Privacy Policy
PRIVACY POLICY STATEMENT
Privacy Notice
We take your privacy very seriously. This privacy notice will inform you as to how we look after your personal data when you visit our website www.spinlock.co.uk (“our Website”) (regardless of where you visit from), when you use any Spinlock Sense App or any other App made available by us, and when you correspond with us by telephone, email or otherwise. It tells you about your privacy rights and how the law protects you.
IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how Spinlock Limited collects and processes your personal data through the use of our Website, including any data you may provide through our Website when you make an online enquiry or sign up for our promotional emails, when you use any Spinlock Sense App or any other App made available by us, and when you correspond with us by telephone, email or otherwise.
Our Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Who we are
Spinlock Limited (“we”, “us”, “our”) is a ‘data controller’ for the purposes of your personal data. This means that we determine the purpose and means of the processing of your personal data. You will find our contact details at the end of this privacy notice (see below: “How to contact us”).
PERSONAL DATA WE COLLECT ABOUT YOU
Personal data is any information relating to an identified or identifiable individual.
We collect, use, store and transfer different kinds of personal data about you. This may include:
- Full name;
- Job title;
- Business name;
- Name of your employer or the organisation you represent;
- Address;
- Email address;
- Unique identification number;
- Telephone numbers (mobile and landline);
- Geo location data, if you have a Spinlock Sense product and you have opted to switch on the location services setting in the App and/or on your device (location data may or may not be personal data, depending on the circumstances);
- Technical information from when you visit our Website, including your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website;
- Information about how you use our Website;
- Your billing and transaction information;
- Profile information, including purchases or orders made by you;
- Your personal or professional interests;
- Marketing and communications information, including your preferences in receiving marketing from us and our third parties and your communication preferences; and
- Information that you volunteer to us when you make an online enquiry and when you correspond with us by telephone, email or otherwise.
We also collect, use and share aggregated data, such as sail usage data from our Sail-Sense product for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
If you do not provide personal data
For individual business customers or suppliers, where we need to collect personal data to enter into a contract with you and you fail to provide that data when requested, we may not be able to enter the contract with you. This data may include your name, address and email address. For individual customers, if you thereafter do not provide the personal data we ask for which may include further contact details, this may delay or prevent us from providing our products or services to you.
HOW YOUR PERSONAL DATA IS COLLECTED
Depending on the circumstances, we use different methods to collect personal data from and about you including:
- Directly from you. You may give us your personal data by filling in forms on our Website or by corresponding with us by email, telephone or otherwise. This includes personal data you provide when you:
- complete an online enquiry form;
- subscribe to our promotional emails; or
- use any Spinlock Sense App or any other App made available by us.
- Other sources. We may receive personal data about you from various sources as set out below:
- Contact, financial and transaction data from providers of technical and payment and delivery services;
- From an employee or representative of the organisation for whom you work;
- Via third party subscribers of the Spinlock Sense App or any other App made available by us (location data only; any location data collected may or may not be personal data, depending on the circumstances); and
- Via our IT systems e.g. door entry systems and reception logs, automated monitoring of our Website and other technical systems (such as our computer networks and connections), CCTV and access control systems, communication systems and email.
HOW AND WHY WE USE YOUR PERSONAL DATA
Under data protection law, we can only use your personal data if we have a proper reason for doing so, for example:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest is when we or a third party have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use your personal data for and our lawful basis for doing so.
