Privacy and cookies policy

1. Introduction

1.1 We are committed to safeguarding the privacy of our website visitors.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can [specify whether you would like to receive direct marketing communications and limit the collection, sharing and publication of your personal data.

1.4 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.5 In this policy, “we”, “us” and “our” refer to Spinners Group Limited. For more information about us, see Section 14.

2. The personal data that we collect

2.1 In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.

2.2 We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer.

2.3 We may process your website user account data (“account data“). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by DesignMyNight. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.

2.5 We may process information relating to our customer relationships (“customer relationship data“). The customer relationship data may include your name, the name of your business or employer, your job title or role, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you, or between us and your employer. The source of the customer relationship data is you and/or your employer.

2.6 We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.

2.7 We may process [information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.

2.8 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.

2.9 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

3. Purposes of processing and legal bases

3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2 Operations – We may process your personal data for the purposes of operating our website, providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.

3.3 Relationships and communications – We may process contact data, account data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business

3.6 Direct marketing – We may process contact data, account data, profile data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users. 

3.7 Research and analysis – We may process usage data, service data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally. 

3.8 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy. 

3.9 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others. 

3.10 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person. 

4. Providing your personal data to others 

4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. 

4.2 Financial transactions relating to our website and services are handled by our payment services providers, Worldpay. We will share transaction data with our payment services providers only to the extent necessary for the purposes of [processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. 

4.3 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. 

5. Security of personal data 

5.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data. 

5.2 We will store [your personal data] on [secure servers, personal computers and mobile devices, and in secure manual record-keeping systems]. 

5.3 The following personal data will be stored by us in encrypted form: [your name, contact information, password(s) and cardholder data]. 

5.4 Data[ relating to [your enquiries and financial transactions]] that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology. 

5.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet. 

5.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website). 

6. Your rights 

6.1 In this Section 9, we have listed the rights that you have under data protection law. 

6.2 Your principal rights under data protection law are:

(a) the right to access – you can ask for copies of your personal data;

(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c) the right to erasure – you can ask us to erase your personal data;

(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;

(e) the right to object to processing – you can object to the processing of your personal data;

(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;

(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and

(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent. 

6.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelinesrecommendations-best-practices_en and https://ico.org.uk/fororganisations/guide-to-data-protection/guide-to-the-general-data-protectionregulation-gdpr/individual-rights/. 

6.4 You may exercise any of your rights in relation to your personal data [by written notice to us, using the contact details set out below]. 

7. Third party websites 

7.1 Our website includes hyperlinks to, and details of, third party websites. 

7.2 In general we have no control over, and are not responsible for, the privacy policies and practices of third parties. 

8. Updating information 

8.1 Please let us know if the personal information that we hold about you needs to be corrected or updated. 

9. About cookies 

9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. 

9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. 

9.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies. 

10. Cookies that we use 

10.1 We use cookies for the following purposes: 

(a) [authentication and status – we use cookies [to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website][ (cookies used for this purpose are: [identify cookies])]]; 

(b) [shopping cart – we use cookies to [maintain the state of your shopping cart as you navigate our website][ (cookies used for this purpose are: [identify cookies])]]; 

(c) [personalisation – we use cookies [to store information about your preferences and to personalise our website for you][ (cookies used for this purpose are: [identify cookies])]]; 

(d) [security – we use cookies [as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally][ (cookies used for this purpose are: [identify cookies])]]; 

(e) [advertising – we use cookies [to help us to display advertisements that will be relevant to you][ (cookies used for this purpose are: [identify cookies])]]; 

(f) [analysis – we use cookies [to help us to analyse the use and performance of our website and services][ (cookies used for this purpose are: [identify cookies])]]; and 

(g) [cookie consent – we use cookies [to store your preferences in relation to the use of cookies more generally][ (cookies used for this purpose are: [identify cookies])]]. 

11. Cookies used by our service providers 

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website. 

11.2 We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy.[ The relevant cookies are: [identify cookies].] 

11.3 We use a Facebook pixel on our website. Using the pixel, Facebook collects information about the users and use of our website. The information is used to personalise Facebook advertisements and to analyse the use of our website. To find out more about the Facebook pixel and about Facebook’s use of personal data generally, see the Facebook cookie policy at https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at https://www.facebook.com/about/privacy. The Facebook cookie policy includes information about controlling Facebook’s use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at https://www.facebook.com/help/568137493302217. 

12. Managing cookies 

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links: 

(a) https://support.google.com/chrome/answer/95647 (Chrome); 

(b) https://support.mozilla.org/en-US/kb/enhanced-tracking-protectionfirefox-desktop (Firefox); 

(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera); 

(d) https://support.microsoft.com/en-gb/help/17442/windows-internetexplorer-delete-manage-cookies (Internet Explorer); 

(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-andwebsite-data-sfri11471/mac (Safari); and 

(f) https://support.microsoft.com/en-gb/help/4468242/microsoft-edgebrowsing-data-and-privacy (Edge). 

12.2 Blocking all cookies will have a negative impact upon the usability of many websites. 

12.3 If you block cookies, you will not be able to use all the features on our website. 

13. Amendments 

13.1 We may update this policy from time to time by publishing a new version on our website. 

13.2 You should check this page occasionally to ensure you are happy with any changes to this policy. 

13.3 We may notify you of significant changes to this policy by email. 

14. Our details 

14.1 This website is owned and operated by Spinners Group Limited 

14.2 We are registered in England and Wales under registration number 13966525, and our registered office is at 27 Old Gloucester Street, London, WC1N 3AX 14.3 You can contact us: 

(b) using our website contact form 

(d) by email, using the email address published on our website