Tel: +44 (0)1785 827600
privacy

Privacy Policy

Last revised 23rd July 2018


  1. Introduction

Thanks for choosing Winning Moves!


We aim to give you the best experience possible, at all times. Our intention is to give you a user experience that knocks your socks off, in terms of the ease of use of our systems, how great they look and what they can do. We also recognise that part of you using our systems is knowing that the data you put in to our systems is safe and secure. This policy sets out how and why we gather personal data, what we do with it, how long we keep it for and what your rights are with regard to the data that we hold.


  1. About our Policy

This Privacy Policy coves how we use your data. The terms governing your use of our systems and services are outlined in our licence agreements with you and our published terms and conditions of use.


From time to time we may develop new services and/or may give you access to additional services that we already have. If not otherwise stated, this Policy will continue to apply. However, if our actions results in a change to the way we deal with your personal data, we’ll tell you about it.


This Policy covers all of our existing systems and will be reviewed from time to time. We will undertake to review this policy where:

  • We introduce a new system/service;

  • We develop new functionality which requires the collection of additional data from you;

  • We change the personal data that we collect or how we process it;

  • We change the length of time we retain any personal information;

  • There is a change in the law;

  • Or at any rate, at least every 6 months.


The systems falling within the scope of this Policy are:

  • Benchmark Index (also branded as Winning Measures)

  • Skills Needs Analysis

  • Virtual Adviser

  • Tourism Portal

  • Winning CRM

  • Workplace Innovation Tool


If you need further clarity on this Policy, please contact us using the details in the Contact us section (below).


Winning Moves Ltd is both a data controller and data processor for the purposes of its systems. We are a data controller because we decide the personal information we need to collect from you so that we can provide the services to you. We are a data processor because we store and analyse the information that you provide to us.


As a user of our systems you are a data processor as you input data in to our systems in order to access and/or produce a report from these. In some circumstances you will also be a data controller e.g. where our systems allow you to add your own content. Where you do add your own content, you must make sure it does not infringe anyone’s personal rights under the General Data Protection Regulations as you could be held liable for prosecution.

  1. What personal data do we collect

The new General Data Protection Regulations provide certain rights for you, and obligations for us as a data controller and/or processor in relation to the personal data that you provide only. Personal data is anything from which a living individual can be identified. Therefore some data that you input in to our systems will be naturally excluded from the scope of this Policy as it is not personal information e.g. limited company financials.


The following personal data is collected through our systems:


Benchmark Index (Winning Measures)

Skills Needs Analysis

Virtual Adviser

Tourism Portal

Winning CRM

Adviser Details

Name




Contact Address and Postcode




Contact Number




Email address




Photo





Day rate information





Date contracted





For businesses advisers are supporting

Business Name




Contact Name




Contact Address




Contact Phone number




Sole Trader financials (raw data)





Sole trader performance information (output report)






Type of support provided*





Value of support provided*





Documentation relating to the support provided e.g. deminimis forms, business assist sheets





For individuals accessing systems directly

Name




Contact Address and postcode




Email address




Contact phone number




Responses to question sets




Personalised output reports providing information and guidance on how to improve




Preferences in terms of the information they wish to see



Contact details for others within the business





* only becomes personal data when combined with other data to identify the individual e.g. business name (if sole trader) or individuals name


  1. Why do we collect this personal data?

Adviser Details

  • So that we can give you access to our services

  • So that we can manage and administer your user account, including suspending access where licence periods have ended

  • So that we can search your details to offer you opportunities of being involved with bids and of working with us

  • So that we can determine project costs

  • So that we can manage our contract with you for the supply of services

  • To communicate with you directly to advise of system downtime, changes and new functionality

For businesses advisers are supporting

  • So that advisers can input the correct performance information against the correct business

  • So that we can generate a personalised output report for the businesses, detailing how they are positioned vs. The marketplace

  • So that we can analyse, aggregated performance data to give anonymised market assessments

  • So that we can aggregate performance data to give anonymised percentile information against which to plot the specific company and show their individual performance

  • So that we can determine the amount of support provided and ensure businesses do not exceed their entitlement

  • So that we can comply with the requirements of the Department for Communities and Local Government for the management of European Funded projects


For individuals accessing systems directly

  • So that we can give you access to our services

  • So that we can manage and administer your user account, including suspending access where licence periods have ended

  • So that we can show you the information you want to see and that is relevant to you

  • So that we can give others in your business access to our systems

  • To communicate with you directly to advise of system downtime, changes and new functionality


  1. What do we do with your personal data?

We only retain your personal data for as long as we need to, to perform our contract of service with you, for legitimate business reasons or to comply with other legal requirements. We do not sell or share your data with third parties, though our systems may provide the functionality for our users to share data with third parties for the purposes of allowing others to contact you to offer direct business support that you have asked for.


