This Privacy Policy applies between you, the User of this Website, and Newman Bros Limited, the owner and provider of this Website. Newman Bros Limited takes the privacy of your information very seriously. This Privacy Policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.
Please read this Privacy Policy carefully.
Definitions and Interpretation
Data |
collectively all information that you submit to Newman Bros Limited via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws; |
Cookies |
a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies); |
Data Protection Laws |
any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation; |
GDPR |
the UK General Data Protection Regulation; |
Newman Bros Limited, we or us |
Newman Bros Limited, a company incorporated in England and Wales with registered number 14316074 whose registered office is at 167-169 Great Portland Street, 5th Floor, London, W1W 5PF; |
UK and EU Cookie Law |
the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 & the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018; |
User or you |
any third party that accesses the Website and is not either (i) employed by Newman Bros Limited and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Newman Bros Limited and accessing the Website in connection with the provision of such services; and |
Website |
the website that you are currently using, www.winamhr.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions. |
2. In this Privacy Policy, unless the context requires a different interpretation:
b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this Privacy Policy;
c. a reference to a person includes firms, companies, government entities, trusts and partnerships;
d. "including" is understood to mean "including without limitation";
e. reference to any statutory provision includes any modification or amendment of it;
f. the headings and sub-headings do not form part of this Privacy Policy.
Scope of this Privacy Policy
4. For purposes of the applicable Data Protection Laws, Newman Bros Limited is the "data controller". This means that Newman Bros Limited determines the purposes for which, and the manner in which, your Data is processed.
Data Collected
b. date of birth;
c. gender;
d. job title;
e. profession;
f. contact Information such as email addresses and telephone numbers;
g. demographic information such as postcode, preferences and interests;
h. financial information such as credit / debit card numbers;
i. IP address (automatically collected);
j. web browser type and version (automatically collected);
k. operating system (automatically collected);
l. a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);
in each case, in accordance with this Privacy Policy.
How We Collect Data
b. data is received from other sources; and
c. data is collected automatically.
Data That is Given to Us by You
b. when you register with us and set up an account to receive our products/services;
c. when you make payments to us, through this Website or otherwise;
d. when you elect to receive marketing communications from us;
e. when you use our services;
in each case, in accordance with this Privacy Policy.
Data That is Collected Automatically
b. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".
Our Use of Data
b. improvement of our products / services;
c. transmission by email of marketing materials that may be of interest to you;
d. contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Website;
in each case, in accordance with this Privacy Policy.
12. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).
13. For the delivery of direct marketing to you via e-mail, we'll need your consent, whether via an opt-in or soft-opt-in:
b. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we'll provide.
c. if you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed "Your rights" below.
14. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
15. We may use your Data to show you Newman Bros Limited adverts and other content on other websites. If you do not want us to use your data to show you Newman Bros Limited adverts and other content on other websites, please turn off the relevant cookies (please refer to the section headed "Cookies" below).
Who We Share Data With
b. our employees, agents and/or professional advisors;
c. third party service providers who provide services to us which require the processing of personal data;
d. third party payment providers who process payments made over the Website;
e. relevant authorities if required by law;
in each case, in accordance with this Privacy Policy.
Keeping Data Secure
b. we store your Data on secure servers.
c. payment details are encrypted using SSL technology (typically you will see a lock icon or green address bar (or both) in your browser when we use this technology.
18. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: care@winamhr.com.
19. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Data Retention
21. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
Your Rights
b. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.
c. Right to erase - the right to request that we delete or remove your Data from our systems.
d. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.
e. Right to data portability - the right to request that we move, copy or transfer your Data.
f. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.
23. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: care@winamhr.com.
24. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.
25. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.
Transfers Outside the United Kingdom and European Economic Area
27. We will only transfer Data outside the UK or EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, e.g. by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission.
28. To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.
Links to Other Websites
Changes of Business Ownership and Control
31. We may also disclose Data to a prospective purchaser of our business or any part of it.
32. In the above instances, we will take steps with the aim of ensuring your privacy is protected.
Cookies
34. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
35. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Newman Bros Limited to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
36. This Website may place the following Cookies:
Type of Cookie |
Purpose |
Strictly necessary cookies |
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services. |
Analytical/performance cookies |
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. |
Functionality cookies |
These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). By using the Website, you agree to our placement of functionality cookie. |
Targeting cookies |
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. |
37. You can find a list of Cookies that we use in the Cookies Schedule.
38. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please see the help menu in your internet browser. You can switch off Cookies at any time, however, you may lose any information that enables you to access the Website more quickly and efficiently.
39. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
40. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
41. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.
General
43. If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.
44. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
45. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.
Changes to This Privacy Policy
Attribution
This Privacy Policy was updated on 10 January 2024.