Version Date: 24 May 2018

As part of our ongoing commitment to transparency in how we process and keep your data safe, we have put new measures in place. We have updated our Privacy Policy to reflect this commitment and to illustrate recent changes we have made to strengthen your right to privacy.

We have also included updates to meet the high standards of data protection as laid out in the General Data Protection Regulation (GDPR) which was introduced across the European Union. These GDPR regulations impact organisations that are processing the personal data of people residing in the EU, as well as users who reside in the EU.

But whether you are in the EU or not, we believe data security and control is important to all of our users. That is why we aim to be open about how we use the information you share and why we will always keep your data safe and secure.

At Winter Circle, we collect information through our website, app, servers, as well as our in-house membership and client teams. Gathering this information helps us build better technology and create better experiences.

Below are some of the changes we have made to our Privacy Policy where we have listed the data we may collect, along with details on its storage and how you can access it if you wish.

What does Winter Circle do?

Winter Circle is an invitation-only digital network for the world's leading executives. We help global organisations find their next senior leaders by connecting them directly with the best talent. An exclusive digital destination, both members and clients use Winter Circle to find unique opportunities, ideas and intelligence.

What information is collected?

When you visit a Winter Circle webpage or the Winter Circle app, the following information may be collected:

  • Clicks, Mouse Movements/Hovers, Scrolling
  • Browser Type
  • Device (Desktop/Tablet/Phone)
  • Default Language
  • Operating System
  • Screen Resolution
  • Duration (Time on Site)
  • Navigation (URLs)
  • Page Content (HTML)
  • ISP & Approx. ISP Location (City, State/Region, Country)
  • Referrer URL
  • Visitor Type (First Time/Returning)
  • Custom Tags or Variables

When you join as a member or client, either through online registration or over the phone with one of our membership or client teams, personally identifiable information may be processed and stored. Individual logins mean that you can keep your details accurate and up to date whenever you sign into your profile.

What is your legal basis for processing personal information?

Whenever we process your personal information we must have a "legal basis" for doing so. The different legal bases we rely on are:

Legitimate interests: Processing is necessary for us to conduct our business, but not where your fundamental rights of privacy are outweighed by our legitimate interests;
Consent: You have told us you are happy for us to process sensitive information for a specific purpose;
Performance of a contract: We must process your personal information in order to be able to provide you with one of our products or services;
Public information: We process personal information which you have already made public.

Where is our data stored?

Our goal as a company is to provide our customers with secure, fast, and reliable services and the storage of data is an integral part of doing this.

Winter Circle stores data in its AWS data centre located in the US. In order to bring you world-class products and to provide vital maintenance such as 24/7 technical or customer support, we may also permit employees and contractors located outside the EU (e.g. in the US, Hong Kong and Singapore) access to certain data for product development as well as technical and/or customer support.

What can I do?

Data Access

If you wish to access your data, including any data held by our third party providers, please contact us at

Data Correction

If you wish to correct your data, please sign in to your profile where you can edit all of your personal details. If you are unable to sign in to your member profile or experience any technical problems when editing your data, please contact us at

Data Erasure

If you wish to have your data erased, please contact us at

Revoking Consent

If you gave your consent to the processing of sensitive information and wish to revoke this consent, please sign in to your profile where you can edit all of your personal details. If you are unable to sign in to your member profile or experience any technical problems when editing your data, please contact us at

Opt Out

If you would like to choose the type of content you receive from us or prefer to opt out of all communications, please sign in to your account where you can edit this in your settings. You can also unsubscribe from emails at the bottom of each email you receive from us. If you are unable to log in to your account or experience any technical problems, please contact us at

Where can I read your Privacy Policy?

You can read it here.


If you have any questions, please email and we will be happy to help or provide more information.