Winton and Partners Limited respects your privacy and is committed to protecting your personal information. This privacy notice will let you know how we look after your personal information generally as well as when you visit our website and tell you about your privacy rights and how the law protects you.
This privacy notice aims to give you information on how Winton and Partners Limited collects and processes your personal data. It is intended to cover all of your rights and information required under new data laws (GDPR) that come into effect on 25th May 2018 but we may need to update the information.
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.
Who we are?
Winton and Partners Limited is the controller and responsible for your personal data (collectively referred to as “Winton and Partners” “we”, “us” or “our” in this privacy notice).
What data do we collect about you?
We collect and process a range of personal information.
We will collect your full name and contact details (such as phone number, email address and postal address) from you whenever you deal with us.
When we provide our services to you, or on your behalf, where we are required to do so by law, we will collect information relating to your identity, which will be at least one form of photographic identification (such as a passport, a driving licence or an identification card) and one form of documentation with proof of your place of residence (such as a recent utility bill).
The types of personal information we collect about you usually falls into the following categories:
- Identity and contact information from our direct interaction with clients and contacts in order to provide our services
- Financial information which may include bank account details
- Contact information from our clients and contacts in order to engage in direct marketing, keep you up to date on the services we offer and other issues that may be of interest to you
For the above purposes, a client includes any organisation or individual who is identified as a client on Winton and Partners systems (regardless of whether we charge any fees) and a contact includes any individual who is a contact of the company whether a representative of a client or a former or prospective client, any supplier, consultant, another professional adviser, intermediary or agent.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have requested from us but we will notify you if this is the case at the time.
We may need to collect information from third party sources (for example, to verify your identity). The third party is responsible for your information and its disclosure to us and you should always check that privacy notices and statements from any entity that makes available information about you.
How do we process your personal information?
The law requires us to ensure we have a lawful basis for processing your personal information. This is usually because it is necessary for:
- the performance of a contract that you enter in to with us; and/or
- our legitimate interests or those of a third party; and/or
- compliance with a legal obligation.
Sometimes, we may ask you to consent to our collection and use of certain of your personal information. Where this is the case, you can change your mind and withdraw your consent at any time by e-mailing us at email@example.com
In relation to direct marketing, you can always opt out of receiving our marketing messages ? see below.
Why do we use your personal information?
We use your personal information for the purposes listed below.
- delivering our services to our clients and fulfilling our contractual obligations in this regard
- undertaking client checks and assessing whether to do business with a client or contact
- managing activities related to your services
- fulfilling and responding to requests from you or made on your behalf
- tailoring, developing, improving our services
- communications with our clients and contacts including:
– marketing and promotional messages
– providing information relating to matters that may be of interest to clients and contacts
– notifications of events and new services
- for our internal business management and operational purposes
- ensuring content from our web site is presented to you in the most effective manner for you.
Who do we share your personal information with?
Your data may be accessed by and shared with all employees of Winton and Partners Limited.
We may release your information to third parties if we are required to do so by law (e.g. by a court order) or in connection with the prevention of fraud or other crime.
How can you opt out of direct marketing?
You can ask us to stop sending you marketing messages at any time by:
- following the opt-out links on any marketing message sent to you
- contacting us at any time at the details or below or via firstname.lastname@example.org
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the provision of our services or other transactions with us.
How do we protect the personal information you provide to us?
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you keep my information?
We will not to keep your personally identifiable information in a form that allows you to be identified for any longer than is reasonably necessary for achieving the permitted purposes. This means that data will be destroyed or erased from our systems or anonymised when it has reached the applicable retention period.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
What happens to your personal information on a change of control of our business?
In the event of a business change in control resulting from, for example, a sale to, or merger with, another entity, we may transfer your personally identifiable information to the new party in control.