This policy (together with our Terms and Conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting this website you are accepting and consenting to the practices described in this policy.
For the purpose of this policy, “Data Protection Legislation” means the General Data Protection Regulation 2016 (“GDPR”) unless and until the GDPR is no longer directly applicable in the UK, together with any national implement laws, regulations and secondary legislation as updated from time to time in the UK including the Data Protection Act 2018 (“DPA”), and any successor legislation to the GDPR and the DPA. The data controller is HS Products Ltd (05189436) trading as Spinks.
INFORMATION COLLECTED BY US
We may collect and process the following data about you:
- Information you give us.You may give us information about you by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, address, e-mail address and phone number. We retain this information for 10 years where we use it to send you marketing communications (either on the grounds of legitimate interests or consent, as applicable) and, in respect of all other personal data, for 8 years from the date of collection; and
- Information we collect about you. With regard to each of your visits to our website we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type, and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number; and
- Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We retain this information for 10 years where we use it to send you marketing communications (either on the grounds of legitimate interests or consent, as applicable) and, in respect of all other personal data, for 8 years from the date of collection.
OUR USE OF YOUR INFORMATION
Provided that we have obtained your consent to the extent we are required to under the Data Protection Legislation, we may use the information we receive and/or collect about you to:
- fulfil our obligations under any contract we have entered into with you and to provide you with information, products and services you have requested;
- send you newsletters and marketing information if you have consented to us doing so;
- notify you of products and services we offer that are similar to those you have purchased or enquired about;
- notify you of changes to our services and products;
- ensure that content from our website is presented in the most effective manner for you and your computer; and
- carry out customer management activities to enable us to deliver better goods and services to our customers.
We collect and process much of your personal information on the grounds of legitimate interests, which include some or all of the following:
- where the processing enables us to enhance, modify, personalise or otherwise improve the website, our services and communications for the benefit of our customers;
- to identify and prevent fraud;
- to enhance the security of our network and information systems;
- to better understand how people interact with our websites;
- administer the website and for internal operations, including data analysis, troubleshooting and testing, research, statistical and survey purposes;
- as part of our efforts to keep our website safe and secure; and
- to determine the effectiveness of promotional campaigns and advertising.
If we require your personal data for fulfilment of a contract with you (for example to provide goods and services you have requested), we may be unable to fulfil the contract without your personal data.
If we are unable to rely on legitimate interests or any other ground set out in the GDPR to process your personal data, we will obtain consent from you to the processing.
If we obtain consent from you to do so, we may provide your personal details to third parties so that they can contact you directly in respect of services and/or products in which you may be interested.
You have the right to withdraw your consent to the processing of your personal data at any time. If you would like to withdraw your consent, or prefer not to receive any of the above-mentioned information (or if you only want to receive certain information) from us please let us know by contacting us via the following webpage: https://www.spinks-springs.com/contact. Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit. Withdrawal of your consent won’t affect any processing we have carried out in respect of your personal data prior to you withdrawing consent.
If you wish to have your information removed from our database or if you do not want us to contact you for marketing purposes, please let us know by clicking the “Unsubscribe” option in any email we send to you and providing the details requested and we will take steps to ensure that this information is deleted as soon as reasonably practicable.
Third Party Sites
DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
In addition to as set out elsewhere in this policy, we may disclose your personal information to third parties:
- If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- If HS Products Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and
LOCATION OF YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. We may transmit your personal data outside of the EEA to the Rocket Science Group LLC, trading as MailChimp, a provider of marketing and email platforms. MailChimp is located in the United States of America and is a registered member of the Privacy Shield scheme which guarantees appropriate safeguards are in place in respect of the personal data we transfer to it.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your rights in respect of your data
There are a number of rights available to you under GDPR:
- Access to your information
You can ask us to confirm that we process your personal data and provide access to and copies of the information we hold about you by contacting us via the following webpage: https://www.spinks-springs.com/contact. We will process your request to access your information and provide this information to you free of charge unless your request is manifestly unfounded or excessive or repetitive, in which case we are entitled to charge a reasonable fee. We may also charge if you request more than one copy of the same information.
We will provide the information you request as soon as possible and in any event within one month of receiving your request, unless there are extenuating circumstances. If we need more information to comply with your request, we’ll let you know.
- Rectification of your data
If you believe personal data we hold about you is inaccurate or incomplete, or any of the information you provide to us changes, please let us know as soon as possible so that we can make the necessary changes to the information we hold for you on our database. If you wish to make any changes to your information, please contact us via the following webpage: https://www.spinks.co.uk/get-in-touch.
We will comply with your request within one month of receiving it, unless we don’t feel it’s appropriate for us to do so in which case we’ll let you know why. We’ll also let you know if we need more time to comply with your request.
- Right to be forgotten
In some circumstances, you have the right to ask us to delete personal data we hold about you. This right is available to you:
- where we no longer need your personal data for the purpose for which we collected it;
- where we have collected your personal data on the grounds of consent and you withdraw that consent;
- where you object to the processing and we don’t have any overriding legitimate interests to continuing processing the data;
- where we have unlawfully processed your personal data (i.e. we have failed to comply with GDPR);
- where the personal data has to be deleted to comply with a legal obligation; and
- where the personal data we process relates to the offer of online services to a child.
There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know
To request that your information is deleted, please contact us via the following webpage: https://www.spinks.co.uk/get-in-touch.
- Right to restrict / object to processing
In some circumstances you are entitled to ask us to suppress processing of your personal data. This means we will stop actively processing your personal data but we don’t have to delete it. This right is available to you:
- if you believe the personal data we hold isn’t accurate – we’ll cease processing it until we can verify its accuracy;
- if you have objected to us processing the data (see below) – we’ll cease processing it until we have determined whether our legitimate interests override your objection;
- if the processing is unlawful; or
- if we no longer need the data but you would like us to keep it because you need it to establish, exercise or defend a legal claim.
You are entitled to object to us processing your personal data:
- if the processing is based on legitimate interests or performance of a task in the public interest or exercise of official authority;
- for direct marketing purposes (including profiling); and/or
- for the purposes of scientific or historical research and statistics.
In order to object, you must have grounds for doing so based on your particular situation. We will stop processing your data unless we can demonstrate that there are compelling legitimate grounds which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.
If you wish to restrict or object to the processing of your information, please contact us via the following webpage: https://www.spinks.co.uk/get-in-touch.
- Data Portability
You have the right to ask us to provide your personal data in a structured, commonly used and machine-readable format so that you are able to transmit the personal data to another data controller. This right only applies:
- to personal data you provide to us;
- where processing is based on your consent or for performance of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests); and
- where we carry out the processing by automated means.
We’ll respond to your request as soon as possible and in any event within one month from the date we receive it. If we need more time, we’ll let you know.
If you have any complaints about our use of your personal data, please contact us. You are also entitled to report any concerns which you may have to supervisory authority in your jurisdiction. The supervisory authority in the UK is the Information Commissioner’s Office. You can call the ICO on 0303 123 1113 or get in touch via other means as set out on the ICO website at https://ico.org.uk/concerns/.
We always welcome your views about our website and policy. If you have any queries or comments about this policy, please contact us here or by emailing email@example.com.
HS Products Ltd trading as Spinks
Registered in: England (05189436).
Registered office: 6 Millennium Drive, Leeds, West Yorkshire, LS11 5BP