WIN|WIN Privacy Policy

1. PURPOSE OF THIS PRIVACY NOTICE

The https://Fleetwood.winwin.ie website (the “Website”) is operated by Scream Ltd t/a WIN|WIN, (“WIN|WIN”, “we”, “our” and “us”) of Unit 3, Argyle Square, Morehampton Road, Dublin 4, D04 DC64, Ireland. WIN|WIN respects your right to data protection and privacy.

This Privacy Policy (“Notice”, “Policy”) sets out the basis on which we use, process, store or disclose any personal information about you (“Personal Data”) as detailed below, that we collect from you or that you provide to us through the Website. The Personal Data provided by you will be held by WIN|WIN as a processor on behalf of Fleetwood.

This Notice, together with our Website Terms of Service (the “Terms of Service”) and our Cookie Policy, applies to your use of the Website. We are not responsible for the content or privacy practices of other websites.

2. OVERVIEW OF THIS NOTICE

We process your Personal Data on behalf of Fleetwood, for the purpose of providing you with access to the Website. We may also process your Personal Data for the purposes of responding to your queries (where we will collect only the data you will directly share with us in order to respond to these queries – data such as your name, e-mail address, etc.), sending you reports or marketing communications.

3. WHAT PERSONAL DATA DO WE PROCESS?

We will process the following Personal Data about you when you visit the Website:

Personal Data Type	Details
Usage and Device Data	When you visit the Website or avail of services related to the Website, we will process your Personal Data relating to: your visits and interactions with the Website including which webpages you visit, time and date of access, what you click on or when you perform these actions; your device data including your IP address, location data, device type and language, browser type and other related information; linked third party websites that you access through the Website. Most of this Personal Data is processed using cookies on the Website. Please see our Cookie Policy for more information about how the Website uses different types of cookies.
Contact and Query Data	You may choose to give us your Personal Data, such as your name, e-mail address, title, company/employer details and other details relating to you when you interact with us by submitting queries to us (e.g. through using our Website forms or chatbot)

Personal Data Type

Details

Usage and Device Data

When you visit the Website or avail of services related to the Website, we will process your Personal Data relating to:

your visits and interactions with the Website including which webpages you visit, time and date of access, what you click on or when you perform these actions;
your device data including your IP address, location data, device type and language, browser type and other related information;
linked third party websites that you access through the Website.

Most of this Personal Data is processed using cookies on the Website. Please see our Cookie Policy for more information about how the Website uses different types of cookies.

Contact and Query Data

You may choose to give us your Personal Data, such as your name, e-mail address, title, company/employer details and other details relating to you when you interact with us by submitting queries to us (e.g. through using our Website forms or chatbot)

4. HOW & WHY DO WE USE YOUR PERSONAL DATA

The reasons why (“Legal Basis”) and how (“Purposes”) WIN|WIN processes your Personal Data on the Website are explained table:

Legal Basis	Purposes
Contractual Necessity	It is necessary to process your Personal Data to enter into and perform our contract with you, in particular: To provide you with access to the Website and to allow you to use the Website;
Consent	Where we process your Personal Data by using cookies on our Website, which are not necessary for the Website to operate, we require your consent to do so. Please see our Cookie Policy for more information.
Legitimate Interests	It is necessary to process your Personal Data for the purpose of pursuing our legitimate business interests. The specific purposes of our pursuing our legitimate business interests are detailed below: Queries or Requests: We will process your Personal Data to assess and respond to your Website interactions with us. For example, when you: e-mail a query or request to us; use our Website chatbot; request to talk to our sales team; request a demo of our services. Marketing: We will process your Personal Data for marketing purposes: when you choose to receive our marketing communications (e.g. our monthly newsletter) or when you subscribe to our mailing lists; Events: We will process your Personal Data to invite you to events and where we ask for your feedback after an event. Website Improvements & Functionality: We will process your Personal Data: to provide you with use of the Website and allow you to optimally browse the Website; to improve, test and monitor the effectiveness of the Website; to monitor metrics such as total number of visitors, traffic data and demographic patterns; to ensure the content on the Website is presented in the most effective manner for you and your device. Important: when we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your Personal Data protection rights. We will 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 by law). You have certain rights when we process your Personal Data on this basis, such as the right to object, right to be restriction, right to access, right to erasure. For more information on exercising this right please see section 8 of this Notice (Your Data Protection Rights).
Compliance with Legal Obligations	We may process your Personal Data where it is necessary to comply with legal obligations to which we are subject under European Union and/or European Union Member State laws, including but not limited to safeguarding and complying with law enforcement requests.
Legal Claims	We may process your Personal Data where it is necessary for WIN\|WIN to establish, investigate, exercise or defend a legal claim to which you are a party of.

