PRIVACY AND COOKIE POLICY

Wyndee is an online service that provides a marketing platform for kitesurf centers and information and booking tools for kitesurfers. Our website at https://wyndee.co/, mobile properties, and related applications (collectively, our “Website”) are owned and operated by Mondo Kite LTD (t/a Wyndee) (“Wyndee”, “we”, “us”, “our”). More details about Wyndee can be found near the end of this Policy under the section “Information about us and how you can contact us”

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed, stored and disclosed by us.

We understand that providing personal information online involves a great deal of trust on your part and that you care about how your information is used and shared online. We take this trust very seriously, and make it a high priority to ensure the security and confidentiality of the personal information you provide to us when you visit our Website or use our services and we will only collect and use information in a manner consistent with your rights and our obligations under the law.

Before submitting your personal information to us, please read this Policy carefully to learn about our privacy practices. By visiting our Website on a desktop, mobile phone, tablet or similar device (a “Device”) or in connection with other sites or services and submitting information to us, you are accepting the practices described herein. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Website. If you do not accept and agree with this Privacy Policy, please stop using our Website immediately.

In General

We receive, process, handle and store any information you voluntarily enter on our Website or give us in any other way in accordance with the terms of this Policy. This includes information that can identify you (“personal information”), including your first and last name, telephone number, postal and email addresses, username and password, and billing information (such as your credit card number, cardholder name, and card expiration date). We may also request information about your kitesurf travel plans (including accommodation and kite surfing skills) and preferences and, if you are a third party supplier, your company or business name. This data is necessary for us to fulfill our contractual obligations to you, and in our legitimate interests in marketing and improving Wyndee.

You can choose not to provide information to us, but in general some information about you is required in order for you to receive relevant offerings from Wyndee and its partners and enjoy other benefits of being a registered member. For example, only registered members are able to post travel reviews, participate in discussion forums, email Wyndee content to themselves and others, access members-only newsletters and travel planning content, and enter surveys, contests, or sweepstakes. In addition, some information is also required in order for you to ask us a question or initiate other transactions on our Website.

Information About Others

You will have the opportunity to provide contact and kitesurf-related information on behalf of other people through our Website. If you make a reservation for someone else through Wyndee, you will need to submit that individual’s personal information. You must obtain the consent of other individuals prior to providing us with their personal information, as any access to view or modify their information will be available only through your account. By submitting any third party personal information, you warrant and represent that you have permission to do so. You must respect the privacy of others and you should not disclose any personal details about other people that may be misleading or cause them harm or offence. It is your responsibility to obtain their prior permission in respect of any mention of them or their personal information where relevant.

Information from Other Sources

We also may periodically obtain both personal and non-personal information about you from affiliated entities, business partners and other independent third-party sources and add it to other information about you. We will work with our existing partners and potential future partners to improve and personalize your use of our Website in accordance with the practices outlined in this section and Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We use third parties such as our partner kite centers when users request to make bookings through our Site.


Automatic Information

We may automatically collect some information from your computer or Device when you visit Wyndee. For example, “session data”, including your IP address, Web browser software, and referring website. We also may collect information about your online activity, such as content viewed, pages visited, and searches and/or reservations facilitated or made. Most of this data is used in the aggregate and does not identify you as an individual. For those pieces of information that can are personally identifiable (such as your IP address), we rely on our legitimate interests in understanding the interests and preferences of our users and customizing your user experience to use and process the data.

Location Information and Other Information from Devices


When you access our Website from a Device, we will collect and use information about you in generally similar ways and for similar purposes as when you access our Website from a desktop. In addition, we may collect information about your location if you have instructed your Device to send such information via the privacy settings on that Device, or if you have uploaded photos tagged with location information. We use the location information collected from your Device or photos for our legitimate interest in enhancing your experience by providing you with relevant content and contextual advertising. You can change the privacy settings of your Device at any time, in order to turn off the functionality to share location information and/or the functionality to tag your photos with location information. Please note that turning off location sharing may affect and restrict certain features. If you have any queries about the privacy settings of your Device, we suggest you contact the manufacturer of your Device or your mobile service provider for help.

