We intend only to process personal information fairly and transparently as required by data protection law
including the UK General Data Protection Regulation (UK GDPR). In particular, before obtaining information
from you (including through use of cookies) we intend to alert you to this Notice, let you know how we intend
to process the information (including through use of cookies) and that we'll only process the information as
permitted by law. The UK GDPR also defines certain 'special categories' of personal information that's
considered more sensitive. These categories require a higher level of protection, as explained below.
Of course, you may browse parts of this Website without providing any information about yourself and
without accepting cookies. In that case, it's unlikely we'll possess and process any information relating to
you.
We'll start this Notice by setting out the conditions we must satisfy before processing your data. However,
you may wish to start with the table at clause 4, which summarises what we intend to collect, or the table at
clause 8.5, which summarises our use of cookies. The Notice also explains some of the security measures
we take to protect your personal information, and tells you certain things we will or won't do. You should read
this Notice in conjunction with the Terms and Conditions.
Sometimes, when you take a new service or product from us, or discuss taking a new service or product but
decide against it, we might wish to provide you with further information about similar services or products by
email or other written electronic communication. In that situation, we will always give you the opportunity to
refuse to receive that further information and if you change your mind please let us know. We'll endeavour to
remind you of your right to opt-out on each occasion that we provide such information.
1. Identity and contact details
1.1 Registered number: 08713086
1.2 Registered office: St Stephen's House, Arthur Road, Windsor, SL4 1RU
1.3 info@winshaw.com
2. When we're allowed to collect information from you
We will only collect personal information relating to you if one of the following conditions has been
satisfied:
2.1 You have clearly told us that you are content for us to collect that information for the particular
purpose or purposes that we will have specified.
2.2 The processing is necessary for the performance of a contract that we have with you.
2.3 The processing is necessary so that we can comply with the law.
2.4 The processing is necessary to protect someone's life.
2.5 The processing is necessary for the performance of a task that's in the public interest.
2.6 The processing is necessary for our or another's legitimate interests - but in this case, we'll
balance those interests against your interests.
3. How to consent
3.1 If we need your consent to collect and use certain information, we'll provide you with the
opportunity to tell us that you're happy to provide that information at the point of collecting it.
3.2 If at any point in time you change your mind and decide that you want to withdraw your consent,
please let us know and we'll endeavour to stop processing your information in the specified
manner, or we'll delete your data if there is no continuing reason for possessing it.
3.3 If you don't consent to a particular bit of processing, we'll endeavour to ensure that the Website
and our service continue to operate without the need for that information.
4. Information we expect to collect from you
4.1 We envisage collecting the following types of information from you:
Information
type
Purpose and related details Justification
Email • We collect this to Send quotes • We'll ask for your consent
4.2 We may collect personal information about you from a number of sources, including the following:
a. From you when you agree to take a service or product from us, in which case this may
include your contact details, date of birth, how you will pay for the product or service
and your bank details.
b. From you when you contact us with an enquiry or in response to a communication from
us, in which case, this may tell us something about how you use our services.
c. As you interact with this Website, we may automatically collect technical information
about your equipment, browsing actions and patterns (such as your internet protocol
(IP) address, your login data, browser type and version, time zone setting and location,
browser plug-in types and versions, operating system and platform, and other
technology on the devices you use to access this Website). We may collect this
personal information by using cookies and other similar technologies.
d. From documents that are available to the public, such as the electoral register.
e. From third parties to whom you have provided information with your consent to pass it
on to other organisations or persons - when we receive such information we will let you
know as soon as is reasonably practicable.
4.3 If you refuse to provide information requested, then if that information is necessary for a service
we provide to you we may need to stop providing that service.
4.4 If at any point you think we've invited you to provide information without explaining why, feel free to
object and ask for our reasons.
