Privacy policy

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Gusto Gen Limited (company number 10775808) (“Gusto” / “we” / “our” / “us”) takes your privacy very seriously and is committing to protecting your personal data. 

If you wish to contact us regarding this privacy policy, please see the contact details here. Gusto is the data controller and our registered office is Springboard Innovation Centre, Cwmbran NP44 3AW, United Kingdom.

This privacy policy (together with the terms and conditions, which you can find here ) sets out the basis on which any personal data we collect from you, or that you provide to us through your use of our websites (https://www.gustogen.eu/, http://www.gustogen.eu/, https://www.gustogen.co.uk/, http://www.gustogen.co.uk/) and any sub-domains (the “Website(s)”), will be processed by us.  

This privacy policy does not apply to websites that you may be able to access via links on the Websites and/or activities offered by third parties. We are not responsible for the collection or use of your personal data from these third party websites.  Please ensure you review any relevant policies.

TOPICS COVERED:

  • DATA WE COLLECT FROM YOU OR ABOUT YOU AND OUR SOURCES OF THAT DATA

  • PURPOSE AND LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

  • MARKETING

  • DISCLOSURE OF YOUR PERSONAL DATA

  • WHERE WE STORE YOUR PERSONAL DATA

  • SECURITY

  • RETAINING PERSONAL DATA

  • YOUR LEGAL RIGHTS

  • COOKIES

  • CHANGES TO THIS PRIVACY POLICY

  • HOW TO CONTACT US

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

DATA WE COLLECT FROM YOU OR ABOUT YOU AND OUR SOURCES OF THAT DATA

We will collect, use, store and transfer the following data about you:

  • Data you give us. You may give us data about you:

    • by filing in a form on a Website. For instance, when you complete the “CONTACT” form on a Website;

    • when you register your details to gain behind the scenes access at Gusto and agree to receive:

      • newsletters with exclusive news and team updates;

      • job notifications;

      • team merchandise offers; and

      • updates on exclusive fan events;

    • if you ask us to provide you with other marketing communications;

    • if you ask us to provide you with personalised online content such as targeted advertising;

    • when entering a competition or prize draw;

    • when you place an order on a Website and during our fulfilment of such order;

    • if you contact us or correspond with us (for example, by phone, email or otherwise) for any other reason, for example, to find out more about Gusto or to enquire about and/or schedule a task with us; or

    • when you provide us with comments, opinions and/or feedback or when you complete a survey, for example, about a Website or any of our products.

  • Data we collect about you. We will collect the following personal data about you:

    • technical information, including the type of device (and its unique device identifier) you use to access a Website, the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug in types and versions, operating systems, mobile network information and platform; and

    • information about your visit to a Website including full Uniform Resource Locators (URL), clickstream to, through and from a Website (including date and time), pages you viewed, page response time, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

  • Data we collect from or which is provided by third parties. We may be given personal data about you by third parties such as the operator of the shop.williamsf1.com™ at a Website, ticket sales websites and social media platforms, or anyone making a booking on your behalf for you to attend Williams’ site or hospitality.

PURPOSE AND LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA

We will use the personal data held about you for the purposes stated below:

