Privacy Policy

This Privacy Policy is effective from 1st March 2024

1. POLICY ACCEPTANCE 

This Privacy Policy applies to the website https://www.amigas.app (“website”) and our Web App, operated by Wingwomen Ltd. and trading as amigas (“Amigas.”) and shall include all personal data processed by us through direct mail, telephone or social media channels. Any reference to “you” or “your” means you, the user.

2. POLICY STATEMENT 

Amigas recognises the trust you place in us when you share personal data with us. We are committed to being open, honest and transparent with our use of personal data.

This Privacy Policy provides you with details of the personal data we collect when we engage with you, how we will use and look after your personal data, your privacy rights and how the law protects you. We will take all reasonable steps to ensure that personal data is safeguarded and kept in accordance with applicable data protection law. 

3. ABOUT US 

Amigas is registered under the name Wingwomen Ltd. in England and Wales under company registration number 15388228. Our registered office address is 20 Wenlock Road, London, England, N1 7GU.

Where we manage personal data, we identify as a Data Controller and recognise and act on our obligations under applicable data protection law, including but not limited to the EU General Data Protection Regulation and the Data Protection Act 2018. We are registered with the Information Commissioner’s Office (ICO). 

You can contact us in relation to data protection matters by email to support@amigas.app.

4. WHAT PERSONAL DATA DO WE COLLECT? 

Personal data is any information relating to an identified or identifiable individual. It does not include data where the identity has been removed (i.e. anonymous data). We may collect, use, store and transfer different kinds of personal data about you when we engage with you. 

This may include: 

(a) Identity Data – first name, last name, date of birth or similar identifiers. If you interact with us through social media, this may include your social media username; 

(b) Contact Data – billing address, email address and telephone numbers; 

(c) Financial Data – payment card details; 

(d) Transaction Data – details about services we have provided to you; 

(e) Technical Data – includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the website; 

(f) Profile Data – your username and password, your preferences, feedback and survey responses; 

(g) Geographical Data – information setting out your primary address to control the use of location services in most mobile devices and desktop settings; 

(h) Usage Data – information about how you use our website and services; 

(i) Marketing and Communications Data – includes your preferences in receiving marketing from us and our third parties and your communication preferences. 

5. HOW DO WE COLLECT PERSONAL DATA? 

We use different methods to collect data from and about you, through: 

  • Using forms on our website 

    • We collect details of a user’s name and email as well as content of any message when using our website forms to get in touch. We may process personal data on the basis of being legitimate to our business or in order to fulfil a contractual obligation in relation to our services. 

  • Applying to become an amigas mentor

    • Amigas has access to and processes personal data for applicants who express an interest in becoming a mentor in order to conduct our business.  We process this data in line with the consent of those supplying the details.

  • Creating an account on the amigas web application

    • Personal details provided during registration on our website are processed so that you can access the amigas mentoring services.

  • Emails

    • We retain copies of emails sent to us and any personal data will be held in accordance with this Privacy Policy on the basis of being legitimate to our business interests. 

  • Other direct interactions

    • You may give us your data by filling in forms or by corresponding with us face-to-face, when attending any events, training, talks or workshops we hold, or through our social media channels. This includes personal data you provide when you: register to receive our services; make enquiries or request information be sent to you; use our services; ask for information to be sent to you; engage with us on social media; contact us directly; or leave comments or reviews on our services. 

  • Social Media

    • We use social media to engage with users and link to our Facebook, Instagram and LinkedIn pages. We do not keep any specific data that identifies you as an individual user but hold details of our followers on these platforms. 

    • If you send us a direct message via social media, the details may be retained by us only as relevant to any ongoing contract or to further our legitimate business interests or as required for legal purposes. The third-party provider may also retain details in accordance with their Privacy Policy. 

  • Visits to our website

    • When you visit our website, we do not attempt to identify you as an individual user, and we will not collect personal data about you unless you specifically provide this to us. 

    • As you interact with our website, technical data may be automatically processed through the use of Cookies, details of which are explained in our Cookie Policy. 

3.1 Special categories of data 

We collect some special category data when you create an account on the amigas web application in order to tailor the Services to you. These are:

  • Gender and marital status; 

  • Sexual orientation

Any other sensitive data, for instance about your religious or political beliefs, ethnicity, physical or mental health condition, names of partners or family members, financial information etc., that you choose to disclose via our Services or communication channels is done so entirely of your own free will. We strongly recommend that you DO NOT disclose such potentially sensitive information whilst using our Services or communication channels. 