Personalised output reports are deleted within 30 days of them being produced however we do retain the aggregated, anonymised performance data.


No data is publicly available through our systems, though we may use publicly available information to help populate your details in our systems e.g. companies House data.


Sharing your Data

Whilst we do not generally share your information, we need to from time to time.


Category of Recipient

Reason for Sharing

Service Providers and Others

We use technical service providers which may operate the technical infrastructure that we need to provide our systems, in particular providers which host, store, manage, and maintain our applications, its content and the data we process. 

Group Companies

Winning Moves is part of The Winning Group. From time to time we may need to share your data with other Group companies for the purposes of our Group financial data e.g. number of transactions, maintaining the services to you and for statistical analysis

Law Enforcement and Data Protection Authorities

We will share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. 

We also will share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection

Purchasers of our business

We will share your personal data in those cases where we sell or negotiate to sell our business to a buyer or prospective buyer. In this situation, Winning Moves will continue to ensure the confidentiality of your personal data and give you notice before your personal data is transferred to the buyer or becomes subject to a different Privacy Policy.



We store all personal data securely with regular back-ups running to prevent data loss or corruption.


  1. Security measures around your personal data – Keeping your personal data safe


We are committed to protecting the personal data held within our systems. We implement appropriate technical and organisational measures to help protect the security of your personal data; however please note that no system is ever completely secure. We have implemented various policies and practices including pseudonymisation of data, encryption, access and data retention policies to guard against unauthorised access and unnecessary retention of personal data in our systems


Your password protects your account, so we encourage you to use a unique, strong password, limit access to your computer and browser and log out when you have finished using our systems. It is a part of the terms and conditions of you use of our systems that you do not share your username and password with any other person.


  1. Your rights in relation to your personal data


You have a right to request details of any personal data we hold about you, aong with rights to have that data corrected (if incorrect), deleted and/or anonymised. If you wish to exercise these rights, please make a request in writing using the details in the Contact us section of this policy. We will respond to all written requests within 1 month of receipt. If we can’t comply with your request we’ll tell you why not. In certain circumstances, we may be legally required to maintain certain personal data e.g.:

  • If there is an unresolved issue relating to your account such as outstanding payments or an unresolved claim or dispute we will retain personal data until the issue is resolved;

  • Where the law dictates we retain personal information for financial, audit, tax, legal or accounting obligations;

  • Where our legitimate business interests require us to e.g. to maintain the security of our users

  1. Transfer of your data to other countries

We may transfer your personal data to other countries. Where we do so, we ensure those other countries are either within the European Economic Area or have been deemed to have equivalent levels of protections for safeguarding data.


  1. Links/Advertisements

Some of our systems may display advertisements and links to third parties. We cannot be held responsible for third parties’ privacy practices and content. If you click on any third party link, you are leaving the Winning Moves service and this Privacy Policy will not apply once you leave our service. Please read their respective Privacy Policies before you provide any personal data.


  1. Children

Winning Moves does not target its services at those under 13 years of age. In most instances, the process for getting a licence for our system will safeguard against use by children. However:

  1. If you are under 13 years and seeking to use our systems, please do not register

  2. If you are aware someone under 13 has registered to use our system, please contact us using the Contact Information section of this Policy.


If we become aware we have data related to a person under the age of 13, we will take reasonable steps to remove that data from our system which may include deleting any account/s.


  1. Changes to this Policy

Sometimes we’ll need to change and update this Policy. If we do, we’ll tell you and give you enough notice, as circumstances permit, that things are changing. Please make sure you read the Policy carefully and take note of any notices we send you to advise of changes.


  1. Contact us

You can contact us in the following ways:

Email to: dataprotection@winningmoves.com

By post to: Winning Moves Ltd

Baskerville House

2, Centenary Square

Birmingham

B1 2ND

England