Privacy Policy

SECTION 1 - WHO WE ARE

This website is owned and operated by Highbury Studio Ltd. trading as “Wink!”. Our company information and contact details can be found on our site.

SECTION 2 - WHAT’S THE POINT OF THIS POLICY?

It tells you what to expect when we collect personal information from users of our website. Please only use our services if you are completely happy with this policy.

Generally, the policy covers only information provided to us. If you give personal information to other people, such as payment providers or other websites, please check their privacy policies.

SECTION 3 - MIGHT THE POLICY CHANGE?

We will take reasonable steps to give you notice of the new version.

SECTION 4 - WHAT DO WE COLLECT?

The information which you upload to our service or otherwise give us such as your name and contact details; other information you provide to us such as proof of ID that we may require for verification purposes; account information such as your username and password; details about your transactions on our service; information that you include in communications with us including surveys and feedback; and contact or other information which you give or allow us to use for newsletters or other marketing.

Automated information about your use of our service such as: the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, log in details, the site from which you arrived at our service, details of your activity with date/time stamps including pages you visited and your searches/transactions.

The following information about you may be provided to us by other people:

Limited billing information sent to us by our payment provider for verification purposes e.g., your name, email address and billing address.

SECTION 5 - WHAT’S OUR REASON / LEGAL BASIS FOR COLLECTING THE INFORMATION?

Because it’s necessary to take steps at your request to enter into a contract with you and/or to perform such a contract. This applies to information such as initial enquiries and to account, contact, transaction and profile information.

Because it’s in our legitimate interests, e.g., sending marketing communications to customers about our similar products, managing and improving our service including tracking usage patterns and preventing or detecting fraud or abuse. This applies to information such as contact details, automated usage data and to surveys and feedback.

Because you’ve specifically agreed on our service (e.g., by selecting a consent box). This may apply to contact or other information that you specifically agree to us using for certain kinds of marketing. You can withdraw permission at any time as explained on our service or by emailing us at the above email address.

SECTION 6 - HOW LONG DO WE KEEP PERSONAL INFORMATION?

Until you ask us to delete it or our contract with you has ended.

We may nonetheless hold on to some (or all) of your information for longer if reasonably needed for legal, regulatory or tax reasons, deal with disputes, prevent fraud or abuse and/or enforce our terms and conditions (typically up to six years).

We will keep your information which we use only for newsletters or other marketing until you tell us to stop sending you such messages.

We will generally keep automated browsing information for up to 26 months.

SECTION 7 - TO WHOM DO WE SEND OR MAKE AVAILABLE YOUR PERSONAL INFORMATION?

To other people who supply us with services, e.g., delivering goods, website hosting and management, payment, customer service, email distribution, e-commerce, analytics, review management, customer survey, live chat etc.

To regulators, the police and other law enforcement or official authorities to help deal with fraud and abuse and/or comply with legal requirements and/or to protect us or others.

To insurers and professional advisers in connection with our insurance cover or to deal with legal claims.

To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.

SECTION 8 - DO WE SEND YOUR INFORMATION OUTSIDE THE UK?

Your personal information which we collect is stored within the UK and is not transferred to any other countries except as follows.

Your personal information (e.g., name, contact details, IP address, browsing information) may be transferred outside the UK (generally to the US) by companies that provide us with hosting, e-commerce, analytics, email distribution and other services.

If so, we will ensure that there is a legal basis to do so, for example under contracts with standard contractual clauses sanctioned by the Information Commissioner that are designed to provide adequate safeguards for your personal information.

We may need to send your contact information to delivery companies in your country, including outside the UK/EEA, to enable us to perform the contract with you.

SECTION 9 - WHAT RIGHTS DO YOU HAVE?

If the legal requirements are met: To ask us for access to your personal information, to rectify it if there are mistakes, to delete it or restrict its use in certain circumstances or to “data portability” or to withdraw any consent you’ve given (e.g. marketing).

You may also have the right to object to the use of your personal information in certain circumstances.

If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you have the right to complain to the Information Commissioner’s Office (ICO).

For more information about your rights, visit the ICO’s website: ico.org.uk.

SECTION 10 - WHAT ABOUT COOKIES?

We and/or other companies use cookies and other tracking technologies on our website. A cookie is an identifier (a small file of letters and numbers) that is sent to your web browser. Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the website owner or others. Some are session temporary “session” cookies that remain in the cookie file of your browser only until your browser is closed. Whereas persistent cookies stay for longer (depending on the lifetime of the specific cookie). For further information on cookies, including how to use your browser to block them and how to delete existing cookies, visit: allaboutcookies.org. Our site’s functionality will be limited if you configure your browser to reject cookies.

We ourselves may place the following types of cookies:Companies which provide us with a service also place cookies. Some of these cookies (e.g., from Google) may involve certain information, such as your name and contact details and/or the IP and web address of the page you’re visiting, being sent to the company concerned. Below is a summary of the kinds of cookies used together with details about who places them and where you can go to get more information and to opt out (where possible):

Policy Version 1.1 Effective Date: 18/03/2024