Privacy Policy

AN OVERVIEW OF DATA PROTECTION

General information

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all information that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Privacy Policy set out below.

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The data on this website is processed by the operator of the website, Winter & Co. UK Limited, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the UK GDPR)” in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form or when placing an order.Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyse your user patterns. Other data is used in order to communicate with you to manage our relationship or to process and deliver your order.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or erased. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analysed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.For detailed information about these analysis programs please consult our Privacy Policy below.

2. Hosting and Content Delivery Networks (CDN)

We are hosting the content of our website at the following provider:

External Hosting

This website is hosted externally. Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.The external hosting serves the purpose of fulfilling the contract with our potential and existing customers and in the legitimate interest of secure, fast, and efficient provision of our online services by a professional provider. If appropriate consent has been obtained, the processing is carried out exclusively on that basis, insofar the consent includes the storage of cookies or the access to information in the user's end device (e.g., device fingerprinting). This consent can be revoked at any time.Our host(s) will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.We are using the following host:Google LLC1600 Amphitheatre Parkway, Mountain ViewCA 94043, USA

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Google Cloud CDN

We use the Google Cloud CDN content delivery network. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.Google offers a globally distributed content delivery network. Technically, the transfer of information between your browser and our website is routed through the Google network. This enables us to increase the global accessibility and performance of our website.The use of Google Cloud CDN is based on our legitimate interest to ensure the most error-free and secure provision of our website.Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://cloud.google.com/terms/eu-model-contract-clause.You can find more information about Google Cloud CDN here: https://cloud.google.com/cdn/docs/overview?hl=en.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

3. General information and mandatory information

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Privacy Policy.

We keep our privacy policy under regular review. [This version was last updated in March 2026]. Whenever you use this website, a variety of personal information will be collected. Personal data comprises information that can be used alone or with other information to personally identify an individual. This Privacy Policy explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

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.

INFORMATION ABOUT THE RESPONSIBLE PARTY (REFERRED TO AS THE “CONTROLLER” IN THE GDPR)

The data processing controller on this website is:

Winter & Co. UK Limited (company number: 00998715)
Stonehill
Huntingdon
Cambridgeshire
PE29 6ED
Phone: +44 1480 377177
E-mail: sales@winteruk.com 

The controller is the legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us using the above details.

STORAGE DURATION

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

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

• Identity Data includes first name, last name, username or similar identifier, title.
• 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, browser plug-in types and versions, operating system and platform, device ID 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.
• Usage Data includes information about how you interact with and 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 which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

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, for example a new address or email address.

HOW IS YOUR PERSONAL DATA COLLECTED?

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

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for 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 within this document.

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Technical Data is collected from the following parties:

• analytics providers such as Google based outside the UK;
• advertising networks; and
• search information providers.

Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services such as Stripe LLC based outside the UK.

Identity and Contact Data is collected from publicly available sources such as Companies House based inside the UK.

GENERAL INFORMATION ON THE LEGAL BASIS FOR THE DATA PROCESSING ON THIS WEBSITE

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).

Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

INFORMATION ON INTERNATIONAL DATA TRANSFERS

We share your personal data within the Winter & Co Group of entities. This will involve transferring your data outside the UK to our overseas offices in:

• Germany
• Switzerland
• USA & Canada

We host the personal data we process in relation to this website and our online shop on cloud infrastructure located in the European Union, currently in data centres in the Netherlands and Belgium. These countries form part of the EU/EEA and are subject to adequacy regulations under UK data protection law, so transfers of personal data from the UK to these locations are not considered “restricted transfers” under the UK GDPR. If, in the future, personal data were to be transferred on from these locations to countries that are not subject to an adequacy decision pursuant to UK law, we will implement appropriate safeguards before any such transfer takes place, in the form of an International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses.

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

For example, we use, among other technologies, tools from companies located in third-party countries that are not safe under data protection law, as well as US tools whose providers are not certified under the UK Extension to the EU-US Data Privacy Framework (DPF). If these tools are enabled, your personal data may be transferred to and processed in these countries. We would like you to note that no level of data protection comparable to that in the UK can be guaranteed in third countries that are insecure in terms of data protection law.We would like to point out that the US, as a secure third-party country, generally has a level of data protection comparable to that of the EU. Data transfer to the US is therefore permitted if the recipient is certified under the “UK Extension to the EU-US Data Privacy Framework” (DPF) or has appropriate additional assurances. Information on transfers to third-party countries, including the data recipients, can be found in this Privacy Policy.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely, the USA and Ireland.

