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Privacy & Cookies Policy

My Wind Phone (“MWP” or “We”) is committed to protecting and respecting your (“you” or “your”) privacy. This policy sets out the basis on which any Personal Data we collect from you or provide to us will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Data and how we treat it.

1. Definitions

In this policy the following words have the following meanings: "Data Protection Laws" means any Applicable Law relating to the processing, privacy, and use

of Personal Data, including (a) in the United Kingdom, (i) the Data

Protection Act 1998 and the Privacy and Electronic Communications

(EC Directive) Regulations 2003, SI 2003/2426, and any laws or

regulations implementing Directive 95/46/EC (Data Protection

Directive) or Directive 2002/58/EC (ePrivacy Directive); and/or (ii) the

General Data Protection Regulation (EU) 2016/679 (GDPR), and/or

any corresponding or equivalent national laws or regulations (Revised

UK DP Law) (b) in member states of the European Union, the Data

Protection Directive or the GDPR, once applicable, and the ePrivacy

The directive, and all relevant member state laws or regulations giving

effect to or corresponding with any of them; and (c) any judicial or

administrative interpretation of any of the above, any guidance,

guidelines, codes of practice, approved codes of conduct or approved certification mechanisms issued by any relevant Supervisory

Authority; "Personal Data" means any information relating to an identified or identifiable natural person ("Data Subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person and where referred to in this policy includes special categories of Personal Data.

2. Information we collect from you. This is information about you that you give us by contacting us

via our website www.mywindphone (“our site”) or by corresponding with us by phone, email, or otherwise. The information you give us may include your name, address, e-mail address, and phone number.

3. Information we receive from other sources. We are working closely with third parties (including, for example, analytics providers). Please see our cookies policy for further details.

4. Children’s Privacy.

Our site is not directed to children under the age of 13 and we do not knowingly solicit or collect information from children under the age of 13 without prior parental consent. If we learn that a child under the age of 13 has submitted Personal Data to us without parental consent, we will take all reasonable measures to delete such information from our databases and/or not use such information for any purpose (except as necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any Personal

Data we have collected from a child under 13, please contact us as indicated in the Contact section

of this Policy.

5. Cookies.

Through Google Analytics, our website uses cookies. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

6. Uses made of the information

6.1. We will only use your Personal Data to the extent that the law allows us to do so. Under the GDPR we rely on the following legal bases for processing your Personal Data:

6.1.1. where you have given us your consent.

6.1.2. where it is necessary to perform a contract, we have entered into or are about to enter into with you; or

6.1.3. where it is necessary for the purposes of our legitimate interests (or those of a third party) and your interests or fundamental rights and freedoms do not override those


6.2. We use information held about you in the following ways:

6.2.1. processing of an inquiry received from you; or

6.2.2. processing a request for further information or in response to you expressing an interest in one or more of our products or services.

6.3. Information you give to us. We will use this information:

6.3.1. to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products, and services that you request from us;

6.3.2. to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;

6.3.3. to provide you with information about goods or services related to your inquiry.

6.3.4. to notify you about changes to the service we provide; and

6.3.5. to ensure that content from our site is presented in the most effective manner for you and for your computer.

6.4. Information we collect about you. We will use this information:

6.4.1. to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

6.4.2. to improve our site to ensure that content is presented in the most effective manner for you and for your computer; and

6.4.3. as part of our efforts to keep our site safe and secure.

6.5. Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We will use this information

and the combined information for the purposes set out above (depending on the types of information we receive).

7. Disclosure of your information

7.1. You agree that we have the right to share your Personal Data with:

7.1.1. Selected third parties including business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you;

7.1.2. analytics and search engine providers that assist us in the improvement and optimization of our site;

7.2. We will not disclose your personal information to third parties except:

7.2.1. In the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets.

7.2.2. If MWP or substantially all of its assets are acquired by a third party, in which case Personal Data held by its customers will be one of the transferred assets.

7.2.3. If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce other agreements; or protect the rights,

property, or safety of MWP., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

8. Where we store your Personal Data

8.1. All information you provide to us is stored on our secure servers.

8.2. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

9. Retention of Personal Data

9.1. We will only retain your Personal Data for as long as necessary to fulfill the purposes for which

we collected your Personal Data.

9.2. 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 that Personal Data, and the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

10. Your rights under GDPR

Under certain circumstances, you have the right to:

10.1 Request access to your Personal Data (commonly known as a ‘subject access request’). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

10.2 Request correction of the Personal Data that we hold about you. This enables you to have any

incomplete or inaccurate information we hold about you corrected.

10.3 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 to continue to process it. You also have the right to ask us to delete or remove your Personal Data in certain circumstances.

10.4 Object to 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.

10.5 Request the restriction of processing of your Personal Data. This enables you to ask us to

suspend the processing of Personal Data about you, for example, if you want us to establish its

accuracy or the reason for processing it.

10.6 Request the transfer of your Personal Data to another party.

10.6.1 If you want to review, verify, correct or request the erasure of your Personal Data, object

to the processing of your Personal Data, or request that we transfer a copy of your Personal Data to another party, please contact us as indicated in the Contact section of this Policy.

10.6.2 Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note

that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any

Personal Data to these websites.

10.7 To exercise any of the above rights, you can contact MWP using the information in Section 14 below. You may also have the right to make a GDPR complaint to the relevant

Supervisory Authority. A list of Supervisory Authorities is available here:

11. Privacy Shield Frameworks for EU and Swiss Citizens

MWP complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and

retention of personal information from European Union member countries (including Iceland,

Liechtenstein, and Norway) and Switzerland transferred to the United States pursuant to

Privacy Shield. MWP has certified that it adheres to the Privacy Shield Principles with respect to

such data. If there is any conflict between the policies in this privacy policy and data subject

rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn

more about the Privacy Shield program, and to view our certification page, please visit

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