Winterhighland Ltd runs the Winterhighland mountain conditions website and forum, alongside the Scottish leg of the UK and Ireland Warren Miller Film Tour under an agreement with Adventure Entertainment UK Ltd (the international licensee to Warren Miller Entertainment Inc). Data processed by Winterhighland Ltd in connection with either our website or the Warren Miller tour remains within either the UK and/or the European Union and thus is managed under the GDPR.
Winterhighland Ltd does not store or directly process customer payment information for any purpose, this is done through secure third parties (as of October 2018 Stripe and Paypal).
Please also see our site Terms and Conditions.
The Winterhighland website makes use of first party cookies for site functionality such as user login session_ids and functionality for the forum and public / backcountry report upload functions. These cookies are essential to the basic functioning of the website and will originate from winterhighland.info / winterhighland.com as applicable.
The website makes use of third party cookies relating to the use of and operation of Google Analytics, Google Adsense and double click for publishers. Some external content on our website is dependent on third party cookies for functionality including Twitter and Youtube Social Plugins, and also from the UK Met Office. We understand the competing desires for privacy and control vs a smooth user experience, registered forum members with a session_id set will not be represented with a cookie reminder until a logout event occurs. The most sure fire way to be in control of your cookies is via your browser preferences!
Email addresses are collected via the following methods:
- Transactional use of email addresses and mobile phone numbers falls into 2 categories:
- Purchasing Customer: personal details of and entered by the customer paying for tickets directly on the UK and Ireland WM Tour website.
- Transactional for delivery of tickets additional to the purchaser for delivery of e-tickets to individual film goers in a single booking. This is optional and the purchaser may choice to deliver all tickets to their email address.
These details are entered by the ticket purchaser, thus individual consent has not been obtained.
- The lawful bases for processing is that it is necessary to fulfil the contract.
- These email addresses must NOT be used for any other purpose.
- They are retained to provide verification of tickets and as required to satisfy legal obligations.
- Mobile phone numbers are obtained only for use to allow notification of short notice alterations to an event, such as postponement due to adverse weather.
- Lawful basis for processing is that it is for the legitimate interest of the data subject.
- Mobile phone numbers are not used for marketing purposes and are not passed on to any third party except law enforcement agencies where legally compelled to do so.
- A distinct past customer email list is maintained to notify previous ticket purchasers of the upcoming tour. This list consists solely of email addresses that fit (a) above.
- Recital 47 of the GDPR specifically states that “the processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest”.
- The e-privacy directive however requires consent to send out marketing emails unless:
- the recipient is an existing customer or potential customer who has previously made an enquiry for a product or service
- the direct marketing is in respect to similar products and services only; and
- the recipient has been given a simple means of refusing (free of charge except for the costs of the transmission of the refusal) the use of his contact details for the purposes of such direct marketing, at the time that the details were initially collected, and at the time of each subsequent communication.
- Thus the lawful basis for processing is that of legitimate interest as the data subject is an existing customer, the direct marketing is respect of the Warren Miller film tour (or similar event) and the recipients have the option to opt out in each email.
- Emails will be limited to a handful per year, both generic UK tour emails and a location specific based on venue attended previously.
- Tour Website Newsletter / Winterhighland Snow Alerts opt-in. Email addresses and name only (no further personal details) are collected by active opt-in on both the Winterhighland and Warren Miller UK tour website.
- These email addresses are as per opt in purpose:
- used to send out alerts ahead of each Warren Miller Film Tour event and to announce tickets on sale dates.
- To send snow alerts primarily early and late in the snowsports season to those signed up to the Winterhighland alert list.
- As no further information is obtained (as of October 2018) these emails are generic and not geo-targeted.
- So long as the sign up terms remain as per October 2018; these email addresses are not to be used for third party marketing or passed on to third parties except where required by law.
