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Privacy Policy

Last updated on 23rd October 2023.

Introduction

This Privacy Policy describes how Westerwood (WG) Global Ltd, known as WGNSTAR (“WGNSTAR“, “we” or “us”) collects, uses, shares and otherwise processes your personal data on or in connection with your use of the WGNSTAR website at https://wgnstar.com/ website (“Website”); how we protect it; and the choices you may make with respect to it. At WGNSTAR we are committed to providing you with an Internet experience that respects and protects your data protection and privacy rights. We protect your personal data in accordance with applicable data protection and privacy laws.

By visiting this Website, you acknowledge that we will process your personal data in accordance with the terms of this Privacy Policy. Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of those other websites. You should read those third party websites’ privacy policies to learn how they process your personal data.

This Privacy Policy only applies to this Website. WGNSTAR products and services are subject to their own terms and conditions and may also be subject to different privacy and data protection policies or terms which apply instead of this Privacy Policy.

Types of Information Collected

Personal Data

This is data that identifies you or can be used to identify or contact you and may include your name, address, email address, telephone number, etc. Such personal data is only collected from you if you voluntarily submit it to us (eg, by contacting us at the email or physical addresses specified at the end of this Privacy Policy or by using any webforms or other communication tools that we may make available on this Website from time-to-time) or that we otherwise learn about you from your use of this Website and from our other communications and other dealings with you and/or Your Organization.

If you provide us with any personal data relating to another person, you hereby represent and warrant that you have the authority to share that personal data with us and to permit us to use that personal data as described in this Privacy Policy, and that you have given a copy of this Privacy Policy to that other person. 

We do not collect or otherwise process sensitive or special category personal data (eg, personal data relating to your race, ethnicity, religious or philosophical beliefs, sex life or health) or personal data relating to criminal convictions and offenses, from you on or through our Website.

Non-Personal Data

Like many Websites, we gather statistical and other analytical information collected on an aggregate basis of visitors to our website. This non-personal data comprises information that cannot be used to identify, track or contact you, such as demographic information regarding, for example, user IP addresses where they have been clipped or anonymized, browser types and other anonymous statistical data involving the use of our Website. 

We use this information to keep our Website working as you expect it to, to analyze traffic on our Website, to prevent non-genuine users and/or malicious software from engaging in abusive activities on our Website, and to enable performance and product and service improvements.

WGNSTAR is the sole owner of the personal data and non-personal data collected on or through this Website. We will not sell, share, disclose or rent this information to others in ways different from what is disclosed in this Privacy Policy.

How We Use Your Personal Data

We will use and otherwise process any personal data you provide to us or that we otherwise obtain about you as described in this Privacy Policy, as necessary to pursue our legitimate business and related interests including for the following purposes:

  1. to provide you with information about a product or a service you have requested or inquired about and to otherwise communicate with you about them;
  2. to operate, manage, administer and improve our business and our client and service provider engagements and relationships;
  3. to manage, maintain and expand our business;
  4. for corporate marketing, business development and analysis purposes;
  5. to enforce our terms and conditions as applicable to the use of our Website (including its content), products and services;
  6. to operate, manage and ensure the security of our information technology and systems;
  7. to establish, exercise and/or defend legal claims;  
  8. to protect our rights, privacy, safety and property and where relevant, those of others; and
  9. to investigate, respond to and address complaints or incidents relating to us or our business, to maintain service quality and to train our staff.

We also process your personal data as we believe to be necessary or appropriate to comply with applicable laws and regulations that we are subject to and our regulatory monitoring and reporting obligations (which may include laws outside your country of residence), to respond to requests from public and government authorities (which may include authorities outside your country of residence), to cooperate with law enforcement, and for other legal and/or regulatory reasons.

We do not generally rely on consent as the legal basis for processing your personal data. If ever we do seek to rely on your consent as the legal basis for processing your personal data, we will always make this clear to you at the time we ask for your consent and you will always have the choice to give or withhold  your consent.

In some cases, our legal basis may be that the processing is necessary for the performance of a task carried out in the substantial public interest on the basis of law (eg, the prevention and detection of crime or to protect the rights, privacy, safety or property of you or others).

You are not required to provide any personal data to us, but we may not be able to provide you with the information about our products or services that you request in the absence of you providing such personal data.

We do not use your personal data that we collect or otherwise obtain in connection with your use of our Website for direct marketing nor do we engage in automated decision making in respect of your personal data. We do not collect or otherwise process your biometric data on or through our Website.