DISCLOSURES OF PERSONAL DATA

In the scope of our business activities, we cooperate with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is required as part of the fulfilment of a contract, if we are legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure, or if another legal basis permits the disclosure of this data.

When using processors, we only disclose personal data of our customers on the basis of a valid contract on data processing. In the case of joint processing, a joint processing agreement is concluded. We require 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.

YOUR LEGAL RIGHTS

REVOCATION OF YOUR CONSENT TO THE PROCESSING OF DATA

A wide range of data processing transactions are possible only subject to your express consent. You can revoke, at any time, any consent you have given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation. 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.

RIGHT TO OBJECT TO THE COLLECTION OF DATA IN SPECIAL CASES; RIGHT TO OBJECT TO DIRECT ADVERTISING

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF LEGITIMATE INTEREST (OURS OR THOSE OF A THIRD PARTY), YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS PRIVACY POLICY. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS.IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA FOR THOSE PURPOSES AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES.

RIGHT TO LOG A COMPLAINT WITH THE COMPETENT SUPERVISORY AGENCY

In the event of violations of the GDPR, data subjects are entitled to log a complaint with the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint. You can raise your complaint with us via email to sales@winteruk.com

RIGHT TO DATA PORTABILITY

You have the right to have data that we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

INFORMATION ABOUT ACCESS TO, RECTIFICATION AND ERADICATION OF DATA

Within the scope of the applicable statutory provisions, you may request a copy of the personal data we hold about you and to check that we are lawfully processing it. You may also require us to rectify any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us. In certain circumstances you may 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, 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. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

RIGHT TO DEMAND PROCESSING RESTRICTIONS

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

In the event that you should dispute the accuracy of your data held by us. We will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we suspend the processing of your personal data.

If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.

If we do not need your personal data any longer but you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.

If you have raised an objection to our use of your data for legitimate interests, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

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.

SSL AND/OR TLS ENCRYPTION

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

REJECTION OF UNSOLICITED E-MAILS

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

4. RECORDING AND OTHER PROCESSING OF DATA ON THIS WEBSITE

COOKIES

Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into websites (e.g., cookies for handling payment services).Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos). These are known as “essential cookies” or “strictly necessary cookies”. Other cookies may be used to analyse user behaviour (“Analytical cookies”) or for promotional purposes (“Targeting cookies”).Cookies, which are required for the performance of electronic communication transactions, for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of legitimate interests, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis of the consent obtained; this consent may be revoked at any time.You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete-function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.Which cookies and services are used on this website can be found in this privacy policy.

SERVER LOG FILES

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

• The type and version of browser used
• The used operating system
• Referrer URL
• The hostname of the accessing computer
• The time of the server inquiry
• The IP address

This data is not merged with other data sources.This data is recorded on the basis of legitimate interests. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

SPECIFIC COOKIES USED ON OUR WEBSHOP, THEIR PURPOSE AND DURATION

ESSENTIAL COOKIES (FIRST PARTY)

• CraftSessionId — maintains your session (session cookie)
• CRAFT_CSRF_TOKEN — protects forms from CSRF (session cookie)
• <hash>_identity — remembers your login (up to 1 hour)
• <hash>_username — remembers your last username (up to 1 year)
• <hash>_commerce_cart — stores your cart ID (up to 1 year)

THIRD PARTY COOKIES

• __stripe_mid — fraud prevention and payment security (up to 2 years; set by Stripe)

Cookies being set by only visiting the sign-in page (prior to login): CRAFT_CSRF_TOKEN

These are standard Craft/Commerce/Stripe runtime cookies. These cookies are all technical cookies and as such are not used for marketing/tracking purposes.

Craft is the Content Management System (CMS) and Commerce is the store plugin for the CMS. Stripe is the Payment Service Provider for all transactions.

CONTACT FORM

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.The processing of these data is based on necessity to perform a contract with you or take steps at your request, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us or on your agreement if this has been requested; the consent can be revoked at any time.The information you have entered into the contact form shall remain with us until you ask us to erase the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.

