Definitions and interpretation
collectively all information that you submit to Wincura Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;
Data Protection Laws
any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;
the General Data Protection Regulation (EU) 2016/679;
Wincura Limited, we or us
Wincura Limited, a company incorporated in England and Wales with registered number 06135118 whose registered office is at Innovation Centre Medway, Maidstone Road, Chatham, Kent. ME5 9FD
User or you
any third party that accesses the Website and is not either (i) employed by Wincura Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Wincura Limited and accessing the Website in connection with the provision of such services; and
the website that you are currently using, www.wincura.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.
- a. the singular includes the plural and vice versa;
- c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
- d. “including” is understood to mean “including without limitation”;
- e. reference to any statutory provision includes any modification or amendment of it;
4. For purposes of the applicable Data Protection Laws, Wincura Limited is the “data controller”. This means that Wincura Limited determines the purposes for which, and the manner in which, your Data is processed.
5. We may collect the following Data, which includes personal Data, from you:
- a. name;
- b. contact Information such as email addresses and telephone numbers;
How we collect Data
6. We collect Data in the following ways:
- a. data is given to us by you;
- b. data is received from other sources; and
- c. data is collected automatically.
Data that is given to us by you
7. Wincura Limited will collect your Data in a number of ways, for example:
- a. when you contact us through the Website, by telephone, post, e-mail or through any other means;
- b. when you register with us and set up an account to receive our products/services;
- c. when you make payments to us, through this Website or otherwise;
- d. when you elect to receive marketing communications from us;
- e. when you use our services;
Data that is received from third parties
8.Wincura Limited will receive Data about you from the following third parties:
- a. Sub-contractors
- b. Clients
- c. Customers
- d. Lead generating and marketing agents.
Data that is received from publicly available third parties’ sources
9. We will receive Data about you from the following publicly available third-party sources:
- a. Companies house
- b. Voter’s registry
Data that is collected automatically
10. To the extent that you access the Website, we will collect your Data automatically, for example:
- a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
Our use of Data
11. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:
- a. internal record keeping;
- b. improvement of our products / services;
- c. transmission by email of marketing materials that may be of interest to you;
12. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
13. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:
- a. soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
- b. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
- c. if you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
14. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Who we share Data with
15. We may share your Data with the following groups of people for the following reasons:
- a. our employees, agents and/or professional advisors – to provide bespoke service offering to our clients and customers;
- b. relevant authorities – to comply with GDPR regulations and audit process;
Keeping Data secure
16. We will use technical and organizational measures to safeguard your Data, for example:
- a. access to your account is controlled by a password and a user name that is unique to you.
- b. we store your Data on secure servers.
17. Technical and organizational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorized access to your Data, please let us know immediately by contacting us via this e-mail address: email@example.com.
18. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
20. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
21. You have the following rights in relation to your Data:
- a. Right to access – the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
- b. Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.
- c. Right to erase – the right to request that we delete or remove your Data from our systems.
- d. Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.
- e. Right to data portability – the right to request that we move, copy or transfer your Data.
- f. Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.
22. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: firstname.lastname@example.org
23. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/
24. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Links to other websites
Changes of business ownership and control
27. We may also disclose Data to a prospective purchaser of our business or any part of it.
28. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
31. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
32. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
Data Privacy Officer, Wincura Limited.
24 July 2020
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