Disclosure of Your Personal Data

We disclose your personal data, for the reasons explained above under ‘How We Use Your Personal Data’ as follows:

  1. If you use this Website on behalf of Your Organization, to Your Organization in connection with the products and services that we provide to Your Organization if they are our client, or otherwise in connection with our dealings with Your Organization;
  2.  to our affiliates (this includes Westerwood Global USA Corporation and any other affiliate(s) that may be listed on our Website from time-to-time) for the purpose of managing our and their client, service provider and other business counterparty relationships;
  3. to our third party service providers that provide data storage and processing, fraud monitoring, call center and/or other customer services, hosting services and other technology and business process outsourcing services;
  4. to our legal and professional service providers including our legal advisors, accountants, auditors, insurers and tax advisors;
  5. to government and law enforcement authorities and other persons involved in, or contemplating, legal proceedings;
  6. to competent regulatory, prosecuting, tax or governmental authorities, courts or other tribunals in any jurisdiction;
  7. to other persons or bodies where disclosure is required by applicable laws and/or regulations; and
  8. to third parties in connection with any actual or potential reorganization, sale, merger, liquidation, receivership, disposal or transfer of all or substantially all of the assets of our company.

Transfer of Your Personal Data

The personal data we collect and otherwise process through and in connection with your use of this Website may be stored and otherwise processed in any country where we have facilities or in which we engage with our affiliates, customers, service providers, other business counterparties, and regulatory, prosecuting, tax and governmental authorities, courts and tribunals, including in the EEA, UK and US.  The laws of these countries may have different data protection laws and standards to those which apply in the country or jurisdiction where you live. 

WGNSTAR will take all steps reasonably necessary to ensure that your personal data is protected securely and in accordance with this Privacy Policy and applicable law, and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place to protect your personal data.

For transfers from the EEA or UK to third countries whose data protection laws are not considered by the European Commission or the UK government to provide an adequate level of protection, we have put in place measures that are intended to protect your personal data, such as by ensuring that the recipient is bound by approved standard contractual clauses or other appropriate safeguards in accordance with EU and UK data protection laws. 

Access, Change or Delete Your Personal Data

You have certain rights in relation to your personal data. If you would like to request us to provide you with a copy of your personal data, update or correct your personal data, delete your personal data or restrict the processing of your personal data, or if you object to our processing of your personal data, you may contact us as indicated in the Contact Us section below. However, please note that these are not absolute rights and they may be limited in some cases. For example, if we need to process your personal data to comply with an obligation that we have under an applicable law or regulation, then we will not be able to delete it until that legal or regulatory obligation no longer applies to us. 

For your protection, we may need to verify your identity before actioning your request. We will endeavor to comply with your request as soon as reasonably practicable and in any event in accordance  with any timeframe required by applicable law. 

You may also contact us if you would like to receive a copy of the relevant data transfer safeguards referenced under the Transfer of your Personal Data section above.

You have the right to file a complaint with the relevant data protection authorities where you live or work or where the alleged infringement of data protection law occurred.

Use by Minors 

The Website is not intended for or directed to individuals under the age of sixteen (16) (or if different, the age of consent or majority in the place where you live) and we do not knowingly collect personal data from or about such individuals. If you are under the age of 16 (or if different, the age of consent or majority in the place where you live), you will need your parent’s or legal guardian’s permission to use the Website. Please consult with your parent or legal guardian before using the Website.

If you are a parent or legal guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected or otherwise received personal data from anyone under the age of sixteen (16) (or if different, the age of consent or majority in the place where the individual lives) without verification of parental consent, we will take the necessary steps to delete and otherwise cease processing that personal data.

Security

WGNSTAR will take all steps reasonably necessary to ensure that your personal data is protected securely and in accordance with this Privacy Policy and applicable law. Your personal data is held on secure servers and we seek to use a range of reasonable organizational, technical, and administrative measures to protect your personal data that are proportionate to the risk associated with the relevant personal data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.

Retention of Personal Data

We only retain your personal data for as long as is necessary for the purposes for which the personal data was collected, including as necessary for maintaining our relationship with you or Your Organization. We will also retain your personal data to the extent required to enable us to comply with our obligations under laws and regulations that apply to us. Our retention of personal data will at all times be subject to our records retention policies and procedures and applicable law. When we no longer have a valid legal reason to retain your personal data, we will securely destroy it or alternatively, we will anonymize it in an irreversible manner, so that that information it is no longer personal data and cannot be associated with you.

Privacy Policy Changes

We may update this Privacy Policy from time to time. In such case, we will post the updated Privacy Policy on this Website. 

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this Website.

Contact Us

For the purposes of the processing activities described in this Privacy Statement, Westerwood (WG) Global Limited, known as WGNSTAR, is the data controller of your personal data.

If you have any questions about this Privacy Policy, including how we process your personal data, or if you wish to exercise your data protection rights, you may contact us as follows:

By email: info@wgnstar.com; or

By Post: Westerwood (WG) Global Limited, known as WGNSTAR, Unit H1, Maynooth Business Campus, Maynooth, Co. Kildare, W23 E4A8, Ireland.