Effective as of 2022-03-14
- Important information and who we are
At Winnrs Circle Ltd ("we", "us", or "our") we are committed to protecting and respecting your privacy and Personal Data in compliance with our relevant obligations under the EU General Data Protection Regulation ("GDPR"), UK General Data Protection Regulation ("UK GDPR") and Data Protection Act 2018.
The individuals from which we may gather and use data can include:
- Suppliers Business contacts
- Employees/Staff Members
- Third parties connected to your customers, and
- Any other people that the organisation has a relationship with or may need to contact.
- Who is Your Data Controller
Winnrs Circle Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR or UK GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us on email at firstname.lastname@example.org or sent in a letter to, 16 Great Queen Street, Covent Garden, London, WC2B 5AH United Kingdom.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
- Processing Data on Behalf of a Controller and Processors’ responsibility to you
In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as "Processors"). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:
- Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR and UK GDPR (see section B.5 below for more information on those bases);
- Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
- Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
- Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
- Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights;
- Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and UK GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
- Maintain a record of all categories of processing activities carried out on behalf of a Controller;
- Cooperate, on request, with the supervisory authority in the performance of its tasks;
- Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
- Notify the Controller without undue delay after becoming aware of a Personal Data Breach;
B. LEGAL BASIS FOR DATA COLLECTION
"Personal Data" means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
- Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
- Contact Data: This is data relating to your phone number, postal addresses, email addresses, phone numbers.
- Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
- Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
- Financial Data: These are your banking details e.g. your billing address, account number and sort code.
- Transactional Data: This is information of details and records of all payments you have made for our services or products.
We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
- The Legal Basis for Collecting That Data
There are a number of justifiable reasons under the GDPR and UK GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
- “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
- “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service. This may include verifying your identity, taking payments, providing customer service, and communicating with you.
- “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
- “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.
C. HOW WE USE YOUR PERSONAL DATA
- Our Uses
We will only use your Personal Data when the law allows us to. Set out below are the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis.
Examples provided are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.
- Marketing and Content Updates
You will receive marketing and new content communications from us if you have and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.
- Change of Purpose
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
D. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
- What Control Do I Have Over Winnrs Circle Ltd’s Use Of My Personal Data?
You have certain rights under existing data protection laws, including the right (following a written request) to access a copy of your personal data that we are processing. In accordance with GDPR and UK GDPR, you will have the following rights:
- “Right to access”: the right to request certain information about, access to and copies of the personal data about you that we are holding (see below for further information);
- “Right to rectification”: the right to have your personal data rectified if it is inaccurate or incomplete.
In certain circumstances, in accordance with GDPR and UK GDPR, you will also have the following rights:
- “Right to erasure”: the right to withdraw your consent to our processing of the data (if the legal basis for processing is based on your consent) and the right to request that we delete or erase your personal data from our systems (however, this will not apply if we are required to hold on to the information for compliance with any legal obligation or if we require the information to establish or defend any legal claim);
- “Right to restriction of use of your information”: the right to stop us from using your personal data or limit the way in which we can use it;
- “Right to data portability”: the right to request that we return any information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another company, where technically feasible; and
- “Right to object”: the right to object to our use of your personal data including where we use it for our legitimate interests or for marketing purposes.
You may delete your account by contacting email@example.com – this will remove your account page from our systems and our related software.
We do not guarantee the ability to delete all stored data. If you would like us to delete/correct personally identifiable data, let us know and we will action your request as soon as practicable.
Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.
You can access information associated with your account by logging into your account you created with us.
- How Does Winnrs Circle Ltd Protect Customers’ Personal Data?
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including adopting industry-standard security protocols and encryption for our databases. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Winnrs Circle Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
- Opting Out Of Marketing Promotions
You can ask us to stop sending you marketing messages at any time by using the unsubscribe link in our marketing materials, or by contacting firstname.lastname@example.org.
Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
- How to Request your Data and the Process for Obtaining it
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
E. YOUR DATA AND THIRD PARTIES
- Will We Share Your Data With Third Parties?
We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors (only when necessary and with your consent) or affiliates (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions).
We may also share Personal Data with interested parties in the event that Winnrs Circle Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
- Third-Party Links
F. HOW LONG WILL WE RETAIN YOUR DATA FOR?
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
G. AGE LIMIT FOR OUR USERS
You must not use Winnrs Circle Ltd unless you are aged 16 or older. If you are under 16 and you access Winnrs Circle Ltd by lying about your age, you must immediately stop using Winnrs Circle Ltd.
This website is not intended for children and we do not knowingly collect data relating to children.
H. NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY
All uses of the word “including” mean “including but not limited to” and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).
Our staff are not authorised to contract on behalf of Winnrs Circle Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from Winnrs Circle Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Winnrs circle Ltd rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Winnrs Circle Ltd legal department.