5. SHARING OF YOUR PERSONAL DATA

Depending on our reasons for processing your Personal Data, we will share it with all or some of the following recipients (“Recipients”):

Business units within WIN|WIN (e.g. sales, marketing, legal, system administration and/or management);
External service providers who provide services to the Website or our business (e.g., Inc. Google, Inc. Google Analytics)
Professional advisors who provide professional services to us, such as legal advisors and consultants.

6. WHEN THIS NOTICE DOES NOT APPLY

The Website contains links to other websites and resources (“Linked Website(s)”) provided by third parties for your information and convenience only. WIN|WIN is not responsible for the privacy/data protection notices or practices of any Linked Website and does not accept liability in connection with any Linked Website.

This Notice only governs the Personal Data processed by WIN|WIN on the Website and not Linked Websites. When accessing Linked Websites, you should read the privacy/data protection notice published on the relevant Linked Website. We have no control over the contents of Linked Websites and accept no responsibility for them or for any loss or damage that may arise from your use of Linked Websites.

7. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

As mentioned, we will not collect your Personal Data, unless you directly share it with us by contacting us. In most cases we only act as a processor on behalf of Fleetwood.

Generally, your Personal Data will not be retained for long periods of time and, in most instances, it will be kept in line with the retention periods set out below:

Personal Data Type	Retention Period
Usage and Device Data	The length of your session on the Website.
Contact and Query Data	Queries/requests: the length of time it takes to address or conclude your query or request and, in some cases, a reasonable period of time after that to allow for follow-up actions; Marketing details: generally, 18 months but this period may be longer or shorter depending on whether you unsubscribe; Legal claims: the length of time it takes to establish, exercise or defend a claim plus a reasonable period of time after that to allow for follow-up actions; Legal obligation compliance: the period specified by the legislation (if any) or a reasonable period of time to demonstrate compliance with the legal obligation.

8. YOUR DATA PROTECTION RIGHTS

You have a number of rights in relation to your Personal Data, which are set out below. In particular, these rights include the right to object of processing of your Personal Data where that processing is carried out for our legitimate interests. Note that these rights are not absolute. You can exercise these rights by e-mailing datarequests@winwin.com. We will aim to respond to your request within one-month of receiving it. We may have to extend the timeline of our response by 2 further months if necessary but we will contact you if this need arises. Please also note that we may need to verify your identity when you exercise your data protection rights.

Your Rights	Details
Right to Information	You have a right to be provided with clear, transparent and easily understandable information about how we process your Personal Data. We give effect to this right by making this Notice available to you on the Website.
Right to Object	You have a right to object to our processing of your Personal Data where we rely on our legitimate business interests to process such data. You can request that we stop processing your Personal Data, and we will do so, unless we can demonstrate compelling legitimate grounds to continue processing your Personal Data or if we need your Personal Data in connection with any legal claims.
Right to Withdraw Consent (Cookies)	You have a right to withdraw your consent to our processing of your Personal Data at any time. You can withdraw your consent by updating your cookies preferences and/or unsubscribing using the “unsubscribe” link in any e-mails we send you.
Right of Access	You have the right to access the Personal Data we process about you. If you exercise this right, you will receive confirmation about whether we process your Personal Data and, if so, a copy of your Personal Data we currently have records of.
Right to Rectification	You have the right to correct the Personal Data we process about you if the Personal Data we hold about you is accurate or incomplete.
Right to Erasure	You have a right to request, in certain circumstances, the deletion of your Personal Data - for example if you exercise the right to object and we do not have an overriding reason to continue processing your Personal Data or if we no longer need to process your Personal Data.
Right to Restriction	You have the right, in certain circumstances, to restrict our processing of your Personal Data – for example, if you contest the accuracy of the Personal Data we hold about you or you object to us processing your Personal Data.
Right to Lodge a Complaint	You have the right to lodge a complaint with the Data Protection Commission (“DPC”) about our processing of your Personal Data. To do so, use the DPC’s “Raise a Concern” form . We encourage you to contact us before raising a concern with the DPC to see if we can resolve any concerns you have about our processing of your Personal Data.

9. CONTACT US

If you have any questions, comments or concerns about the way your Personal Data are being used or processed by WIN|WIN, please submit your question, comment or concern by e-mailing: datarequests@winwin.com

10. CHANGES TO THIS NOTICE

This Notice will be regularly reviewed and may be amended and updated as necessary. Any updates to this Notice will be posted to this section of the Website.