Purpose of ProcessingType of personal dataLegal basis for processing
To process and deliver any order you place directly with Gusto including managing payments, fees and charges and collect and recover money owed to us.Your name, email address, password, billing address, delivery address, credit or debit card details and phone number.Performance of a contract.
To manage our relationship with you, including-       dealing with any enquiries, correspondence, concerns or complaints you have raised with us;-       notifying you about changes to our terms and conditions and privacy policy; or-       asking you to leave a review or take a survey.Your name, email address, address, job title, company name, opinion and information about any concerns or issues you have raised.Performance of a contract and our legitimate interest – to enable us to keep our records updated and to better understand our fans, guests and customers.
To enable you to partake in a prize draw, competition or complete a survey.Your name, email address, job title, company name, phone number and address details.Performance of a contract and legitimate interest – to enable us to understand our fans and customers better.
To allow you to attend the Gusto offices or any other area.Your name, email address, phone number and address details.Legitimate interest – to enable us to provide you with access. 
As part of our efforts to keep the Websites safe and secure.Your personal contact details and the technical information mentioned above.Legitimate interest – to improve and ensure the safety of the Websites.
To compile reports (which do not personally identify you) about the use of the Websites. The technical information mentioned above. Legitimate interest – to improve the Websites.
To ensure that content on the Websites is presented in the most effective manner for you and for your device.The technical information mentioned above. Legitimate interest – to improve the Websites.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.The technical information mentioned above.Legitimate interest – to understand our fans better, keep the Websites updated and relevant and to develop our business and to inform our marketing strategy. 
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.The technical information mentioned above. Legitimate interest – to understand our fans better, keep the Websites updated and relevant and to develop our business and to inform our marketing strategy. 
To better understand our audience.The technical information mentioned above, email address, address, date of birth, job titles and which organisation you are from.Legitimate interest – to allow us to prepare statistical information to be used internally to better understand our fans, but also to be shared with our advertisers in non-personally identifying form to enable them to understand who their adverts are presented to and who they wish to target for advertising purposes.
To provide you with marketing communications, for example, newsletters, updates and notifications.Your name, postal address, phone number or email address.Consent.
To provide you with marketing communications with information about our sponsors and partners and news and updates about their services, activities and products.  Your name, postal address, phone number or email addressConsent.
To make suggestions and recommendations to you about products, services or events that may be of interest to you.Your name, date of birth, email address, postal address, phone number or the technical information mentioned above.Consent.
To provide personalised online content to you (via the Websites, social media platforms or our online partners). The technical information mentioned above, your name and email address.Consent.
 

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. 

Where we have a legal basis to use your personal data without consent (as we have described above), this policy fulfils our duty to process personal data fairly and lawfully and in a manner that you would expect given the nature of our relationship with you, by giving you appropriate notice and explanation of the way in which your personal data will be used.

Where consent is required for our use of your personal data, by ticking the appropriate consent box or otherwise communicating your consent, you consent to our use of that personal data for the purposes covered by the specific consent that you have given.  For example, we will only process your personal data for marketing purposes if we have your consent to do so. 

MARKETING

As mentioned above, we would like to send and present you with information about Gusto which may be of interest to you.

We will never provide your personal data to other businesses so they can use your personal data for marketing purposes.

We will only send and present you with marketing communications if you would like us to. You will have the opportunity to clearly set out whether you wish to receive marketing communications from us by ticking the relevant boxes.

DISCLOSURE OF YOUR PERSONAL DATA

We may share your personal data with selected third parties in accordance with this policy, including:

  • with Google, Facebook, Twitter and Microsoft (if you use your account with them to sign up / in with us), if applicable;

  • service providers (for example, IT services or CRM services), business partners, suppliers and sub-contractors for the performance of any contract we enter into with you, but also when sending out marketing communications;

  • professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;

  • any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;

  • analytics and search engine providers that assist us in the improvement and optimisation of the Websites;

  • government or other law enforcement agencies, in connection with the investigation of unlawful activities or for other legal reasons (this may include your location information); or

  • a third party where all or substantially all of our assets are acquired by such third party, in which case personal data held by us, including your personal data, will be one of the transferred assets (however, we will let you know before this happens).

WHERE WE STORE YOUR PERSONAL DATA

Where possible, we do not transfer the personal data we collect about you outside of the EU, but this is sometimes necessary in order for us to process your data in accordance with this policy. We are permitted to do in certain circumstances, including where: (i) the European Commission has determined that the destination country has adequate safeguards in place to protect your personal data; (ii) if the case of the US, if the third party to whom data is transferred is committed to the EU-US Privacy Shield programme; and (iii) we have put in place adequate safeguards with the third party processor by other means, the most common of which is a set of contractual clauses. Irrespective of whether (i) or (ii) applies, we put in place appropriate contractual clauses to ensure adequate protection with each third party supplier to ensure that they respect the EU and UK laws on data protection. If you require further information on any countries we may transfer your data to outside of the EU, whether there is an adequacy decision in place and/or what protective measures we have implemented, you can request it from us by submitting a query to the contact details at the end of this policy.