5. Using your personal information
5.1 Data protection, privacy and security are important to us, and we shall only use your personal
information for specified purposes and shall not keep such personal information longer than is
necessary to fulfil these purposes. The following are examples of such purposes. We have also
indicated below which UK GDPR justification applies, however it will depend on the circumstances
of each case.
a. To help us to identify you when you contact us. This will normally be necessary for the
performance of our contract.
b. To help us to identify accounts, services and/or products which you could have from us
or selected partners from time to time. We may do this by automatic means using a
scoring system, which uses the personal information you've provided and/or any
information we hold about you and personal information from third party agencies
(including credit reference agencies). We will only use your information for this purpose
if you agree to it.
c. To help us to administer and to contact you about improved administration of any
accounts, services and products we have provided before, do provide now or will or
may provide in the future. This will often be necessary, but sometimes the
improvements will not be necessary in which case we will ask whether you agree.
d. To allow us to carry out marketing analysis and customer profiling (including with
transactional information), conduct research, including creating statistical and testing
information. This will sometimes require that you consent, but will sometimes be exempt
as market research.
e. To help to prevent and detect fraud or loss. This will only be done in certain
circumstances when we consider it necessary or the law requires it.
f. To allow us to contact you by written electronic means (such as email, text or
multimedia messages) about products and services offered by us where:
i. these products are similar to those you have already purchased from us,
ii. you were given the opportunity to opt out of being contacted by us at the
time your personal information was originally collected by us and at the
time of our subsequent communications with you, and
iii. you have not opted out of us contacting you.
g. To allow us to contact you in any way (including mail, email, telephone, visit, text or
multimedia messages) about products and services offered by us and selected partners
where you have expressly consented to us doing so.
h. We may monitor and record communications with you (including phone conversations
and emails) for quality assurance and compliance.
i. Before doing that, we will always tell you of our intentions and of the
specific purpose in making the recording. Sometimes such recordings will
be necessary to comply with the law. Alternatively, sometimes the recording
will be necessary for our legitimate interest, but in that case we'll only
record the call if our interest outweighs yours. This will depend on all the
circumstances, in particular the importance of the information and whether
we can obtain the information another way that's less intrusive.
ii. If we think the recording would be useful for us but that it's not necessary
for our legitimate interest, we'll ask whether you consent to the recording,
and will provide an option for you to tell us that you consent. In those
situations, if you don't consent, the call will either automatically end or will
not be recorded.
i. When it's required by law, we'll check your details with fraud prevention agencies. If you
provide false or inaccurate information and we suspect fraud, we intend to record this.
5.2 We will not disclose your personal information to any third party except in accordance with this
Notice, and then only in one of the following circumstances:
a. They will be processing the data on our behalf as a data processor (where we'll be the
data controller). In that situation, we'll always have a contract with the data processor as
set out in the UK GDPR. This contract provides significant restrictions as to how the
data processor operates so that you can be confident your data is protected to the same
degree as provided in this Notice.
b. Sometimes it might be necessary to share data with another data controller. Before
doing that we'll always tell you. Note that if we receive information about you from a
third party, then as soon as reasonably practicable afterwards we'll let you know; that's
required by the UK GDPR.
c. Alternatively, sometimes we might consider it to be in your interest to send your
information to a third party. If that's the case, we'll always ask whether you agree before
sending.
5.3 Where you give us personal information on behalf of someone else, you confirm that you have
provided them with the information set out in this Notice and that they have not objected to such
use of their personal information.
5.4 We may allow other people and organisations to use personal information we hold about you in
the following circumstances:
a. If we, or substantially all of our assets, are acquired or are in the process of being
acquired by a third party, in which case personal information held by us, about our
customers, will be one of the transferred assets.
b. If we have been legitimately asked to provide information for legal or regulatory
purposes or as part of legal proceedings or prospective legal proceedings.
c. We may employ companies and individuals to perform functions on our behalf and we
may disclose your personal information to these parties for the purposes set out above,
for example, for fulfilling orders, delivering packages, sending postal mail and email,
removing repetitive information from customer lists, analysing data, providing marketing
assistance, providing search results and links (including paid listings and links) and
providing customer service. From time to time, these other people and organisations to
whom we may pass your personal information may be outside the European Economic
Area. We will take all steps reasonably necessary to ensure that your personal
information is treated securely and in accordance with this Notice and the UK GDPR.
We require all third-party service providers processing your personal information for us
(as our data processor) to respect the security of your personal data and to treat it in
accordance with the law. We do not allow them to use your personal data for their own
purposes and only permit them to process your personal data for specified purposes
and in accordance with our instructions.
