Privacy & Cookie Policy

Effective Date: August 15, 2025

1.        Who We Are

This privacy policy explains how Winter Strategies Limited (“we”, “us”, or “our”) collects, uses, and protects your personal information. We are the data controller for the purposes of UK data protection laws.

If you have any questions about how we handle your data, please contact us at the email address above.

2.        Information We Collect

 We may collect and process the following categories of personal data:

  • Contact Information: name, email address, telephone number, address and job title.

  • Technical Data: IP address, browser type, operating system, device ID and other technology on the devices you use to access our website.

  • Usage Data: pages visited, time spent on our website and navigation patterns

  • Correspondence: emails or messages you send to us.

  • Marketing Preferences: your choices regarding receiving marketing communications from us.

We do not collect sensitive personal data unless it is necessary and you have provided explicit consent.

3.        How We Collect Information

We collect personal data in the following ways:

  • Directly from you when you:

    • fill in forms on our website; and

    • contact us via email or phone.

  • Automatically through cookies and similar technologies (see Section 9 below).

4.        How We Use Your Information

We use your personal data to:

  • respond to enquiries or contact requests;

  • provide and improve our services;

  • comply with relevant legal and regulatory requirements;

  • use data analytics to improve our website, services, customer relationships and experiences; and

  • send accepted marketing communications.

5.        Legal Bases for Processing

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • Performance of a contract with you – where we need to perform the contract we are about to enter into or have entered into with you.

  • Legitimate interests – to operate, grow, and protect our business (e.g., to prevent fraud and enable us to give you the best and most secure customer experience). When we rely on legitimate interests, we ensure we consider and balance any potential impact on you and your rights (both positive and negative) before processing 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).

  • Legal obligation – where it is necessary for compliance with a legal obligation that we are subject to.

  • Consent - where we have obtained your active agreement to use your personal data for a specified purpose, for example for placing non-essential cookies and sending marketing communications.

6.        Data Sharing and Transfers

We may share your personal data with:

  • Service providers acting as processors who provide IT and system administration services.

  • Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors and insurers.

  • Regulators and authorities, such as HMRC, regulators and other authorities acting as processors or joint controllers based in the United Kingdom where legally required.

In the event of a sale or transfer of business assets, your data may be shared with potential buyers under confidentiality agreements.

International Transfers

We may transfer your personal data to service providers located outside the UK. This may include countries whose laws do not provide the same level of data protection as UK law. Where this occurs:

  • we only transfer personal data to countries that have been deemed by the UK government to provide an adequate level of protection for personal data; or

  • we use appropriate safeguards, such as the UK-approved Standard Contractual Clauses (SCCs), to ensure your data is protected.

7.        Data Retention

We retain your data only as long as necessary to fulfil the purposes we collected it for, including to satisfy legal, regulatory, tax, accounting, or reporting requirements.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorised use or disclosure; and applicable legal requirements.

By law, we must retain basic information about our customers (including contact and communication data) for six years after they cease being customers.

In some circumstances, you can ask us to delete your data (see Section 8 below).

8.        Your Rights

Under data protection laws, you have the right to:

  • Request access to your personal data.

  • Request correction of inaccurate or incomplete data.

  • Request erasure of your data, where there is no lawful reason for us to keep it.

  • Object to processing where we rely on legitimate interests, unless we have compelling legitimate grounds to continue.

  • Object to direct marketing at any time;

  • Request restriction of processing in specific situations (e.g. if accuracy is contested or processing is unlawful).

  • Request the transfer of your data in a structured, commonly used, machine-readable format.

  • ·Withdraw consent at any time where we rely on it.

To exercise any of these rights, please contact us at Inquiries@Winter-Strategies.com.

9.       Cookies

What Are Cookies?

Cookies are small text files placed on your device when you visit websites. They help websites work effectively and provide information to the site owner.

Our Use of Cookies

We use the following types of cookies on our website:

  • Strictly Necessary Cookies – essential for the site to function properly.

  • Analytical/Performance Cookies – help us understand how visitors use our site.

  • Functionality Cookies – remember your preferences.

  • Targeting Cookies – used to deliver relevant advertising.

Cookie Consent

When you first visit our website, you will be asked to consent to non-essential cookies. You can:

  • accept all cookies;

  • reject non-essential cookies; and

  • adjust cookie settings.

You can also manage cookies through your browser settings. For more information, visit www.allaboutcookies.org.

10. 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 place cookies on your device, 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 and cookie policies of every website you visit before providing any personal data.

11. Contact Details

If you have any questions or would like to exercise your rights, please contact us in the following ways:

  • Email address: Inquiries@Winter-Strategies.com.

  • Postal address: 4th Floor Glendinning House, 6 Murray Street, Belfast, Northern Ireland, United Kingdom, BT1 6DN.

12. Complaints

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk.

We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us first.

13. Changes to This Policy

We keep our Privacy and Cookie Policy under regular review Any updates will be posted on this page with a new effective date.

Please keep us informed of any changes to your personal data during your relationship with us.