Privacy Notice

WENUP LTD - Privacy Policy

wenup.co.uk (our website) is provided by WENUP LTD trading as WE-NUP (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, or through the provision of our services to you, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (‘PECR’) as amended or updated from time-to-time.

What this policy applies to

This privacy policy relates to your use of our website and our services.

Throughout our website we may link to other websites owned and operated by certain trusted third parties. Those third-party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third-party websites, please consult their privacy policies as appropriate.

Personal data we collect about you

We will collect and use the following personal data about you:

• your name, address and contact information, including email address and telephone number;
• information to check and verify your identity, e.g., date of birth;
• your gender;
• location data;
• your billing information, transaction and payment card or other payment method information;
• bank account and financial details such as pensions and savings;
• payment information (i.e., you card number, expiry date and security code);
• details of any information, feedback or other matters you give to us by phone, email, post or via social media; and
• your activities on, and use of, our website.

You must provide this personal data to enable us to provide you with our services. If you do not choose to give us your personal data, we may not be able to provide you with our services. We will tell you when this is the case.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

How your personal data is collected

We collect personal data from you:

• directly, when you enter or send us information, such as when you have a meeting with us or otherwise communicate with us (including via email communication, feedback or telephone calls), and
• indirectly, such as (i) when you meet with a professional legal adviser; and (ii) when you browse our website (see section on ‘Cookies’ for further information.

How and why we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

• where you have given consent
• to comply with our legal and regulatory obligations
• for the performance of a contract with you or to take steps at your request before entering into a contract, or
• for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Creating and managing your account with us	For our legitimate interests, i.e., to be as efficient as we can so we can deliver the best service to you at the best price; and To perform our contract with you or to take steps at your request before entering into a contract.
Providing services to you	To perform our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us	To comply with our legal and regulatory obligations; and For our legitimate interests, i.e., to minimise fraud that could be damaging for you and/or us.
Enforcing legal rights or defend or undertake legal proceedings	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, i.e., to protect our business, interests and rights
Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website	Depending on the circumstances: —your consent (see ‘Cookies’ below); and —where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e., to be as efficient as we can so we can deliver the best service to you at the best price If you have provided such a consent, you may withdraw it at any time by contacting us (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Communications with you not related to marketing, including about changes to our Terms or policies or changes to the services or important notices	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, i.e., to be as efficient as we can so we can deliver the best service to you at the best price
Protecting the security of systems and data used to provide the services	To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Statistical analysis to help us understand our customer base	For our legitimate interests, i.e., to be as efficient as we can so we can deliver the best service to you at the best price
Updating and enhancing customer records	Depending on the circumstances: —to perform our contract with you or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —where neither of the above apply, for our legitimate interests, e.g., making sure that we can keep in touch with our customers about existing services
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business	To comply with our legal and regulatory obligations
Marketing our services to existing and former customers	For our legitimate interests, i.e., to promote our business to existing and former customers
For audit purposes	For our legitimate interests so we can demonstrate we operate at the highest standards

Marketing

We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes. This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by contacting us.

We will always treat your personal data with the utmost respect and never sell share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We routinely share personal data with:

• third parties we use to help deliver our services to you, e.g., payment service providers, warehouses and delivery companies;
• other third parties we use to help us run our business, e.g., marketing agencies or website hosts and website analytics providers;
• professional legal advisers e.g., solicitors and barristers; and
• our bank.

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.

We or the third parties mentioned above occasionally also share personal data with:

• our auditors, e.g., in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations; and
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised, but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it is used.

Different retention periods apply for different types of personal data. We will retain some of your personal data indefinitely in order for us to defend against legal claims and in order to comply with our legal obligations and duties to the courts of England and Wales (such as your contact details, and a copy of your nuptial agreement and any communication data which we collected when we provided services to you).

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

Transferring your personal data out of the UK and EEA

Other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.

We do not routinely transfer your personal data outside of the UK or EEA. Where is it necessary for us to do so, we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data to ensure that your personal data is protected.

Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:

• in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
• a specific exception applies under relevant data protection law.

Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) legally approved international data transfer agreements as recognised or issued further to Article 46(2) of the UK GDPR.

Cookies

A cookie is a small text file which is placed onto your device (e.g., computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

For further information on cookies please see our Cookies Policy

Your rights

You generally have the following rights, which you can usually exercise free of charge:

Access to a copy of your personal data	The right to be provided with a copy of your personal data.
Correction (also known as rectification)	The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data in certain situations.
Restriction of use	The right to require us to restrict use of your personal data in certain circumstances, e.g., if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party in certain situations
To object to use	The right to object: —at any time to your personal data being used for direct marketing (including profiling) —in certain other situations to our continued use of your personal data, e.g., where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to decisions without human involvement	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by our website
The right to withdraw consents	If you have provided us with a consent to use your personal data, you have a right to withdraw that consent easily at any time You may withdraw consents by contacting us. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

Please note that some of the above rights may be limited in some circumstances under applicable law.  In particular, We-Nup is exempt from the UK GDPR provisions on or relating to the right to be informed and the right of access in relation to:

• Information in respect of which a claim to legal professional privilege or, in Scotland, communications, could be maintained in legal proceedings; or
• Information in respect of which a duty of confidentiality is owed by a professional legal adviser to a client of the adviser.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please contact us (see: ‘How to contact us’ below).

 When contacting us please:

• provide enough information to identify yourself (e.g., your full name and address) and any additional identity information we may reasonably request from you, and
• let us know which right(s) you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.

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

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the UK’s Information Commissioner Office who may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

Changes to this privacy policy

We may change this privacy policy from time to time—when we make significant changes, we will take steps to inform you.

How to contact us

You can contact us by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below

Full name:          Mr James Brookner

Address:         WENUP LTD, No. 15 7 Alfred Street, London, United Kingdom, E3 2BE.

Email:                      hello@wenup.co.uk

Do you need extra help?

If you would like this policy in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).