Privacy Policy
Privacy Policy
Overview
(A) Who we are: We are Wingback Limited, a leader in sustainable manufacturing based in England. Our company number is 10948782 and our registered office is Unit 2.02 - 2.04 Oxo Tower Wharf Bargehouse Street, Southbank, London, England, SE1 9PH. All references in this policy to "Wingback", "our", "us" or "we" refer to WIngback Limited or companies and suppliers which provide services to us, as appropriate. All references in this policy to "our websites" are a reference to the websites owned by Wingback.
This privacy policy tells you how your information is collected and used by us and shared with others, how we keep it safe and the rights you have to access and control its use. We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you.
(B) Who this policy applies to: This policy applies to: visitors to our websites; customers; prospective customers; and people who contact us with enquiries or that we contact in relation to orders.
Depending on our relationship, we will collect and use your information in different ways. Please click on the links above to find out the information that we collect about you and how we use this information.
(C) What this policy contains: This privacy policy describes the following important topics relating to your information:
how we obtain your personal information;
what information we collect about you and how we use it;
our legal basis for using your personal information;
how and why we share your personal information;
how long we store your personal information;
your rights;
children;
marketing;
where we may transfer your personal information;
risks and how we keep your personal information secure;
links to other websites;
changes to this privacy policy; and
further questions and how to make a complaint.
(D) You have rights to object. You may ask to us stop using your personal information for direct marketing and where we use of your personal information on the basis of our, or another person's, legitimate interest. You can find out more information in section 6.
(E) What you need to do and your confirmation to us: Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.
- How we obtain your personal information
1.1 You may provide us with your personal information voluntarily. However, we may also receive information about you from third parties such as marketing agencies, market research companies, our suppliers, contractors and consultants, group companies, business partners, and third-party websites, which we refer to as "third party sources" or "suppliers" throughout this policy. We may also collect personal information from you using a variety of technologies that automatically and passively collect information when you use our websites (usage data).
1.2 You may give us personal information by completing forms on our websites, registering for an account, enquiring about or ordering products from us, entering a competition, signing up to receive emails, completing customer satisfaction surveys or otherwise providing feedback , or by contacting us by phone, email or other means. This includes, for example, where you provide your personal information to us in order to receive information or services from us.
- What information we collect about you and how we use it
2.1 Visitors to our websites
(a) What personal information we collect about you
We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number;
(v) information provided when you correspond with us;
(vi) any updates to information provided to us;
(vii) personal information we collect about you or that we obtain from our third party sources;
(viii) the following information created and recorded automatically when you visit our websites:
(A) Technical information. This includes: the Internet protocol (IP) address used to connect your computer to the internet address or other unique identifier for the computer or other electronic device that you use to access our websites; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; and operating system and platform.
(B) Information about your visit and your behaviour on our websites (for example, the pages that you click on). This may include the website you visit before and after visiting our websites (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads; and
(ix) demographic information, including gender and age.
(b) How we use your personal information
We will collect, use and store the personal information listed above for the following reasons:
(i) to allow you to access and use our websites;
(ii) to receive enquiries from you through our websites about our products and business;
(iii) to ensure that content from our websites is presented in the most effective manner for you and for your computer or other electronic device;
(iv) to understand how you access and use our websites;
(v) to understand you better and tailor our websites' content and services to your needs and interests; and
(vi) to administer and improve our websites and products, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our web pages.
Please see sections 2.5 and 2.6 for more details about how we use your personal information.
(c) Cookies
(i) Some pages on our websites use cookies, which are small files placed on your internet browser when you visit our websites. We use cookies in order to distinguish you from other users of our websites and services and improve your user experience by understanding and remembering key information that you have provided to us.
(ii) Where we use cookies on our websites, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our websites or to use all the functionality provided through our websites.
(iii) For detailed information on the cookies we use and the purposes for which we use them, please refer to our cookie policy.
2.2 Customers
(a) What personal information we collect about you
We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number;
(v) your age;
(vi) your gender;
(vii) information provided when you place orders;
(i) information provided when you correspond with us;
(ii) any updates to information provided to us;
(iii) customer service information, customer relationship management and marketing information; and
(iv) information you provide to help us provide you with improved products, for example if we ask you to fill in a survey or questionnaire.