- Win Tickets (paper and where applicable electronic competition entry):
- Email addresses and related personal data obtained by Winterhighland Ltd up to and including the Line of Descent Tour may only be used by Winterhighland Ltd and solely for the purpose of notifying the individual of the upcoming/current tour.
- The lawful basis of processing shall be consent and legitimate interests of both Winterhighland Ltd and the individual.
- Limited number of emails solely regarding WM Tour means very limited intrusion, no wider marketing use protects privacy and notification of upcoming tour dates is expected by majority of relevant individuals.
- As evidence of legitimate interest of customers, it is noted that lack of prior notification due to data protection policies preventing Winterhighland Ltd notifying customers of the previous tour organisers has been a source of complaint.
- Win Tickets went virtual from October 2019 starting with the TIMELESS Tour and are managed by Adventure Entertainment. Winterhighland has access to this data on the following basis:
- Legitimate interest as lawful basis for processing with respect management of the UK WM Tour Grand Prize Draws.
- Win Ticket opt-ins for consent for processing of included personal data by Winterhighland Ltd:
- For the purpose of Warren Miller Film Tour marketing, win tickets have an explicit opt in to be notified of future tours. Personal data collected & retained will include the following:
- Name [From win Ticket]
- Email Address [From win Ticket]
- Mobile phone number due in part to issues contacting prize winners.
- Venue attended
- Postcode sector [May include on tickets to help analyse tour reach, venue and marketing effectiveness]
- A distinct explicit opt-in to receive Winterhighland Ltd newsletter / snow alerts or promotional emails.
- Win Ticket opt-ins for consent for processing of included personal data by third party ‘Tour Partners’ will be an explicit opt-in for each tour partner and as such will only be available to the presenting sponsor and major partners.
The winterhighland.info website is non transactional and the minimal amount of personal information required to having a functioning user account system is processed and retained for that purpose.
User Account Registration requires:
- A verifiable email address
- A username of the individuals choosing.
- Replacement of temporary verification code with a user supplied password to complete the registration process.
- Users have the option of indicating real name and mountain sports interests for use in their forum signature.
Email addresses, usernames and password hashes are stored on a distinct database server that is separate from either the main website server or the forum server. This data is retained for user account functionality and the legal basis for processing said data is user consent and legitimate interest.
We do not currently store additional user information beyond that which individual users choose to publish on the public forum or user generated snow reports on the main website.
The Winterhighland site user database is hosted separately to and managed separately from personal data processed for the Warren Miller Film Tour, and Winterhighland user data is not provided to third parties.
Winterhighland continues to operate over http to minimise the data overheads for use of the site in remote locations over very limited data services. For this reason it is even more important that you DO NOT use a password you use for high security services.
User generated content becomes part of our website community, subsequent deletion of content can break conversations, and debase a historical record. While users can edit their own posts, we ask that this feature is not used retrospectively to render long standing conversations nonsensical.
When you make a post you are actively publishing it to the public internet, please keep in mind all legal responsibilities.
When you submit user generated content to the website and/or forum the IP address from which you submitted that content is logged.
If for any reason you wish us to deactivate or delete your Winterhighland account, please contact us by email at the address below. Please note that while we will delete accounts, including removing username from forum posts, we will not delete the posts associated with that account unless for an exceptional reason at our discretion. Content posted from an account deleted by user request will show as a guest account with the poster name guest.
We reserve the right to deactivate / delete abusive user accounts without any prior warning, these are a non exhaustive list of examples of circumstances where we may consider this course of action to be in the interests of our online community.
- Repeated spam abuse (whether bot or human poster)
- Malicious activity or posting offensive and/or illegal content
- Abusing other members of our mountain sports community
- Posting content that leaves either the poster or Winterhighland Ltd at risk of legal action
Where a user account is deactivated for abuse, the user login credentials are wiped and account disabled, but username and content not otherwise moderated will remain visible to all visitors.
Where an account is deleted for abuse, the username will be replaced with deleted and/or all user content removed if deemed necessary.