Pri­vacy statement

Curlew Edi­tions Ltd (“us”, “we”, or “our”) oper­ates the Win​ter​pa​pers​.com web­site (the “Service”).

This page informs you of our poli­cies regard­ing the col­lec­tion, use, and dis­clo­sure of per­sonal data when you use our Ser­vice and the choices you have asso­ci­ated with that data.

We use your data to pro­vide and improve the Ser­vice. By using the Ser­vice, you agree to the col­lec­tion and use of infor­ma­tion in accor­dance with this pol­icy. Unless oth­er­wise defined in this Pri­vacy Pol­icy, terms used in this Pri­vacy Pol­icy have the same mean­ings as in our Terms and Con­di­tions, acces­si­ble from Win​ter​pa​pers​.com


Per­sonal Data

Per­sonal Data means data about a liv­ing indi­vid­ual who can be iden­ti­fied from those data (or from those and other infor­ma­tion either in our pos­ses­sion or likely to come into our possession).

Usage Data

Usage Data is data col­lected auto­mat­i­cally either gen­er­ated by the use of the Ser­vice or from the Ser­vice infra­struc­ture itself (for exam­ple, the dura­tion of a page visit).


Cook­ies are small pieces of data stored on a User’s device.

Data Con­troller

Data Con­troller means a per­son who (either alone or jointly or in com­mon with other per­sons) deter­mines the pur­poses for which and the man­ner in which any per­sonal data are, or are to be, processed.

For the pur­pose of this Pri­vacy Pol­icy, we are a Data Con­troller of your data.

Data Proces­sor (or Ser­vice Providers)

Data Proces­sor (or Ser­vice Provider) means any per­son (other than an employee of the Data Con­troller) who processes the data on behalf of the Data Controller.

We may use the ser­vices of var­i­ous Ser­vice Providers in order to process your data more effectively.

Data Sub­ject

Data Sub­ject is any liv­ing indi­vid­ual who is the sub­ject of Per­sonal Data.


The User is the indi­vid­ual using our Ser­vice. The User cor­re­sponds to the Data Sub­ject, who is the sub­ject of Per­sonal Data.

Infor­ma­tion Col­lec­tion And Use

We col­lect sev­eral dif­fer­ent types of infor­ma­tion for var­i­ous pur­poses to pro­vide and improve our Ser­vice to you.

Types of Data Collected

Per­sonal Data

While using our Ser­vice, we may ask you to pro­vide us with cer­tain per­son­ally iden­ti­fi­able infor­ma­tion that can be used to con­tact or iden­tify you (“Per­sonal Data”). Per­son­ally iden­ti­fi­able infor­ma­tion may include, but is not lim­ited to:

  • Email address
  • First name and last name
  • Phone num­ber
  • Address, State, Province, ZIP/​Postal code, City
  • Cook­ies and Usage Data

We may use your Per­sonal Data to con­tact you with newslet­ters, mar­ket­ing or pro­mo­tional mate­ri­als and other infor­ma­tion that may be of inter­est to you. You may opt out of receiv­ing any, or all, of these com­mu­ni­ca­tions from us by fol­low­ing the unsub­scribe link or instruc­tions pro­vided in any email we send.

Usage Data

We may also col­lect infor­ma­tion how the Ser­vice is accessed and used (“Usage Data”). This Usage Data may include infor­ma­tion such as your computer’s Inter­net Pro­to­col address (e.g. IP address), browser type, browser ver­sion, the pages of our Ser­vice that you visit, the time and date of your visit, the time spent on those pages, unique device iden­ti­fiers and other diag­nos­tic data.

Track­ing & Cook­ies Data

We use cook­ies and sim­i­lar track­ing tech­nolo­gies to track the activ­ity on our Ser­vice and hold cer­tain information.

Cook­ies are files with small amount of data which may include an anony­mous unique iden­ti­fier. Cook­ies are sent to your browser from a web­site and stored on your device. Track­ing tech­nolo­gies also used are bea­cons, tags, and scripts to col­lect and track infor­ma­tion and to improve and ana­lyze our Service.

You can instruct your browser to refuse all cook­ies or to indi­cate when a cookie is being sent. How­ever, if you do not accept cook­ies, you may not be able to use some por­tions of our Service.

Exam­ples of Cook­ies we use:

  • Ses­sion Cook­ies. We use Ses­sion Cook­ies to oper­ate our Service.
  • Pref­er­ence Cook­ies. We use Pref­er­ence Cook­ies to remem­ber your pref­er­ences and var­i­ous settings.
  • Secu­rity Cook­ies. We use Secu­rity Cook­ies for secu­rity purposes.

