Privacy Policy | Winston's Leather

Introduction

Welcome to the Winston’s Leather's privacy policy.

Winston’s Leather respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. Important Information and who we are

2. T he data we collect about you

3. How your personal data is collected

4. How we use your personal data

5. Disclosure of your personal data

6. International transfers

7. Data security

8. Data retention

9. Your legal rights

10. Glossary

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Winston’s Leather collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service or when you contact us about the products or services that we offer.

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.

Winston’s Leather is the controller and responsible for your personal data (collectively referred to as "Winston’s Leather", "we", "us" or "our" in this privacy policy). If you have any questions about this privacy policy, please contact us via email at: winstonsleather@gmail.com.

If you have any concerns or complaints regarding the way in which we process your data, please email us directly using the email address above. You also 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 do contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We may update our privacy policy from time to time and any updated version will be published on our website. A copy of the current and historic privacy policies can be obtained by contacting us via email using the details set out above.

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.

Third-party links

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 we are not responsible, or accept any liability, for their privacy statements or policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about 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).

Our website is not intended for children and we do not knowingly collect data relating to children.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes information such as: title, first name, last name, username or similar identifier.

Contact Data includes information such as: billing address, delivery address, email address and telephone numbers.

Financial Data includes information such as: bank account and payment card details.

Transaction Data includes information such as: details of your purchases and the fulfilment of your orders (such as, order number, number of items, title of items, single item price, subtotal, shipping, tax etc.); details about payments to and from you and other details of products and services you have purchased from us, and correspondence or communications with you in respect of your orders.

Technical Data includes information such as: your internet protocol (IP) address, browser type and version, time zone setting and geographical location, 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 information such as: purchases or orders made by you, your product interests, preferences, feedback and survey responses.

Usage Data includes information: about how you use our website and products and services used by you.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may 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 products or services). 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.

3. How your personal data is collected

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

Direct interactions. You may give us your Identity, Contact, Financial, Transaction, Profile and Marketing 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 products on our website;
- request marketing or information to be sent to you; or
- give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns and Contact Data where tasks carried out via our website remain uncompleted, such as incomplete orders or abandoned baskets. We collect this data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical Data from analytics providers such as Google based outside the UK;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK; and
- Identity and Contact data from third parties, including organisations (including law enforcement agencies), associations and groups, who share data for the purposes of fraud prevention and detection.

4. How we use your personal data

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 For example, to process a payment from you, fulfil your order or provide customer support to you; or

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; or

Where we need to comply with a legal obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

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, in a table format, 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.

Please 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 in the table below:

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest

To register you as a new customer Identity Performance of a contract with you

Contact

To process and deliver your order

including:

communicating with you about your Identity Performance of a contract with you

order; Contact Necessary for our legitimate interests

managing and processing payments, refunds, Financial (to recover debts due to us)

fees and charges; Transaction

collecting and recovering money owed Marketing & Communications

to us;

arranging delivery of your order.

To manage our relationship with you which

will include:

providing you with any information, products and Identity Performance of a contract with you

services that you request from us; Contact Necessary to comply with a legal

notifying you about changes to our terms or Profile obligation

providing customer services to you; (to keep our records updated and to
asking you to leave a review. study how customers use out products/services)

To administer, protect and improve our business and Identity Necessary for our legitimate interests

our website (including troubleshooting, data analysis, Contact (for running our business, provision of

testing, system maintenance, support, reporting and Technical administration and IT services, network

hosting of data, obtaining professional advice, Profile security, to prevent fraud and in the

managing risks) Transaction context of a sale, reorganisation or

Marketing & Communications restructuring of the business)

Necessary to comply with a legal obligation

To deliver relevant website content and advertisements Identity Necessary for our legitimate interests

to you and measure or understand the effectiveness of Contact (to study how customers use our the advertising we serve to you Profile products/services, to develop them, Usage to grow our business and to inform

Marketing & Communications our marketing strategy)

Technical

To use data analytics to improve our website, Technical Necessary for our legitimate interests

products/ services, marketing, customer relationships Usage (to define types of customers for our

and experiences products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you Identity Necessary for our legitimate interests

about products or services that may be of interest Contact (to develop our products/services

to you Technical and grow our business)

Usage

Profile

Marketing & Communications

To inform or remind you by email of any task carried Identity Necessary for our legitimate interests

out via our website which remains uncompleted, Contact (to improve the shopping experience

such as incomplete orders or abandoned baskets Usage of our customers)

To comply with a legal obligation Identity Necessary to comply with a legal Contact obligation

Financial

Transactional

Technical

Profile

Usage

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.

