Spiral Sites understands that your privacy is important to
you and that you care about how your
personal data is used and shared online. We respect and value the
privacy of everyone who visits this
website, www.spiralsites.com (“Our Site”) and will only collect and use
personal data in ways that are described here, and in a manner that is
consistent with Our obligations and your rights under the law.
upon your first use of Our Site. If you do not accept and agree with this
1. Definitions and Interpretation
In this Policy, the following terms shall have the following
“Account” - means an account required to access and/or use
certain areas and features of Our Site;
“Cookie” - means a small text file placed on your computer
or device by Our Site when you visit certain parts of Our Site and/or when
you use certain features of Our Site. Details of the Cookies used by Our Site
are set out in section 13, below;
“Cookie Law” - means the relevant parts of the Privacy and
Electronic Communications (EC Directive) Regulations 2003;
“personal data” - means any and all data that relates to an
identifiable person who can be directly or indirectly identified from that
data. In this case, it means personal data that you give to Us via Our Site. This definition shall,
where applicable, incorporate the definitions provided in the Data Protection
Act 1998 or EU Regulation 2016/679 – the General Data Protection Regulation
“We/Us/Our” - means Spiral Sites Ltd, a limited company
registered in England under company number 4232841, whose registered address
is 11 Dione Crescent,
Oakhurst, Swindon, SN25 2JW, and whose main trading address is 11 Dione Crescent, Oakhurst, Swindon, SN25
2. Information About Us
2.1 Our Site is owned and operated by Spiral Sites Ltd, a limited company registered in England under company number 4232841, whose registered address is 11 Dione Crescent, Oakhurst, Swindon, SN25 2JW and whose main trading address is 11 Dione Crescent, Oakhurst, Swindon, SN25 2JW.
2.2 Our Data Protection Officer is Jon Eastwood, and can be contacted by email at firstname.lastname@example.org, or by post at 11 Dione Crescent, Oakhurst, Swindon, SN25 2JW.
3. What Does This Policy Cover?
applies only to your use of Our Site. Our Site may contain links to other
websites. Please note that We have no control over how your data is collected,
stored, or used by other websites and We advise you to check the privacy
policies of any such websites before providing any data to them.
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes;
4.1.7 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or
all of the following personal and non-personal data (please also see section 13
5.2 contact information such as email addresses and telephone numbers;
5.3 IP address;
5.4 web browser type and version;
5.5 operating system;
5.6 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Act 1998 or GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your access to Our Site;
6.2.2 Personalising and tailoring your experience on Our Site;
6.2.3 Supplying Our products or services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.4 Personalising and tailoring Our products or services for you;
6.2.5 Replying to emails from you;
6.2.6 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by using unsubscribe links in any marketing emails;
6.2.7 Market research;
6.2.8 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email or telephone or text message or post with information, news and offers on Our products or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 1998 or GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.5.1 Any personal data that us used to provide services to you will be kept for 6 years due to accounting regulations whereby we must retain accounting data;
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Steps We take to secure and protect your data include:
7.4.1 Data is stored on secure dedicated servers used solely by Us.
7.4.2 Only our staff have access to this data.
7.4.3 Server access is limited to our office locations
8. Do We Share Your Data?
8.1 Subject to section 8.2, We will not share any of your data with any third parties for any purposes.
8.2 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.4 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
10. How Can You Control Your Data?
10.1 When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right to Withhold Information
11.1 You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
12. How Can You Access Your Data?
You have the right to
ask for a copy of any of your personal data held by Us (where such data is held.
Under the GDPR, no fee is payable and We will provide any and all information
in response to your request free of charge. Please contact Us for more details
or using the contact details below in section 14. Alternatively, please refer to Our Data Protection Policy https://www.spiralsites.com/data-protection-policy/.
Our Site may place and access certain first party Cookies on
your computer or device. First party Cookies are those placed directly by Us
experience of Our Site and to provide and improve Our products or services. By
using Our Site you may also receive certain third party Cookies on your
computer or device. Third party Cookies are those placed by websites, services,
and/or parties other than Us. Third party Cookies are used on Our Site for live
help chat functions. In addition, Our Site uses analytics services provided by
set of tools used to collect and analyse usage statistics, enabling Us to
better understand how people use Our Site. For more details, please refer to
14. Contacting Us
If you have any questions about Our Site or this Privacy
Policy, please contact Us by email at email@example.com, or by post at 11 Dione Crescent, Oakhurst, Swindon, Wiltshire, SN25 2JW.
Please ensure that your query is clear, particularly if it is a request for
information about the data We hold about you (as under section 12, above).
We may change this
changes will be immediately posted on Our Site and you will be deemed to have
following the alterations. We recommend that you check this page regularly to