Privacy policy and cookies

Privacy Policy

Introduction

Welcome to Windrose Consulting Group’s privacy policy.

Windrose Consulting Group respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Windrose Consulting Group collects and processes your personal data through your use of this website, including any data you may provide through this website when you use the “contact us” section or the “we’re hiring” section.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

Windrose Consulting Group is the controller and responsible for your personal data (collectively referred to as "Windrose Consulting Group", "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:

  • Company Name:: Windrose Consulting Group

  • Email address: info@windrosecg.com

  • Telephone number: +1 (484) 235-0599

 United States:

  • Legal Name: Windrose Consulting Group, LLC

  • Address: 161 Washington Street, Suite 330, Conshohocken, PA 19428, USA

  • Company Number: 47-3066189

United Kingdom:

  • Legal Name: Windrose Consulting Group Ltd.

  • Address: 69 Carter Lane, London, EC4V 5EQ, UK

  • Company Number: 09867836

Switzerland:

  • Legal Name: Windrose Consulting Group GmbH.

  • Address: Grabenstrasse 8, 6004 Luzern, Switzerland

  • Company Number: 1856845

Data Protection Authorities

You have the right to make a complaint at any time to your local data protection authority:

  • United Kingdom: Information Commissioner's Office (ICO) – www.ico.org.uk

  • United States: Please contact your local or state data protection authority, as the US does not have a federal data protection authority. For complaints related to financial data, you may contact the Federal Trade Commission (FTC) – www.ftc.gov.

  • Switzerland: Federal Data Protection and Information Commissioner (FDPIC) – www.edoeb.admin.ch

We would appreciate the opportunity to deal with your concerns before you approach a data protection authority, so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in January 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name and last name.

  • Contact Data includes email address.

  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

  • Usage Data includes information about how you use our website.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us via our website or by email.

  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

    • Technical Data from the following parties:

      • analytics providers such as Google;

      • advertising and professional networks (e.g., LinkedIn); and

      • search information providers.

    • Identity and Contact Data from data brokers or aggregators.

    • Identity and Contact Data from publicly available sources.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal obligation.

See section 11 to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

  1. Purpose/Activity: To register you as a new customer

    • Type of data: Identity, Contact

    • Lawful basis for processing including basis of legitimate interest:

      • Performance of a contract with you

  2. Purpose/Activity: Collection of Data from Public Domains to identify potential respondents for market research by accessing publicly available contact information.

    • Type of data: Identity, Contact, Banking (if provided and consented to for compensation purposes)

    • Lawful basis for processing including basis of legitimate interest:

      • Legitimate Interests: Processing is necessary for the purposes of the legitimate interests pursued by the controller to recruit potential research participants for market research purposes.

  3. Purpose/Activity: Contacting Individuals and Collecting Further Information: To conduct market research on behalf of our clients, which includes soliciting the advice of experts around client products and, where consented, collecting further personal and banking information for compensation purposes.

    • Type of data: Identity, Contact, Banking (if provided and consented to for compensation purposes)

    • Lawful basis for processing including basis of legitimate interest:

      • Consent: Explicit consent is obtained from the participants for processing their personal and banking data for the specific purpose of market research and compensation.

      • Legitimate Interests: Where initial contact is made to potential participants who have not yet consented, the processing is necessary for our legitimate interests to engage with potential research participants.

  4. Purpose/Activity: Data Retention for Non-Responsive Contacts: To maintain records of contact attempts for potential research participants to ensure efficient management of market research activities and to avoid repeated contacts where no response was received.

    • Type of data: Identity, Contact

    • Lawful basis for processing including basis of legitimate interest:

      • Legitimate Interests: Keeping records of contact attempts is necessary for our legitimate interests in managing our research activities efficiently and respecting the preferences of potential participants.

  5. Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

    • Type of data: Identity, Contact, Technical

    • Lawful basis for processing including basis of legitimate interest:

      • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

      • Necessary to comply with a legal obligation

  6. Purpose/Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

    • Type of data: Identity, Contact, Technical, Usage

    • Lawful basis for processing including basis of legitimate interest:

      • Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

  7. Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

    • Type of data: Technical, Usage

    • Lawful basis for processing including basis of legitimate interest:

      • Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy below.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Internal Third Parties as set out in the Glossary.

  • External Third Parties as set out in the Glossary.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Windrose Consulting Group operates globally, and as such, your personal data may be transferred to, and processed in, countries other than the country in which you reside. These countries may have data protection laws that are different to the laws of your country. Specifically, our servers are located in the UK, US, and Switzerland, and our third-party service providers and partners operate around the world.

When we transfer your personal data out of the UK, US, or Switzerland to other countries, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

  • Adequacy Decisions: We transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the relevant authorities in the UK, US, and Switzerland. For instance, transfers between the UK, US, and Switzerland are considered adequate under respective local regulations due to mutual adequacy decisions or recognition agreements.

  • Standard Contractual Clauses (SCCs): Where we use certain service providers in countries without adequacy decisions, we use specific contracts approved by authorities in the UK, US, and Switzerland (such as SCCs) which give personal data the same protection it has in these countries.

  • Binding Corporate Rules (BCRs): For internal transfers within Windrose Consulting Group, we may rely on Binding Corporate Rules approved by relevant data protection authorities to allow for the transfer of personal data from the EU/EEA to countries not deemed adequate by the European Commission.