(b) How we use your personal information
We will collect, use and store the personal information listed above for the following reasons:
(i) to process and fulfil orders you have placed with us;
(ii) to send you emails to confirm your order status, shipment, and/or inventory details;
(iii) to deal with any enquiries or issues you have about our products or your orders;
(iv) to provide customer support;
(v) to carry out statistical analysis and market research; and
(vi) for marketing purposes, or to contact you (including by email or post) with information about our products (we will only to this where you have consented, or it is otherwise in our legitimate interests).
Please see sections 2.5 and 2.6 for more details about how we use your personal information.
2.3 Prospective customers who we send marketing communications to
(a) We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number; and
(v) information about your preferences.
(b) How we use your personal information
We will collect, use and store the personal information listed above for marketing purposes, or to contact you (including by email or post) with information about our products which you either request, or which we feel will be of interest to you (we will only to this where you have consented, or it is otherwise in our legitimate interests).
Please see sections 2.5 and 2.6 for more details about how we use your personal information.
(c) Source of personal information. We may receive some of your personal information from third parties, such as marketing agencies.
2.4 People who contact us with enquiries or that we contact in relation to orders
(a) We, or third parties on our behalf, may collect and use any of the following information about you:
(i) your name including your title;
(ii) your postal address;
(iii) your email address;
(iv) your telephone number;
(v) information provided when you correspond with us; and
(vi) any updates to information provided to us.
(b) How we use your personal information
We will collect, use and store the personal information listed above to deal with any enquiries or issues you have about our products or orders you've placed with us, including any questions you may have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes, for the carrying on of our business or to meet our customer and future customer demand.
Please see sections 2.5 and 2.6 for more details about how we use your personal information.
2.5 Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:
(a) to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests;
(b) for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;
(c) to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and
(d) to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
2.6 Aggregated and anonymous information
We may use your personal information and combine it with the personal information of others to identify trends and share or provide this trend information in an aggregated and anonymous form with third parties. For example, we may use information about your browsing habits as part of an aggregated number to identify which are our most popular website pages.
- Legal basis for use of your personal information
3.1 We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:
(a) our use of your personal information is necessary to perform our obligations under any contract with you (for example, to sell and provide you with our products, to fulfil an order which you place with us, to comply with the terms of use of our websites; or
(b) our use of your personal information is necessary for complying with our legal obligations (for example, if you contact us requesting access to personal data we hold about you); or
(c) where neither (a) nor (b) apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:
(i) run, grow and develop our business;
(ii) operate our websites;
(iii) select appropriately skilled and qualified suppliers;
(iv) carry out marketing, market research and business development;
(v) provide products to our customers, make and receive payment and provide customer services;
(vi) invest in and roll out new products to benefit the communities in which we operate;
(vii) place, track and ensure fulfilment of orders with our suppliers; and
(viii) for internal group administrative purposes.
If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details in section 13.
3.2 We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described below).
3.3 If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at hello@wingback.co.uk and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide products and services to you.
- How and why we share your personal information with others
4.1 We will share your personal information with the following third parties or categories of third parties:
(a) our group companies where it is in our legitimate interests to do so for internal administrative purposes (for example, ensuring consistent and coherent delivery of products to our customers, corporate strategy, compliance, auditing and monitoring, research and development and quality assurance);
(b) suppliers who provide information technology and office services, including software and website development, website hosting, management and evaluation, exchange and cross referencing;
(c) our service providers and subcontractors, including but not limited to payment processors, fraud protection services, suppliers of technical and support services, insurers, suppliers providing order fulfilment, warehousing and delivery services;
(d) companies that assist us in our marketing, advertising and promotional activities, including partnerships with other companies whose products or services we think you might enjoy; and
(e) analytics providers, optimization firms, and similar third parties that assist us in the improvement and optimisation of our websites.
4.2 Any third parties with whom we share your personal information are limited (by law and by contract) in their ability to use your personal information for any purpose other than to provide services for us. We will ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws.
