Privacy & Cookies
Privacy & Cookies
Windsor understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of our clients and everyone who visits this website, www.windsorcm .com (“Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Cookie” means a small text file placed on your computer or device by the Site when you visit certain parts of the Site and/or when you use certain features of the Site. Details of the Cookies used by the Site are set out below;
and “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
2. What Does This Policy Cover?
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
5. What Data Do We Collect?
Depending upon your case, we may collect some or all of the following personal and non-personal data
- Date of birth;
- Email address;
- Telephone number;
- Business name;
- Job title;
- Payment information;
- Other personal information as required for performance of our services.
5. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:
- Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products and services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email or post that you have opted-in to (you may unsubscribe or opt-out at any time)
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or text message or post with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
5. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
5. How and Where Do You Store or Transfer My Personal Data?
We will store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR. On occasions it might be required to transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law. We might also be required to transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR as follows.
We share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage.
5. Can I Withhold Information?
You may access Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 30 days. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
12. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: info@Windsorcm.com
Postal Address: 1 Knightsbridge Green, Knightsbridge, London, SW1X 7NE, UK
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
The scope and purpose of this Data Protection Privacy Notice
This Data Protection Privacy Notice explains how Windsor Capital Management Ltd (“Windsor”, “we”, “us”, “our”), collects, uses, shares and otherwise processes your Personal Data in connection with your relationship with Windsor in accordance with applicable data privacy laws and the General Data Protection Regulation (“GDPR”).
The term “Personal Data” as used in this Data Protection Privacy Notice means any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. This definition provides for a wide range of personal identifiers to constitute personal data, including, for example, name, date of birth, residential address, identification number, location data or online identifier.
What information do we collect about you, how do we collect it and what do we use it for? The kinds of Personal Data we may collect include your contact details (such as your address, email address and telephone number) and, where required for contractual, legal or regulatory obligations, additional information (including, but not limited to, date of birth, bank account details, tax identification numbers, copies of identification documents and numbers)In most cases, we will collect the Personal Data directly from you but may also obtain it from other sources (for example, public registers).
In accordance with applicable data privacy laws and the GDPR, we will only process your Personal Data for specific purposes where there is a lawful basis for doing so. The lawful basis, and purposes that we may rely on are:
- you have consented to us doing so (consent) – in limited circumstances, we may obtain your consent to send you information about our products and services (but, in such cases, you can opt out of receiving such communications at any time through the method provided in the communications themselves or by using the contact information provided below);
- we need it to perform the contract we have entered into with you (contract) – this includes, but is not limited to, where we have entered into an agreement with you and the Personal Data is needed to ensure that the terms of the contract can be fulfilled;
- we need it to comply with a legal obligation (legal obligation) – these obligations include, for example, where we have a regulatory obligation to conduct customer due diligence or are required to provide information to tax authorities; or
- we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms (legitimate interest) – this includes the provision of services by us and our direct marketing activities. To this end, we will use your Personal Data to deliver services to you and/or to work or act for you. Furthermore, we will also use your Personal Data to inform you about us and our services and to build our relationship with you.
we (or a third party) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms (legitimate interest) – this includes the provision of services by us and our direct marketing activities. To this end, we will use your Personal Data to deliver services to you and/or to work or act for you. Furthermore, we will also use your Personal Data to inform you about us and our services and to build our relationship with you.
- we need it to comply with a legal
- request rectification of your Personal Data;
- request the erasure of your Personal Data;
- request the restriction of processing of your Personal Data;
- object to the processing of your Personal Data.
Please note, some of the above rights may only be exercised in specific circumstances – they are not absolute. In addition, you may also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues or, as the case may be, another competent supervisory authority of an EU member state.
Right to withdraw consent
In case you have provided your consent to the collection, processing and transfer of your Personal Data, you have the right to fully or partly withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. In cases where we have processed your Personal Data for direct marketing purposes, you have the right to object at any time, in which case we will no longer process your Personal Data for such direct marketing purposes.
How long will we retain your information?
We will only retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. To determine the appropriate retention period for your Personal Data, we will 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. If you would like to know more information about our retention practices, please contact us using the information provided below. In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data. Upon expiry of the applicable retention period we will securely destroy your Personal Data in accordance with applicable laws and regulations.
You will in general not have to pay a fee to exercise any of your individual rights mentioned in this Data Protection Privacy Notice. However, we may charge a reasonable fee if your request to exercise your individual rights is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
Changes to this Data Protection Privacy Notice
Windsor reserves the right to update this Data Protection Privacy Notice at any time and, in such cases, we will make an updated copy available on our website, or where required by law, we will contact you directly.
If you have any queries, questions, concerns or require any further information in relation to the Data Protection Privacy Notice or you wish to exercise any of your rights, please do not hesitate to contact us at firstname.lastname@example.org.