1. OUR COMMITMENT TO YOUR PRIVACY
If you cannot, or will not, provide us with the personal information we reasonably require, we may be unable to provide you with the information or services you have requested.
2. PERSONAL DATA
“Personal Data” is information or pieces of information that could allow you to be identified, such as for example:
- Name and contact details (e.g. postal and email address, telephone number)
- Account information (e.g. user name, profile picture or social media account ID)
- Technical information, e.g. screen/user name, IP address, browser and device data, information collected through cookies, pixel tags and other technologies, server log file data, app usage data and location data
- Preferences (e.g. shopping habits, preferred educational courses)
How do we collect Personal Data?
We collect Personal Data in a variety of ways:
How do we use Personal Data?
- Your Personal Data will be processed by WIN for the purposes of customer service, administrative services or statistical purposes.
How do we share Personal Data?
- We may share your Personal Data with our (tech) support teams, that may be based outside the EEA / Switzerland. We do not share your Personal Data with anyone else.
- We have put appropriate safeguards in place for transfers of your Personal Data outside the EEA/Switzerland, including the standard data protection clauses adopted by the European Commission, available at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32004D0915 and https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087. For more information on standard data protection clauses in place, please see the contact section below.
- We may also share Personal Data as we believe to be necessary:
- (a) under applicable law;
- (b) to comply with legal process
- (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence;
- (d) to enforce our terms and conditions or a contract;
- (e) to protect our operations;
- (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and
- (g) to allow us to pursue available remedies or limit the damages that we may sustain.
On what do we base our right to collect and use Personal Data?
We base our right to collect and use your Personal Data on the need to do so in order to provide you with the services that you have ordered from us.
We use appropriate organizational, technical and administrative measures to keep the Personal Data under our control accurate and up-to-date, as well as to protect the Personal Data against unauthorised or unlawful processing and the accidental loss, destruction or damage of the Personal Data.
If at any time you wish to stop receiving marketing communications from us you can use the unsubscribe feature in the marketing communication you received or let us know by using the contact information listed in the “Contact Us” section. In your request, please indicate that you wish to stop receiving marketing communications from us.
Please note that changes may not be effective immediately. We will endeavour to comply with your request(s) as soon as reasonably practicable.
5. HOW LONG DO WE STORE PERSONAL DATA?
We will only keep your Personal Data for as long as it is necessary for the purposes for which it has been collected or in accordance with time limits stipulated by law and market practice, unless further retention is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims or unless a specific time period has been communicated.
7. YOUR RIGHTS
You have a right to, once per calendar year, contact us and without cost find out which information about you that is being used. You have a right to receive your Personal Data in a machine readable format. You have the right to, at any time, withdraw your consent or object to us using your Personal Data for direct marketing purposes and you may at any time request that the use of your Personal Data is restricted or that we shall delete your Personal Data. Upon your request, we are also obliged to correct Personal Data about you that is incorrect, incomplete or misleading.
8. CONTACT US
If you would like to have a copy of the information WIN holds about you; a copy of the standard data protection clauses or would like to exercise any of your rights, please contact us via the details as listed on the website.
If you have complaints about our handling of your Personal Data, you have a right to contact the supervisory authority in the country where you live.