Cookies and Other Web Technologies


Cookies are small data text files and can be stored on your computer’s hard drive or your Device (if your Web browser permits) when you visit certain parts of our Website and/or when you use certain features of our Website. Wyndee may use cookies for the following general purposes:

 

  1. To help us recognize your browser as a previous visitor and save and remember any preferences that may have been set while your browser was visiting our Website. For example, if you register on our Website, we may use cookies to remember your registration information, so you do not need to log into our site each time you visit. We also may record your password in a cookie, if you checked the box entitled “Save this password for automatic sign-in.” Please note that member IDs, passwords, and any other account-related data included in such cookies are encrypted for security purposes;

 

  1. To help us customize the content, experience, and advertisements provided to you on our Websites and on other websites across the Internet. For example, when you access a web page, a cookie is automatically set by us, our service providers, or our partners to recognize your browser as you navigate on the Internet and to present you with information and advertising based on your apparent interests. See the section “Display of Advertising/Your Choices” for more information about our online advertising practices and your choices; and 
  2. To help measure and research the effectiveness of features and offerings, advertisements, and email communications (by determining which emails you open and act upon). 

As well as using first party cookies (which are placed directly by us and are used only by us), we also use analytical/performance cookies, functionality cookies, strictly necessary cookies and social media cookies. By using our Website you may also receive certain third party cookies on your computer or Device (which are those placed by websites, services, and/or parties other than us). You have the right to opt-out of third party cookies and social media cookies and to object to automated profiling. To do so, please contact us using the contact information provided below.

 

Before cookies are placed on your computer or Device, you will be shown a message requesting your consent to set those cookies. By giving your consent to the placing of cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of cookies; however certain features of our Website may not function fully or as intended.

 

The Help portion of the toolbar on most browsers should tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable most types of cookies. Please note that if you refuse to accept cookies, you may not be able to access certain important features and tools on our Website. For more information on cookies and how to disable them, you can consult the information provided at the following link: http://www.allaboutcookies.org.

 

Our Website also may use Web beacons (also known as clear gifs, pixel tags or Web bugs), which are tiny graphics with a unique identifier, similar in function to cookies, that are placed in the code of a Web page. We use Web beacons to monitor the traffic patterns of users from one page within our sites to another, to deliver or communicate with cookies, to understand whether you have come to our site from an online advertisement displayed on a third-party website, and to improve Website performance. We also may allow our service providers to use Web beacons to help us understand which emails have been opened by recipients and to track the visitor traffic and actions on our Website. This helps us measure the effectiveness of our content and other offerings.

Display of Advertising/Your Choices – Data collected to serve you with relevant advertising

We are committed to providing you with relevant content and information on our Website and across any affiliated sites. To do this, we may collect information about your kitesurf-related searches and other site activities and use this information to serve you with ads on our Website or elsewhere online that match your apparent interests.


We do not share your personal information (such as email addresses) with unaffiliated third parties so they can serve you with advertisements.

Many of the advertisements you see on our Website are served by Wyndee or its service providers. But we may also allow third parties to collect information about your online activities through cookies and other technologies. Advertisers whose content appears on our Website may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. These third parties include (1) business partners, who collect information when you view or interact with one of their advertisements on our sites, and (2) advertising networks, who collect information about your interests when you view or interact with one of the advertisements they place on many different websites on the Internet. The information gathered by these third parties is used to make predictions about your characteristics, interests or preferences and to display advertisements on our Website and across the Internet tailored to your apparent interests. Your activity is monitored using cookies (as detailed above). You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on our Website.

Please note that we do not have access to or control over cookies or other technologies these third parties may use to collect information about your interests, and the information practices of these third parties are not covered by this Privacy Policy.

