Introduction
Thisprivacy notice provides you with details of how we collect and process yourpersonal data through your use of our site https://spear-sales-consulting.webflow.io
By providing us withyour data, you warrant to us that you are over 13 years of age.
Spear Sales is the datacontroller and we are responsible for your personal data (referred to as “we”,“us” or “our” in this privacy notice).
Contact Details
Our full details are:
Full name of legal entity: Spear Sales Limited
Email address: alex@spear-sales.com
Postal address: Bay Tree House, Chapel Lane, Pirbright GU24 0JZ
It isvery important that the information we hold about you is accurate and up todate. Please let us know if at any time your personal information changes by emailingus at alex@spear-sales.com.
What data do we collect about you, forwhat purpose and on what grounds do we process it?
Personaldata means any information capable of identifying an individual. It does notinclude anonymised data.
We mayprocess the following categories of personal data about you:
CommunicationData that includes any communication that you send to uswhether that be through the contact form on our website, through email, text,social media messaging, social media posting or any other communication thatyou send us. We process this data for the purposes of communicating with you,for record keeping and for the establishment, pursuance or defence of legalclaims. Our lawful ground for this processing is our legitimate interests,which in this case are to reply to communications sent to us, to keep recordsand to establish, pursue or defend legal claims.
CustomerData that includes data relating to any purchases of goodsand/or services such as your name, title, billing address, delivery addressemail address, phone number, contact details, purchase details and your carddetails. We process this data to supply the goods and/or services you havepurchased and to keep records of such transactions. Our lawful ground for thisprocessing is the performance of a contract between you and us and/or takingsteps at your request to enter into such a contract.
UserData that includes data about how you use our website andany online services together with any data that you post for publication on ourwebsite or through other online services. We process this data to operate ourwebsite and ensure relevant content is provided to you, to ensure the securityof our website, to maintain back- ups of our website and/or databases and toenable publication and administration of our website, other online services andbusiness. Our lawful ground for this processing is our legitimate interestswhich in this case are to enable us to properly administer our website and ourbusiness.
TechnicalData that includes data about your use of our website andonline services such as your IP address, your login data, details about yourbrowser, length of visit to pages on our website, page views and navigationpaths, details about the number of times you use our website, time zonesettings and other technology on the devices you use to access our website. Thesource of this data is from our analytics tracking system. We process this datato analyse your use of our website and other online services, to administer andprotect our business and website, to deliver relevant website content andadvertisements to you and to understand the effectiveness of our advertising.Our lawful ground for this processing is our legitimate interests which in thiscase are to enable us to properly administer our website and our business andto grow our business and to decide our marketing strategy.
MarketingData that includes data about your preferences inreceiving marketing from us and our third parties and your communication preferences.We process this data to enable you to partake in our promotions such ascompetitions, prize draws and free give-aways, to deliver relevant websitecontent and advertisements to you and measure or understand the effectivenessof this advertising. Our lawful ground for this processing is our legitimateinterests which in this case are to study how customers use ourproducts/services, to develop them, to grow our business and to decide ourmarketing strategy.
We mayuse Customer Data, User Data, Technical Data and MarketingData to deliver relevant website content and advertisements to you(including Facebook adverts or other display advertisements) and to measure orunderstand the effectiveness of the advertising we serve you. Our lawful groundfor this processing is legitimate interests which is to grow our business. Wemay also use such data to send other marketing communications to you. Ourlawful ground for this processing is either consent or legitimate interests(namely to grow our business).
SensitiveData
We do not collect any Sensitive Data about you. Sensitivedata refers to data that includes details about your race or ethnicity,religious or philosophical beliefs, sex life, sexual orientation, politicalopinions, trade union membership, information about your health and genetic andbiometric data. We do not collect any information about criminal convictionsand offences.
Where we are required to collect personal data by law, or under the terms ofthe contract between us and you do not provide us with that data whenrequested, we may not be able to perform the contract (for example, to delivergoods or services to you). If you don’t provide us with the requested data, wemay have to cancel a product or service you have ordered but if we do, we willnotify you at the time.
