Website Privacy Policy (GDPR)

Introduction

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or the UK Information Commissioner’s Office (ICO) in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the UK) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

About us

When we say “we” or “us” in this privacy policy, we mean Winchburgh Developments Limited.

Personal information we collect about you

We may collect and use the following personal information about you:

  • your name and contact information, including email address and telephone number and sometimes company details where you contact us on behalf of a company
  • your gender information, if you choose to give this to us
  • your personal or professional interests
  • your professional and / or personal online presence, e.g. LinkedIn or Facebook profile
  • information about how you use our website, IT, communication and other systems
  • your responses to surveys, competitions and promotions

We may also collect and use personal information about you in the following circumstances:

  • where you have signed up to attend an event organised by us, we may collect certain allergy and dietary information to ensure we can cater to your requirements, as well as information about your preferences should you wish to be invited to future events
  • where you apply for a job or internship with us, we may collect information provided by you in the application form, or information contained in your CV or covering letter, as well as information obtained throughout the application and interview process about your experience and skills
  • if you are a journalist, blogger or social media influencer we may process your name and professional contact details obtained from the Gorkana database or other publicly available sources

This personal information is required to provide services, either to you directly or to our clients. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.

How your personal information is collected

We collect most of this personal information directly from you whether by in person, by telephone, text or email and/or via our website. However, we may also collect information:

  • from publicly accessible sources, e.g. LinkedIn or Companies House;
  • directly from a third party, e.g. we collect journalist and media contact information from the Gorkana database
  • from cookies on our website—for more information on our use of cookies, please see our cookies policy
  • if you are applying for a job or internship, we may collect information about you from your third party references
  • via our IT systems, e.g. door entry systems and reception logs, and automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems

How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

  • to comply with our legal and regulatory obligations;
  • for the performance of our contract with you or to take steps at your request before entering into a contract;
  • for our legitimate interests or those of a third party; or
  • where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The list below explains what we use (process) your personal information for and our legal basis for doing so:

  • Events: If you are interested in attending one of our events that we are responsible for organising (whether in our own name or on behalf of one of our clients), we collect your information for our legitimate interests (i.e. to be able to organise the run events as part of our service delivery). We will seek your consent to use any health, disability, dietary or allergy information which we may need to use in this context.
  • Job and Internship Applications: We collect personal information in the context of processing job and internship application as necessary to comply with our legal and regulatory obligations to ensure that our application processes comply with applicable laws, and also for our legitimate interests to ensure that candidates are appropriately qualified and suitable for working with us. Such processing may also be necessary for us to take steps before entering to an employment contract with a candidate.
  • Business Contacts: We use personal contact details of business contacts (including journalists, bloggers, social media influencers and others who we work with in the context of delivering marketing services on behalf of our clients) for our own legitimate interests of running our business, and also for the legitimate interests of our clients to benefit from the services that we provide to them.
  • Website: The technical information gathered from the use of our website (including through our use of cookies) which may include personal data, is used for our legitimate interest of ensuring that our website is functioning properly and to help us make business decisions about the information to be provided on our website.
  • Marketing: Where personal information is used for marketing purposes, we will ask for your consent to do this.

Promotional communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our services, events, news and promotions.

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

  • contacting us at the details above
  • using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

We may ask you to confirm or update your marketing preferences in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal information with

We routinely share personal information with:

  • third parties we use to help deliver our services, e.g. IT service providers such as hosting service providers, marketing and messaging platform providers and suppliers used to help us organise and run events
  • our professional services advisers (such as a lawyers, accountants and auditors)

Google Analytics – we work with Google Analytics to automatically collect information including: IP address; MAC (Media Access Control) address; unique identifier or other persistent or non-persistent device identifier; device software platform and firmware, mobile phone carrier and geo location data to help us understand your use of our website such as how often you return, what parts of the website you visit, how you use the website and how long you spend on the website. This third party provider is prohibited from using our data for any other purposes. Go to http://www.google.com/analytics/terms/us.html to read the Google Analytics Privacy Policy. We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

How long your personal information will be kept

We will keep your personal information for as long as is necessary:

  • to respond to any questions, complaints or claims made by you or on your behalf
  • to show that we treated you fairly
  • to keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. Further details on this are available from our DPO. When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Transferring your personal information out of the EEA

It is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g. with our service providers located outside the EEA (such as the US).

