Privacy Notice for W5

We want you to know that when you use our organisation you can trust us with your information. We are determined to do nothing that would infringe your rights or undermine your trust. This Privacy Notice describes the information we collect about you, how it is used and shared, and your rights regarding it.

Data Controller

W5 (WhoWhatWhereWhenWhy Limited) is registered with the Information Commissioner’s Office (ICO) as a Data Controller for the personal data that we hold and process. Our registered address is 2 Queens Quay Belfast BT3 9QQ and our registration numbers are Z8120847 & Z8120878. Our Data Protection Lead can be contacted at [email protected]

Data Collection

All the information that we hold about you is provided to us by yourself when you seek to use our services. We will tell you why we need the information and how we will use it.

Our Lawful Basis for processing your information

The General Data Protection Regulation (GDPR) requires all organisations that process personal data to have a Lawful Basis for doing so. Lawful Bases include:

  • Consent of the data subject
  • Performance of a contract with the data subject or to take steps to enter into a contract
  • Compliance with a legal obligation
  • To protect the vital interests of a data subject or another person
  • Performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
  • The legitimate interests of ourselves, or a third party, except where such interests are overridden by the interests, rights or freedoms of the data subject.

Examples of Legitimate Interests:

  • Where the data subject is a client or in the service of the controller;
  • Transmission within a group of undertakings for internal administrative purposes;
  • Processing necessary to ensure network and information security, including preventing unauthorised access;
  • Processing for direct marketing purposes, or to prevent fraud; and
  • Reporting possible criminal acts or threats to public security.

Our lawful basis is consent of the data subject or performance of a contract with the data subject or to take steps to enter a contract and our legitimate interest is processing for direct marketing purposes.

    We use your information to:

    • Provide goods, services, deliveries, quotations, and information, for example, newsletters:
    • Process or support payments for goods and services;
    • Conduct data analysis, testing, and research (including for product development), and to monitor and analyse usage and activity trends;
    • Maintain the safety, security and integrity of our services;
    • Direct your enquiries to the appropriate customer support staff;
    • Investigate and address your concerns;
    • Communicate with you about products, services, promotions, surveys, news, updates and events;
    • Process promotions/competitions, including prizes, and send you information about our services and those of our business partners;
    • Investigate or address legal proceedings relating to your use of our services/products, or as otherwise allowed by applicable law;
    • Make statutory returns as required by the law.

    We do not use automated decision-making in the processing of your personal data.

    We collect and process both personal data and special categories of personal data as defined in the GDPR. This includes:

    Customer data

    • Name;
    • Email;
    • Phone number;
    • Address;
    • Payment or bank details;
    • Date of birth;
    • Location details;
    • Device IP address and MAC address;
    • CCTV images;
    • Customer correspondence;
    • Cookies, including Facebook and Google Analytics.

    We may share your personal data with:

    • Partners that help us deliver our goods and services;
    • Our fellow subsidiaries of the Odyssey Trust Group;
    • Our legal advisors in the event of a dispute or other legal matter;
    • Law enforcement officials, government authorities, or other third parties to meet our legal obligations;
    • In connection with, or during negotiations of, any merger, sale of company [assets, consolidation or restructuring, financing, refinancing, or acquisition of some or all of our business by another company;]
    • Any other party where we ask you and you consent to the sharing.

    Transfers to third countries and international organisations

    We do not transfer your data to any third county or international partner outside of the EU.


    We retain your personal data while you remain a customer or client as per our Retention and Disposal Policy. This policy details how long we hold data for and how we dispose of it when it no longer needs to be held. We will delete or anonymise your information at your request unless:

    • There is an unresolved issue, such as claim or dispute;
    • We are legally required to; or
    • There are overriding legitimate business interests, including but not limited to fraud prevention and protecting customers' safety and security.

    Your Rights

    The General Data Protection Regulation gives you specific rights around your personal data. For example, you have to be informed about the information we hold and what we use it for, you can ask for a copy of the personal information we hold about you, you can ask us to correct any inaccuracies with the personal data we hold, you can ask us to stop sending you direct mail, or emails, or in some circumstances ask us to stop processing your details. Finally, if we do something irregular or improper with your personal data you can seek compensation for any distress you are caused or loss you have incurred. You can find out more information from the ICO’s website and this is the organisation that you can complain to if you are unhappy with how we deal with you.

    Accessing and Correcting Your Information

    You may request access to, correction of, or a copy of your information by contacting us at [email protected]

    We will not charge a fee for a subject access request.


    You may unsubscribe from receiving emails and other messages from our organisation by following the instructions in those messages.


    Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements. We use cookies to:

    • Validate users;
    • Remember user preferences and settings;
    • Determine frequency of accessing our content;
    • Measure the effectiveness of advertising campaigns on such platforms as Facebook; and
    • Analyse site visits and trends on such platforms as Google Analytics.
    • For E-Commerce tracking

    We will occasionally update our Privacy Notice. When we make significant changes relevant to you, we will notify you of these. We will also publish the updated Notice on our website.