privacy policy

Last revised 30th March 2020

1. Introduction

Thanks for choosing Winning Moves and using our website!

Winning Moves is a business support consultancy based in Birmingham, England and trades under the brands of Winning Moves and Databuild. We also have a not-for-profit brand – the Centre for Digital Technology Adoption (“CDTA”). C4dta.co.uk is the registered web domain for the CDTA.

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.

2. About our Policy

This Privacy Policy coves how we use personal data when you use our websites and our systems. 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 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

  • Winning Moves website and linked microsites (currently hosted at www.winningmoves.com)

  • CDTA website and microsites (currently hosted at www.c4dta.co.uk)

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 and its websites. 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 and/or provide us with information so we can confirm your eligibility for funded support. In some circumstances you will also be a data controller e.g. where our systems allow you to add your own content or where you have also made decisions about the personal data collected via a system, and what should be done with it. Where you are also a controller, you must make sure it does not infringe anyone’s personal rights under the General Data Protection Regulations, Data Protection Act and other associated or relevant legislation as you could be held liable for prosecution.

3. What personal data do we collect

The new General Data Protection Regulations, as enacted by the Data Protection Act provide certain rights for those whom we collect information from, 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 and sites 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:


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


4. 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

For individuals that contact us directly or complete an online form

  • So that we can get back in touch with you

  • So that we can determine eligibility for funded support programmes

5. 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.

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.

Licensees

Licensees need to be able to see the personal information they input to our systems so that they can generate business specific output reports and/or access contact information for individuals within those businesses.

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.

Funding providers

Where we deliver projects on behalf of the public sector, we may need to share your data with the funding bodies for the purposes of analysing uptake of support and to demonstrate compliance with funding rules. This will include, but isn’t limited to, MHCLG and the European Commission.

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

6. 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.

Where you email us, it is important that you ensure you have appropriate security measures in place yourself, for the secure transmission of any messages to us.

7. Your rights in relation to your personal data

You have a right to request details of any personal data we hold about you, along 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

As a Licensee of our systems, the businesses whose personal data you input also have the same rights as you do. If you receive a request from a business for a copy of personal data held about them within our systems, you must verify the authenticity of the request and then tell us straight away, detailing the nature of the request, who wants the information and what they want us to do with it. We will then respond to you either:

  • Providing the information as requested; or

  • Amending or deleting the information as requested; or

  • Outlining why we can’t amend/delete or provide the information requested

It should be noted that very limited personal data is collected from use of the Winning Moves product suite.

8. Transfer of data to other countries

We may transfer 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.

9. 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.

10. 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:

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

b. 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.

11. 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.

12. 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