Privacy Policy

CWind is committed to respecting your privacy. All personal information is collected and processed is in accordance with the UK’s Data Protection Law which means the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) and any equivalent legislation amending, supplementing or replacing the GDPR.

Please read this policy carefully before you submit any personal information via our websites.

Who we are

When we refer to `we`, `our`, `us` or `CWind`, we are referring to CWind Ltd, as the context indicates.

Policy Scope

For the purpose of this privacy policy, ‘personal information’ is information that relates to an identified or identifiable individual.

This privacy policy explains how we will collect, store, use and otherwise process your personal information.

This policy may change from time to time and, if it does, the up-to-date version will always be available on our website and becomes effective immediately.

This Policy applies to personal information acquired through various media, this can include, but not be limited to;

• current and prospective client’s personnel;
• third parties with whom we have contact by virtue of providing our services;
• contractors/ suppliers and their personnel;
• those with whom we work in the context of our corporate responsibility initiatives;
• those who submit correspondence to us
• details are otherwise entered into our systems and portals;
• any visitor to our offices and projects; and,
• when you use any of the electronic communication including but not limited to, telephone, fax, email, or our website to contact us

When you visit the company’s website, (www.cwind.group ) to view any pages or read product information, you do so without telling us who you are and without revealing any personal information. While we do not collect identifying information about visitors to our website, we do use standard software/cookies to collect information for the strict purpose of tracking activity on our website. This allows us to better understand how many people use our websites and which pages and features are most popular. Please refer to our Cookies Policy section (below) for further details.

Pages of the company website may, from time to time, contain links to and from other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that the Company does not accept any responsibility or liability for these policies or use of the third parties website.

Privacy Information

Your personal data will only be processed for the purposes set out below and in accordance with Data Protection Law. The Company will not process your personal data in any manner incompatible with these purposes unless we are required to do so by law.

The Company may hold and process your personal data for the following purposes:

• to record and respond to any communication you have made with us including by way of telephone, through the website, email address of the Company, any other electronic form of communication and post;
• to provide you with information that you have requested or to send you subscriptions that you have consented to, such as the news alerts and marketing campaigns. When providing you company information via email we use a third party platform called Campaign Monitor, where we use track click and open rates as well the platforms analytics functionality to monitor and enhance our communications for our subscribers.

• manage our relationship with you or third parties (such as your personnel) including for administration, accounting and relationship management purposes;
• process any application you or your representative has submitted for an employment or other opportunity (such as agency or volunteering work) with the Company;
• equal opportunities monitoring information (including information about your gender, race, ethnicity, sexual orientation and disabilities);
• on-boarding with the Company and pre-employment screening such as reference checks, right to work checks and criminal conviction checks;
• for administration purposes and access to our systems and portals;
• help us develop the website to be more useful to you, to keep it safe and secure;
• to respond to any problems you report with our website;
• to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical purposes;
• to allow you to participate in interactive features on our website when you choose to do so;
• for the security of our business including photographic images, video recording, and administration of any attendance to our offices and projects;
• to comply with any legal obligations which apply to us or policies that we have in place; and

• as necessary to prevent illegal activity or to protect our interests or the interests of a third party such as our clients.

Special Category Data

In addition to the above special category personal information may also need to be processed where the Company needs to:

• carry out its legal obligations;
• to run the business;
• where the processing is necessary for the assessment of your working capacity, occupational health or obtaining a medical diagnosis; or,
• where it is needed in the public interest
• in the vital interest of the individual, such as medical emergency.

In exceptional circumstances, we may process this data without your explicit consent, we will notify you of these at that time.

Criminal Offence Data

GDPR rules for special category data do not apply to information about criminal allegations, proceedings or convictions. Instead, there are separate safeguards for personal data relating to criminal convictions and offences, or related security measures. The processing of criminal data by the Company will be done so in accordance with the specific conditions set out in Schedule 1 of the Data Protection Act 2018, and any additional safeguards as set out by the act will be put in place before we do so.

Legal Basis for Processing

We rely on one or more of the following legal basis for processing your personal data:

• for the performance of, or entry into, a contract with you or a third party (such as your personnel);
• to comply with our legal and regulatory obligations;
• CWind has a legitimate interest in doing so and where our legitimate interests are not overridden by your (or the relevant individual’s) interest. These legitimate interests will include our interests in managing our relationship with our clients, administering visits to our offices and projects and ascertaining compliance with our policies and procedures;
• where processing of special category data is necessary in the context of the establishment, exercise or defense of legal claims or in the substantial public interest; and
• where we have obtained your express consent to do so;
• On the grounds of “Vital Interest” where processing is intended to cover only the interests that are essential for someone’s life – eg. delivery of emergency medical care where you as the individual are unable to give consent.

