This Privacy and Cookie Policy (the “Policy”) applies to the Gainsway site at gainsway.com (the “Site”).

1. Introduction and your consent

1.1 The Site is owned and operated by Gainsway Services Limited trading as Gainsway (“Gainsway”, “us”, “our”, “we”). We are committed to protecting the privacy of subscribers and visitors (together referred to as “Users”) to the Site. This Policy explains what information we may collect about you, how we will use it and the steps that we will take to ensure that such information is kept secure.

1.2 We may change or update this Policy for any reason (for example, in order to comply with new legal requirements) and the date of any update will be described at the bottom of the Policy. We will take reasonable steps to bring any material changes to the Policy to your attention.

1.3 The Site may have links to other sites. Third party sites should have their own privacy policies and we recommend that you read such policies to find out how your personal information is protected. We are not responsible for how such third party sites protect your privacy.

1.4 By using the Site, you consent to us collecting and using your personal information in accordance with this Policy.

2. Fair Processing Notice

2.1 Gainsway collects and processes data as part of our activities. Some of this data is collected and processed based on your consent. Some of it may be required in order to meet legal and contractual obligations. Some of it will be processed on the basis of legitimate interest.

2.2 We are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy. We may pass your personal information on to any service providers who are contracted to Gainsway in the course of dealing with you. Any such contractors will be obliged to keep your information securely and use it only to fulfil the service they provide.

3. Information we collect

3.1 When you subscribe for or use our services we may collect details about you, such as: Full Name; Email addresses; Physical Address; Phone Numbers; Transaction Information; User/Device ID/Internet Protocol Address; and Anonymised Behavioural Data regarding the way you interact with our Site.

3.2 Such details are collected in a number of ways: they can be obtained via the use of cookies (more on this below), or other tracking systems; or when you register to purchase a particular service from us. We may also collect information you give us over the telephone or in written or other communications.

3.3 We use the information we collect from you for the following purposes: to fulfil orders you have made for services; to conduct market research, compile customer reviews and analysis; to verify your identity; to personalise your visits to the Site and develop the design and style of the Site to improve the services provided to you; to inform you about the latest changes to the Site or services or promotional offers that you might find interesting; to communicate with you or to deal with, and respond to you about a question you have submitted; and to carry out statistical, technical and logistical analysis.

3.4 We will process (i.e. collect, store and use) the information you provide in a manner that is compatible with the UK/EU’s General Data Protection Regulation (“GDPR”). We will endeavour to keep your information accurate and up to date and not keep it for longer than is necessary. In some instances the law sets the length of time information has to be kept, but in most cases Gainsway will use its discretion to ensure that we do not keep records outside of our normal business requirements.

3.5 You will not receive unsolicited marketing from us or trusted third parties unless you have agreed to do so. However, Gainsway may email you occasionally with information about changes to the Site, the services available and products you are currently or have been subscribed to in the past, where we believe there is a legitimate interest to do so.

4. Parties with whom we share information

4.1 We will not sell or make available your personal information to third parties (subject to clause 2.2 above). You may have given us your permission to be contacted by our trusted partners, affiliates or other third parties with offers relating to their products, offers, services or promotions. If this is the case and you subsequently decide you no longer wish to be contacted by our partners, affiliates or other third parties, please notify us by email at the following address: info@gainsway.com.

4.2 We compile anonymous statistics of user trends which we may make use of ourselves, or pass to our associated companies and/or selected partners.

4.3 We may disclose anonymised details about use of the Site and our services to other businesses (for example, to demonstrate patterns of use to advertisers and other business partners). The information we pass on will not include any personal information by which you may be identified.

4.4 We may forward your personal information to a law enforcement or government authority if we are asked to do so or required to do so in order to comply with the law, with an investigation of suspected illegal activities, or with any suspected misuse of the Site by you.

4.5 We may transfer or assign any of the information described in this Policy to third parties as a result of a sale, consolidation, change of control, transfer of assets or reorganisation of our business.

5. Data security

5.1 We have adopted measures to ensure that Users’ personal details are not misused, accidentally destroyed, lost or altered. Where information is transferred to a third party, that third party will be required to keep your personal details secure to the same standards we apply.

5.2 We endeavour to prevent unauthorised disclosures of your personal information by any approved suppliers that we work with. However, we are not responsible for any unauthorised disclosures or other breaches of security or for the actions of others if the relevant personal information was passed to them with your permission or as required by law.

6. Transfer of details overseas

Given the global nature of the Internet, the use of the Internet to collect and process personal information may involve the transmission of data internationally. Therefore, by browsing the Site and communicating electronically with us, you acknowledge and agree that we may process your personal information overseas.

7. Retention and deletion

7.1 We will take reasonable steps to ensure the accuracy of the information we hold about you. We will not use your personal information unless it is (to the best of our knowledge) accurate and up to date.

7.2 If you believe your details are incorrect, you can email us at: feedback@gainsway.com.

7.3 We will not keep your personal information for longer than is necessary. Once it has been decided that the information is no longer needed, or you have enacted your right for erasure, it will be deleted in line with your rights under GDPR.

8. Invoking your rights under GDPR and accessing your details

8.1 Under GDPR you have multiple rights, including the right to find out what information we hold about you, request that it be updated, object to it being processed, ask that it be deleted, or restrict its processing. If you would like to exercise any of these rights, please email us at: feedback@gainsway.com.

8.2 We will provide you with a summary of personal information that we hold on you upon your request. To make a request, please send an email to feedback@gainsway.com and it will be handled in line with applicable legislation.

8.3 You can also request that the personal information that we hold about you is removed from our system. However, this may mean that we can no longer provide you with the services that you wish to receive.

9. Data protection registration

Gainsway Services Limited is a registered data controller under GDPR and is registered with the Information Commissioner’s Office (“ICO”) with a Data Protection Registration Number of ZB347854. Should you wish to raise a complaint about any aspect of how we have handled your personal information, you can do so with the ICO.

10. Cookies

10.1 We may use cookies to keep the Site secure and personalised. Cookies are small files of data or code that are used to identify your device when you use and interact with the Site. Cookies are often used for remembering your preferences, to identify relevant content for you, to remember you are logged in to the Site, to enable you to interact with our services and to assist in our non-personalised analytics activities.

10.2 You may be able to disable and manage some cookies through your browser settings, although please be aware that if you disable or remove cookies, some parts of the Site may not function properly.

10.3 If you have any questions in relation to how we use cookies, please email us at: feedback@gainsway.com.

Last updated: 24 September 2024