3.1.1 Children 

We do not market this website or our Services to those under 18 years old. Consistent with the GDPR we will never knowingly request personally identifiable information from anyone under the age of 18 years old. We will take appropriate steps to delete any personal data of individuals less than 18 years of age that has been collected on our website upon learning of the existence of such data. 

6. INFORMATION WE GET FROM OTHER SOURCES 

From time to time, we may need to obtain information from third parties about you. This will only apply where it is necessary to provide our services and as permitted by law. 

We may receive personal data relating to your identity and contact data from data partners and data from any third parties who are permitted by law or have your permission to share your personal data with us, such as via social media. 

7. HOW WE USE YOUR DATA 

UK data protection law requires us to have a “legal basis” for processing personal data. The legal bases we rely on are: 

  • Compliance with a legal or regulatory obligation; 

  • Carrying out activities that are legitimate to our business interests; 

  • Consent. However, generally, we shall not rely on consent as a legal basis for processing your personal data other than where the law requires it. Where our legal basis is consent, you have the right to withdraw consent any time. 

Detailed list of the reasons for us using personal data.

  1. Online registration: 

Type of data: (a) Identity (b) Contact 

2. Mentor application processing:

Type of data: (a) Identity (b) Contact 

3. To process payments 

Type of data: (a) Identity (b) Contact (c) Financial (d) Transaction 

4. Obligations to administer and improve the website and amigas web application

Type of data: (e) Technical (h) Usage 

It is in our legitimate interests to develop and improve our products and services, so that we can continue to provide products and services that our customers want to use, and to make sure we continue to be competitive 


5. To send email notifications which have been specifically requested 

Type of data: (a) Identity (b) Contact 

It is in our legitimate interests to give you information about our products and services that you may be interested in 


6. To send marketing communications, where expressly agreed eg newsletters; 

Type of data: (a) Identity (b) Contact (i) Marketing and Communications 

In the case of electronic marketing when we have your consent to do so

7. To provide third parties with statistical information about our users 

Type of data: (e) Technical  (h) Usage 

It is in our legitimate interests to better understand how our customers use our products and what changes we could make to improve them


8. To ask for feedback or review 

Type of data: (a) Identity (b) Contact 

It is in our legitimate interests to better understand how our customers use our products and what changes we could make to improve them 


9. To deal with enquiries and complaints 

Type of data: (a) Identity (b) Contact (c) Financial (d) Transaction (e) Technical (h) Usage 

It is in our legitimate interests to make sure that our customer accounts are well-managed, so that our customers are provided with a high standard of service 


Users contacting this website and/or its owners do so at their own discretion and provide any such personal data requested at their own risk. Your personal data is kept private and stored securely until a time it is no longer required or has no use. 


Our legitimate interests 

When we use our legitimate interests as the legal basis for processing your personal data, we will consider and balance any potential impact on you and your rights before we process your personal data. We will only then proceed where we believe our interests are not overridden by the impact on you. Our legitimate interests include the management of our business operations. 

8. SHARING INFORMATION 

Disclosure 

We don’t share, sell, or distribute your data to third parties, except as contractually agreed with you or as explained in this Privacy Policy. We may disclose your personal data if we are required to do so by law, in connection with any legal proceedings, and in order to establish, exercise or defend our legal rights, or if otherwise legally permitted. 

Data Processors 

We use Data Processors who act on our instruction in relation to the management of your personal data and where this applies, all data processors are required to confirm that they adhere to data protection law and regulations. We will ensure that any Data Processors used only operate on our written instructions and comply with their obligations under the GDPR. 

Data Processors who provide services to amigas include those providing mentoring, or other services such as workshops, groups or training events. Personal data is only collected and/or provided on a need to know basis. 

Marketing 

We may carry out direct marketing by email or text. We will ask for your consent to receiving marketing communications (including newsletters) when you register on the website and you have the option not to give consent and to withdraw consent given at any time. 

You may withdraw your consent for us to contact you by email to support@amigas.app. We may continue to contact you for non-marketing purposes if there is another lawful basis to do so. Non-personally identifiable information may be provided to other third parties for marketing, advertising or other uses. 

