Privacy Policy

1.1 Wingcom (“us”, “we”, or “our”) operate the wingcom.co.uk website (the “Service”).

1.2 All your Personal Data shall be held and used in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR”) and national laws implementing GDPR and any legislation that replaces it in whole or in part and any other legislation relating to the protection of personal data. If you want to know more about what Personal Data we collect and hold, or want to exercise any of your rights as set out below, please email us.

1.3 Wingcom are the controller of your Personal Data for the purposes of GDPR.

1.4 We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.

2.1 While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but not be limited to:

• Title.
• Last Name.
• Email Address.
• Phone Number.
• Cookies and Usage Data.

2.2 You may provide us with information in a number of ways:

• By supplying us with the information listed above, on an individual basis or by registering to use our Service;
• By corresponding with us via email, in which case we may retain the content of your email messages together with your email address and our responses.

2.3 We may use your Personal Data to contact you with, marketing or promotional material and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications, by clicking ‘Unsubscribe’ on any email marketing material or by contacting Wingcom direct.

3.1 We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

4.1 We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

However, if you do not accept cookies, you may not be able to use some portions of our Service. Examples of Cookies we use;

• Session Cookies;
• Preference Cookies;
• Security Cookies.

5.1 Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

6.1 Wingcom uses the collected data for various purposes:

• To provide and maintain our Service.
• To inform you about our products.
• Changes to our Service.
• To provide customer support.
• To gather valuable information so that we can improve our Service.
• To monitor the usage of our Service.

7.1 Wingcom will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

7.2 Wingcom will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

7.3 In certain circumstances, once we have deleted or anonymised your data, we may need to retain parts of it (for example, your email address), in order to comply with our obligations under GDPR or other legislation, or for fraud detection purposes.

8.1 Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your country where the data protection laws may differ than those within your area. If you are located outside the United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United Kingdom and process it there.

8.2 Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

8.3 Wingcom will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

9.1 Under certain circumstances, Wingcom may be required to disclose your Personal Data, if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

10.1 Wingcom may disclose your Personal Data in the good faith, belief, that such action is necessary to:

• To comply with a legal obligation.
• To protect and defend the rights or property of Wingcom.
• To prevent or investigate possible wrongdoing in connection with the Service.
• To protect the personal safety of users of the Service or the public.
• To protect against legal liability.

10.2 Under GDPR, the main grounds that we rely upon in order to process your Personal Data are the following:

• Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your Personal Data. We may also be obliged by law to disclose your Information to a regulatory body or law enforcement agency;
• Necessary for the purposes of legitimate interests – either we, or a third party, will need to process your Personal Data for the purposes of our (or a third party’s) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your Information protected. Our legitimate interests include responding to requests and enquiries from you or a third party, notifying of changes to our Service, optimising our website and user experience, informing you about related and relevant properties and ensuring that our operations are conducted in an appropriate and efficient manner;
• Consent – in some circumstances, we may ask for your consent to process your Personal Data in a particular way.

11.1 The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

12.1 We may employ third party companies and individuals to facilitate our Service (“Service Providers” or “Data Processors”). To provide the Service on our behalf, or to perform Service-related assistance, analysing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

13.1 We may use third-party Service Providers to monitor and analyse the use of our Service.

13.2 Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

13.3 You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

13.4 For more information on the privacy practices of Google, please visit the Google Privacy terms web page.

14.1 In order to provide certain services, we will share your Personal Data with third party service providers. We will not share your Personal Data with any third party where it is not necessary to do so, or necessary to provide a service to you. Circumstances when Personal Data may be shared include;

• Email logistics.
• Website development, where we may need to provide website FTP access to our trusted developers.

15.1 Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s website. We strongly advise you to review the Privacy Policy of every site that you visit.

We have no control over and assume no responsibility for the content or practices of any third party websites.

16.1 We may update our Policies from time to time and reserve the right to do so. You are advised to review this Privacy Policy periodically for any changes.

17.1 You may contact us by telephone, email or in writing, using the details at the top of this privacy policy. Enquiries should be directed to Keir Wingrove.

18.1 If you are unhappy about our use of your information, you are also entitled to lodge a complaint with the UK Information Commissioner’s Office using any of the below contact methods:

Telephone
0303 123 11113

Website
https://ico.org.uk/