Consent

By consenting you are giving the Company permission to process your personal information specifically for the purposes identified. Where we are asking you for sensitive personal information we will always tell you why and how the information will be used. When consent is required for Company to process this sensitive information, your consent will be explicitly requested by the Company.

If you are under 18, please ensure that you have obtained your parental / guardian’s permission in advance whenever you provide personal information to us.

You may withdraw consent at any time by writing to CWind, Data Protection Officer at:
GRO Centre
Humber Bridge Road
Port of Grimsby
North Lincolnshire
DN31 3AS
United Kingdom

or via email:   info@cwind.group

Please note: if you do withdraw your consent, we may still be able to process some of your personal information on other grounds, we will notify you of these at that time.

Third Parties please note: Where you provide personal information relating to your personnel or other third parties (e.g. if you are a recruitment agent), the Company considers that you have received and warrant the consent from the individual to do so, and that the information is accurate and up-to-date. It remains your responsibility to inform us if the wishes of the third party changes or, if any of their personal information changes.

Information transfers to third parties

For the purposes set out above, the Company may transfer personal data to third parties including some that operate outside of the EU. These include our clients, subsidiaries, sub-contractors, vessels, services providers or suppliers including our website operator, professional advisors, insurers and regulatory bodies. This will be for one of the following reasons:

• you specifically request that we do this;
• it is necessary to provide information or services to you;
• for our legitimate interests, or,
• the legitimate interests of a third party ;
• in the public interest; or
• to carry out our legal or regulatory obligations.

We will not rent or sell personal data to any other organisation or individual.

Information Security

Appropriate technical and organisational measures have been put in place to ensure the continued security of your personal data. Through Data Protection Impact Assessments (DPIAs) the Company determines appropriate and proportional risk treatments. Encryption has been deploy in certain instances, and the company has appropriate policies for Information Security handling, Data Security, Data Restoration and Data Back Up which are periodically reviewed.

The Company has put in place certain technical measures to ensure the security of the information collected and its correct use. These are appropriate to the nature of the information and to prevent unauthorised access. All incoming emails are scanned using virus-checking software. The software will also block unsolicited marketing email (spam) and emails which have potentially inappropriate attachments. All personal data you register on our website will be located behind a firewall. Once we have received your information, we follow strict security procedures as to how your personal data is stored and who sees it, to help stop any unauthorised person getting hold of it. Access to your personal data will only be given to those who strictly need such access.

Where personal data is shared with third parties within CWind but where the receiver is based outside of the European Economic Area (EEA) eg. to one of our vessels, the Company will ensure full and continued compliance with Data Protection Law.

Under the governance of “Restricted Transfer” and with appropriate safeguards in place, your data may be transferred to third parties outside of the organisation which are also outside of the EEA.

Instances where the Company requires to take extraordinary action/s requiring disclosure or use of your personal data and where it has been determined that lawful use or consent has not otherwise been obtained, the Company will seek your consent to do so as well as provide you with the related Privacy Information.

Storage Limitation

We will keep your personal data stored on our systems for only as long as is necessary to achieve our business objectives, albeit we may keep your data for longer than this if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for statistical purposes.

The third parties we engage to provide services on our behalf will keep your personal data stored on their systems for as long as is necessary to provide the services to you or for such purposes that the personal data was disclosed for. The company has agreements in place regarding third-party retention and destruction of personal information.

The Company processes and procedures comply with the Data Protection Regulation in respect of storage limitation, whereby the Company.

• keeps personal data for no longer than it is needed.
• can justify how long you keep personal data.
• holds periodic reviews of the data held,
• erases or anonymise’s personal data when you no longer required.
• considers challenges to your retention of data.
• respects that individuals have a right to erasure if the data is no longer needed.
• keeps personal data for longer when keeping it for public interest archiving, scientific or historical research, or statistical purposes.

Your Rights

GDPR provides the following rights to individuals, which are :

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling.

When you make a request/exercise your rights under GDPR we describe this as a Data Subject Access Request or DSAR.  Before we action your DSAR we are required to confirm your identity, please be advised, if we have doubts about your identity when responding to your DSAR, we will ask for more identification data (ID). We will only request information that is necessary to confirm who you are. We will let you know as soon as possible if we need more information before responding to your request. The period (30 days) for responding to your request will begin once we receive this additional ID information and we are confident that you are who you say you are.

GDPR allows for you to make a DSAR via a third party. Often, this will be a solicitor acting on your behalf. In these cases, the company will take steps to be satisfied that the third party making the request is entitled to act on your behalf, noting that it is the third party’s responsibility to provide evidence of such entitlement.

Your “Rights” in brief :

1. Right to be Informed

You have the right to be informed about the collection and use of your personal data. This is a key transparency requirement under the GDPR. Whereby the company shall:

• inform you of the purposes, and any change in purpose, for processing your personal data;
• make “privacy information” available at the time we collect your personal information

There are a few circumstances when you do not need to provide people with privacy information, such as if an individual already has the information or if it would involve a disproportionate effort to provide it to you.

