose to give us.

You can choose to provide us with additional personal information. This information may include:

Information About Others payment instrument belonging to another person or information about a co-traveler. By providing us with personal information about others, you certify that you have permission to provide that information to Winda for the purposes described in this Privacy Policy, have shared the Winda Privacy Policy with them, and they have read and understood that it applies to them.

Other Information. Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with our customer care team and other Customers or Service Provider, or share your activity with us. This may include health or dietary information if you choose to share it with us.

2.3 Information Automatically Collected by Using the Winda Platform and our Payment Services.

When you use the Winda Platform and Payment Services, we automatically collect personal information. This information may include:

Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS depending on your device settings. We may also collect this information when you’re not using the website if you enable this through your settings or device permissions.

Usage Information. Such as the pages or content you view, searches for Listings, bookings you have made, and other actions on the Winda Platform.

Log Data and Device Information. Such as details about how you’ve used the Winda Platform (including if you clicked on links to third-party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Winda Platform. We may collect this information even if you haven’t created a Winda account or logged in.

We use cookies, mobile identifiers, tracking URLs, log data, and similar technologies to help provide, protect, and improve the Winda Platform. We use these technologies for a number of purposes, such as:

to enable you to use and access the Winda Platform and the Payment Services

to enable, facilitate and streamline the functioning of and your access to the Winda Platform

to enable, facilitate and streamline the functioning of and your access to the Winda Platform

to better understand how you navigate through and interact with the Winda Platform and to improve the Winda Platform

to serve you tailored advertising (such as on the Winda Platform, emails, and on third-party websites)

to show you content (e.g., advertisements) that is more relevant to you

to monitor and analyze the performance, operation, and effectiveness of the Winda Platform and Winda advertisements

to enforce legal agreements that govern the use of the Winda Platform

for fraud detection and prevention, trust and safety, and investigations

for purposes of our own customer support, analytics, research, product development, and regulatory compliance.

Third parties

Winda permits third parties to collect the information described above through our Service and discloses such information to third parties for business purposes as described in this Privacy Policy, including but not limited to providing advertising on our Service and elsewhere based on users’ online activities over time and across different sites, services, and devices.

Third parties place technologies such as pixels and SDKs on the Winda Platform. These technologies (1) help us analyze how you use the Winda Platform, such as by noting the third-party services from which you arrived, (2) market and advertise Winda services to you on the Winda Platform and third-party websites, (3) help us detect or prevent fraud or conduct risk assessments, and (4) collect information about your activities on the Winda Platform, other sites, and/or the ads you have clicked on. For example, to help us better understand how people use the Winda Platform, we work with a number of analytics partners, including Google Analytics.

Third parties may also use such tracking technologies to collect or receive information from the Winda Platform and elsewhere and use that information to serve ads that they believe are most likely to be of interest to you and measure the effectiveness of their ads both on the Winda Platform and on other websites and online services. Targeting and advertising cookies we use may include Google, and other advertising networks and services we use from time to time. See here for information on how Google manages data in its ad products. For more information about targeting and advertising cookies and how you can opt-out, you can visit the Network Advertising Initiative’s opt-out page, the Digital Advertising Alliance’s opt-out page, or http://youronlinechoices.eu. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page. To the extent advertising technology is integrated into the Winda Platform and you opt-out of tailored advertising, you may still receive advertising content. In that case, the advertising content will just not be tailored to your interests. Also, we do not control any of these opt-out links and are not responsible for the availability or accuracy of these mechanisms. Users can opt out of the collection and use of information for ad targeting by updating their Facebook account ad settings and by contacting info@winda.guide with a description of your request and validation information.

Third-Party Social Plugins: The Winda Platform may use social plugins provided and operated by third parties, such as Facebook’s Like Button. As a result of this, you may send to the third party the information that you are viewing on a certain part of the Winda Platform. If you are not logged into your account with the third party, then the third party may not know your identity. If you are logged in to your account with the third party, then the third party may be able to link information or actions about your interactions with the Winda Platform to your account with them. Please refer to the third party’s privacy policies to learn more about its data practices.

Your Choices: Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. While you may disable cookies through your browser settings, the Winda Platform currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to a lack of standardization regarding how that signal should be interpreted.

Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address, and other related transaction details.

2.4 Personal Information We Collect from Third Parties.

We collect personal information from other sources, such as:

Third-Party Services. If you link, connect, or log in to the Winda Platform with a third-party service (e.g. Google, Facebook), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.

Background Information. For Customers to the extent permitted by applicable laws, we may obtain the local version of police, background, or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.

Enterprise Product Invitations and Account Management. Organizations that use our Enterprise products may submit personal information to facilitate account management and invitations to use enterprise products.

Referrals and co-travelers. If you are invited to the Winda Platform, such as a co-traveler on a trip, the person who invited you can submit personal information about you such as your email address or other contact information.

Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data, or information to help detect fraud and safety issues from third-party service providers and/or partners and combine it with information we have about you. For example, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Winda Platform, or about your activities and interactions from our partners. We may receive health information, including but not limited to, health information related to contagious diseases.


3.1 Provide, Improve, and Develop the Winda Platform. Such as to:

enable you to access the Winda Platform and make and receive payments,

enable you to communicate with other Customers, Service Providers

process your request,

perform analytics, debug and conduct research,

provide customer service, training,

send you messages, updates, security alerts, and account notifications,

if you provide us with your contacts’ information, such as your friends or co-travelers, we may process this information: (i) to facilitate your referral invitations, (ii) to share your trip details and facilitate trip planning, (iii) for fraud detection and prevention, and (iv) to facilitate your requests or for any other purpose you authorize,

personalize and customize your activity based on your interactions with the Winda Platform, your search and booking history, your profile information and preferences, and other content you submit, and

enable your use of our enterprise products

3.2 Create and Maintain a Trusted and Safer Environment. Including to:

detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,

study and combat discrimination,

conduct security investigations and risk assessments,

verify or authenticate information provided by you,

conduct checks against databases and other information sources, including background or police checks,

comply with our legal obligations, protect the health and well-being of our Customers, Service Providers, their employees, and members of the public,

resolve disputes with our Customers and Service Providers, including sharing information about disputes related to your role as a Customer or Service Provider,

enforce our agreements with third parties,

comply with the law, respond to legal requests, prevent harm, and protect our rights

enforce our Terms and other policies (Payments Policy) and,

in connection with the activities above, we may conduct profiling based on your interactions with the Winda Platform, your profile information and other content you submit to Winda, and information obtained from third parties. In limited cases, automated processes, which analyze your account and activities on the Winda platform as well as information in relation to activities on and off the Winda platform that can be associated with you, could restrict or suspend access to the Winda Platform if such processes detect activity that may pose a safety or other risk to Winda, our community, or third parties. If you would like to challenge decisions based on automated processes, please contact us via the Contact Information section below.

3.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing. For example to:

send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,

personalize, measure, and improve our advertising,

administer referral programs, rewards, surveys, contests, or other promotional activities or events sponsored or managed by Winda or its third-party partners,

analyze characteristics and preferences to send you promotional messages, marketing, advertising, and other information that we think might be of interest to you, and

invite you to events and relevant opportunities.

3.4 Provide Payment services. Personal information is used to enable, or authorize third parties to use, Payment Services such as to:

detect and prevent money laundering, fraud, abuse, and security incidents,

conduct security investigations and risk assessments,

comply with legal obligations (such as anti-money laundering regulations),

enforce the Payment Terms and other payment policies,

with your consent, send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences, and

provide and improve Payment Services.


4.1 Sharing With Your Consent or at Your Direction.

Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application or website to access your Winda account or participating in promotional activities by Winda partners or third parties. Where permissible under applicable law, we may use certain information about you such as your email address, de-identify it, and share it with social media platforms to generate leads, drive traffic to Winda, or otherwise promote our products and services.

4.2 Information You Publish in Profiles, Listings, and other Public Information.

You can make certain information publicly visible to others, such as:

Your public profile page, which includes your profile photo, first name (or initials where applicable), description, and city.

Listing pages that include information such as the Accommodation or Activities approximate or precise location description, transport, calendar availability, profile photo, aggregated demand information (like page views over a period of time), and additional information you choose to share.

Reviews, ratings, and other public feedback.

Content in a community or discussion forum, blog, or social media post.

We may display parts of your public profile and other Content you make available to the public like Listing details on third-party sites, platforms, and apps. Information you share publicly on the Winda Platform may be indexed through third-party search engines. In some cases, you may opt out of this feature in your account settings.


You can exercise any of the rights described in this section consistent with applicable law. We may ask you to verify your identity and request before taking further action on your request.

5.1 Managing Your Information.

You can access and update some of your personal information through your Account settings. If you connected your Winda Account to a third-party service, like Facebook or Google, you can change your settings and unlink from that service in your Account settings. You are responsible for keeping your personal information up to date.

5.2 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).

5.3 Data Erasure.

In some jurisdictions, you can request that your personal information be deleted. Please note that if you request deletion of your personal information, or if your account is suspended, terminated, or voluntarily closed:

We may retain your personal information as necessary for our legitimate business interests, such as the prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend a Winda Account for fraud or safety reasons, we may retain information from that Winda Account to prevent that Customer from opening a new Winda Account in the future.

We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Winda and Winda Payments may keep information for tax, legal reporting, and auditing obligations.

Information you have shared with others (e.g., Reviews, forum postings) will continue to be publicly visible on Winda, even after your Winda Account is canceled. However, attribution of such information to you will be removed. Some copies of your information (e.g., log records) will remain in our database but are disassociated from personal identifiers.

Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.


While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration.


We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Winda Platform will be subject to the revised Privacy Policy.