We will only use your personal data for a purpose it was collected for or areasonably compatible purpose if necessary. For more information on this pleaseemail us at alex@spear-sales.com. In case we need to use your details foran unrelated new purpose we will let you know and explain the legal grounds forprocessing.
We may process your personal data without your knowledge or consent where thisis required or permitted by law.
We do not carry out automated decision making or any type of automatedprofiling.
We may collect data about you by you providing the data directly to us (forexample by filling in forms on our site or by sending us emails). We mayautomatically collect certain data from you as you use our website by usingcookies and similar technologies. Please see our cookie policy for more detailsabout this alex@spear-sales.com
We mayreceive data from third parties such as analytics providers such as Googlebased outside the EU, advertising networks such as Facebook based outside theEU, such as search information providers such as Google based outside the EU,providers of technical, payment and delivery services, such as data brokers oraggregators.
We may also receive data from publicly availably sources such as CompaniesHouse and the Electoral Register based inside the EU.
Marketing Communications
Ourlawful ground of processing your personal data to send you marketingcommunications is either your consent or our legitimate interests (namely togrow our business).
Under the Privacy andElectronic Communications Regulations, we may send you marketing communicationsfrom us if (i) you made a purchase or asked for information from us about ourgoods or services or (ii) you agreed to receive marketing communications and ineach case you have not opted out of receiving such communications since. Underthese regulations, if you are a limited company, we may send you marketingemails without your consent. However you can still opt out of receivingmarketing emails from us at any time.
Before we share yourpersonal data with any third party for their own marketing purposes we will getyour express consent.
You can ask us or thirdparties to stop sending you marketing messages at any time by following theopt-out links on any marketing message sent to you OR by emailing us at alex@spear-sales.comat any time.
If youopt out of receiving marketing communications this opt-out does not apply topersonal data provided as a result of other transactions, such as purchases,warranty registrations etc.
Disclosures of your Personal Data
We mayhave to share your personal data with the parties set out below:
Service providers whoprovide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers
Government bodies that require us to report processing activities
Third parties to whom we sell, transfer, or merge parts of our business or ourassets.
Werequire all third parties to whom we transfer your data to respect the securityof your personal data and to treat it in accordance with the law. We only allowsuch third parties to process your personal data for specified purposes and in accordancewith our instructions.
International Transfers
Countriesoutside of the European Economic Area (EEA) do not always offer the samelevels of protection to your personal data, so European law has prohibitedtransfers of personal data outside of the EEA unless the transfer meets certaincriteria.
Many of our thirdparties service providers are based outside the European Economic Area (EEA)so their processing of your personal data will involve a transfer of dataoutside the EEA.
Whenever we transferyour personal data out of the EEA, we do our best to ensure a similar degree ofsecurity of data by ensuring at least one of the following safeguards is inplace:
We will only transferyour personal data to countries that the European Commission have approved asproviding an adequate level of protection for personal data by; or
Wherewe use certain service providers, we may use specific contracts or codes ofconduct or certification mechanisms approved by the European Commission whichgive personal data the same protection it has in Europe; or
If we use US-based providers that are part of EU-US Privacy Shield, we maytransfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicitconsent to the specific transfer. You will have the right to withdraw thisconsent at any time.
Data Security
Wehave put in place security measures to prevent your personal data from beingaccidentally lost, used, altered, disclosed, or accessed without authorisation.We also allow access to your personal data only to those employees and partnerswho have a business need to know such data. They will only process yourpersonal data on our instructions and they must keep it confidential.
Wehave procedures in place to deal with any suspected personal data breach andwill notify you and any applicable regulator of a breach if we are legallyrequired to.
Data Retention
Wewill only retain your personal data for as long as necessary to fulfil thepurposes we collected it for, including for the purposes of satisfying anylegal, accounting, or reporting requirements.
When deciding what thecorrect time is to keep the data for we look at its amount, nature andsensitivity, potential risk of harm from unauthorised use or disclosure, theprocessing purposes, if these can be achieved by other means and legalrequirements.
