Spotless Interactive Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.spotless.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“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 Part 14, below; and “Cookie Law”means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
- Information About Us
Our Site is owned and operated by Spotless Interactive, a limited company registered in England under company number 05176813.
Registered address: First Floor, 140 Old Street, London EC1V 9BJ.
Main trading address: First Floor, 140 Old Street, London EC1V 9BJ.
VAT number: 848 852771.
Data Protection Officer: Ben Logan.
Email address: firstname.lastname@example.org
Telephone number: +44 (0) 207 870 4091
Postal Address: First Floor, 140 Old Street, London EC1V 9BJ.
- What Does This Policy Cover?
- What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
- What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
b) The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we Please contact us using the details in Part 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we use it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
- What Data Do We Collect?
- Email address;
- Telephone number;
- Job title;
- IP address;
- Web browser type and version;
- Operating system;
- A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
- How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email that you have opted-in to (you may unsubscribe or opt-out at any time by using the unsubscribe options in the email).
- Analysing your use of our Site and gathering feedback to enable us to continually improve our Site and your user experience.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and telephone with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
- How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reasons for which it was first collected.
- How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the GDPR or to equivalent standards by law.
Under certain circumstances we will transfer your information outside of the European Economic Area. We will only do this with your informed consent, when it is necessary to perform a contract we have with you or where the receiving organisation has adequate safeguards in place – for example certification under the EU-US Privacy Shield framework.
All our third-party data processors have been carefully chosen as service suppliers who also practice responsible data handling. We believe that each has in place appropriate protections to ensure the security of the data we store or process with them and have clear policies for how they treat that data. But if in doubt you should review their individual Privacy Policies.
Amazon Web Services (File storage): https://aws.amazon.com/compliance/data-privacy-faq
Google Email / Drive (Email delivery & file storage): https://policies.google.com/privacy
Google (Website analytics): https://support.google.com/analytics/answer/6004245?hl=en
Media Temple (Hosting): https://mediatemple.net/legal/privacy-policy/
Campaign Monitor (Email marketing): https://www.campaignmonitor.com/policies/
- Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We will never sell, distribute or intentionally make your personal information public. All your interactions with our website are protected by strong 256-bit encryption and we collect the minimum of personal information needed to provide an effective service.
- How Can I Control My Personal Data?
11.1 In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via our Site, you may be given options to restrict our use of your personal 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).
- Can I Withhold Information?
- How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 14 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
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. All Cookies used by and on our Site are used in accordance with current Cookie Law.
Essential cookies required for the site to function will be set automatically, but before any others are placed on your computer or device you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our Site may not function fully or as intended.
Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our Site is used. This, in turn, enables us to improve our Site and the services offered through it.
Name of CookiePartyProviderPurpose_gaFirst PartyGoogle_gatFirst PartyGoogleSet by Google Analytics to distinguish between users. Expires after 24 hours._gidFirst PartyGoogleSet by Google to throttle the request rate to its Analytics service. Expires after 1 minute._galiFirst PartyGoogleSet by Google Analytics to help distinguish between different links to the same URL within our site. Expires after 1 minute.bkdc, bkuThird PartyOracle BlueKaiSet by the AddThis social sharing tool to provide personalised marketing. Expiry after 6 months. You can learn more and opt-out here: http://www.addthis.com/privacy/opt-outsc_anonymous_idThird PartySoundcloudSet on pages where the embedded Soundcloud audio player appears. Expires after 10 years.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
- How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Ben Logan):
Email address: email@example.com
Telephone number: +44 (0) 207 870 4091
Postal Address: First Floor, 140 Old Street, London, EC1V 9BJ.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
22/05/2018 – Update to policy published