Privacy Policy

Spoog 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 all of Member and Partners 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.

1. Information About Us

Spoog Limited.

Limited Company registered in England under company number 13143456

Registered address: Invision House Wilbury Way, Hitchin

Herts SG4 0TY

1. What Does This Policy Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

1. 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.

The personal data that we use is set out in Part 5, below

1. What Are My Rights?

Under the GDPR, you have the following rights, which we will always aim to uphold:

1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.

2. The right to access the personal data we hold about you. Part 10 will tell you how to do this.

3. 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 11 to find out more.

4. 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 have. Please contact us using the details in Part 11 to find out more.

5. The right to restrict (i.e. prevent) the processing of your personal data.

6. The right to object to us using your personal data for a particular purpose or purposes.

7. The right to data portability. This means that, if you have provided personal data to us directly, we are using 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.

8. Rights relating to automated decision-making and profiling.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

1. What Personal Data Do You Collect?

We may collect some or all of the following personal data to fulfil our contractual obligations as defined our Terms and Conditions (this may vary according to your relationship with us:

Name;
Date of birth;
Gender;
Address;
Email address;
Telephone number;
Business name;
Job title;
Payment information;
Information about your preferences and interests;
Order history

1. 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 will be used for the following purposes:

Providing and managing your account.
Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.
Personalising and tailoring our products and services for you.
Communicating with you. This may include responding to emails or calls from you.
Supplying you with information by email or post that you have opted-in to (you may unsubscribe or opt-out at any time by unsubscribing on emails or contact us directly).
Providing specific details to our partners in order to fulfil requests.

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, telephone, text message or post with information, news, and offers on our products or 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.

We use the following automated system/s for carrying out certain kinds of decision-making or profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so. Please contact us to find out more about using the details in Part 11.

The following automated decision-making method(s) may be used:
Google Analytics – a web analytics tool used to track and report website traffic to allow us to understand where our customers are find us.
The following automated profiling may take place:
Mailchimp – an email automation software for customer segmentation and to understand what type of services you may like and offer relevant services to you.
Our Sites use a unique tracking code to support Google Display Advertising enabling Google Analytics to collect traffic data by using our cookies. This is in addition to the data collected through the standard Google Analytics implementation allowing the Remarketing feature based on Display Advertising from Google. It is with this feature that we use Remarketing with Google Analytics to advertise online adhering to the Google Adwords Remarketing Policy and its sensitive category restrictions.
We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimise, and serve advertisements based on your past visits to our Sites for 30 days.
Cookies. A cookie is a text file placed on a device when a user visits a website. Cookies can be temporary (e.g. session) or permanent (e.g. persistent). They can also be first party (e.g. placed by us) or third party (e.g. placed by a third party advertiser or ad server).
Flash Cookies. A Flash cookie (or locally shared object) is a data file placed on your device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your device. This can operate across all your browsers.
HTML5. HTML5 cookies can be programmed through HTML5 local storage and do not require a plug-in.
ETag or entity tag. An opaque identifier assigned by a web server to a specific version of a resource found at a URL that acts as a form of device identifier.

You have the right to object to the use of cookies. We provide information about our use of cookies on our Sites in this privacy promise and through our cookie information page which is linked in a pop-up banner when you first visit one of our Sites. If you do not change the settings on your internet browser to disable, remove or reject cookies, you are deemed to consent to our use of cookies on our Sites. Please note that we are not required to obtain your consent to the use of cookies where storage of, or access to, the information collected by such cookies is strictly necessary for us to provide the services that you have requested.

If you do not wish for cookies to be installed on your computer, you can change the settings on your internet browser to disable, remove or reject cookies. For more information about how to do this, you should consult the “Help” section of your browser. In some but not all instances, cookies can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and you will see that different browsers offer different functionality and options in this regard. Please note that rejecting cookies via your browser may not be effective with regard to HMTL5 and Flash cookies (which are explained in more detail above). For information on disabling Flash cookies, please go to Adobe’s website www.adobe.com.

Each time you revisit one of our Sites your ability to restrict the use of cookies is subject to your browser settings and limitations at the time. Please be aware that if you disable, remove or reject cookies, some parts of our Sites may not work and we may not be able to provide you with our services and/or fulfil your orders.

1. 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 reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

For as long as your contract or agreement states and until you request the information for removal;
For accounting and/or any compliance related purposes

1. 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. In circumstances where we need to share your data with external third parties outside of EEA for reasons related to a service you request or we need to provide to you, we will advise you.

All information you provide to us is stored on our secure servers or servers hosted by third party service providers. Any payment transactions will be encrypted using SSL/TLS technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping this password confidential.

Once we have received your information, appropriate security measures will be adopted to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, you acknowledge that we cannot guarantee the security of data you send over the internet and that you send your information at your own risk.

Your information will only be held for a reasonable period or as long as the law requires or permits.

The following safeguard[s] are applied to such transfers:

We require that all of our partners sign our partnership agreement and NDA confirming that they uphold the same level of discretion and security regarding your data

Our Sites may contain links to websites that are operated by third parties. We do not control and accept no liability or responsibility for those websites and this privacy promise does not apply to those websites. Please consult the terms and conditions and privacy policies of those third party websites to find out how they collect and use your personal data.

Advertisements contained on our Sites operate as links to the advertiser’s website and as such any information they collect by virtue of your clicking on that link will be collected and used by the relevant advertiser in accordance with the privacy policy of that advertiser.

1. Do You Share My Personal Data?

We may sometimes contract with the following third parties to supply products services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.

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.

1. 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 11.

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 two weeks 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.

1. 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;

Email address: zara@spoog.com

Telephone number: +44(0)7890823527

Postal Address: Invision House Wilbury Way, Hitchin, Herts SG4 0TY

1. Changes to this Privacy Notice

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.

Any changes will be made available via Email or Post.New Paragraph

Call us: +44(0)7890823527