For tax purposes the lawrequires us to keep basic information about our customers (including Contact,Identity, Financial and Transaction Data) for six years after they stop beingcustomers.
Insome circumstances we may anonymise your personal data for research orstatistical purposes in which case we may use this information indefinitelywithout further notice to you.
Your Legal Rights
Underdata protection laws you have rights in relation to your personal data thatinclude the right to request access, correction, erasure, restriction,transfer, to object to processing, to portability of data and (where the lawfulground of processing is consent) to withdraw consent.
You can see more aboutthese rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exerciseany of the rights set out above, please email us at alex@spear-sales.com
You will not have to paya fee to access your personal data (or to exercise any of the other rights).However, we may charge a reasonable fee if your request is clearly unfounded,repetitive or excessive or refuse to comply with your request in these circumstances.
We may need to requestspecific information from you to help us confirm your identity and ensure yourright to access your personal data (or to exercise any of your other rights).This is a security measure to ensure that personal data is not disclosed to anyperson who has no right to receive it. We may also contact you to ask you forfurther information in relation to your request to speed up our response.
We try to respond to alllegitimate requests within one month. Occasionally it may take us longer than amonth if your request is particularly complex or you have made a number ofrequests. In this case, we will notify you.
If youare not happy with any aspect of how we collect and use your data, you have theright to complain to the Information Commissioner’s Office (ICO), the UKsupervisory authority for data protection issues (www.ico.org.uk). We should begrateful if you would contact us first if you do have a complaint so that wecan try to resolve it for you.
Third-party Links
Thiswebsite may include links to third-party websites, plug-ins and applications.Clicking on those links or enabling those connections may allow third partiesto collect or share data about you. We do not control these third-partywebsites and are not responsible for their privacy statements. When you leaveour website, we encourage you to read the privacy notice of every website youvisit.
Cookies
Youcan set your browser to refuse all or some browser cookies, or to alert youwhen websites set or access cookies. If you disable or refuse cookies, pleasenote that some parts of this website may become inaccessible or not functionproperly.
What is a Cookie?
A "cookie" is a piece ofinformation that is stored on your computer's hard drive and which records howyou move your way around a website so that, when you revisit that website, itcan present tailored options based on the information stored about your lastvisit. Cookies can also be used to analyse traffic and for advertising andmarketing purposes.
Cookies are used by nearly all websites and do not harm your system.
If you want to check or change what types of cookies you accept, this canusually be altered within your browser settings. You can block cookies at anytime by activating the setting on your browser that allows you to refuse thesetting of all or some cookies. However, if you use your browser settings toblock all cookies (including essential cookies) you may not be able to accessall or parts of our site.
How do we use Cookies?
We use cookies to track your use ofour website. This enables us to understand how you use the site and track anypatterns with regards how you are using our website. This helps us to developand improve our website as well as products and / or services in response towhat you might need or want.
Cookies are either:
Session cookies: these are only stored on your computer during your web session andare automatically deleted when you close your browser – they usually store ananonymous session ID allowing you to browse a website without having to log into each page but they do not collect any personal data from your computer; or
Persistent cookies: a persistent cookie is stored as a file on your computer and itremains there when you close your web browser. The cookie can be read by thewebsite that created it when you visit that website again. We use persistentcookies for Google Analytics.
Cookies can also be categorised as follows:
Strictly necessary cookies: These cookies are essential to enable you to use thewebsite effectively, such as when buying a product and / or service, andtherefore cannot be turned off. Without these cookies, the services availableto you on our website cannot be provided. These cookies do not gatherinformation about you that could be used for marketing or remembering where youhave been on the internet.
Performance cookies: These cookies enable us to monitor and improve the performance ofour website. For example, they allow us to count visits, identify trafficsources and see which parts of the site are most popular.
Functionality cookies: These cookies allow our websiteto remember choices you make and provide enhanced features. For instance, wemay be able to provide you with news or updates relevant to the services youuse. They may also be used to provide services you have requested such asviewing a video or commenting on a blog. The information these cookies collectis usually anonymised.