REQUEST BY E-MAIL, TELEPHONE, OR FAX

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.These data are processed on the basis of necessity to perform a contract with you or take pre-contract steps you request if your inquiry is related to the fulfilment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us or on the basis of your consent if it has been obtained; the consent can be revoked at any time.The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

COMMUNICATION VIA WHATSAPP

For communication with our customers and other third parties, one of the services we use is the instant messaging service WhatsApp. The provider is WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.The communication is encrypted end-to-end (peer-to-peer), which prevents WhatsApp or other third parties from gaining access to the communication content. However, WhatsApp does gain access to metadata created during the communication process (for example, sender, recipient, and time). We would also like to point out that WhatsApp has stated that it shares personal data of its users with its U.S.-based parent company Meta. Further details on data processing can be found in the WhatsApp privacy policy at: https://www.whatsapp.com/legal/#privacy-policy.The use of WhatsApp is based on our legitimate interest in communicating as quickly and effectively as possible with customers, interested parties and other business and contractual partners. If a corresponding consent has been requested, data processing is carried out exclusively on the basis of the consent; this consent may be revoked at any time with effect for the future.The communication content exchanged between and on WhatsApp remains with us until you request us to delete it, revoke your consent to storage or the purpose for which the data is stored ceases to apply (e.g. after your request has been processed). Mandatory legal provisions, in particular retention periods, remain unaffected.The company is certified in accordance with the “UK Extension to the EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US (which has been extended by the UK pursuant to the UK-US data bridge), which is intended to ensure compliance with UK data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/7735.We have concluded a data processing agreement (DPA) with the above-mentioned provider.

REGISTRATION ON THIS WEBSITE

You have the option to register on this website to be able to use additional website functions, such as placing orders for our products or services. We shall use the data you enter only for the purpose of using the respective offer or service you have registered for. The required information we request at the time of registration must be entered in full. Otherwise, we shall reject the registration.To notify you of any important changes to the scope of our portfolio or in the event of technical modifications, we shall use the e-mail address provided during the registration process.We shall process the data entered during the registration process on the basis of your consent.The data recorded during the registration process shall be stored by us as long as you are registered on this website. Subsequently, such data shall be deleted. This shall be without prejudice to mandatory statutory retention obligations.

PLACING ORDERS FOR PRODUCTS AND/OR SERVICES ON THIS WEBSITE

When you place an order for products and/or services, you will be required to provide identity data, contact data and financial data. We shall use the data you provide together with transaction data in order to process and deliver your order, including the management of fees, payments and charges and collection and recovery of money owed. The legal basis of our data processing will be performance of a contract with you and, if we need to recover any money from you, this will be in our legitimate business interests.

5. ANALYSIS TOOLS AND ADVERTISING

GOOGLE TAG MANAGER

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, IrelandThe Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.The Google Tag Manager is used on the basis of legitimate interests. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on his website. If appropriate consent has been obtained, the processing is carried out exclusively on that basis, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting). This consent can be revoked at any time.

GOOGLE ANALYTICS

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.Google Analytics enables the website operator to analyse the behaviour patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. This data is summarized in a user-ID and assigned to the respective end device of the website visitor.Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Google Analytics uses various modelling approaches to augment the collected data sets and uses machine learning technologies in data analysis.Google Analytics uses technologies that make the recognition of the user for the purpose of analysing the user behaviour patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored.The use of these services occurs on the basis of your consent. You may revoke your consent at any time.Data transmission to the US is based on International Data Transfer Addendum to the EU Commission Standard Contractual Clauses (SCC). Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

BROWSER PLUG-IN

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

CONTRACT DATA PROCESSING

We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the UK data protection legislation to the fullest when using Google Analytics.

6. MARKETING COMMUNICATIONS

MAILSHOTS

If you would like to receive mailshots, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the mailshots. This is information you may provide on registration of your account on our website. Further data is not collected or is only provided by you on a voluntary basis. For the handling of the mailshot, we use service providers, which are described below.

OPTING OUT OF MARKETING

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us at sales@winteruk.com.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations, updates to our Terms and Conditions, checking that your contact details are correct.

