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GDPR Compliance

Last Updated: May 14, 2026

winter-gleam is committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018.

1. Data Controller

winter-gleam is the data controller responsible for your personal data. Our contact details are:

Email: [email protected]
Address: 42 Deansgate, Manchester, M3 2EG, United Kingdom

2. Legal Basis for Processing

We process your personal data based on the following legal grounds:

  • Contract Performance: Processing is necessary to fulfil our contract with you when you book our programmes
  • Legitimate Interests: We have a legitimate interest in improving our services and communicating with you
  • Consent: Where you have given explicit consent for specific purposes
  • Legal Obligation: Where we need to comply with legal requirements

3. Your Rights Under GDPR

3.1 Right to Access

You have the right to request copies of your personal data. We may charge a reasonable fee if your request is clearly unfounded or excessive.

3.2 Right to Rectification

You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

3.3 Right to Erasure

You have the right to request that we erase your personal data under certain conditions, such as when the data is no longer necessary for the purposes for which it was collected.

3.4 Right to Restrict Processing

You have the right to request that we restrict the processing of your personal data under certain conditions.

3.5 Right to Data Portability

You have the right to request that we transfer the data we have collected to another organisation, or directly to you, under certain conditions.

3.6 Right to Object

You have the right to object to our processing of your personal data under certain conditions, particularly for direct marketing purposes.

3.7 Rights Related to Automated Decision Making

We do not use automated decision-making or profiling in our processing of your personal data.

4. How to Exercise Your Rights

To exercise any of your rights under GDPR, please:

  • Email us at [email protected]
  • Clearly state which right you wish to exercise
  • Provide sufficient information to identify you

We will respond to your request within one month of receipt. In complex cases, we may extend this period by two additional months and will inform you of any such extension.

5. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including:

  • Programme booking and delivery: Duration of the programme plus 12 months
  • Financial records: 7 years (for tax purposes)
  • Marketing communications: Until you unsubscribe or request deletion

6. Data Security

We have implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including:

  • Encryption of personal data
  • Regular security assessments
  • Access controls and authentication
  • Staff training on data protection

7. International Data Transfers

Your personal data is stored and processed within the United Kingdom. If we need to transfer your data outside the UK, we will ensure appropriate safeguards are in place.

8. Data Breach Notification

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you without undue delay and within 72 hours of becoming aware of the breach.

9. Children's Data

We take extra care when processing data relating to children. We require parental or guardian consent for children under 16 years of age. Parents and guardians have the right to exercise data protection rights on behalf of their children.

10. Complaints

If you believe we have not handled your personal data properly, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Tel: 0303 123 1113
Website: ico.org.uk

11. Updates to This Notice

We may update this GDPR compliance notice from time to time to reflect changes in our practices or legal requirements. We encourage you to review this page periodically.

12. Contact Us

If you have any questions about our GDPR compliance or how we handle your personal data, please contact us at [email protected]

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