Use of Data

Curlew Edi­tions Ltd uses the col­lected data for var­i­ous purposes:

  • To pro­vide and main­tain our Service
  • To notify you about changes to our Service
  • To allow you to par­tic­i­pate in inter­ac­tive fea­tures of our Ser­vice when you choose to do so
  • To pro­vide cus­tomer support
  • To gather analy­sis or valu­able infor­ma­tion so that we can improve our Service
  • To mon­i­tor the usage of our Service
  • To detect, pre­vent and address tech­ni­cal issues
  • To pro­vide you with news, spe­cial offers and gen­eral infor­ma­tion about other goods, ser­vices and events which we offer that are sim­i­lar to those that you have already pur­chased or enquired about unless you have opted not to receive such information

Reten­tion of Data

Curlew Edi­tions Ltd will retain your Per­sonal Data only for as long as is nec­es­sary for the pur­poses set out in this Pri­vacy Pol­icy. We will retain and use your Per­sonal Data to the extent nec­es­sary to com­ply with our legal oblig­a­tions (for exam­ple, if we are required to retain your data to com­ply with applic­a­ble laws), resolve dis­putes, and enforce our legal agree­ments and policies.

Curlew Edi­tions Ltd will also retain Usage Data for inter­nal analy­sis pur­poses. Usage Data is gen­er­ally retained for a shorter period of time, except when this data is used to strengthen the secu­rity or to improve the func­tion­al­ity of our Ser­vice, or we are legally oblig­ated to retain this data for longer time periods.

Trans­fer Of Data

Your infor­ma­tion, includ­ing Per­sonal Data, may be trans­ferred to — and main­tained on — com­put­ers located out­side of your state, province, coun­try or other gov­ern­men­tal juris­dic­tion where the data pro­tec­tion laws may dif­fer than those from your jurisdiction.

If you are located out­side Ire­land and choose to pro­vide infor­ma­tion to us, please note that we trans­fer the data, includ­ing Per­sonal Data, to Ire­land and process it there.

Your con­sent to this Pri­vacy Pol­icy fol­lowed by your sub­mis­sion of such infor­ma­tion rep­re­sents your agree­ment to that transfer.

Curlew Edi­tions Ltd will take all steps rea­son­ably nec­es­sary to ensure that your data is treated securely and in accor­dance with this Pri­vacy Pol­icy and no trans­fer of your Per­sonal Data will take place to an orga­ni­za­tion or a coun­try unless there are ade­quate con­trols in place includ­ing the secu­rity of your data and other per­sonal information.

Dis­clo­sure Of Data

Dis­clo­sure for Law Enforcement

Under cer­tain cir­cum­stances, Curlew Edi­tions Ltd may be required to dis­close your Per­sonal Data if required to do so by law or in response to valid requests by pub­lic author­i­ties (e.g. a court or a gov­ern­ment agency).

Legal Require­ments

Curlew Edi­tions Ltd may dis­close your Per­sonal Data in the good faith belief that such action is nec­es­sary to:

  • To com­ply with a legal obligation
  • To pro­tect and defend the rights or prop­erty of Curlew Edi­tions Ltd
  • To pre­vent or inves­ti­gate pos­si­ble wrong­do­ing in con­nec­tion with the Service
  • To pro­tect the per­sonal safety of users of the Ser­vice or the public
  • To pro­tect against legal liability

Secu­rity Of Data

The secu­rity of your data is impor­tant to us, but remem­ber that no method of trans­mis­sion over the Inter­net, or method of elec­tronic stor­age is 100% secure. While we strive to use com­mer­cially accept­able means to pro­tect your Per­sonal Data, we can­not guar­an­tee its absolute security.

Your Rights

Curlew Edi­tions Ltd aims to take rea­son­able steps to allow you to cor­rect, amend, delete, or limit the use of your Per­sonal Data.

When­ever made pos­si­ble, you can update your Per­sonal Data directly within your account set­tings sec­tion. If you are unable to change your Per­sonal Data, please con­tact us to make the required changes.

If you wish to be informed what Per­sonal Data we hold about you and if you want it to be removed from our sys­tems, please con­tact us.

In cer­tain cir­cum­stances, you have the right:

  • To access and receive a copy of the Per­sonal Data we hold about you
  • To rec­tify any Per­sonal Data held about you that is inaccurate
  • To request the dele­tion of Per­sonal Data held about you

You have the right to data porta­bil­ity for the infor­ma­tion you pro­vide to Curlew Edi­tions Ltd. You can request to obtain a copy of your Per­sonal Data in a com­monly used elec­tronic for­mat so that you can man­age and move it.