2. Right of Access

You have the right to request a copy of the information that we hold about you. Your request will be processed and the information to which you are entitled will be collated and provided to you no later than one month (except in extenuating circumstances) from when we receive your request, subject to the requirements and exemptions of Data Protection Law. If such extenuating circumstances mean we are unable to comply with your request within one month, we will tell you as soon as possible about this delay.

3. Right of Rectification

You have a right to correct data that we hold about you that is inaccurate or incomplete.  Where your personal data is inaccurate or where you would like us to complete any incomplete information, you can provide us with a statement that sets out the details of your request for rectification. For certain systems, you will be asked to sign a declaration of accuracy.

4. Right to be Forgotten

In certain circumstances, you can ask for the data we hold about you to be erased from our records. You can request that the Company deletes your personal data where it does not have grounds to continue processing your personal data. The Company will be unable to comply with your request in certain circumstances including, for example, if the Company has a legal obligation to continue processing the data, we will advise you in this instance.

5. Right to Restrict Processing

You have the right to the restriction of processing where certain conditions apply. You have the right to request restriction of processing by the company in the following circumstances:

• you contest the accuracy of your personal data and you are verifying the accuracy of the data;
• you consider that the data has been unlawfully processed and you oppose erasure and request restriction instead;
• you need the company to keep your personal information in order to establish, exercise or defend a legal claim.

6. Right of Portability

The right to data portability, gives you the right to receive personal data previously provided to the company (as the data controller), in a structured, commonly used and machine-readable format. It also gives you the right to request that a company transmits this data directly to another controller. Your right to data portability only applies when:

• the companies lawful basis for processing this information is consent or
• for the performance of a contract; or
• personal information processed by automated means (ie excluding paper files).

7. Right to Object

You can restrict the Company’s processing of your personal data where:

• the Company is processing your personal data on the basis of its legitimate interests;
• you have grounds to believe that the Company no longer needs the personal data for the purposes;
• the processing is unlawful; or,
• you have contested the accuracy of the personal data.

8. Rights in relation to automated decision making and profiling.

GDPR has additional rules to protect you if the company chooses to carry out solely automated decision-making processes that have legal or similarly significant effects on you. The company can only carry out this type of decision-making where the decision is:

• necessary for the entry into or performance of a contract;
• authorised by Union or Member state law applicable to the controller; or
• based on the individual’s explicit consent.

In the event that the company undertakes automated processing, it will advise you. It will also introduce simple ways for you request human intervention or challenge a decision and will carry out regular checks to make sure that our systems are working as intended.

To exercise your rights in the first instance please write to the company’s Data Protection Officer (DPO) and send to:

CWind (FAO: Data Protection Officer)
GRO Centre
Humber Bridge Road
Port of Grimsby
North Lincolnshire
DN31 3AS
United Kingdom

or via email:   info@cwind.group

Social plug-ins

• Social plug-ins from Facebook

We use social plug-ins from facebook.com, operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. You can recognise these plug-ins by their Facebook logo. Here is an example of how these plug-ins work:

If you click on the Facebook “Share” button, the relevant information is transmitted directly from your browser to Facebook and stored there. Facebook will make the shared content public on your Facebook profile. If you are logged in on Facebook, the plug-in can assign the visit of our website directly to your Facebook profile. Facebook may collect information about your website behaviour and that you have accessed our website.

We have no influence on the data gathered by the plug-in. Even if you are not logged in or registered on Facebook, there is a possibility that the plug-ins forward your IP-address which is then stored by Facebook. For details about collecting and handling your personal data by Facebook and your related rights, please refer to the Facebook data privacy policy which can be found on www.facebook.com. If you do not want Facebook to link data about you via our website to your Facebook profile, you have to log out of your Facebook profile before you visit our website and change the retargeting settings within your Facebook profile.

• Social plug-ins from Twitter

With Twitter and its Retweet functions, we use social plug-ins from Twitter.com, operated by Twitter Inc. 795 Folsom St., Suite 600, San Francisco, CA 94107. If you retweet one of our contents, your visit on our website will be announced to third parties and assigned to your Twitter account. Details about collecting and handling your personal data by Twitter as well as your rights and setting options for protecting your personal information can be found in the Twitter privacy policy which can be found at www.twitter.com.

• Social plug-ins from LinkedIn

We use plug-ins which are provided by LinkedIn Corporation (LinkedIn), 2029 Stierlin Court, Mountain View, CA 94043, USA. These plug-ins can be identified by the LinkedIn logo and the LinkedIn “Share” button. If you access our website using this plug-in, your browser sets up a direct connection to the LinkedIn servers. LinkedIn receives information that you (your IP-address) has accessed our website. If you click on the LinkedIn “Share” button while you are logged in on your LinkedIn account, you can link certain content on your LinkedIn-Profile which enables LinkedIn to allocate the visit to our website to your LinkedIn account. We do not know the content of the data transferred to LinkedIn or how LinkedIn uses such data.