6. Protecting information
6.1 We have strict security measures to protect personal information.
6.2 We work to protect the security of your information during transmission by using Secure Sockets
Layer (SSL) software to encrypt information you input.
6.3 We maintain physical, electronic and procedural safeguards in connection with the collection,
storage and disclosure of personally identifiable customer information. Our security procedures
mean that we may occasionally request proof of identity before we disclose personal information
to you.
6.4 It is important for you to protect against unauthorised access to your password and to your
computer. Be sure to sign off when you finish using a shared computer.
7. The internet
7.1 If you communicate with us using the internet, we may occasionally email you about our services
and products. When you first give us personal information through the Website, we will normally
give you the opportunity to say whether you would prefer that we don't contact you by email for
that purpose. You can also always send us an email (at the address set out below) at any time if
you change your mind.
7.2 Please remember that communications over the internet, such as emails and webmails
(messages sent through a website), are not secure unless they have been encrypted. Your
communications may go through a number of countries before they are delivered - this is the
nature of the internet. We cannot accept responsibility for any unauthorised access or loss of
personal information that is beyond our control.
8. Cookies and other internet tracking technology
8.1 When we provide services, we want to make them easy, useful and reliable. This sometimes
involves placing small amounts of information on your computer, which is sent back to us at a later
time. These are called 'cookies'. These cookies are listed in the table at clause 8.5. Some
websites don't use cookies but use related technology for gaining information about website users
such as JavaScript, web beacons (also known as action tags or single-pixel gifs), and other
technologies to measure the effectiveness of their ads and to personalise advertising content.
Multiple cookies may be found in a single file depending on which browser you use.
8.2 Where applicable, this section of the Notice also relates to that technology but the term 'cookie' is
used throughout.
8.3 Some of these cookies are essential to services you've requested from us, whereas others are
used to improve services for you, for example through:
a. Letting you navigate between pages efficiently
b. Enabling a service to recognise your computer so you don't have to give the same
information during one task
c. Recognising that you have already given a username and password so you don't need
to enter it for every web page requested
d. Measuring how many people are using services, so they can be made easier to use and
that there is enough capacity to ensure they are fast
8.4 To learn more about cookies, you may wish to visit: www.allaboutcookies.org,
www.youronlinechoices.eu or www.google.com/policies/technologies/cookies/
8.5 This Website uses, or allows use of, the following cookies:
Cookie name Cookie qualities Consent
needed
Web visit • Visitor numbers
• Category 3 - functionality
• First party: we're placing the cookie
• Persistent cookie, expiry: In the future
Yes
8.6 The distinctions referred to in the above table are as follows:
a. First party versus third party cookies - we set first party cookies ourselves; third party
cookies are set by other entities via our Website.
b. Session versus persistent cookies - session cookies only persist for the duration of that
visit; persistent cookies last for longer.
c. Categories 1-4 found in the ICC UK Cookie guide, as explained below. Category 1
cookies don't require your consent, though we must still tell you about those cookies.
Categories 2-4 do require your specific and informed consent.
Category 1 Strictly
necessary
These cookies are essential in order to enable you to move around the
website and use its features, such as accessing secure areas of the website.
Without these cookies services you have asked for, like shopping baskets or
e-billing, cannot be provided.
We include in this category cookies that are used only for electronic
communication. (The ICC doesn't refer to these cookies, but the law is the
same.)
Category 2 Performance These cookies collect information about how visitors use a website, for
instance which pages visitors go to most often, and if they get error
messages from web pages. This information is only used to improve how a
website works.
Category 3 Functionality These cookies allow the website to remember choices you make (such as
your user name, language or the region you are in) and provide enhanced,
more personal features. For instance, a website may be able to provide you
with local weather reports or traffic news by storing in a cookie the region in
which you are currently located. These cookies can also be used to
remember changes you have made to text size, fonts and other parts of web
pages that you can customise. They may also be used to provide services
you have asked for such as a live chat session.
