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Privacy Policy

Definitions

Company: The Wind Section Ltd, incorporated in Scotland with company number SC270053 and having its registered office at 11-13 Cumberland Street, Edinburgh, Scotland, EH3 6RT.

The Company is fully committed to upholding its Privacy Policy. Providing the Company with your personal information is an act of trust; an act that is taken very seriously in the way that the Company operates. This privacy policy aims to give you information on how the Company collects and processes your personal data through your use of this website, including any data you may provide through this website when you, for example, sign up to our newsletter, purchase a product or service, take part in a competition, contact us. Information is also provided on how to change or de-activate your data.

We keep our privacy policy under regular review. This Privacy Policy was last updated on 11/05/2022. The Company strives to be fully compliant with all applicable data protection legislation in the UK including the UK GDPR and the Data Protection Act 2018.

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 – where you have an account on our website, you can update your personal data online. Alternatively, please contact our DPO on the details provided below.

This website is not intended for children and we do not knowingly collect data relating to children.
If you have any questions about this privacy policy, your personal data or our privacy practices, please contact our Data Protection Officer (DPO) in the following ways:

Full name of legal entity: The Wind Section Ltd
Email address: info@thewindsection.com
Postal address: The Wind Section Ltd, 11-13 Cumberland Street, Edinburgh, Scotland, EH3 6RT

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Information We May Collect From You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, transfer and process the following data about you which we have grouped together as follows:

  • Identity Data includes first name, last name, business name, username or similar identifier.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, page response times, download errors, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses, information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for, length of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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 goods). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How We Collect Personal Data From You

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • Purchase our products or services;
    • create an account on our website;
    • subscribe to our service or publications;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We may receive information about you if you use any of the other websites we operate, the other services we provide and/or any of our social media pages. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. All third-party organisations that we work with are, so far as we are aware, data protection compliant.

Uses Made of the Information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
    • i.e. processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract, like when you buy a product from us.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
    • i.e. legitimate interest means the interests of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes For Which We Will Use Your Personal Data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

1. Purpose/Activity

To register you as a new customer

1. Type of Data

(a) Identity

(b) Contact

1. Lawful basis for processing including basis of legitimate interest

Performance of a contract with you

2. Purpose/Activity

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

2. Type of Data

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

2. Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

3. Purpose/Activity

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

3. Type of data

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

3. Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

4. Purpose/Activity

To enable you to partake in a prize draw, competition or complete a survey

4. Type of data

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

4. Lawful basis for processing including basis of legitimate interest

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

5. Purpose/Activity

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

5. Type of data 

(a) Identity

(b) Contact

(c) Technical

5. Lawful basis for processing including basis of legitimate interest

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

6. Purpose/Activity

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

6. Type of data

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

6. Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) 

7. Purpose/Activity

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

7. Type of data

(a) Technical

(b) Usage

7. Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) 

8. Purpose/Activity

To make suggestions and recommendations to you about goods or services that may be of interest to you (including from our sister brands)

8. Type of data

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

8. Lawful basis for processing including basis of legitimate interest

Necessary for our legitimate interests (to develop our products/services and grow our business) 

Marketing: We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. 

Promotional offers from The Wind Section Ltd: We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from The Wind Section Ltd if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing: We will never share your personal data with any third party for marketing purposes.

Opting out: 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 or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies: You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of Purpose: We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure Of Your Information

We may share information with selected third parties including;

  • If the Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • In the event that we sell or buy any business or assets in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreement; or to protect our rights, property, or safety, our customers, or other. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  • To pass on the appropriate personal information to:
    • any of the industry-leading payment providers that we use to process your payments. These include Shopify, Klarna, PayPal, Amazon Pay, Apple Pay and Google Pay. The Company will never store your credit or debit card information.
    • professional advisers acting as processors or joint controller including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
    • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
    • to our delivery partners who require it to deliver your order. Such partners include Sendcloud, UPS, DPD, Royal Mail and other fulfilment and delivery partners we may use from time to time.

In order to offer you Klarna’s payment methods, we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with Klarna’s own privacy notice (https://www.klarna.com/uk/privacy/ ).

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Where We Store Your Personal Data

The data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all necessary steps as we can to ensure that your data is treated securely and in accordance with this privacy policy.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Personally Identifiable Information

Personally identifiable information is defined as any personal information that could identify you such as your name, address, telephone number, billing and shipping information, credit card information or e-mail address. Generally, when you visit The Wind Section Ltd website, you are not required to disclose who you are or reveal any personally identifiable information. Since The Wind Section Ltd takes your privacy seriously, no personally identifiable information will be collected unless it is voluntarily provided.

Access To Information

The Company will not sell or provide any personal details in its possession to third party marketing companies. Only directors and authorised employees of the Company have access to customer information.

Security And Storage Of Information Collected

The Company 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, agents, contractors and other third parties 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 put in place 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.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see “your rights” below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data's accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Please visit the ICO website (https://ico.org.uk/) to find out more about these rights.

If you wish to exercise any of the rights set out above, please contact us at info@thewindsection.com

No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit To Respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes To The Privacy Policy

To fully protect your privacy, the Company reserves the right to amend this Policy at any time and for any reason. Amended terms will be posted via the Company website as they occur and you are encouraged to check back regularly for updates.

No Contract Or Liability

Nothing contained in this Policy is intended to create a contract or agreement between the Company and any user providing identifiable information in any form, visiting the Company’s website. All necessary steps will be taken to comply with this Privacy Policy, but to the extent permitted by Law, nothing in this policy is intended to hold the Company liable for any failure to comply with this policy.

Where To Make A Complaint

If you have a complaint regarding any aspect of your personal data or this privacy policy, please write to us at the above address. If you are still not satisfied with the outcome of your complaint, you may write to the Information Commissioner’s Office at the following address:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

You can also contact the Information Commissioner’s Office using their online form: https://ico.org.uk/global/contact-us/