• LinkedIn Insights

This enables in-depth campaign reporting and unlocks valuable insight about website visitors. The LinkedIn Insight Tag tracks conversions (sign ups), allows for retargeting of ads to website visitors, and unlocks additional insights about members interacting with LinkedIn ads. Details about collecting and handling your personal data by LinkedIn as well as your rights and setting options for protecting your personal information can be found in the LinkedIn privacy policy which can be found at www.linkedin.com. If you do not want to track your behaviour as a LinkedIn member on third-party websites, you can opt out in your LinkedIn settings.

Cookies Policy

What are Cookies?

There is a technology called “Cookies” which can be used to provide you with tailored information when visiting the Company website. A Cookie is an element of data the website will send to your browser, which will then be stored on your computer. This element of data is a piece of text, not a program. The website can only access the information from a Cookie sent by specific website and it cannot access other Cookies sent by other websites or the information contained there. Additionally, we cannot learn your email address or any other information about you through the use of a Cookie.

Why does the website use Cookies?

The Company uses Cookies to track usage of the website and to customise your experience when you are visiting the website. By tracking usage, we can best determine what features of the website best serve you.

What benefits do I receive from Cookies?

Overall, the use of Cookies helps to give you a customised experience when visiting the website. Through the use of Cookies, we will know what’s working and what’s not. That information is then used to keep our website fresh and relevant to you. Cookies also allow for the personalisation of any online services we may provide to you.

May I decline to accept a Cookie?

You may refuse the use of Cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of our website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above

You will be given the option to accept or decline non-essential cookies when you first visit our website and every 30 days thereafter. You can manage Cookies at any time during a 30 day period by following the relevant instructions below depending on the browser you are using:

• Google Chrome:

https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en

• Internet Explorer:

https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies

• Firefox:

https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

• Safari:

https://support.apple.com/kb/ph21411?locale=en_GB

• Opera:

https://www.opera.com/help/tutorials/security/privacy/

Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “Cookies”, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the Cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

Session and Persistent Cookies

Cookies, whether session or persistent, are also described as first-party or third-party cookies. Cookies relating to content coming from the page’s primary server are first party Cookies and where the web page’s content does not come from the page’s primary server they are referred to as third-party cookies. Listed here are all the Cookies that we use to manage website delivery to your browser:

• Session cookies
• Google Analytics Cookies

A Session Cookie enhances the user experience when using the website. These enable you to carry out some essential functions on our site, such as maintaining log in details for the session or transaction. They also help by minimising the need to transfer information across the net. They are not stored on your computer and they expire when you terminate your browser session.

A Google Analytics cookies defines user sessions as well as to provide a number of key features in the Google Analytics reports. Google Analytics sets or updates cookies only to collect data required for the reports and cookies set by Google Analytics for this website and only send data to our servers, effectively making these cookies the personal property of our website domain. The data cannot be altered or retrieved by any service on any other domain. All have a medium level of privacy tracking.

__utma: This Cookie is used to identify unique visitors to our sites. The results are sent to our Google Analytics account so that we may see how many unique visitors come to this site based over a period of time. This is a persistent cookie and expires in 2 years.

__utmb: This Cookie is used by Google Analytics to determine the visitor session times on our sites. Each time you visit a new page on the site the cookie is set to expire within 30 minutes, if it does not find an existing cookie, a new one is created.

__utmc: This Cookie is used by Google Analytics in conjunction with __utmb to determine visitor sessions. Unlike __utmb this Cookie does not have an expiry date, it determines whether a new session should be created based on whether you have previously closed your browser, re-opened it and come back to the site. As a Session Cookie, it runs just for that visit.

__utmz: This Cookie is used by Google Analytics to determine the type of referral used by each visitor to arrive at our site. The cookie determines if the user has come directly to the site or via a search engine, email or email campaign. We use this data to understand how our users arrive at the website. It is a persistent cookie and expires in 6 months.

Concerns relating to our Privacy Policy or to our use of Cookies

If you have concerns relating to our Privacy Policy or our use of Cookies, please write to our Data Protection Officer at :

CWind, (FAO Data Protection Officer)
GRO Centre
Humber Bridge Road
Port of Grimsby
North Lincolnshire
DN31 3AS
United Kingdom

or email:   info@cwind.group

If you remain dissatisfied following our response to any enquiry you can address your concerns to the Information Commissioners office (ICO), by contacting them via their livechat service ico.org.uk/livechat or calling their help line on 0303 123 1113,  or via their website www.ico.org.uk.

End of Policy