 

With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email, telephone and post with information, news and offers on our services and the products and services offered by our third-party suppliers. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the Data Protection Act 1998, the General Data Protection Regulation (GDPR), and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended).

 

When you submit information via our Website, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails, at the point of providing your details and by managing your account).


How we use your information

All personal data is stored securely in accordance with the principles of the Data Protection Act 1998 and the GDPR. Wyndee uses the information we collect about you to provide the best possible services to you, including for the following general purposes:

 

  • for registration and to provide and manage your account, including to allow your access to and use of our Website;
  • to communicate with you in general, including to provide information about Wyndee and invitations from the Wyndee community;
  • to allow you to participate in interactive features of our Service when you choose to do so;
  • to enable us to publish your reviews, forum posts, and other content to the Wyndee community;
  • to facilitate your booking of kitesurf reservations and to provide any other services we may make available from time to time;
  • to respond to your questions and comments; to supply you with email newsletters that you may have subscribed to;
  • to measure interest in and improve our products, services, and Website;
  • to notify you about special offers and products or services available from us or our partners that may be of interest to you;
  • to otherwise customize your experience with Wyndee, including personalising and tailoring  your experience on our Website and customizing the ads shown to you;
  • to solicit information from you, including through surveys; to resolve disputes or troubleshoot problems;
  • to prevent potentially prohibited or illegal activities; to enforce our Terms of Use; and
  • as otherwise described to you at the point of collection.

 

If you have signed up with us as the owner or manager of a kite center, we will send you email messages at the email address you provide to us (unless you choose to opt out of such communications).

 

With whom we share your information

Wyndee may share your information with the following entities:

 

  1. Suppliers, including but not limited to kitesurf centers who fulfill your travel reservations. Throughout Wyndee and its affiliated sites, all products and services provided by third-party suppliers are described as such. Information that we share with suppliers to facilitate reservations will be treated according to applicable suppliers’ privacy policies, except for payment information. We share payment information only when it is necessary for travel reservations facilitated through or made on Wyndee, and we restrict suppliers’ use of payment information for these purposes. We encourage you to review the privacy policies, terms of use, and other policies of any travel supplier whose products and services you may purchase through our Website. Please note that these suppliers also may contact you as necessary to obtain additional information about you or your travel plans, to facilitate your travel reservations, or for other purposes consistent with the practices described in their privacy policies and terms of use; 
  2. Third-party vendors who provide services or functions on our behalf, including business analytics, payment processing, search engine facilities, customer service, advertising and marketing, public relations, distribution of surveys or sweepstakes programs, and fraud prevention. We may also authorize third-party vendors to collect information on our behalf, including, for example, as necessary to operate features of our Website or to facilitate the delivery of online advertising tailored to your interests. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose. We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law; 
  3. Business partners with whom we may offer products or services in conjunction. You can tell when a third party is involved in a product or service you have requested because their name will appear either with ours or separately. If you choose to access these optional services, we may share information about you, including your personal information, with those partners. Please note that we do not control the privacy practices of these third-party business partners; 
  4. Referring websites. If you were referred to Wyndee from another website, we may share your registration information, such as your name, email address, mailing address, telephone number and travel preferences, about you with that referring website. We have not placed limitations on the referring websites’ use of personal information and we encourage you to review the privacy policies of any website that referred you to Wyndee; and 
  5. Social Media Services. You can choose to access certain third party social media websites and services through our Website (such as Facebook). When you do so, you are sharing information with those sites, and the information you share will be governed by their privacy policies. You also grant us access to your data held by that third party account. You may also be able to modify your privacy settings with these third party social media websites. 