Please note that we may ask you to ver­ify your iden­tity before respond­ing to such requests.

Ser­vice Providers

We may employ third party com­pa­nies and indi­vid­u­als to facil­i­tate our Ser­vice (“Ser­vice Providers”), to pro­vide the Ser­vice on our behalf, to per­form Service-​related ser­vices or to assist us in ana­lyz­ing how our Ser­vice is used.

These third par­ties have access to your Per­sonal Data only to per­form these tasks on our behalf and are oblig­ated not to dis­close or use it for any other purpose.


We may use third-​party Ser­vice Providers to mon­i­tor and ana­lyze the use of our Service.

  • Google Ana­lyt­ics

    Google Ana­lyt­ics is a web ana­lyt­ics ser­vice offered by Google that tracks and reports web­site traf­fic. Google uses the data col­lected to track and mon­i­tor the use of our Ser­vice. This data is shared with other Google ser­vices. Google may use the col­lected data to con­tex­tu­al­ize and per­son­al­ize the ads of its own adver­tis­ing network.

    You can opt-​out of hav­ing made your activ­ity on the Ser­vice avail­able to Google Ana­lyt­ics by installing the Google Ana­lyt­ics opt-​out browser add-​on. The add-​on pre­vents the Google Ana­lyt­ics JavaScript (ga.js, analytics.js, and dc.js) from shar­ing infor­ma­tion with Google Ana­lyt­ics about vis­its activity.

    For more infor­ma­tion on the pri­vacy prac­tices of Google, please visit the Google Pri­vacy & Terms web page: http://​www​.google​.com/​i​n​t​l​/​e​n​/​p​o​l​i​c​i​e​s​/​p​r​i​vacy/

  • Stat­counter

    Stat­counter is a web traf­fic analy­sis tool. You can read the Pri­vacy Pol­icy for Stat­counter here: https://​stat​counter​.com/​a​b​o​u​t​/​l​egal/

  • Addthis

    AddThis is a web­site tool that pro­vides a way to share pages on our site by email and on social net­works. You can read the Pri­vacy Pol­icy for AddThis here: http://​www​.addthis​.com/​p​r​i​vacy/


We may pro­vide paid prod­ucts and/​or ser­vices within the Ser­vice. In that case, we use third-​party ser­vices for pay­ment pro­cess­ing (e.g. pay­ment processors).

We will not store or col­lect your pay­ment card details. That infor­ma­tion is pro­vided directly to our third-​party pay­ment proces­sors whose use of your per­sonal infor­ma­tion is gov­erned by their Pri­vacy Pol­icy. These pay­ment proces­sors adhere to the stan­dards set by PCI-​DSS as man­aged by the PCI Secu­rity Stan­dards Coun­cil, which is a joint effort of brands like Visa, Mas­ter­card, Amer­i­can Express and Dis­cover. PCI-​DSS require­ments help ensure the secure han­dling of pay­ment information.

The pay­ment proces­sors we work with are:

  • Pay­Pal

  • Stripe

    Their Pri­vacy Poli­cies can be viewed on their websites

Links To Other Sites

Our Ser­vice may con­tain links to other sites that are not oper­ated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Pri­vacy Pol­icy of every site you visit.

We have no con­trol over and assume no respon­si­bil­ity for the con­tent, pri­vacy poli­cies or prac­tices of any third party sites or services.

Children’s Pri­vacy

Our Ser­vice does not address any­one under the age of 13 (“Children”).

We do not know­ingly col­lect per­son­ally iden­ti­fi­able infor­ma­tion from any­one under the age of 13. If you are a par­ent or guardian and you are aware that your Chil­dren has pro­vided us with Per­sonal Data, please con­tact us. If we become aware that we have col­lected Per­sonal Data from chil­dren with­out ver­i­fi­ca­tion of parental con­sent, we take steps to remove that infor­ma­tion from our servers.

Changes To This Pri­vacy Policy

We may update our Pri­vacy Pol­icy from time to time. We will notify you of any changes by post­ing the new Pri­vacy Pol­icy on this page.

We will let you know via email and/​or a promi­nent notice on our Ser­vice, prior to the change becom­ing effec­tive and update the “effec­tive date” at the foot of this Pri­vacy Policy.

You are advised to review this Pri­vacy Pol­icy peri­od­i­cally for any changes. Changes to this Pri­vacy Pol­icy are effec­tive when they are posted on this page.

Con­tact Us

If you have any ques­tions about this Pri­vacy Pol­icy, please con­tact us:

  • By email:

Effec­tive date: May 23 2018