If you would like to find out more about this or obtain a copy of the relevant standard contractual clauses, please contact us at The Legal Department, Gusto Gen Ltd, Springboard Innovation Centre, Cwmbran, NP44 3AW, UK or by email at contact@gustogen.eu

SECURITY

All the information you provide us with is stored on secure servers.  We will use technical and organisation measures to safeguard your personal data. 

Where you have chosen (or we have given you) access details and/or a password which enable you to access your Williams team profile, you are responsible for keeping these access details and password confidential.  We ask you not to share your access details and password with anyone. 

We maintain (and ensure that anyone we share your personal data with maintains) appropriate technical and organisational measures to ensure that an appropriate level of security in respect of all personal data we process. 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 the Websites and you acknowledge that any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features which are appropriate to the type of personal data you have provided to try to prevent unauthorised access or inadvertent disclosure.

RETAINING PERSONAL DATA

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Even if you request that we erase your data, we may still need to keep it (please see below) or may keep it in a form that doesn’t identify you.  Unless you have an account on our website (to gain behind the scenes access) or you have agreed that we may use your personal data for marketing purposes (for example, to provide you with team updates and other marketing communications), we will only keep your personal data for six years after you have made a purchase from us or via the Websites. Please note that where you make a purchase through a webpage which is operated by a third party you should refer to their privacy policies for further information as to how your data is handled and how long it is kept.

YOUR LEGAL RIGHTS

You have the following rights with regard to your personal data:

  • Access. You have the right to access data we hold about you. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    • Rectification or erasure. You have the right to request that we rectify or delete any personal data that we hold about you (unless we have the legal right to retain it). This right does not extend to non-personal data. Please note that your rights to request erasure may be limited by applicable law.

    • Restriction. You also have the right to restrict us from processing your personal data if the data is inaccurate, the processing is unlawful or we no longer need your personal data for the purposes for which we hold it.

    • Data portability. You have the right to obtain personal data we hold about you, in a structured, electronic format, and to transmit such data to another data controller if the legal basis for processing such personal data is consent.

    • Object /change of preferences. You have a right to request that we stop processing your personal data where we are relying on a legitimate interest (or those of a third party). You have the right to object where we are processing your personal data for direct marketing purposes. For example, if you have given your consent to receive team updates or other marketing communications, but have changed your mind, you have the ability to opt out from receiving such communications going forward by contacting us using the details provided below or by clicking the relevant link in any communications you receive.

    • Complaints. If for any reason you are not happy with the way that we have handled your personal data, please contact us. If you are still not happy, you have the right to make a complaint to the Information Commissioner’s Office.

Please note that if you ask us to stop processing your personal data in certain ways or erase your personal data, and this type of processing of data is needed to facilitate your use of the Websites or the provision of products or services to you, you may not be able to use the Websites or receive products or services from us as you did before.  This does not include your right to object to direct marketing, which can be exercised at any time without restrictions. Please allow at least ten working days for your request to be actioned.

Please note that the rights mentioned above do not extend to non-personal data. 

If you would like to exercise any of the rights mentioned above, please contact us at The Legal Department, Gusto Gen Ltd, Springboard Innovation Centre, Cwmbran ,NP44 3AW, UK or by email at contact@gustogen.eu

COOKIES

Our Websites use cookies and other similar technologies (as described below) to distinguish you from other users of our Websites. This helps us to provide you with a good experience when you browse our Site, allows us to improve our Websites and provide you with tailored content and advertising.

Cookies are small files of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's or mobile device's hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of the Websites. They include, for example, cookies that enable you to log into secure areas of the Websites, use a shopping cart or make use of e-billing services.