  • Specific Exceptions in Limited Circumstances: In limited cases, we may transfer personal data based on specific exceptions provided by data protection laws when necessary for the performance of a contract with you, or to protect your vital interests or those of another person.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Breach Notification

Commitment to Data Security:

Windrose Consulting Group is committed to ensuring the security and protection of the personal information that we process, and to acting in accordance with data protection laws and regulations in the event of a data breach.

What Constitutes a Data Breach:

A personal data breach can occur when there is a security incident that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

Breach Detection and Response:

We have implemented detection and response plans for addressing any personal data breaches. This includes internal data security policies and immediate containment and mitigation procedures.

Notification Process:

In the event of a data breach, we will notify the relevant data protection authority (or authorities) without undue delay and, where feasible, within 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

Communication to Data Subjects:

If the data breach is likely to result in a high risk to the rights and freedoms of individuals, we will inform those individuals without undue delay. This notification will provide information about the nature of the breach, the likely consequences of the breach, the measures taken or proposed to be taken by us to address the breach, and suggestions for the affected individuals to mitigate possible adverse effects.

Documentation of Data Breaches:

All personal data breaches will be recorded in our breach register and managed in accordance with our Data Protection Impact Assessment policy. This documentation will allow us to comply with legal obligations and to improve our preventative measures over time.

Contact Information:

For any questions or concerns regarding our breach response practices, please contact us.

9. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see paragraph 11 to find out more about these rights:

  • Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data.

  • Object to processing of your personal data.

  • Request restriction of processing your personal data.

  • Request transfer of your personal data.

  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Glossary

DEFINITIONS

  • Personal Data: 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.

  • Processing: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

  • Controller: The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

  • Processor: A natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller.

  • Consent: Any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

  • Data Subject: The identified or identifiable natural person to whom personal data relates.

  • Third Party: A natural or legal person, public authority, agency, or body other than the data subject, controller, processor, and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

  • Data Protection Authority (DPA): An independent public authority that is legally tasked with overseeing compliance with applicable data protection laws to protect the personal data and privacy of individuals.

  • Personal Data Breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

  • Personal Data Breach: A breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

  • Standard Contractual Clauses (SCCs): Legal tools providing adequate safeguards for data protection for those data transferred internationally, used between controllers and processors.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do 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 to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

As part of the Windrose Consulting Group, your personal data may be shared with our subsidiaries, affiliates, or holding companies. These internal third parties may use your data only for the purposes set forth in this privacy policy and are subject to the same safeguards and compliance requirements. Current internal third parties include:

  • Windrose Consulting Group LLC: Based in the United States, handling our operations in North America.

  • Windrose Consulting Group Ltd.: Based in the United Kingdom, handling our operations in the UK.

  • Windrose Consulting Group GmbH: Based in Switzerland, handling our operations in Switzerland.

All internal third parties are required to follow our strict data protection policies. This internal sharing of data is crucial for the seamless provision of our services across different regions, ensuring that you receive consistent quality and responsiveness no matter where you interact with our group.

External Third Parties

  • HM Revenue & Customs (HMRC), regulators, and other authorities in the United Kingdom: These entities may act as processors or joint controllers and require reporting of processing activities for compliance with legal obligations, such as tax laws and anti-money laundering regulations.

  • Internal Revenue Service (IRS) and state-level authorities in the United States: These entities may act as processors or joint controllers and require reporting of processing activities for compliance with legal obligations, such as tax laws and anti-money laundering regulations.

  • Federal Data Protection and Information Commissioner (FDPIC) and cantonal authorities in Switzerland: These authorities oversee compliance with data protection laws and may require disclosures of personal data for regulatory and legal compliance.

  • Professional advisers acting as processors or joint controllers including lawyers and accountants based in the United States, United Kingdom, and Switzerland who provide consultancy, banking, legal, insurance and accounting services.

  • Service providers acting as processors based in the United States, United Kingdom, and Switzerland who provide translation and transcription services.

All such transfers and disclosures are conducted in strict adherence to legal requirements and are limited to the data necessary for fulfilling these obligations. Our engagement with these external third parties ensures that your personal data is processed lawfully and securely, maintaining the highest levels of data protection and privacy.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data 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.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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 continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy.

  • Where our use of the data is unlawful but you do not want us to erase it.

  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Cookies and other technologies we use

We use cookies and/or similar technologies to analyze customer behavior.

A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make websites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.

We use cookies for the following purposes:

  • Necessary cookies – these cookies are required for you to be able to use some important features on our website. These cookies don’t collect any personal information.

  • Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalized features possible. For example, they might remember your name and e-mail in forms so you don’t have to re-enter this information next time when commenting.

  • Analytics cookies – these cookies are used to track the use and performance of our website and services

Here are the cookies we use:

  • Google Analytics – persistent cookie – 2-year duration – we use Google Analytics to improve the user experience on the website (you can opt out here)

  • Hotjar

    • We use Hotjar in order to better understand our users 'needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users' experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don't like, etc.) and this enables us to maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users' behavior and their devices. This includes a device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile.

    • Hotjar is contractually forbidden to sell any of the data collected on our behalf.

    • For further details, please see the 'about Hotjar' section of Hotjar's support site.