These transfers are subject to special rules under European and UK data protection law.

These non-EEA countries do not have the same data protection laws as the UK and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to ensure that any US-based suppliers are certified under the EU-US Privacy Shield scheme, or alternatively to use standard data protection contract clauses that have been approved by the European Commission.

If you would like further information on international transfers of data, please contact our DPO.

Cookies and Tracking

Use of cookies

A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website. We use cookies on our website to:

  • recognise you whenever you visit our website (this speeds up your access to the website as you do not have to log in each time);
  • obtain information about your preferences, online movements and use of the internet;
  • carry out research and statistical analysis to help improve our content; and
  • make your online experience more efficient and enjoyable.

In most cases we will need your consent in order to use cookies on this website. The exception is where the cookie is essential in order for us to provide you with a service you have requested.

If you visit our website when your browser is set to accept cookies, we will interpret this as an indication that you consent to our use of cookies and other similar technologies as described in this website cookie policy. If you change your mind in the future about letting us use cookies, you can modify the settings of your browser to reject cookies or disable cookies completely.

Description of cookies

The table below provides some information on the cookies which we use on our website:

Cookie Name What it does Why is it used How long it lasts
BizoID LinkedIn Ad analytics Stores classification / taxonomy and browser identifier information 6 Months
BizoUserMatchHistory LinkedIn Ad analytics Stores classification / taxonomy and browser identifier information 6 Months
BizoNetworkPartnerIndex LinkedIn Ad analytics Stores classification / taxonomy and browser identifier information 6 Months
BizoData LinkedIn Ad analytics Stores classification / taxonomy and browser identifier information 6 Months
BizoCustomSegments LinkedIn Ad analytics Stores classification / taxonomy and browser identifier information 6 Months
bcookie LinkedIn Ad analytics Browser ID cookie 1 Year
UserMatchHistory LinkedIn Ad analytics Used for LinkedIn Ad analytics 6 Months
UserPixelRotationList LinkedIn Ad analytics Used for LinkedIn Ad analytics 6 Months
RT LinkedIn Ad analytics Used for LinkedIn Ad analytics 1 Day
lidc LinkedIn Ad analytics Used for routing 1 Day
lang LinkedIn Ad analytics Used for storing language information Session cookie (deletes after user closes the website)
wfvt_ WordPress fence security Cookie set by the Wordfence Security WordPress plugin which notes information about your general geographic location. Session cookie (deletes after user closes the website)
wordfence_verifiedHuman WordPress fence security Cookie set by the Wordfence Security WordPress plugin to protect the site against malicious attacks. Session cookie (deletes after user closes the website)
_ga Google Analytics Used to distinguish users. 2 Years
_gid Google Analytics Used to distinguish users. 1 Day

 

How to turn off cookies

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of our website. For further information about cookies and how to disable them please go to the ICO’s webpage on cookies:  https://ico.org.uk/for-the-public/online/cookies/.

Your Privacy Rights

Data protection laws give you a number of rights as set out below. If you would like to exercise any of your rights, please contact our DPO in writing.

  • Access: you may request access to a copy of your personal information.
  • Withdraw Consent: where our processing of your personal information is based on your consent, you can withdraw your consent at any time.
  • Rectification: you may ask us to rectify any inaccurate information we hold about you.
  • Erasure: you may ask us to delete the personal information we hold about you, where there is no reason for us to continue to hold your information.
  • Portability: you may ask us to provide you with the personal information that we hold about you in a structured, commonly used, machine readable format, or you can ask us to send your information in this format to another controller.
  • Object: you may object to our processing of your personal information.
  • Restriction: you can ask us to restrict the personal information we use about you where you have asked for it to be erased or where you have objected to our use of it.

If you are not happy with the way in which we process your personal information, or the way in which we handle any request by you to exercise your privacy rights, you may make a complaint to the ICO by visiting its website at https://ico.org.uk/concerns/ or on 0303 123 1113.

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this privacy policy

This privacy notice was last updated on April 30 2019.

We may change this privacy notice from time to time—when we do we will inform you via an announcement on our website.

 

 

© 2019 Winchburgh Developments Limited | Privacy Policy