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Privacy Policy

GWFD respects your privacy and is committed to protecting your personal data. This privacy notice 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.  Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.

Important information and who we are
  1. Purpose of this privacy notice:

This privacy notice aims to give you information on how GWFD collects and processes your personal data through your use of this website, including any data you may provide through this website when you [sign up to our newsletter, register and/or purchase a product or service, as well as installing and signing up to any GWFD powered application or our mobile applications].This website is not intended for children and we do not knowingly collect data relating to children.It is important that you read this privacy notice together along with our Website Terms & Conditions, which may be amended from time to time, or any fair processing notice 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 notice supplements the other notices and is not intended to override them.

  1. Controller

This privacy notice is issued on behalf of the GWFD so when we mention “GWFD”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the GWFD Group responsible for processing your data. GWFD is the controller and responsible for this website.We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice.

  1. Changes to the privacy notice and your duty to inform us of changes.

We may revise this Privacy Policy from time to time. Therefore, we may undertake a few changes to it. This version of the policy will govern our use of your information. If we make any material changes in the way we use your Personal Information, we shall notify you by posting an announcement on our Service or sending you an email in order to obtain your approval. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.Please note that it is substantial 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.

  1. 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 are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you
  1. What Is Personal Information?

“Personal information” means information that specifically identifies an individual (such as a name, address, telephone number, mobile number or e-mail address, birthday, Twitter and/or Facebook usernames) or information about that individual that is directly linked to personally identifiable information.We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.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 offenses.

  1. What Personal Information Do We Collect?

Personal Information You Provide Us with: We receive and store any information you enter on our Service or that you provide us with in any other way. The types of Personal Information collected may include your name, email address, phone number, birthday, Twitter and/or Facebook usernames, use information regarding your use of our Service, and browser information. We automatically receive your location when you use the Service. The Personal Information you provide is used for such purposes as allowing you to set up a user account and profile that can be used to interact with other users through the Service, improving the content of the Service, customizing the advertising and content you see, and communicating with you about events and new features. We may also draw upon this Personal Information in order to adapt the Services of our community to your needs, to research the effectiveness of our network and Services, and to develop new tools for the community.Information Collected Automatically: When you use the Service, GWFD automatically receives and records information on our server logs from your browser or mobile platform, including your location, IP address, cookie information, and the page you requested. We treat this data as non-Personal Information, except where we are required to do otherwise under applicable law. GWFD only uses this data in aggregate form. We may provide aggregate information to our partners about how our customers, collectively, use our site, so that our partners may also understand how often people use their services and our Service.
Payment: GWFD uses a third party as a payment gateway in order to handle all the payments processes. Accordingly, the third party shall be responsible for any credit/debit cards details and personally identifiable information. Therefore, GWFD shall not incur any liability in the event of a breach of any of the foregoing by the third party. If you fail to provide personal dataWhere 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 our Services). In this case, we may have to cancel the Service which you have with us, provided that we will notify you if this is the case at the time.

How is your personal data collected?

