Spendkey Limited (“Spendkey”)respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Spendkey is the controller and responsible for your personal data (collectively referred to as “Spendkey”, “we”,“us” or “our”).
1. CONTACT DETAILS
1.1. If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: Spendkey Limited
Email address: alex@spendkey.co.uk
Postal address: Spendkey Limited,213 Kingsbury Road, Sri Abji Bapashree House, Suite 15 I Floor, London, NW9 8AQ
Telephone number: +44 07813 699 237
1.2. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues(www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance to try and resolve the issue.
2. INFORMATION THAT WE COLLECT FROM YOU
2.1. When you visit the website or make an order through the website, as part of the ordering process, you may be asked to provide information about yourself. We may also collect information about your usage of the website and information about you from the messages you post to the website and the emails or letters you may send to us. In this process we may collect, use, store and transfer different kinds of personal data about you which we have grouped as follows:
• Identity Data includes your names, username or similar identifier, and date of birth;
• Contact Data includes billing address, delivery address, email address and telephone numbers;
• Financial Data includes bank account and payment card details;
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us;
• Technical Data includes internet protocol (IP) address, 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 this website;
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses (if applicable);
• Usage Data includes information about how you use our website, products and services; and
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.2. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 policy.
2.3. We do not collect any Special Categories of Personal Data about you (including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). This website is not intended for children and we do not knowingly collect data relating to children.
3. USE OF YOUR INFORMATION
3.1.Your information will enable us to provide you with the services you have requested, to bill you and to contact you, where necessary, concerning our services. We may also use your information where we have a legal basis to do so, including where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests or where we need to comply with a legal obligation
3.2. We will also use and analyse the information we collect so that we can administer, support, improve and develop our business. We may use your information to contact you for your views on our services and to notify you occasionally about important changes or developments to the website or our services.
3.3. Where you have expressly consented, we may use your information to inform you of our products and services that may be of interest to you, including services that may be the subject of direct marketing. We may contact you to do so by email, post, telephone or mobile messaging.
3.4. Where you have expressly consented, we may also share information with third parties to use your information to let you know about goods and services which may be of interest to you (by email, post, telephone, mobile messaging).
3.5. If you do not want us to use your data in this way or change your mind about being contacted in the future, please let us know by contacting us.
3.6. By submitting comments and feedback regarding the website and the services, you consent to us using such comments and feedback on the website and in any marketing or advertising materials.
4. DISCLOSURE OF YOUR INFORMATION
4.1. The information you provide to us will be transferred to and stored on our servers in the EU, and for the purposes set out in this privacy policy may be accessed by or given to our staff working for third parties including companies within our group of companies.
4.2. The information you provide us with may need to be accessed by those third parties that process information, such as credit card payments/address details, and provide support services for us. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
4.3. If you have expressly consented, we may allow carefully selected third parties, including marketing and advertising companies, our affiliates and associates, to contact you occasionally about services that may be of interest to you. If you change your mind about being contacted by these companies in the future, please let us know by contacting us.
4.4. If our business enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors.
4.5. We may disclose your personal information if we are required by law to do so or if you violate our website’s terms and conditions.
5. SECURITY AND DATA RETENTION
We take reasonable steps and follow best industry practices to protect your information from unauthorised access and against unlawful processing, accidental loss, and destruction. However, the transmission of your information to the website remains at your own risk. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6. ACCESSING AND UPDATING
You have the right to see the information we hold about you and to ask us to make any changes to ensure that it is accurate and up to date. You may do so by submitting a request using the contact details set out in this privacy policy. We may charge a fee to meet our costs in providing you with details of the information we hold about you.
7. WITHDRAWING YOUR CONSENT
Where we rely on your consent as the legal basis for processing your personal data, you may withdraw your consent at any time. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, you can exercise this right at any later time by using the unsubscribe link on any marketing e-mail you receive, or by contacting us directly.
8. OBJECTING TO OUR USE OF YOUR PERSONAL DATA
Where we rely on our legitimate business interests as the legal basis for processing your personal data for any purpose(s), you may object to us using your personal data for these purposes by e-mailing or writing to us at the contact details provided. Except for the purposes for which we are sure we can continue to process your personal data, we will temporarily stop processing your personal data in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection law, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
9. ERASING YOUR PERSONAL DATA OR RESTRICTING ITS PROCESSING
9.1. In certain circumstances, you may ask for your personal data to be removed from our systems by e-mailing or writing to us. Provided we do not have any continuing lawful reason to continue processing or holding your personal data, we will make reasonable efforts to comply with your request.
9.2. You may also ask us to restrict processing your personal data where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. We may only process your personal data whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
9.3. Where we rely on your consent as the legal basis for processing your personal data or need to process it in connection with your contract, you may ask us to provide you with a copy of that information in a structured data file.
9.4. You can ask us to send your personal data directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal data if it contains the personal data of other individuals or we have another lawful reason to withhold that information.
9.5. We will erase your data, unless we have to keep it for legitimate business or legal purposes.
10. CHANGES TO OUR PRIVACY POLICY
We keep our privacy policy under regular review. Any changes to our privacy policy will be posted to the website and, where appropriate, through email notification. We may modify this privacy policy at any time, so ensure you review it regularly. Historic versions can be obtained by contacting us.
11. THIRD-PARTY SERVICES
11.1. Third-party providers used by us should only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. However, certain third-party service providers, such as payment gateways and processors, have their own privacy policies concerning the information we are required to provide to them for your payment transactions. Please always read their respective privacy policies and ensure you understand how they process and use your information.
11.2. Once you leave our website or are redirected to a third-party website or application, you are no longer covered by this privacy policy or our website’s terms and conditions. We do not control these third-party websites and are not responsible for their privacy practices. We encourage you to read their privacy statements.
12. COOKIES
We use cookies to enable your best user experience on our website. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible to you or not function properly.