For individual customers with whom we have contracts – to provide our products and services to you Necessary for the performance of our contract with you or to take steps at your request before entering into a contract with you. Necessary for our legitimate interests or those of a third party e.g. to the extent to which personal data is collected via any Spinlock Sense App or any other App made available by us, to be able to achieve our commercial objectives and assist our customers in achieving their commercial objectives
For other individuals who work for or represent corporate business customers (or prospective corporate business customers) e.g. for corresponding with you about the products and services we offer, to provide a price quote, to respond to your queries and to manage the contract with the organisation you work for or represent
Necessary for our legitimate interests or those of a third party e.g. to deal with pre-contractual enquiries or issues and to manage the contract with the organisation you work for or represent and to the extent to which personal data is collected via any Spinlock Sense App or any other App made available by us, to be able to achieve our commercial objectives and assist our customers in achieving their commercial objectives
For individual suppliers with whom we have contracts e.g. for corresponding with you about the products or services you offer, to obtain a price quote and to take steps under the contract with you
Necessary for the performance of our contract with you or to take steps at your request before entering into a contract with you
For individuals who work for or represent our corporate suppliers (or prospective corporate suppliers) e.g. for corresponding with you about the products or services your organisation offers, to obtain a price quote and to manage the contract with the organisation you work for or represent
Necessary for our legitimate interests or those of a third party e.g. to deal with pre-contractual enquiries or issues and to manage the contract with the organisation you work for or represent
To manage our relationship with you, or the organisation which you work for or represent, which will include (where appropriate) notifying you about changes to our terms of business or privacy notice or dealing with complaints
Necessary to comply with our legal obligations
Necessary for our legitimate interests i.e. to manage our relationship with you or the organisation you work for or represent, and to analyse and improve the products or services we offer
To prevent and detect fraud against you or us
Necessary for our legitimate interests or those of a third party i.e. to minimise fraud that could be damaging for us and for you
Other processing necessary to comply with legal and regulatory obligations that apply to our business or as otherwise permitted or required by law
Necessary to comply with our legal obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
Necessary to comply with our legal obligations
Ensuring business policies are adhered to e.g. policies covering data security
Necessary to comply with our legal obligations Necessary for our legitimate interests or those of a third party e.g. to make sure we are following our own internal procedures so we can deliver the best service to you or the organisation you work for or represent
Operational reasons, such as improving efficiency, training and quality control
Necessary for our legitimate interests or those of a third party e.g. to be as efficient as we can so we can deliver the best service for you or the organisation you work for or represent, at the best price
Ensuring the confidentiality of commercially sensitive information
Necessary to comply with our legal obligations Necessary for our legitimate interests or those of a third party i.e. to protect commercially valuable information
Statistical analysis to help us manage our business e.g. in relation to our financial performance, customer base, product range or other efficiency measures
Necessary for our legitimate interests or those of a third party e.g. to be as efficient as we can so we can deliver the best service for you or the organisation you work for or represent, at the best price
Preventing unauthorised access and modifications to systems
Necessary to comply with our legal obligations Necessary for our legitimate interests or those of a third party e.g. to prevent and detect criminal activity that could be damaging for us and for you or the organisation you work for or represent
Updating and maintaining customer and supplier records
Necessary to comply with our legal obligations Necessary for our legitimate interests or those of a third party e.g. to make sure we can keep in touch with our customers and other contacts
Staff management and administration
Necessary for our legitimate interests or those of a third party e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service we are able to
External audits for the audit of our accounts
Necessary to comply with our legal obligations
To make suggestions and recommendations to you about products or services that may be of interest to you or the organisation you work for or represent
Necessary for our legitimate interests e.g. to develop our products/services and grow our business
To enforce or apply our Website and/or App terms and conditions or any other agreements
Necessary for our legitimate interests or those of a third party e.g. to enforce our legal rights and protect our business
To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Necessary for our legitimate interests e.g. for running our business, provision of administration and IT services, network security and to prevent fraud Necessary to comply with our legal obligations
To deliver relevant website content to you and measure or understand the effectiveness of the content
Necessary for our legitimate interests e.g. to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests e.g. to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and inform our marketing strategy
For testimonials on our Website
With your consent
Where we rely on consent as a lawful basis to process your personal data, you have the right to withdraw your consent at any time. To do this, please telephone, email or write to us (see below: “How to contact us”).
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
Marketing communications
We may use your personal data to send you periodic communications by email, post and text about our products and services.
We have a legitimate interest in processing your personal data for marketing purposes. This means we do not usually need your consent to send you information about our products and services. However, where consent is needed, we will ask for this consent separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- emailing prosupport@spinlock.co.uk;
- writing to us at Birmingham Road, Cowes, Isle of Wight, PO31 7BH (for the attention of the Operations Director); or
- using the ‘unsubscribe’ link in our emails or ‘STOP’ number in texts.
We may ask you to confirm or update your marketing preferences if there are changes in the law, regulation, or the structure of our business.
Third party marketing
We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.
Cookies
We may obtain information about your general usage of our Website by using a cookie which is stored on your browser or the hard drive of your computer, although we do not use cookies to identify individuals. Usage information helps us to improve our Website and to deliver a better and more personalised service. Some of the cookies we use are essential for our Website to operate.
You can block cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies. You can also indicate your preference to our Website to control its use of cookies. However, if you block cookies you may not be able to use all the features of our Website. For further information about our use of cookies, please refer to our cookies policy which you will find on our Website.
WHO DO WE SHARE YOUR PERSONAL DATA WITH
Depending on the circumstances, we may share your personal data with:
- External service providers we use to help run our business e.g. website hosting provider, email service provider, marketing service provider, IT providers, document management providers, banks, payment card providers and postal service providers;
- Professional advisers including lawyers, bankers, loss adjusters, insurers, auditors, technical consultants and experts; and
- Advertisers and advertising networks to send you marketing communications.
