This notice explains how we use your personal data, describes the categories of personal data we process and for what purposes. It applies when you use our websites or any of our related products or services. We are committed to collecting and using personal data fairly and in accordance with the requirements of the General Data Protection Regulation (GDPR).

We hold the privacy of your personal information in the highest regard. The following discloses our information gathering and dissemination practices for this website.

Who We Are

Wincham International Limited (Company No. 05579766) whose registered office is at Wincham House, Greenfield Farm Trading Estate, Congleton, Cheshire CW12 4TR. You can contact our Administration and Client Services Department by telephone on 01260 299700.

Other firms within the Wincham International Group with which we may share your personal data are:

• Wincham Accountants Limited. Registered number 05607266 (England)
• Wincham Consultants Limited. Registered number 05143003 (England)

The Registered Office for these Companies is: Wincham House, Greenfield Farm Trading Estate, Congleton, Cheshire CW12 4TR.

• Wincham Spanish Services SL. Registered number B54842695 (Spain)

The registered address for this company is Avenida Ejercitos Espanoles 10, Edificio Apolo VII, Calpe 03710, Alicante.

What Information/Data Do We Collect?

When you visit this website you may provide us with two types of information: personal information you knowingly choose to disclose that is collected on an individual basis and Website use information collected on an aggregate basis as you and others browse our Website.

• Personal Information You Choose to Provide
  For a better experience while using our Service, we may require you to provide us with certain personally identifiable information, including but not limited to your name, phone number, and postal address. The information that we collect will be used to contact or identify you.
  • Registration Information
    When you register for any of our products, services or newsletters you will provide us information about yourself.
    • Data relating to your identity: We may collect information from you when you fill in an online registration/enquiry form for any of our website services. We may also collect information you give us over the telephone or in written or other communications.
    • Email Information: If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses. We provide the same protections for these electronic communications that we employ in the maintenance of information received by mail and telephone.
  • IP Addresses
    IP addresses are used by your computer every time you are connected to the Internet. Your IP address is a number that is used by computers on the network to identify your computer. IP addresses are automatically collected by our web server as part of demographic and profile data known as traffic data so that data (such as the Web pages you request) can be sent to you.
• Website Use Information
  Similar to other commercial Websites, our Website utilises a standard technology called "cookies" (please click here to see our Cookie Policy which forms part of this Privacy Policy.) and web server log files to collect information about how our Website is used. Information gathered through cookies and Web server logs may include the date and time of visits, the pages viewed, time spent at our Website, and the Websites visited just before and just after our Website.

Why We Collect Information about You?

We will only ask you for your personal data where it is necessary to fulfil the following purposes. Where providing us with your personal data is optional, we will inform you of this. Our purposes are grouped under our legal bases for processing.

Entering into and fulfilling a contract between you and us
To deliver the products and services we provide, including:

• Making and accepting payments, and receiving deposits on your behalf;
• Providing you with information, advice and guidance on the products and services you hold;
• To address enquiries or complaints we may receive from you or a representative appointed by you.

Fulfilling our legal obligations

• Checking your identity
• Assisting you with managing the products and services you hold;
• Maintaining records of our business, as required by law - for instance, keeping records of our accounts;
• Complying with laws which require us to provide information, directly or indirectly to any national authority, for the purpose of calculating and collection of tax;
• To otherwise meet our obligations under all laws and regulations based on law which apply to our business activities; and
• Identifying and managing risks to our organisation.

For our legitimate interests
As a commercial organisation:

• Understanding how our customers use our products and services, so we can improve these.
• Developing new products and services and identifying which may be of interest to you - this may involve profiling;
• Where we have the relevant permissions, contacting you to make you aware of these products and services - note: we may contact you for a reasonable period after you cease your relationship with us;
• Sharing information with organisations who introduce you to us under a commercial agreement - for instance, where we pay them commission;
• Improving our systems and processes, which may include using your personal data to test the accuracy of these, but only where it is essential to do so;
• To recover money owed to us;
• To otherwise exercise our rights under our contracts with you for the provision of the products and services you hold;
• To invite you to participate in market research and customer surveys;
• Sharing your personal data with any person to whom we may transfer, or may consider transferring any of our rights or business; and

How Do We Use your personal information?