Category 4 Targeting and
advertising
These cookies are used to deliver adverts more relevant to you and your
interests. They are also used to limit the number of times you see an
advertisement as well as help measure the effectiveness of the advertising
campaign. They are usually placed by advertising networks with the website
operator’s permission. They remember that you have visited a website and
this information is shared with other organisations such as advertisers. Quite
often targeting or advertising cookies will be linked to site functionality
provided by the other organisation.
8.7 As with any other information we may collect from you, we'll work to protect the security of your
information during transmission by using Secure Sockets Layer (SSL) software to encrypt
information you input.
8.8 The Website may include links to third-party websites. We do not provide any personally
identifiable customer personal information to these third-party websites unless permitted in
accordance with this privacy notice, however as to cookies please see above clause 8.
8.9 We exclude all liability for loss that you may incur when using these third-party websites.
9. Your legal rights
9.1 Under certain circumstances, you have rights under data protection laws in relation to your
personal information.
9.2 You have the right to:
a. Request access to your personal information (commonly known as a 'data subject
access request'). This enables you to receive a copy of the personal information we
hold about you and to check that we are lawfully processing it.
b. Request correction of the personal information that we hold about you. This enables you
to have any incomplete or inaccurate information we hold about you corrected, though
we may need to verify the accuracy of the new information you provide to us.
c. Request erasure of your personal information. This enables you to ask us to delete or
remove personal information where there is no good reason for us continuing to process
it. You also have the right to ask us to delete or remove your personal information where
you have successfully exercised your right to object to processing (see below), where
we may have processed your information unlawfully or where we're required to erase
your personal information to comply with the law. Note, however, that we may not
always be able to comply with your request for erasure for specific legal reasons which
will be notified to you, if applicable, at the time of your request.
d. Object to processing of your personal information where we're relying on a legitimate
interest (or those of a third party) and there is something about your particular situation
which makes you want to object to processing on this ground as you feel it impacts on
your fundamental rights and freedoms. You also have the right to object where we're
processing your personal information for direct marketing purposes. In some cases, we
may demonstrate that we have compelling legitimate grounds to process your
information which override your rights and freedoms.
e. Request restriction of processing of your personal information. This enables you to ask
us to suspend the processing of your personal information in the following situations:
i. if you want us to establish the information's accuracy;
ii. where our use of the information is unlawful but you do not want us to
erase it;
iii. where you need us to hold the information even if we no longer require it as
you need it to establish, exercise or defend legal claims; or
iv. you have objected to our use of your information but we need to verify
whether we have overriding legitimate grounds to use it.
f. Request the transfer of your personal information to you or to a third party. We will
provide to you, or a third party you have chosen, your personal information in a
structured, commonly used, machine-readable format. Note that this right only applies
to automated information which you initially provided consent for us to use or where we
used the information to perform a contract with you.
g. Withdraw consent at any time where we're relying on consent to process your personal
information. However, this will not affect the lawfulness of any processing carried out
before you withdraw your consent. If you withdraw your consent, we may not be able to
provide certain products or services to you. We will advise you if this is the case at the
time you withdraw your consent.
9.3 You will not have to pay a fee to access your personal information (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive
or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
9.4 We may need to request specific information from you to help us confirm your identity and ensure
your right to access your personal information (or to exercise any of your other rights). This is a
security measure to ensure that personal information 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.
9.5 We try to respond to all legitimate requests within one month. Occasionally it may take us longer
than a month if your request is particularly complex or you have made a number of requests. In
this case, we will notify you and keep you updated.
10.Further information
10.1 If you would like any more information or you have any comments about this Notice, or if your wish
to exercise any of your legal rights, please either write to us at Data Protection Manager, Winshaw
Outsourcing Limited, St Stephen's House, Arthur Road, Windsor, SL4 1RU, or email us at
info@winshaw.com.
10.2 Please note that we may have to amend this Notice on occasion, for example if we change the
cookies that we use. If we do that, we will publish the amended version on the Website. In that
situation we will endeavour to alert you to the change, but it's also your responsibility to check
regularly to determine whether this Notice has changed.
10.3 You can ask us for a copy of this Notice by writing to the above address or by emailing us at
info@winshaw.com. This Notice applies to personal information we hold about individuals. It does
not apply to information we hold about companies and other organisations.
