Privacy Policy

  1. General

We recognize that your privacy is very important, and we take it seriously. This Privacy Policy describes our policies and procedures governing the collection and processing (i.e., access, use, disclosure, and transfer) of your personal data when you use the website and any related software (collectively, the “Website”). We will not collect and process your personal data in any manner that is incompatible with this Privacy Policy.

  1. Your consent

By using the Website and the Services, you consent to our processing of your personal data for the specified, explicit, and legitimate purposes described in this Privacy Policy.

We will seek your express consent prior to: (1) using your personal data for any purposes that are not explicitly indicated in this Privacy Policy; (2) providing you with any marketing communication; (3) transferring your personal data to third parties that are not indicated in this Privacy Policy; or (4) significantly amending this Privacy Policy.

Consent as follows: “The Terms of the Privacy Policy are subject to change by Windward Fund with or without notice in order to stay in compliance with any and all applicable local, state and federal laws.”

  1. Responsible authority

The authority responsible for the collection and processing of your personal data is Windward Fund., having a principal place of business at 1201 Connecticut Ave NW #7, Washington, DC 20036.


  1. Types of personal data we collect

Throughout this Privacy Policy, the term “personal data” refers to all information that allows us to identify you as a natural person. We collect the following types of personal data:

Registration data. When you sign up on the Website, we collect the following personal data:

  • Your email address;
  • Your name 
  • Your zip code

Contact data. If you contact us by email or any other available means, we will collect your email address and other available contact details, the content of your email messages, and our responses.

Log files. The log files collected by us may include some of your personal data, such as your Internet Protocol (“IP”) address, and non-personal data, such as your web request, browser type, referring/exit pages and URLs, number of clicks, landing pages, and pages viewed. Log files are automatically reported by your browser each time you access the Website. When you use the Website, our servers will automatically record the information that your web browser sends.

Contact data. We will use your contact data to respond to your questions, messages, and requests.

If we would like to use your personal data for any purposes that are not mentioned in this Privacy Policy, we will seek your explicit consent in advance for that particular purpose.

  1. Marketing communication

We will use your contact information to send you marketing messages (e.g., advertisement, brochures, and updates on our new products and Services). If you do not want to receive such messages, at any time, you may opt out by following the instructions in the message (e.g., by clicking on the “unsubscribe” link) or by contacting us directly at

Please note that we may send you information about our new Services that are closely related to the Services already used by you without obtaining your prior consent.

  1. Disclosure of personal data to third parties

If it is necessary to ensure the provision of the Services, proper functioning of the Website, and performance of a contract concluded with you, we may share your personal data with third parties that provide us with technical support or provide services on behalf of us.

If we do this, we will put reasonable efforts to ensure that such third parties guarantee an adequate level of protection of your personal data that is compatible with this Privacy Policy. Please note that some of the third parties indicated in this Privacy policy may be located outside of the jurisdiction in which you reside.

  1. Your rights

You can exercise your rights regarding your personal data collected through the Website by contacting us by email at

The right to access, rectification, portability, and erasure. Upon our request, we will provide you with information on if and what personal data is stored by us. In order to fulfill this request, you will need you to provide us with an identifying piece of data so we can locate the personal data on our system. You will then have the right to request us to access the personal data, rectify/change it, transfer it to you, or request us to erase it from our systems.

The right to object and restrict processing. You have the right to object or restrict processing of your personal data, such as request us to stop sending emails to you. Please note that, in this case, we may not be able to provide you with certain services.

The right of withdraw consent. If you provide us with your express consent, you can revoke it from us at any time.

The right to launch a complaint. If you would like to launch a complaint about the way in which your personal data is handled, please contact us first. After you contact us, we will send you a confirmation that we have received your complaint. Afterwards, we will investigate your complaint and provide you with our response within a reasonable timeframe but no later than 2 weeks. If you are a resident of the European Union and you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

  1. Children’s privacy

Protecting the privacy of children is especially important to us. We do not knowingly collect or solicit personal data from anyone under the age of 18 or knowingly allow such persons to register on the Website. If we become aware that we have collected personal data from a person under the age of 18 without verification of parental consent, we will immediately remove such personal data. The parent or guardian of a person under the age of 18 who has provided us with personal data without obtaining parental or guardian consent in advance may contact us and request us to destroy or de-identify the personal data.

  1. How we protect personal data

We use commercially reasonable physical, managerial, and technical safeguards (e.g., limited access to personal data and secured networks) to preserve the integrity and security of your personal data. We cannot, however, ensure or warrant the security of any personal data you share with us or guarantee that your personal data may not be accessed, disclosed, altered, or destroyed by a breach that occurs outside of our reasonable control. In the event that personal data is compromised as a result of a breach of security, we will take the necessary steps to mitigate the breach as required by the applicable law.

  1. Links to other websites

This Privacy Policy applies to the Website only. We are not responsible for the practices employed by websites linked to or from the Website, nor the information or content contained therein. Please remember that when you use a link to go from the Website to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on the Website, is subject to that website’s own rules and policies.

  1. Cookies

What are cookies?

Cookies are text files containing small amounts of information which are sent to your browser and stored on your computer, mobile phone or other device when you visit a website. The cookies send information back to the originating website or another website that recognizes that cookie. Cookies can be permanent (these are known as persistent cookies) where they remain on your computer until you delete them, or temporary (these are known as session cookies) where they last only until you close your browser. Cookies can also be first-party cookies which are set by the website which is being visited, or third-party cookies which are set by a website other than the one being visited.

What cookies do we use?

These cookies can be used to limit the number of times you see an advertisement as well as help manage the delivery of advertising campaigns. Advertising cookies are also used to customize the advertising across the Website and make it more relevant to you. Advertising cookies are placed by third parties such as advertisers, ad platforms and their agents, and can be permanent or temporary cookies. In short, they are related to advertising services and your experience. 

Third-party cookies. On some pages of the Website, we may have content from third-party services, such as YouTube or Facebook. Please note that we do not control any cookies which are used by these services and you should check the relevant third-party website for more information about these.

How to manage & remove cookies?

If you would like to restrict, block or remove cookies, you can do this through contacting us at

  1. Google Analytics

The Website uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics is used to analyze how the Services are used, diagnose service or technical problems and monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns. Google Analytics also uses cookies and the information generated by the cookie regarding your use of the Website (including your IP address) is transmitted to a Google server in the U.S. and stored. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on Website activity, and providing other services relating to Website activity and Internet usage. Google may also pass this information on to third parties in so far as this is required by law or if third parties process the data on Google’s behalf. Google will not under any circumstances associate your IP address with any other data held by Google.

You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of the Website. You can also prevent the data generated by cookies about your use of the Website (including your IP address) being passed to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link:

By using the Website you agree to the processing of data about you by Google in the manner described above and for the aforementioned purpose. You can find more detailed information on Google’s Privacy Policy.

  1. Contact Information

If you have any questions about our practices or this Privacy Policy, please contact us and specify the keyword “Privacy” in the subject line.

Our other contact details are:

1201 Connecticut Ave NW #7, Washington, DC 20036.