Data protection law says that we can only use personal data if we have a proper reason to do so. For example, these reasons include fulfilling a contract we have with you, when we have a legal duty, when it is in our legitimate interest or when you consent to its use. When data protection law allows us to process your personal data for our own legitimate interests, it is only allowed provided those interests do not override your own interests and/ or your fundamental rights and freedoms.

We use personal information for purposes of administering our business activities, providing the products and services you requested, to process your payment, to monitor the use of the service, our marketing and promotional efforts and improve our content and service offerings, and customise our site's content, layout, services and for other lawful purposes. These uses improve our site and better tailor it to meet your needs. Such information may be shared with our co-companies, trading partners and legal representatives in order to execute the desired tax planning structure that you have requested. Personally identifiable information or business information will not be shared with parties except as required by law.

We may also use the information we collect to notify you about important changes to our Website and new services we think you will find valuable. You may notify us at any time if you do not wish to receive these offers by emailing us at the link provided on the contact page.

Consent

By using our Website, you consent to our collection and use of your personal information as described in this Privacy Policy.

Your consent is required for Wincham International Limited to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data, we will always tell you why and how the information will be used.

We reserve the right to amend this privacy policy at any time with or without notice.

Retention period

We will retain your personal data for as long as we are obliged, under relevant legislation and regulation, or where no such rules apply, for no longer than it is necessary for our lawful purposes. This will usually be no more than twelve years from the point at which the obligation to retain a record containing your personal data begins. The retention period of your personal data may need to be extended where we require this to bring or defend legal claims. We may also retain data for longer periods for statistical purposes, and if so we will anonymise or pseudonymise this

How Can You Access and Correct Your Information?

You may request access to all your personally identifiable information that we collect online and maintain in our database by emailing the Data Protection Officer at the usual address.

Your rights as a data subject
If Wincham International Limited does hold personal data about you, you can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Wincham International Limited or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn't collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

Sharing and Selling Information

We DO NOT share, sell, lend or lease any of the information that uniquely identify a subscriber (such as email addresses or personal details) with anyone except to the extent it is necessary to process transactions or provide services that you have requested.

What about Legally Compelled Disclosure of Information?

We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights. We may also disclose account information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our Terms of Service or to protect the safety of our users and the Public.

What About Other Websites Linked to Our Website?

This Website may contain links to various websites and social network platforms managed on third party servers by people and organisations over which Wincham International Limited has no control. Therefore, we are not responsible for the practices employed by Websites linked to or from our Website or the information or content contained therein. Often links to other Websites are provided solely as pointers to information on topics that may be useful to the users of our Website.

Please remember that when you use a link to go from our Website to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including websites, which have a link on our Website, is subject to that Website's own rules and policies. Please read over those rules and policies before proceeding.

Our Commitment to Data Security

We have put in place measures to protect the security of your information.

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

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

Choice/Opt-In/Opt-Out

This site allows visitors to unsubscribe so that they will not receive future messages. After unsubscribing we will discontinue sending the particular messages as soon as technically feasible. You can unsubscribe at any time by logging into your user account on the Website or by clicking on the link in the marketing email.

Acquisition or Changes in Ownership

In the event that the website (or a substantial portion of its assets) is acquired, your information would be considered part of those assets, and may be part of those assets that are transferred.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Wincham International Limited, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority (Information Commissioners' Office) and Wincham International Limited's Data Protection Officer at:

Wincham House
Greenfield Farm Trading Estate
Congleton
Cheshire
CW12 4TR

Policy Modifications

We keep our Privacy Notice under regular review. This notice was last updated in May 2018. We may change this Privacy Policy from time to time. We will post any changes here, so be sure to check back periodically. However, please be assured that if the Privacy Policy changes in the future, we will not use the personal information you have submitted to us under this Privacy Policy in a manner that is materially inconsistent with this Privacy Policy, without your prior consent.