  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Websites when they are using them. This helps us to improve the way the Websites work, for example, by ensuring that users are finding what they are looking for easily.

  • Functionality cookies. These are used to recognise you when you return to the Websites. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

  • Targeting cookies. These cookies record your visit to the Websites, the pages you have visited and the links you have followed. We will use this information to make the Websites and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We use Google Analytics which is an analytical / performance cookie. The Websites use Google Analytics to help analyse how users use the Websites, collecting standard internet log information and visitor behaviour information in an anonymised form from which no user is identifiable. We have also implemented Google Analytics features based on Display Advertising (Google Analytics Demographics and Interest Reporting).

This information is transmitted to Google and processed to compile statistical reports on activity on the Website and so be able to develop the Websites and the content around our users’ interests. These reports allow us to optimise our user experience. Google provide a browser add-on for users who wish to prevent their data from being used by Google Analytics.

Click here and here for an overview of privacy at Google, and click here if you wish to opt out from the operation of Google Analytics.  In addition, you can use the Google Analytics Opt-Out Browser Add-on to disable tracking by Google Analytics.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

CookieExpiryPurpose
_gid24 hoursThis is a Google cookie that is used to distinguish users.
_gat_UA-37733489-1_gat_UA-37733489-4_gat_UA-37733489-5_gat_UA-37733489-6_gat_UA-37733489-71 minuteThis is a Google cookie that is used to throttle request rate.
_ga2 yearsThis is a Google cookie that is used to distinguish users.
williamsf1#accept-consent365 daysTracks whether a user has consented to the use of cookies.
williamsf1#marketing-opted-outEnd of SessionTracks whether a user has cleared a message about opting in to marketing communications.
ASP.NET_SessionIdEnd of SessionUsed to identify the users session on our web server. 
.AspNet.ApplicationCookieEnd of Session or when user explicity logs out.Authentication cookie for users who have logged into our identity site.
__RequestVerificationTokenEnd of SessionAnti-forgery token used to help prevent CSRF attacks.
fr3 monthsFacebook Analytics cookie. Contains a unique browser and user id.
vimeo, __qca, __gads, continuous_play_v3, player, _abexps, vuid, is_logged_in, _ga, has_logged_in, _ceg.s, _ceg.u, __ssid, has_uploaded, _mibhv, sst_aid, sst_uidDates are set in the cookies themselves and may vary in length, depending on the purpose of the cookie.To display and deliver videos on our site, we make use of Vimeo, a video sharing website. The embedded Vimeo player, uses these cookies to check if certain features or preferences have been selected by the user. To find about more about how each cookie is used by see Vimeo’s cookie list. More information can be found on Vimeo’s privacy policy.
ARRAffinityEnd of SessionCookie which ensures a user stays on a specific instance of a website or web app in Azure.
 

By clicking “agree” in the cookie consent box when you first access a Website and by continuing to access and use the Websites you accept the use of the cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use browser settings to block all cookies (including essential cookies) you may not be able to access all or part of the Websites.

For more detailed information about cookies and how they can be managed and deleted, please visit www.allaboutcookies.org.

CHANGES TO OUR PRIVACY POLICY

Any changes we make to our privacy policy in the future will be posted on this page, where appropriate, or notified to you by e-mail.  Please check back frequently to see any updates or changes to our privacy policy. 

Continued use of any Website will signify that you agree to such changes.

HOW TO CONTACT US

Questions, comments and requests regarding our privacy policy are welcomed and should be addressed to The Legal Department, Gusto Gen Ltd, Springboard Innovation Centre, Cwmbran ,NP44 3AW, UK or by email at contact@gustogen.eu

Please also contact us if you would like to know more about our data processing activities, to update or amend any of your personal data which you have provided to us or if you believe our records relating to your personal data are incorrect.

Our privacy policy was last updated on 10 April 2020.

Version: PP-04-2020

Our terms and conditions were last updated on 5 May 2020. 

Version: TC-05-2020