We also may share your information if we believe, in our sole discretion, that such disclosure is necessary:

 

  1. To comply with legitimate and enforceable subpoenas, court orders, legislation, or a governmental authority or other legal process or proceedings; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we do not require any further consent from you in order to share your data and will comply as required with any legally binding request that is made of us and we reserve the right to raise or waive any legal objection or right available to us; 
  2. To investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Wyndee, our customers, or others; and in connection with our Terms of Use and other agreements; 
  3. In connection with the sale and/or the transfer of control of all or part of our business, in which case data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by us; 

If you choose to create a profile on Wyndee, certain information in your profile will be publicly viewable and identifiable via your screen name. You will have the ability to view your profile as members of the public will see it. Additionally, if you choose to participate in member-to-member communications, other Wyndee members may contact you by using Mondi Kite as an intermediary; however, Wyndee will not share your email address with any other members nor display it any public manner. All Wyndee members have the option to turn off the member-to-member communication features at any time and edit their privacy settings via their account.

Other than as set out above, you will be notified when personal information about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information.

We also may share aggregate or anonymous information with third parties, including advertisers and investors. For example, we may tell our advertisers the number of visitors our Website receives or the most popular hotels and vacation destinations. This information does not contain any personal information and is used to develop content and services we hope you will find of interest.

How and where do we store your data?

We only keep your data for as long as we need to in order to use it as described in this Policy, and/or for as long as we have your permission to keep it. You can request deletion of your information by closing your account (as described below) or contacting us using the contact information provided below.

 

Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”). You are deemed to accept and agree to this by using our Website and submitting information to us. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties.

 

How you can access your information

We take reasonable steps to ensure that your information is relevant to its intended use, accurate, and complete. You can access and update your personal information by visiting the Member Profile page on the Wyndee Website. You can close your Wyndee account by contacting us using this form. We will send you an email to confirm your request. Please note that after you close an account, you will not be able to sign in or access any of your personal information. However, you can open a new account at any time. Please also note that we may retain certain information associated with your account in our archives, including for analytical purposes as well as for recordkeeping integrity.

 

You also have the legal right to ask for a copy of any of your personal data held by us (where such data is held). Please contact us for more details at hello@wyndee.co.

Your choices with respect to the collection and use of your information

As discussed above, you can choose not to provide us with any information, although it may be needed to take advantage of certain features offered on our Website.


You also can add or update information and close your account as described above. If you decide to close your Wyndee account, we will deactivate your account and remove your profile information from active view. Please note, however, that we may retain in our files some information associated with your account and past transactions for purposes including backups, fraud prevention, dispute resolution, investigations, and compliance with legal requirements.

 

As a registered Wyndee member, you can modify your email subscription choices at any time on the Member Profile page. Whether registered as a Wyndee member or not, you also will be given the opportunity to unsubscribe from promotional messages in any such email we send. Please note that we reserve the right to send you other communications, including service announcements, administrative messages, and surveys relating to your Wyndee account, without offering you the opportunity to opt out of receiving them.


Wyndee wants to make it easy for you to take advantage of travel-related opportunities on our Website. One way we do this is by sending you email messages that contain information about your apparent travel-related interests. For example, if you search for a flight to New York, or New York hotels or reviews on Wyndee, we may send you an email message reminding you about special airfare or hotel offers in New York. Similarly, if you receive an email about New York travel and demonstrate an interest in New York hotels, flights, or local travel reviews by affirmatively clicking on a link about New York hotels in the email, you may receive an email about New York hotel or flight offers. We believe these email messages will provide you with useful information about travel-related special offers available through our sites. Please note that you will have the opportunity to choose not to receive these email messages in any such email we send.

How we protect your information

 

We want you to feel confident about using Wyndee, and we are committed to protecting the information we collect. While no website can guarantee security, we have implemented appropriate administrative, technical, and physical security procedures to help protect, safeguard and secure the personal information you provide to us. For example, only authorized employees are permitted to access personal information, and they only may do so for permitted business functions. In addition, we use encryption when transmitting your personal information between your system and ours, and between our system and those of the parties with whom we share sensitive information, and we employ firewalls and intrusion detection systems to help prevent unauthorized persons from gaining access to your information.

 

Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet.