Marketing

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

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may like, 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 may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time 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 or other transactions.

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 and third party cookies, please see our Cookie Policy here.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data set out above:

Third party service providers that we engage to:
- host our website – Our website is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall. You can read about how Wix.com uses your personal information on their website by following the link here: https://www.wix.com/about/privacy;
- provide payment processing services – financial transactions relating to our website and products are handled by payment service providers, Adyen N.V. and Stripe Inc. via Wix Payments. Your personal data will be shared with the payment service providers only to the extent necessary for the purposes of processing payments, refunding payments and dealing with complaints and queries relating to such payments. All direct payment gateways offered by Wix.com adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council. PCI-DSS requirements help ensure the secure handling of credit card information by the payment service providers. You can read about how Adyen N.V. and Stripe Inc. uses your personal information on their websites by following the links here:
  - https://www.adyen.com/en_GB/policies-and-disclaimer/privacy-policy;
  - https://stripe.com/gb/privacy;
- Deliver products to you – we will engage third party delivery partners to deliver to you, the products you have purchased through our website. We will share your personal data with our delivery partners only to the extent necessary to enable the products you have ordered, to be delivered to you. This also includes our suppliers who may also dispatch and deliver products to you directly;

Professional advisors – we may disclose your personal data to our professional advisors such as lawyers, bankers, auditors, insurers and technical advisors insofar as is reasonably necessary for the purposes of administering and protecting our business, maintaining our website, obtaining professional advice, managing risks to our business, or the establishment, exercise or defence of legal claims whether in court proceedings or in an administrative or out-of-court procedure;

Statutory agencies, regulators or other official bodies or authorities – we may disclose your personal information to comply with a legal obligation;

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

6. International transfers

We may transfer your personal data to a third party to process on our behalf in accordance with the purposes set out above. Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we will take steps to ensure a similar degree of protection is afforded to it in the same way as if it were being processed in the UK. Such steps may include implementing safeguards such as:

Ensuring the country to which personal data is to be transferred has been deemed to provide an adequate level of protection for personal data in accordance with the UK adequacy regulations which include the EEA and all countries, territories and international organisations covered by the European Commission adequacy decisions valid as at 31 December 2020. For further details, please see the ICO website: https://ico.org.uk
using specific contracts approved for use in the UK which give personal data the same protection it has in the UK. For further details, please see ICO website: https://ico.org.uk

7. Data security

We have in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those employees 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.

Our website is hosted on the Wix.com platform. Wix.com has implemented security measures designed to protect the personal information we share with Wix.com, including physical, electronic and procedural measures. Among other things, Wix.com offer HTTPS secure access to most areas on their services; the transmission of sensitive payment information (such as a credit card number) through their designated purchase forms is protected by an industry standard SSL/TLS encrypted connection; and they regularly maintain a PCI DSS (Payment Card Industry Data Security Standards) certification. They also regularly monitor their systems for possible vulnerabilities and attacks, and regularly seek new ways and third party services for further enhancing the security of their services and protection of their visitors’ and users’ privacy.

Regardless of the measures and efforts taken by Wix however, they and we cannot and do not guarantee the absolute protection and security of your personal information or any other information which is uploaded, published or otherwise shared with Wix or anyone else.

In the unfortunate event of a personal data breach we will notify you and any applicable regulator where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

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 legal 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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing your personal data
Request transfer of your personal data
Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.

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.

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.

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.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest 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.

Performance of Contract means 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.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

YOUR LEGAL RIGHTS

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.

(Version 1.0 – 30.10.22)

Terms and Conditions

Cookie Policy

Delivery and Returns

Importnt Information and who we are

The data we collect about you

How your personal data is collected

How we use your personal data

Disclosures of your personal data

International data transfers

Data security

Data retention

Glossary

Your legal rights

lawful basis