If you are the owner of a Spinlock Sense product, and you transfer your device to a new owner, then on a written request from the new owner (and on production of suitable proof of ownership) we may transfer data which is accessible through the associated App to the new owner. This data may include personal data.
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal obligations.
We may also need to share some personal data with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible.
TRANSFERRING YOUR PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA
Some of organisations with whom we share your personal data are based outside the European Economic Area (EEA) (which comprises the countries in the European Union and Iceland, Liechtenstein and Norway) so their processing of your personal data will involve a transfer outside of the EEA.
These transfers are subject to special rules under European and UK data protection law.
Whenever we transfer your personal data outside of the EEA, we ensure a similar degree of protection is afforded to your data by ensuring one of the following (or one of the other grounds set out in data protection law) applies:
- your data is transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- the transfer is necessary for the performance of a contract between you and us;
- the transfer is necessary to establish, exercise or defend legal claims;
- there are adequate safeguards in place between us and the organisation receiving it (e.g. by the use of European Commission approved contractual terms); or
- you have provided explicit consent to the proposed transfer after being informed of any potential risks.
Please contact us (see below: “How to contact us”) if you want further information on the specific mechanism used by us when transferring your personal data outside of the EEA.
WHAT ARE YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA?
Data protection law gives you certain rights, which you can exercise free of charge. Your rights will differ depending on our lawful basis for processing your data:
Access | The right to be provided with a copy of your personal data
Rectification | The right to require us to correct any mistakes in your personal data
To be forgotten | In certain situations, the right to require us to delete your personal data
Restriction of processing | In certain situations, the right to require us to restrict processing of your personal data e.g. if you contest the accuracy of the data
Data portability | In certain situations, the right to ask us to transfer any personal data you provided to us to another organisation
To object | The right to object at any time to your personal data being processed for direct marketing and in certain other situations to our continued processing of your personal data e.g. where processing is carried out for the purpose of our legitimate interests
Rectification | The right to require us to correct any mistakes in your personal data
To be forgotten | In certain situations, the right to require us to delete your personal data
Restriction of processing | In certain situations, the right to require us to restrict processing of your personal data e.g. if you contest the accuracy of the data
Data portability | In certain situations, the right to ask us to transfer any personal data you provided to us to another organisation
To object | The right to object at any time to your personal data being processed for direct marketing and in certain other situations to our continued processing of your personal data e.g. where processing is carried out for the purpose of our legitimate interests
We do not use personal data for automated decision making. For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation. [https://ico.org.uk/your-data-matters/]
If you would like to exercise any of those rights, please email or write to us (see below: “How to contact us”) and let us have enough information to identify you e.g. your full name and address and product or service reference as well as what right you want to exercise and the personal data to which your request relates.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including;
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records of products registered by you; and
- to keep records required by law to comply with our legal obligations.
We will not retain your data for longer than necessary for the purposes set out in this notice. Different retention periods apply for different types of personal data.
KEEPING YOUR PERSONAL DATA SECURE
We have put in place reasonable and appropriate security measures to endeavour to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
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 Website; any transmission is at your own risk.
Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our Website, we encourage you to read the privacy notice of every website you visit.
We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
HOW TO COMPLAIN
We hope that we can resolve any query or concern you may raise about our use of your personal data. If you want to complain about how we have used your personal data, please email or write to us (see below: “How to contact us”). However, if we are not able to resolve your complaint to your satisfaction, you can complain to the UK’s supervisory authority, the Information Commissioner’s Office (ICO). Further information about how to make a complaint to the ICO can be found on the ICO website www.ico.org.uk.
The EU General Data Protection Regulation also gives you right to lodge a complaint with the supervisory authority in the European Union state where you work, normally live or where any alleged infringement of data protection laws occurred.
CHANGES TO THE PRIVACY NOTICE
This version is Revision 1 last updated in July 2019.
We may change this privacy notice from time to time and when we do so, we will inform you via our Website. If any changes are likely to have an adverse impact on your rights under data protection law, we will use reasonable endeavours to notify you of the changes in advance by email or by alternative means.
CHANGES TO YOUR PERSONAL DATA
Please let us know if you change your name, address or any other personal detail (see below: “How to contact us”).
HOW TO CONTACT US
If you have any queries about this privacy notice or how we use your personal data, you can contact us by telephone or post as follows:
If you have any queries about this privacy notice or how we use your personal data, you can contact us by telephone or post as follows:
Spinlock Limited, Birmingham Road, Cowes, PO31 7BH, UK
+44 (0)1983 295555
prosupport@spinlock.co.uk
Do you need extra help?
If you would like this notice in another format (for example large print) please contact us (see above: “How to contact us”).