Privacy Policy
This privacy policy gives you information about how we collect and use your personal data through your use of this website, including
any data you may provide when you register with us, sign up to receive marketing from us and/or contract with us.
This website is not intended for children and we do not knowingly collect data relating to children.
If you have any questions about this privacy policy, including any requests to exercise your legal rights as set out in the “Legal Rights”
section 8 below, please contact us using the information set out in the “Contact details” section 9 below.
Certain sections of this privacy policy may not be applicable to you depending on how you provide your personal data to us or interact with us.
The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Technical Data includes internet protocol (IP) address, any login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
Profile Data includes any username and password, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you interact with us and use our website.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
You are not required to provide us with any personal data regarding your medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs, or other categories of personal data defined as sensitive or special categories of data under applicable data protection laws ("Sensitive Information") in order to use our website or interact with us.
We do not knowingly solicit or collect, and you should not provide to us, any such Sensitive Information, whether through the website or through any other means.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
create any account on our website;
request marketing to be sent to you;
give us feedback or contact us;
interact with us or our website;
attend our events; and
interact with our social media pages and adverts, online chats or community forums, surveys, webinars or blogs.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. More about this in the “Cookies and related technologies” section below.
Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
Technical Data is collected from the following parties:
analytics providers;
advertising networks; and
search information providers.
Contact Data is collected from providers of technical and delivery services.
Identity and Contact Data is collected from data brokers or aggregators.
Identity and Contact Data is collected from publicly available sources such as Companies House and the Electoral Register.
How we use your personal data
Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We process your personal data through electronic and manual means relying on one or more of the following legal bases:
Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
Direct marketing
You will receive marketing communications from us if you have requested information from us or contracted with us and you have not opted out of receiving the marketing.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which services and offers may be of interest to you so that we can then send you relevant marketing communications.
Third-party marketing
We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.
Opting out of marketing
You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us using the information set out in the “Contact details” section 9 below.
If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations, updates to our legal terms and conditions checking that your contact details are correct etc.
Cookies and related technologies.
We and our third-party service providers use "cookies, " "web beacons, " and other automated tracking technology to monitor and collect information regarding your interaction with our website and services. "Cookies" include commonly used pieces of information in the form of small files that are placed on an individual's computer or mobile device to allow us to recognize your computer or mobile device. "Web beacons" (also known as "single–pixel" or "clear" GIFs) include electronic images imbedded in a website, application or email used to pass information from your computer to us.
We may use cookies, web beacons, and other tracking technologies that expire once you close your web browser or that persist and stay on your computer until you delete them.
Disabling/Enabling Cookies: We require your consent for cookies (unless they are strictly necessary) and tracking technologies that we use on our website. Most browsers will allow you to erase some or all of the cookies from your computer or mobile device, block acceptance of cookies, or receive a warning before a cookie is stored. You may also be able to refuse certain web beacons by adjusting the settings on your browser or email software. Please refer to your browser or email software instructions or help screen to learn more about these functions. To find out more about these technologies, visit: https://www.allaboutcookies.org/manage-cookies/
Rejecting or disabling certain website and/or services content or functionality may delay or prevent us from providing certain services to you.
We use the following types of cookies on our website:
Strictly necessary cookies. These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our website. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.
Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.
Disclosures of your personal data
We may share your personal data with the following third parties:
Service Providers. We share personal data with third parties who process personal data on our behalf. For example, we use third parties to: (a) to host and maintain our website and services; and (b) provide product development and support services; and (c) provide marketing services to assist us in our business. We require that these third parties agree to use the personal data we share with them only to perform their obligations to us and to treat all personal data they receive from us in compliance with this privacy policy.
Government authorities and law enforcement officials. We share personal data with these bodies if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Merger or Acquisitions: We may share personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets and our advisers. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers 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.
International transfers
We may transfer your personal data to service providers outside of the UK that carry out certain functions on our behalf. This may involve transferring personal data to countries which have laws that do not provide the same level of data protection as UK law. Where personal data is transferred out of the UK to service providers in a country that is not deemed by the UK to provide an adequate level of protection for personal data, we use: (a) specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement or the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers ; or (b) a vendor's Processor Binding Corporate Rules. To obtain a copy of these contractual safeguards, please contact us using the information set out in the “Contact details” section 9 below.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
Your legal rights
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see "Opting out of marketing” section for details of how to object to receiving direct marketing communications).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data 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.
Withdraw consent at any time where we are relying on consent to process your personal data. 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios
If you want us to establish the data's accuracy;
Where our use of the data is unlawful but you do not want us to erase it;
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us using the information set out in the “Contact details” section 9 below.
No fee usually required
You will not have to pay a fee to access your personal data (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 could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
Contact details
Wing Capital HoldCo Limited (and its group company affiliate(s)) is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
Email address: privacy@dotheyhaveaccess.com
Postal address: 152 High Street, Amersham, England, HP7 0EG, UK
Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.