External links 

Users of the website are advised to adopt a policy of caution before clicking on any external web links. Clicking an external link will take the user away from our website. Once you leave our website or are redirected to a third-party website, plug-in or application, you are no longer governed by this Privacy Policy or our website’s terms and conditions. We cannot guarantee or verify the contents of any externally linked website and users click on external links at their own risk. Amigas and its owners cannot be held liable for any damages, or the consequences of visiting any external links. 

Social media platforms 

Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are subject to our terms and conditions as well as the privacy policies held with each social media platform respectively. 

Users are advised to use social media platforms wisely and communicate and/or engage with them with due care and caution in regard to their own privacy and personal details. This website nor its owners will not ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by email. 

Payment processing 

In order to process your account and take payment for amigas services on the web application or elsewhere we will process your Debit/Credit card details via Stripe. We follow their technical and operational standards to ensure that credit card data provided by cardholders is safeguarded and that all payment transactions are carried out securely. 

9. DATA RETENTION 

We keep your personal data in accordance with our Data Retention Policy which reflects our needs to provide services to you as contracted and also as required to meet legal, statutory and regulatory obligations. The need to hold information is regularly reviewed and data will be disposed of when no longer required. 

10.DATA SECURITY 

We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. We take appropriate steps to ensure a safe processing of personal data, however, we cannot guarantee the security of data transmitted through our website or by email. Any such transmission is at the sender’s own risk. 

11.DATA STORAGE AND TRANSFERS 

We may transfer some or all of your data to countries outside of the EEA where such countries provide adequate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission (EC). 

Where data is to be transferred to a country outside of the EEA which does not offer the same level of protection as the GDPR with respect to the processing of personal data, we will ensure that the company agrees to similar levels of protection. 

Where we transfer data to any organisation based in the US, we may transfer data to them where they provide similar protection to personal data shared between the Europe and the US. 

12.RIGHTS OF DATA SUBJECTS 

Amigas recognises a data subject’s rights and will uphold these in accordance with data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within one month from either (i) the date that we have confirmed your identity or (ii) where we do not need to do this because we already have this information, from the date we received your request. 

You should note that the following rights may not be absolute and may not be upheld where there is valid justification not to do so. 

Subject access requests:

You have the right to ask for a copy of the information that we hold about you by email to support@amigas.app. 

Right to rectification:

Data subjects have the right to request that personal data is amended or changed if it is inaccurate or incorrect. We act on any such request without delay. 

Right to erasure:

Data subjects have the right to ask us to delete personal data from our systems without giving any reason and at any time. We act on any such request without delay. 

Right to restrict processing:

Data subjects have the right to rectification or erasure of personal data in the following circumstances: 

– Personal data is not accurate; 

– The processing of data is unlawful; 

– Data is required to exercise legal rights or defend legal claims; 

– Data is unlawful, although there may be lawful grounds for processing, which 

override this right. 

Right to data portability:

Data subjects have the right to obtain and request the transfer of their data to a different service provider. 

Right to object:

Data subjects have the right to object to the processing of personal data at any time based on their circumstances. This includes objecting to profiling unless it is in the ‘public interest’ or exercised lawfully by an official authority. We will only process personal data upon a legal basis. 

Right not to be subject to decisions based on automated processing:

Amigas do not use any automated processing that results in any automated decision based on personal data. 

Exercising your rights:

If you wish to invoke any of your rights as a data subject, you should contact us by email to support@amigas.app.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may refuse to comply with your request in limited circumstances. 

13.DATA BREACHES 

We will report any unlawful breach of data as required by the GDPR within 72 hours of the breach occurring, if it is considered that data within our control including the control of our data processors, has been compromised, or potentially compromised. If the breach is classified as ‘high risk’ we will notify all data subjects concerned using an appropriate means of communication. We will report relevant breaches as required to the ICO, see below. 

14.CHANGES TO OUR PRIVACY POLICY 

We reserve the right to change this Privacy Policy at any time and users are recommended to review it frequently. Changes will take effect immediately upon their posting on the website. You will be deemed to have accepted any changes to the terms of the privacy policy on your next visit to the website following the amendment. 

15.REPORTING COMPLAINTS 

If you wish to raise a concern about the use of your personal data, you can contact us by email to support@amigas.app. Alternatively, you can formally raise a concern or complaint to the Information Commissioner’s Office (ICO), the UK regulatory authority for data protection: 

Address: Information Commissioner’s Office 

Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Telephone: 0303 123 1113 Website: https://ico.org.uk/concerns