Last Update: May 19th 2019
She Wins Limited, a company incorporated in England and Wales (Company number 11951816) and whose registered address is 20-22 Wenlock Road, London, England, N1 7GU (referred to herein as “we”, “us” or “our”, as the context requires) is committed to protecting and respecting your privacy.
This policy (together with our Terms of Service and/or the Terms of Service of Service Providers partner if applicable, and any other documents referred to on them) set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. It applies to both customers and service providers, and, with regard to transparency provisions according to the General Data Protection Regulation (GDPR), to other individuals whose data we may process except for our employees.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the General Data Protection Regulation (GDPR) and applicable UK laws, we are the data controller where you are using our services through the She Wins Website and other tools. If you are using She Wins through our commercial partners, She Wins may be a joint data controller or a data processor, which will be made clear to you at the point of sharing your data. In cases where She Wins is merely a data processor, it is our partners’ responsibility to inform you about their data processing practices and your rights in that regard.
THE BASIS FOR THE PROCESSING OF YOUR DATA
She Wins processes your data for the purpose of performing the contract that you have entered into for the use of the She Wins service, and/or in order to take steps at your request to enter into this contract.
In addition, some data is processed based on She Wins’s legitimate interest, notably service providers’ data harvested from publicly available data sources for the purpose of vetting them and them performing services to you. Website or other tools analytics for the purposes of enhancing performance, activity, including messages between customers and providers, and device and/or user identifiers (e.g. IMEI), website logs etc. to prevent fraudulent or other malicious activities, website visitor logs for cybersecurity and/or error tracking purposes
Your consent is required for the use of the messaging feature between you and your service provider. Messages may be monitored for quality assurance, fraud identification purposes and other inappropriate behaviour detection and prevention. If you revoke consent by stopping to use the feature, we may still retain old messages based on our legitimate interest to fight fraud and inappropriate behaviour.
INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:
Information you provide us with. It includes information you provide when you book and buy services via our Website/Tools, and when you report a problem with our site or a service you booked. The information you give us may include your name, email address, phone number, address, payment and payment card information, personal description of your situation provided by filling in forms on our Website/Tools or by corresponding with us by in-App chat, email, phone or otherwise.
If you are a service provider, you may provide us additionally with identity verification documents, trade qualifications and accreditations, registrations, certifications and licenses, insurance policies as well as bank account details in which you wish to be paid for the services you perform.
She Wins does not directly hold payment card or payment information but uses third party payment service providers to facilitate payment card processing as described in our Terms of Service.
Information we collect about you. With regard to each of your visits to our website/tools we will automatically collect the following information:
Your computer’s IP address
Source of traffic and/or previous webpage before visiting our website/tools
The pages visited and actions taken within our website/tools
The time spent within our website/tools
Access times and dates
Page response times
and other statistics
Information we receive from other sources. This is information we receive about you from one of our commercial partners. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
The following table sets out the different categories of cookies that our Website/Tools use and why we use them. The lists of third party cookie providers are intended merely as illustrative not comprehensive:
Type of Cookie
Authentication & Session Management
These cookies (including local storage and similar technologies) tell us when you’re logged in, so we can customise your experience.
She Wins Squarespace
Features and Services
These cookies provide functionalities that help us deliver our services on the She Wins platform. For example, allowing you to pay or enabling you to contact She Wins for help via your App if you are a service provider.
She Wins Squarespace
Analytics and Research
She Wins Squarespace
If you have heard about She Wins via an advertisement on another website, we may track the origin of your visit. This is so we can measure conversions and the cost effectiveness of our marketing activity.
She Wins Squarespace
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
Information you give to us. We will use this information:
to respond to your queries via She Wins website/tools;
to place a booking for a service you request on the She Wins website/tools;
to carry out other obligations arising from contracts entered into between you and us;
to connect you with the service provider you selected to perform the services you purchased;
to notify you of special marketing offers for She Wins services or third party products and services;
to notify you about changes to our service;
to ensure that content from our site is presented in the most effective manner for you and for your device;
In the event of a dispute between you and the service provider assigned to carry out the service, to provide the service provider with certain details (which the service provider is obliged to keep confidential and only used for this purpose) in order to enable finding a resolution.
Information we collect about you. We will use this information:
to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our site to ensure that content is presented in the most effective manner for you and for your device;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our site safe and secure;
to measure or understand the effectiveness of services we display on the website/tools;
to make suggestions and recommendations to you and other users of our website/tools about goods or services that may interest you or them.
Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
DISCLOSURE OF YOUR INFORMATION
Subject to the need to perform the contract with you based on our Terms of Service and our legitimate interests, we have the right to share your personal information with selected third parties including:
Service providers you selected to perform services for you when placing a booking on the She Wins website/tools. Further details you shared with us while booking and purchasing services with a given Service provider will only be disclosed to a single service provider you selected.
Commercial partners who have introduced you to the She Wins website/tools whether as a white-label solution powered by She Wins or otherwise;
Analytics, CRM and other software that assist us in the communication with you and the improvement and optimisation of our website/tools;
Manufacturers and distributors of products you may have installed which will be ordered as part of the service booking process;
Our insurance provider for the purpose of assisting you in a claim;
Any other third parties for the purpose of enabling the services you book to be carried out;
Any other third parties with your express consent.
We will disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If we (or substantially all of our assets) are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other agreements; or to protect the rights, property, or safety of She Wins Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on secure servers. Any communication between our website/tools and our databases follow the HTTPS protocol and use industry standard secure sockets layer (SSL) encryption technology connections.
Any payment transactions will be encrypted using SSL encryption technology. Stripe (https://stripe.com/gb), our payments processing provider, securely stores and processes card data for us. We access your payment information via Stripe platform and use their services to handle payments, credits and refunds.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone and if your password has been compromised for any reason or if you have grounds to believe that your password has been compromised, you should immediately contact us and change your password.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
Where another mechanism is not provided, you can also exercise the rights at any time by contacting us at firstname.lastname@example.org.
You have the right to have your data erased, which you can exercise by means of the deactivation of your account. We are not required to delete the information important for the establishment, exercise or defence of legal claims, or that we need to retain in order to comply with the law. Accordingly, we will anonymise your name and contact details but will retain your jobs and associated addresses for a period of 6 years in line with our data retention policy.
You have the right to obtain without undue delay the rectification of inaccurate personal data concerning you, including the right to have incomplete personal data completed e.g. by means of providing a supplementary statement;
You have the right of restriction of processing, where the data is wrongfully processed but should not be erased for a reason listed in Article 18 (1) of the GDPR.
Until a download option has been developed, you may exercise your right of data portability by sending us an email request to obtain your data at email@example.com. In line with the GDPR, we will comply with your request within 30 days free of charge.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
ACCESS TO INFORMATION
The GDPR gives you the right to access information held about you. Your right of access can be exercised in accordance with the GDPR.
We will normally store your information as long as your She Wins account remains active, which includes the history of your purchases. We may delete accounts or specific information before account deactivation where we believe it may no longer be relevant or where an account has been inactive for more than 3 years. Your purchase history may be deleted after 3 years.
If you have sent us an email or other correspondence, or happen to be our partner contact in our CRM system, we will retain your information until we are satisfied it is outdated or no longer relevant, subject to your exercise of the right to erasure.
CONTACT AND COMPLAINTS
You may always launch a complaint regarding our processing of your data with ico.org.uk