Privacy Policy

Scope
What we collect
What we do not collect
How we use information
Michigan video and reading privacy
Who we share with
Email and text messages
Cookies and similar technology
How long we keep information
How information is protected
Your choices and rights
Children
Changes
Contact

1. Scope

This Privacy Policy explains what Winning Ways LLC, a Michigan limited liability company, ("Winning Ways FX," "we," "us") collects when you use winningwaysfx.com, our free lesson library, the member area, and the Pro Academy, and what we do with it.

Winning Ways FX operates through Winning Ways LLC, a Michigan limited liability company. See Section 1 of the Terms of Service for details.

2. What we collect

Information you give us

Free signup: your name and email address.
Paid membership: your email address, the name on your Zelle transfer, and the fact and date of payment.
Support and correspondence: anything you write to us.
Referrals: if you were referred, the referral code used.

Information collected automatically

A first-party cookie holding a referral code, if you arrived through a referral link (60 days).
A short-lived browser session marker after you log in, so you are not asked for your password on every page. It clears when you close the tab.
Standard web server logs kept by our host.
Cloudflare Turnstile collects limited technical signals on the signup form to tell humans from bots.

3. What we do not collect

We do not collect or store card numbers, bank account numbers, or banking credentials. Payment happens entirely inside your own banking app through Zelle; we only see that a transfer arrived and the name attached to it.

We do not collect Social Security numbers, government ID numbers, brokerage credentials, or the contents of your trading accounts. Never send us your broker login or account password. We will never ask for them.

4. How we use information

To create and maintain your membership and issue your password;
To confirm payments and manage access;
To send the educational emails you signed up for;
To answer your questions;
To credit referral rewards;
To protect the Service against bots, fraud, and abuse;
To meet legal and tax obligations.

We do not sell your personal information, and we do not share it for cross-context behavioral advertising.

5. Michigan video and reading privacy

This section reflects the stricter of the two states' rules and applies to all members, wherever you live.

The Michigan Preservation of Personal Privacy Act (Mich. Comp. Laws § 445.1711 et seq.) restricts disclosing records that identify a customer as having purchased, rented, or borrowed video recordings, sound recordings, or written material. Our lesson library plausibly falls within that protection, and it is stricter than anything Florida requires.

Accordingly, as a matter of policy for every member regardless of state:

We will not disclose to any third party a record identifying you as having viewed, purchased, or accessed any specific lesson, course, or video, except with your written consent, as required by law or valid legal process, or as reasonably necessary to enforce payment for that specific material.
We will not sell, rent, or license viewing records for marketing.
Where we can operate without recording which individual member viewed which individual lesson, we prefer that.

6. Who we share with

We share only what is necessary, and only with:

Google — our member list, referral log, and free signup list are stored in Google Sheets and processed by Google Apps Script.
Cloudflare — Turnstile bot protection on the signup form.
YouTube (Google) — free lessons are hosted there; YouTube may set its own cookies when you watch. Watching on YouTube is governed by Google's privacy policy, not ours.
Our web host — Hosting.com.
Professional advisers — accountant or attorney, in confidence.
Legal — where required by law, subpoena, or to protect rights and safety.

If the business is ever sold or reorganized, member information may transfer as part of that transaction; we will give notice and the successor will remain bound by this policy or a comparable one.

We do not sell personal information to anyone.

7. Email and text messages

If you join the free list or become a member, we may email you educational content and account notices. Every marketing email includes an unsubscribe link, honored promptly, consistent with the CAN-SPAM Act. Account and payment notices are not marketing and may still be sent.

Text messages. We do not currently send marketing text messages. If that ever changes, we will obtain prior express written consent before sending any marketing text, will not use an automated system to select or dial numbers without that consent, and will honor STOP immediately — reflecting the stricter standard of the Florida Telephone Solicitation Act (Fla. Stat. § 501.059) as amended, together with the federal Telephone Consumer Protection Act (47 U.S.C. § 227) and Michigan law. Consent to texts will never be a condition of membership.

8. Cookies and similar technology

We use a small number of first-party cookies and browser storage items, all functional rather than advertising:

Referral cookie — remembers who referred you (60 days).
Session marker — keeps you logged in within a browser tab; cleared when the tab closes.
Cloudflare Turnstile — sets what it needs to run the bot check.

We do not use advertising or cross-site tracking cookies. You can clear or block cookies in your browser, though the member login will not persist without the session marker.

9. How long we keep information

Free list: until you unsubscribe or ask us to delete it.
Member records: for the life of your membership and afterward only as long as needed for tax, accounting, and legal purposes (generally [7] years for payment records).
Referral records: as long as needed to administer and document rewards.
Correspondence: generally two years.

10. How information is protected

Access to our Google Sheets is limited to accounts that need it. Passwords for the member area are individual, and access is revoked by marking a member inactive.

An honest limitation. The member area uses a password check that runs in your browser. It keeps ordinary visitors out, but a technically sophisticated person could view member content without a password. We would rather tell you this plainly than imply protection we do not have. Please do not send us sensitive personal or financial information; no method of transmission or storage is completely secure.

11. Your choices and rights

You may, at any time:

Unsubscribe from marketing email;
Ask what we hold about you;
Ask us to correct it;
Ask us to delete it, subject to records we must keep for tax or legal reasons;
Close your account.

Email winningwaystrading@gmail.com and we will respond within 30 days. We will not discriminate against you for exercising these rights.

The Florida Digital Bill of Rights (Fla. Stat. § 501.701 et seq.) applies by its terms only to very large controllers, and we do not meet that threshold. We extend the access, correction, and deletion rights above to all users voluntarily.

12. Children

The Service is for adults 18 and older. We do not knowingly collect information from anyone under 18. If you believe a minor has given us information, email winningwaystrading@gmail.com and we will delete it.

We do not send email to any address on the Michigan Children's Protection Registry (Mich. Comp. Laws § 752.1061 et seq.), and our content is not directed to minors.

13. Changes

We may update this policy. Material changes will be posted with a new date and, if we have your email, sent to you before taking effect.

14. Contact

Winning Ways FX
Winning Ways LLC
Email: winningwaystrading@gmail.com

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