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

  1. From the information you provide to us when you meet us;
  2. From information about you provided to us by your company or an intermediary;
  3. When you communicate with us in writing, by telephone, fax, website registration, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
  4. When you complete (or we complete on your behalf) client on-boarding or application or other forms;
  5. From your agents, advisers, intermediaries, and custodians of your assets;
  6. From publicly available sources or from third parties, most commonly where we need to conduct background checks about you;
  7. Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, and email or otherwise. This includes personal data you provide when you:
    1. apply for our services;
    2. create an account on our website or application;
    3. in case of registering for an event;
    4. filling in your personal data in order to purchase a ticket;
    5. subscribe to our service or publications;
    6. request marketing to be sent to you;
    7. enter a competition, promotion or survey; or
    8. entering data for installing or using any GWFD powered application and/or installing or using GWFD application.
    9. give us some feedback.
  8. Automated technologies or interactions. As you interact with our website, we may 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.
  9. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below Technical Data from the following parties:
    1. analytics providers such as Google;
    2. advertising networks/agencies and
    3. search information providers.
  10. Contact, Financial and Transaction Data from providers of technical, payment and delivery services].
  11. Identity and Contact Data from data brokers or aggregators.
  12. Identity and Contact Data from publicly available sources.
How do we share your information?
  1. Information shared with everyone: Information such as your name and photo, your events, a list of your friends (following and followers), links to any of your social media accounts (i.e.Google+, LinkedIn, Twitter and Facebook) accounts (if you have connected those accounts to your GWFD account), the posts, publicly shared photos, comments you write and badges which are shared by default with the GWFD community.
  2. Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Our agents do not have any right to use Personal Information we share with them beyond what is necessary to assist us, and they provide a comparable level of protection for your Personal Information.
  3. Partners: In addition to the data sharing described above, we enter into relationships with a variety of businesses and work closely with them. In certain situations, these businesses sell items or provide promotions to you through GWFD’ Service. In other situations, GWFD provides services or sells products jointly with these businesses.
  4. Business Transfer: In the event that GWFD is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. The promises in this privacy policy will apply to your information as transferred to the new entity.
  5. Protection of GWFD and Others: We may release Personal Information when we believe in good faith that release is necessary to comply with the law, including laws outside your country of residence; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of GWFD, our employees, our users, or others. This includes exchanging information with other companies and organizations (including outside of your country of residence) for fraud protection and credit risk reduction.
  6. Non-Private or Non-Personal Information: We may share or disclose your non-private, aggregated or otherwise non-personal information, such as your public events, posts or the number of users who clicked on a particular link (even if only happened once).We oblige all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
How we use your personal data
  1. 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:
    1. Where we need to perform the contract, we are about to enter into or have entered into with you.
    2. 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.
    3. Where we need to comply with a legal or regulatory obligation.
  2. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to 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.
  3. Purposes for which we will use your personal data
    1. Performance of a contract with you
      1. We process your personal data because it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.In this respect, we use your personal data for the following:
        1. To prepare a proposal for you regarding the services we offer;
        2. To provide you with the services as set out in our Client Care Letter with you or as otherwise agreed with you from time to time;
        3. To deal with any complaints or feedback you may have;
        4. For any other purpose for which you provide us with your personal data.
      2. In this respect, we may share your personal data with or transfer it to the following:
        1. Your agents, advisers, intermediaries, and custodians of your assets who you tell us about;
        2. Subject to your consent, third parties whom we engage to assist in delivering the services to you, including third parties;
        3. Our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;
        4. Debt collection agencies where it is necessary to recover the money you owe us;
        5. Other third parties such as intermediaries who we introduce to you. We will wherever possible tell you who they are before we introduce you;
        6. Our data storage providers.
    2. Legitimate interests
      1. We also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person.In this respect, we use your personal data for:
        1. For the administration and management of our business, including recovering the money you owe to us, and archiving or statistical analysis;
        2. Seeking advice on our rights and obligations, such as where we require our own legal advice. In this respect, we will share your personal data with our advisers or agents where it is necessary for us to obtain their advice or assistance and with third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business.
    3. Legal obligations
      1. We also process your personal data for our compliance with a legal obligation which we are under. In this respect, we will use your personal data for the following:
        1. To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws;
        2. As required by tax authorities or any competent court or legal authority. In this respect, we will share your personal data with the following:
        3. Our advisers where it is necessary for us to obtain their advice or assistance;
        4. Our auditors where it is necessary as part of their auditing functions;
        5. With third parties who assist us in conducting background checks;
        6. With relevant regulators or law enforcement agencies where we are required to do so.
    4. Marketing
      1. We will send you marketing about services we provide which may be of interest to you, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you or in order to update you with information (such as legal or commercial news) which we believe may be relevant to you. We will communicate this to you in a number of ways including by post, telephone, email or other digital channels.
    5. Promotional offers from us
      1. 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 (Marketing).You will receive marketing communications from us if you have requested information from us or purchased services from us [or if you provided us with your details in case registered for a promotion] and, in each case, you have not opted out of receiving that marketing.
    6. Third-party marketing
      1. We will get your express opt-in consent before we share your personal data with any company outside the GWFD group of companies for marketing purposes.
      2. You can ask us or third parties to stop sending you marketing messages at any time [by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
    7. Cookies
      1. 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.
    8. Change of purpose
      1. 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.
Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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

How long will we use your personal data?We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.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 unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances, we may anonymize 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. If you wish to exercise any of the rights set out above, please contact us

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, if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What may we 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 may 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.

Your legal rights

You have the right to:

  1. Request access to your personal data (commonly known as a “data subject access request”)  – which is stored on Amazon Web Services (AWS) which is located in the United States. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  2. 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.
  3. 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.
  4. Object to the 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.
  5. 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  6. 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.
  7. 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.
What we do if the information is incorrect?

We do perform checks on the information that we receive to detect any defects or mistakes. However, we are reliant upon suppliers, namely Companies House, providing accurate information to us. You have the right to request that we:Rectify any personal data relating to you that is inaccurate; andComplete any incomplete data, including by way of a supplementing, corrective statement. This is known as the right to rectification. If you do exercise your right to rectification, we will take steps to check the information and correct it where necessary.

How do we deal with the “right to be forgotten”?

You have the right to request the erasure of personal data that we hold about you in certain circumstances, for example if it were not acquired for, or has ceased to be necessary for, a lawful purpose. This is known as the right to be forgotten. Where you request that we erase your data, we will usually only do so where the data has ceased to be publicly available, whether at Companies House or otherwise, or where we no longer use it.

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