Privacy Policy

1. Introduction

Wingmine respects your privacy and is committed to protecting personal data. This Privacy Policy explains how we collect, use, disclose and protect personal data when you visit the Wingmine website, contact us by email, or otherwise communicate with Wingmine.

This Privacy Policy applies to information collected through this website and related communications. Additional privacy information may apply if you enter into a formal business or contractual relationship with Wingmine.

2. Data Controller and Contact

Wingmine is responsible for the processing of personal data described in this Privacy Policy. In this Privacy Policy, “Wingmine”, “we”, “us” and “our” refer to Wingmine. For questions about this Privacy Policy, the processing of your personal data or the exercise of your rights, contact info@wingmine.com.

3. Personal Data We Collect

Depending on how you interact with us, we may collect identity and contact information, including your name, email address, telephone number where provided, organisation or employer, and country of residence.

We may collect enquiry and communication information, including messages you send us, materials or information you request, email correspondence and other communications with Wingmine, and records of our response and subsequent discussions.

When you use our website, we may collect limited technical and usage information, including IP address, browser type and version, device type and operating system, pages visited and time spent on the website, referring website or URL, date and time of access, and website security and diagnostic information. We do not currently use non-essential cookies or analytics on this website.

We do not intentionally request special-category personal data through the website or email. Please do not send sensitive personal information unless it is strictly necessary.

4. How We Collect Personal Data

We collect personal data directly from you when you contact us or during subsequent correspondence or discussions with you. We may collect limited technical information automatically where necessary to operate and secure the website, and from service providers that support its operation, security and administration.

5. How and Why We Use Personal Data

We process personal data only where we have a lawful basis for doing so. We use information to respond to questions or enquiries, provide information you request, arrange discussions where appropriate, and manage subsequent correspondence. The lawful basis is our legitimate interest in communicating with prospective business contacts and other professional contacts; where a request may lead to a contractual relationship, processing may also be necessary to take steps at your request before entering into a contract.

We may process technical information to provide and maintain the website, identify and prevent misuse, fraud or security threats, diagnose technical problems, maintain availability and performance, and keep appropriate security records. The lawful basis is our legitimate interest in operating and securing the website and protecting Wingmine, its users and its systems.

We may retain and process information where necessary to maintain appropriate business records; establish, exercise or defend legal claims; respond to regulatory or legal requests; and comply with applicable laws and obligations. The lawful basis is our legitimate interest in protecting our legal and commercial position or compliance with a legal obligation.

Where permitted by law, we may contact you about information directly related to your enquiry or stated area of interest. We will obtain consent where consent is required for marketing communications. You may ask us to stop sending non-essential communications at any time.

6. No Solely Automated Decision-Making

Wingmine does not use personal data collected through the website to make decisions producing legal or similarly significant effects based solely on automated processing.

7. Cookies and Similar Technologies

The website does not currently use non-essential cookies or analytics. If optional analytics cookies or similar technologies are introduced, they will be used only after consent where required by law, and this Privacy Policy will be updated accordingly. You may also configure your browser to block or delete cookies, although doing so may affect website functions if such technologies are introduced.

8. Sharing Personal Data

Wingmine does not sell personal data. We may disclose personal data to website-hosting, technology, IT, cybersecurity and analytics providers where applicable; professional advisers, including legal, compliance, accounting and tax advisers; regulators, courts, public authorities or law-enforcement bodies where required by law; and parties involved in a proposed reorganisation, financing, merger, acquisition or transfer of all or part of our business, subject to appropriate confidentiality protections.

Service providers processing personal data on our behalf are required to handle that information in accordance with our instructions, applicable data-protection law and appropriate confidentiality and security obligations. Personal data will not be shared with third parties for their independent marketing purposes without an appropriate lawful basis.

9. International Data Transfers

Some service providers may process personal data outside Sweden or the European Economic Area. Where personal data is transferred to a country that has not been recognised as providing an adequate level of data protection, we will use appropriate safeguards as required by applicable law. These may include European Commission Standard Contractual Clauses, supplementary technical or organisational safeguards, or another legally recognised transfer mechanism. You may contact us for further information about relevant safeguards.

10. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected. The appropriate retention period depends on the nature of your enquiry or request; whether a prospective or ongoing business relationship exists; the sensitivity and volume of the information; relevant limitation periods; applicable legal, regulatory, accounting or reporting requirements; and the need to establish, exercise or defend legal claims. Where an enquiry does not lead to a business relationship, we retain related information only for a reasonable follow-up and record-keeping period before deleting or anonymising it.

11. Data Security

We use appropriate technical and organisational measures designed to protect personal data against unauthorised access, accidental loss, unlawful use or disclosure, alteration and destruction. Access is limited to individuals and service providers who require it for legitimate business purposes and who are subject to appropriate confidentiality obligations. No website or electronic transmission can be guaranteed to be completely secure.

12. Your Data-Protection Rights

Subject to applicable law and relevant limitations, you may have the right to request access to the personal data we hold about you; correction of inaccurate or incomplete information; deletion; restriction of processing; objection to processing based on legitimate interests; receipt of certain personal data in a structured, commonly used and machine-readable format; transfer of certain data to another controller; withdrawal of consent where processing is based on consent; and to lodge a complaint with a data-protection authority.

Withdrawing consent does not affect the lawfulness of processing performed before consent was withdrawn. These rights are not absolute. We may need to retain or continue processing certain information where permitted or required by law. To exercise your rights, contact info@wingmine.com. We may request information necessary to verify your identity before responding.

13. Right to Object

Where we process personal data based on legitimate interests, you may object to that processing based on your particular situation. Where personal data is processed for direct-marketing purposes, you may object at any time. We will then stop using your personal data for that purpose.

14. Complaints

If you have concerns about how Wingmine handles your personal data, please contact us first so that we can investigate the matter. You also have the right to lodge a complaint with the Swedish Authority for Privacy Protection, Integritetsskyddsmyndigheten (IMY), at www.imy.se. If you live or work in another country within the European Economic Area, you may also contact the data-protection authority in that country.

15. Children and External Websites

The website is not directed at children. We do not knowingly collect personal data from individuals under the age of 18. If you believe that a child has provided personal data to us, please contact us so that we can take appropriate action.

The website may contain links to third-party websites. Wingmine is not responsible for their privacy, security or content. Review the privacy policy of a third-party website before providing personal data.

16. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to the website, our activities, applicable law or the way we process personal data. The latest version will be published on this page with an updated revision date. Material changes may also be communicated through the website or by another appropriate method.