Privacy Policy

Effective date: 9 October 2025

1. Who we are (Controller)

This website (the “Site”) is operated by WINTER SUNSHINE LIMITED (Company No. 15796319), registered address: 30 Auctioneers Way, Northampton, United Kingdom, NN1 1HF (“we”, “us”, or “our”). We are the data controller for personal data processed via zentriq.co.uk.
Contact: info@zentriq.co.uk | +44 7537 185561

This Policy explains how we collect, use, disclose and protect personal data when you browse the Site, create an account, purchase products, or otherwise interact with us. It complements our Cookie Policy, Terms of Service, Shipping & Delivery Policy, Returns & Refunds Policy, and Warranty & Repairs Policy.

2. What data we collect

2.1 Data you provide directly

• Identity & contact: name, email, phone, billing/shipping addresses.
• Account details: username, password, preferences.
• Orders & support: order history, invoices, RMA/warranty requests, communications with our team.
• Proofs & documents (where strictly necessary): ID or KYC/anti-fraud verification data for high-risk orders.
• Marketing choices: newsletter opt-in/opt-out, cookie preferences.

2.2 Data collected automatically

• Technical & usage: IP address, device identifiers, browser, OS, pages viewed, referral URLs, session timestamps, approximate location (derived from IP), error logs.
• Cookies & similar tech: see our Cookie Policy for details.

2.3 Data from third parties

• Payment processors (payment status, fraud risk signals; we do not receive or store full card PANs).
• Carriers & logistics (tracking events, delivery confirmations/returns).
• Service centres/manufacturers (warranty outcomes, serial/IMEI validations).
• Anti-fraud & identity verification providers.

3. Why we use your data (Legal bases)

We process personal data under the UK GDPR/EU GDPR on the following bases:

• Contract: to process orders, take payment, arrange shipping, provide support, manage returns/warranty.
• Legitimate interests: to secure our Site, prevent fraud/abuse, run analytics with safeguards, personalize experience, improve products/services, and communicate non-marketing service messages.
• Legal obligation: tax/accounting records, product safety/recalls, sanctions/export control compliance.
• Consent: non-essential cookies/marketing where required. You can withdraw consent at any time.

4. How we use your data

• Process and deliver orders; provide invoices, updates and tracking.
• Manage your account and provide customer service (including RMA/warranty).
• Verify identity and prevent fraud, chargebacks or misuse.
• Personalize content and improve our Site and operations (performance, diagnostics).
• Send service communications (order updates, policy changes) and, with consent where required, marketing messages.
• Comply with legal obligations and enforce our Terms.

5. Sharing your data

We do not sell your personal data. We share it only with:

• Payment processors / banks / anti-fraud tools (to take payments and prevent fraud).
• Carriers, fulfillment and customs brokers (to deliver your order and manage returns).
• IT/hosting and security providers (to operate the Site, store data securely, detect incidents).
• Analytics and marketing tools (for non-essential processing only with your consent where required).
• Manufacturers/authorized service centres (to facilitate warranty and repairs).
• Professional advisers and authorities (where legally required or to protect our rights).
  In case of a business transfer (merger, acquisition), your data may be transferred in line with this Policy.

6. International transfers

When transferring personal data outside the UK/EEA, we implement appropriate safeguards such as the EU Standard Contractual Clauses (SCCs) and/or the UK IDTA/Addendum, plus technical and organisational measures suited to the risk.

7. Retention

We keep data only as long as needed for the purposes above:

• Orders, invoices, warranty: typically 6–7 years (tax/audit).
• Support tickets/RMAs: generally 24 months after closure.
• Analytics logs: typically 12–24 months in aggregated or pseudonymised form.
• Marketing: until you withdraw consent or object, plus a short suppression period.
  We securely delete or anonymise data when no longer required.

8. Security

We use appropriate technical and organisational measures, including TLS encryption in transit, access controls, segregation of duties, least-privilege, and regular monitoring. No method of transmission or storage is 100% secure; please keep your credentials safe and notify us of any suspected compromise.

9. Your privacy rights

Subject to conditions and local law, you may have the right to:

• Access your personal data;
• Rectify inaccurate or incomplete data;
• Erase data (right to be forgotten);
• Restrict processing;
• Portability (receive data in a structured, machine-readable format);
• Object to processing based on legitimate interests (including direct marketing);
• Withdraw consent for non-essential cookies/marketing at any time.
  To exercise your rights, contact info@zentriq.co.uk. We may need to verify your identity.

You can also lodge a complaint with the UK Information Commissioner’s Office (ICO) or your local EU supervisory authority.

10. Cookies & tracking

We use cookies and similar technologies for essential functions, preferences, performance/analytics and, with consent where applicable, marketing. You can manage preferences via our Cookie Banner/Preferences and your browser settings. See our Cookie Policy for details.

11. Children

Our Site is not intended for children under 16. We do not knowingly collect children’s data. If you believe a child has provided us data, contact us to delete it.

12. Automated decisions & profiling

We may use automated tools for fraud prevention and risk scoring. We do not make decisions producing legal or similarly significant effects solely by automated means without appropriate human review.

13. Third-party links

Our Site may contain links to third-party websites/services. Their privacy practices are governed by their own policies; we are not responsible for them. Please review those policies before sharing personal data.

14. Changes to this Policy

We may update this Policy from time to time. The effective date at the top shows when it last changed. Material updates will be highlighted on this page.

15. Contact us

For questions or to exercise your rights:
WINTER SUNSHINE LIMITED
30 Auctioneers Way, Northampton, United Kingdom, NN1 1HF
info@zentriq.co.uk | +44 7537 185561