Children’s privacy

Wyndee is a general audience site and does not offer services directed at children. Should an individual whom we know to be a child under age 13 send personal information to us, we will delete or destroy such information as soon as reasonably possible.

External links

If any part of the Wyndee Website links you to other websites, those external websites do not operate under this Privacy Policy. We recommend that you examine the privacy statements posted on those other websites to understand their procedures for collecting, using, and disclosing personal information. We are not responsible for the privacy policies, content or security of these linked sites.

 

Rights Under the GDPR

 

If you are an EU citizen, you have the right to:

 

  • Withdraw your consent to the processing of your personal data at any time.  Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so (such as to comply with a legal obligation).
  • Be informed of what data we hold and the purpose for processing the data, as a whole or in parts.
  • Be forgotten and, in some circumstances, have your data erased by ourselves and our affiliates (although this is not an absolute right and there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it).
  • Correct or supplement any information we hold about you that is incorrect or incomplete.
  • Restrict processing of the information we hold about you (for example, so that inaccuracies may be corrected—but again, there may be circumstances where you ask us to restrict processing of your personal data but we are legally entitled to refuse that request).
  • Object to the processing of your data.
  • Obtain your data in a portable manner and reuse the information we hold about you.
  • Challenge any data we use for the purposes of automated decision-making and profiling (in certain circumstances—as above, there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request).
  • Complain to a supervisory authority (e.g. the Information Commissioner’s Office (ICO) in the UK) if  you think any of your rights have been infringed by us. (We would, however, appreciate the chance to address your concerns, so please contact us prior to taking this step).

 

We will notify you and any applicable regulator of a breach of your personal data when we are legally required to do so.

 

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

 

You have the right to ask us not to process your personal data for marketing purposes. We will get your express opt-in consent before we use your data for such purposes or share your personal data with any third parties for such purposes, but you can exercise your right to prevent such processing by contacting us using the contact information below, or by unsubscribing using the links contained in the marketing emails.

 

You may revoke your consent for us to use your personal data as described in this Privacy Policy at any time, and we will delete your data from our systems.

 

To enforce any of the above rights, please contact us using the contact information below.

Changes to this Privacy Policy

Wyndee may change or modify this Privacy Policy in the future as we may deem necessary from time to time or as may be required by law. We will note the date that revisions were last made to this Privacy Policy at the bottom of this page, and any revisions will take effect upon posting. You will be deemed to have accepted the terms of the Privacy Policy on your first use of the Website following the alterations. We will notify our members of material changes to this Privacy Policy by either sending a notice to the email address you provided to us or by placing a notice on our Website. We encourage you to check this Privacy Policy from time to time to review the most current version.

Information about us and how you can contact us

Our Website is owned and operated by Mondo Kite LTD (t/a Wyndee), a limited liability company (number 10714822) incorporated under the laws of the United Kingdom. Wyndee processes personal data as a Data Controller, as defined in the General Data Protection Regulation (GDPR). Mondo Kite LTD (t/a Wyndee) has a Data Protection Office (“DPO”) who is responsible for matters relating to privacy and data protection. The Data Protection Officer is Marketa Strakova and can be reached at hello@wyndee.com or contacted at our registered office: Mando Kite LTD (t/a Wyndee), 85 Great Portland Street, First Floor, W1W 7LT.

 

If you have questions about this Privacy Policy, please email us at hello@wyndee.co or contact us at our registered office address:

Mondo Kite LTD

85 Great Portland St

First Floor

W1W 7LT


Call Recording and Monitoring.
Please be aware that calls to and from Wyndee may be recorded.  We may use the call recordings to monitor our customer service for quality or compliance purposes, to check the accuracy of the information you provide us, for fraud prevention purposes, or to provide training to our staff.  We will retain the call recordings for as long as reasonably necessary to perform such activities and then delete them. Any personal information obtained from you during the call will be treated in accordance with the provisions of this Privacy Policy.

This Privacy Policy is effective as of 29 November 2018.