MAILCHIMP

This website uses the services of Mailchimp to send out its newsletters. The provider is the Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.Among other things, Mailchimp is a service that can be deployed to organize and analyse the sending of newsletters. Whenever you enter data for the purpose of subscribing to a newsletter (e.g. your e-mail address), the information is stored on Mailchimp servers in the United States.With the assistance of the Mailchimp tool, we can analyse the performance of our newsletter campaigns. If you open an e-mail that has been sent through the Mailchimp tool, a file that has been integrated into the e-mail (a so-called web-beacon) connects to Mailchimp’s servers in the United States. As a result, it can be determined whether a newsletter message has been opened and which links the recipient possibly clicked on. Technical information is also recorded at that time (e.g. the time of access, the IP address, type of browser and operating system). This information cannot be allocated to the respective newsletter recipient. Their sole purpose is the performance of statistical analyses of newsletter campaigns. The results of such analyses can be used to tailor future newsletters to the interests of their recipients more effectively.If you do not want to permit an analysis by Mailchimp, you must unsubscribe from the newsletter. We provide a link for you to do this in every newsletter message.The data is processed based on your consent. You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation.The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.Data transmission to the US is based on the International Data Transfer Addendum issued by the Information Commissioner's Office under S.119(A) of the UK Data Protection Act 2018, as updated or amended from time to time (the “UK Addendum”) and the Standard Contractual Clauses (SCC) of the European Commission as amended from time to time by the UK Addendum. Details can be found here: https://mailchimp.com/eu-us-data-transfer-statement/ and https://mailchimp.com/legal/data-processing-addendum/#Annex_C_-_Standard_Contractual_Clauses.After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist, if such action is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.For more details, please consult the Data Privacy Policies of Mailchimp at: https://mailchimp.com/legal/terms/.

DATA PROCESSING

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

7. PLUG-INS AND TOOLS

GOOGLE RECAPTCHA

We use “Google reCAPTCHA” (hereinafter referred to as “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.The purpose of reCAPTCHA is to determine whether data entered on this website (e.g., information entered into a contact form) is being provided by a human user or by an automated program. To determine this, reCAPTCHA analyses the behaviour of the website visitors based on a variety of parameters. This analysis is triggered automatically as soon as the website visitor enters the site. For this analysis, reCAPTCHA evaluates a variety of data (e.g., IP address, time the website visitor spent on the site or cursor movements initiated by the user). The data tracked during such analyses are forwarded to Google.reCAPTCHA analyses run entirely in the background. Website visitors are not alerted that an analysis is underway.Data are stored and analysed on the basis of legitimate interests. The website operator has a legitimate interest in the protection of the operator’s websites against abusive automated spying and against SPAM. If appropriate consent has been obtained, the processing is carried out exclusively on that basis, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting). This consent can be revoked at any time.For more information about Google reCAPTCHA please refer to the Google Data Privacy Declaration and Terms Of Use under the following links: https://policies.google.com/privacy?hl=en and https://policies.google.com/terms?hl=en.

8. ECOMMERCE AND PAYMENT SERVICE PROVIDERS

PROCESSING OF CUSTOMER AND CONTRACT DATA

We collect, process, and use personal customer and contract data for the establishment, content arrangement and modification of our contractual relationships. Data with personal references to the use of this website (usage data) will be collected, processed, and used only if this is necessary to enable the user to use our services or required for billing purposes. The legal basis for these processes is necessity for the performance of a contract with you or to take steps at your request prior to entering into a contract.The collected customer data shall be deleted upon completion of the order or termination of the business relationship and upon expiration of any existing statutory archiving periods. This shall be without prejudice to any statutory archiving periods.

CREDIT CHECKS

We may conduct a credit check in the event that purchases are made on account or based on other payment terms that require us to extend credit (scoring). For this purpose, we transmit the data you have entered (e.g., name, address, age, or banking information) to a credit information agency. Based on this data, the probability of non-payment is determined. If the likelihood of non-payment is excessive, we may reject the respective payment term.The credit check is performed on the basis of contractual fulfilment necessity for the performance of a contract with you or to take steps at your request prior to entering into a contract and to avert non-payment (justified legitimate interest). If consent has been obtained, the credit check shall be performed on that basis; the consent may be revoked at any time.