4.3 We will also disclose your personal information to third parties:
(a) where it is in our legitimate interests to do so to run, grow and develop our business:
(i) if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;
(ii) if substantially all of Wingback’s or any of its affiliates' assets are acquired by a third party, in which case personal information held by Wingback will be one of the transferred assets;
(b) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
(c) in order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
(d) to protect the rights, property, or safety of Wingback, our staff, our customers or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection.
4.4 We may also disclose and use anonymised, aggregated reporting and statistics about users of our websites or our goods for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
4.5 Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so.
- How long we store your personal information
We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
- Your rights
6.1 You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us via email at hello@wingback.co.uk at any time. You have the following rights:
(a) Right of access. You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation whether your personal information is being used by us; details about how and why it is being used; and details of what safeguards are in place if we transfer your information outside of the European Economic Area ("EEA").
(b) Right to update your information. You have a right to request an update to any of your personal information which is out of date or incorrect.
(c) Right to delete your information. You have a right to ask us to delete personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 13.
Unless it is impossible or involves disproportionate effort, we will pass your request onto other recipients of your personal information. You can ask us who the recipients are using the contact details in section 13.
(d) Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 13.
Unless it is impossible or involves disproportionate effort, we will pass your request onto other recipients of your personal information. You can ask us who the recipients are using the contact details in section 13.
(e) Right to stop marketing: You have a right to ask us to stop using your personal information for direct-marketing purposes.
(f) Right to data portability: You have a right to ask us to provide your personal information to a third party provider of services.
(g) Right to object. You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person's legitimate interest.
6.2 We will consider all such requests and provide our response within a reasonable period. Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
6.3 If an exception applies, we will tell you this when responding to your request.
6.4 We may request you provide us with information necessary to confirm your identity before responding to any request you make.
- Children
7.1 You must be aged 13 or over to purchase products from us. Our websites are not directed at children under the age of 13 and we do not knowingly collect any personal information from visitors in this age group.
7.2 If you are under the age of 13 and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible.
7.3 Please contact us at hello@wingback.co.uk if you are aware that we may have inadvertently collected personal information from a child under the age of 13.
- Marketing
8.1 We may collect and use your personal information for undertaking marketing by email, telephone, and/or post.
8.2 We may send you certain marketing communications (including electronic marketing communications to existing customers) if it is in our legitimate interests to do so for marketing purposes.
8.3 We will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your personal information to any third party for such marketing.
8.4 If you wish to stop receiving marketing communications, you can contact us by email at hello@wingback.co.uk.
- Where we may transfer your personal information
9.1 Your personal information may be used, stored and/or accessed by staff operating outside the EEA (including the United States) working for us, other members of our group, our partners, or our suppliers. Further details on to whom your personal information may be disclosed are set out in section 4.
9.2 If we provide any personal information about you to a third party operating outside of the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this privacy policy. These measures may include the following permitted in Articles 45 and 46 of the General Data Protection Regulation:
(a) in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or
(b) in the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
9.3 Further details on the steps we take to protect your personal information is available from us on request by contacting hello@wingback.co.uk.
- Risks and how we keep your personal information secure
10.1 Wingback is committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures. We ensure that:
(a) all information you provide to us is stored on our secure servers; and
(b) any account created with Wingback will be password protected.
10.2 In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect your personal information, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our websites and that any such transmission is at your own risk. Once we have received your personal information, we will use procedures and security features to prevent unauthorised access to it.
10.3 Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
- Links to other websites
Our websites may contain hyperlinks to and from the websites of our partners, advertisers, other third parties. Any hyperlinks we provide are provided for your reference and convenience only and do not imply any endorsement of the activities of such third party websites or any association with their operators. This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.
- Changes to our privacy policy
We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email or in another appropriate manner.
- Further questions and how to make a complaint
13.1 If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact hello@wingback.co.uk. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.
13.2 In accordance with Article 77 of the General Data Protection Regulation, you may also make a complaint to the data protection regulator in the country where you usually live or work, or where an alleged infringement of the General Data Protection Regulation has taken place. In the UK, the data protection regulator is the Information Commissioner's Office. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.
The practices described in this privacy policy statement are current as of 16/05/2024.