Privacy policy
1. Introduction
1.1 We are committed to safeguarding
the privacy of our website visitors and service users.
1.2 This policy applies where we are
acting as a data controller with respect to the personal data of our website
visitors and service users; in other words, where we determine the purposes and
means of the processing of that personal data.
1.3 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.
1.4 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 publication of your information. You can
access the privacy controls via your control panel.
1.5 In this policy, "we",
"us" and "our" refer to Spesoft Limited For more
information about us, see Section 13.
2. Credit
2.1 This document was created using a
template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set
out:
(a) the general categories of
personal data that we may process;
(b) the purposes for which we may
process personal data; and
(c) the legal bases of the
processing.
3.2 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 along with data required to allow you to use and
operate our sites and services. The source of the usage data is websites and
services operated by Spesoft Limited. This usage data may be processed for the
purposes of analysing the use of the website and services and providing you the
ability to operate and access our website and services. The legal basis for
this processing is our legitimate interests, namely monitoring and improving
our websites and services and providing you the ability to use our websites and
services.
3.3 We may process "account
data". The account data may include your name, user name and data you
have provided in order to facilitate your use of our websites and services. The
source of the account data is provided by you. The account data may be
processed for the purposes of operating our website, providing our services,
ensuring the security of our website and services, maintaining back-ups of our
databases and communicating with you. The legal basis for this processing is
our legitimate interests, namely the proper administration of our websites and
business.
3.4 We may process your information
included in your personal profile on our website ("profile data").
The profile data may include your name, address, telephone number, email
address, profile pictures, gender, date of birth, relationship status,
interests and hobbies. The profile data may be processed for the purposes of
enabling and monitoring your use of our website and services. The legal basis
for this processing is our legitimate interests, namely the proper
administration of our website and business.
3.5 We may process your personal data
that are provided in the course of the use of our services ("service
data"). The service data may include information about how you choose
to use our services. The source of the service data is you. The service data
may be processed for the purposes of operating our website, providing our
services, ensuring the security of our website and services, maintaining
back-ups of our databases and communicating with you. The legal basis for this
processing is our legitimate interests, namely the proper administration of our
website and business.
3.6 We may process information that
you post for publication on our website or through our services ("publication
data"). The publication data may be processed for the purposes of
enabling such publication and administering our website and services. The legal
basis for this processing is our legitimate interests, namely the proper
administration of our website and business.
3.7 We may process information
relating to our customer relationships, including customer contact information
("customer relationship data"). The customer relationship data
may include your name, your contact details, and information contained in
communications between us and you. The source of the customer relationship data
is you. The customer relationship data may be processed for the purposes of
managing our relationships with customers, communicating with customers,
keeping records of those communications and promoting our products and services
to customers. The legal basis for this processing is our legitimate interests,
namely the proper management of our customer relationships.
3.9 We may process information
relating to transactions, including purchases of goods and services, that you
enter into with us and/or through our website ("transaction data").
The transaction data may include your contact details, your card details and
the transaction details. The transaction data may be processed for the purpose
of supplying the purchased goods and services and keeping proper records of
those transactions. The legal basis for this processing is the performance of a
contract between you and us and/or taking steps, at your request, to enter into
such a contract and our legitimate interests, namely the proper administration
of our website and business.
3.10 We may process information that
you provide to us for the purpose of subscribing to our email notifications
and/or newsletters ("notification data"). The notification
data may be processed for the purposes of sending you the relevant
notifications and/or newsletters. The legal basis for this processing is the
performance of a contract between you and us and/or taking steps, at your
request, to enter into such a contract.
3.11 We may process information
contained in or relating to any communication that you send to us ("correspondence
data"). The correspondence 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.]
The correspondence data may be processed for the purposes of communicating with
you and record-keeping. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business and
communications with users.
3.12 We may process data based on
your configuration and use of our services This data may include
information about games, applications or software you choose to enable through
the use of our services. The source of this data is you. This data may be
processed for the purpose of providing statistics and information to you and
others. The legal basis for this processing is consent.
3.13 We may process any of your
personal data identified in this policy 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.
3.14 We may process any of your
personal data identified in this policy where necessary for the purposes of
obtaining or maintaining insurance coverage, managing risks, or obtaining
professional advice. The legal basis for this processing is our legitimate
interests, namely the proper protection of our business against risks.
3.15 In addition to the specific
purposes for which we may process your personal data set out in this Section 3,
we may also process any of 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.
3.16 Please do not supply any other
person's personal data to us, unless we prompt you to do so.
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 We may disclose your personal
data to our insurers and/or professional advisers insofar as reasonably
necessary for the purposes of obtaining or maintaining insurance coverage,
managing risks, obtaining professional advice, or the establishment, exercise
or defence of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure.
4.4 Financial transactions relating
to our website and services are handled by our payment services providers, PayPal.
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.
4.5 We may disclose your enquiry data
to one or more of those selected third party suppliers of goods and services
identified on our website for the purpose of enabling them to contact you so
that they can offer, market and sell to you relevant goods and/or services.
Each such third party will act as a data controller in relation to the enquiry
data that we supply to it; and upon contacting you, each such third party will
supply to you a copy of its own privacy policy, which will govern that third
party's use of your personal data.
4.6 In addition to the specific
disclosures of personal data set out in this Section 4, 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. International transfers of
your personal data
5.1 In this Section 5, we provide
information about the circumstances in which your personal data may be
transferred to countries outside the European Economic Area (EEA).
5.3 The hosting facilities for our
website are situated in the Netherlands.
5.5 You acknowledge that personal
data that you submit for publication through our website or services may be
available, via the internet, around the world. We cannot prevent the use (or
misuse) of such personal data by others.
6. Retaining and deleting
personal data
6.1 This Section 6 sets out our data
retention policies and procedure, which are designed to help ensure that we
comply with our legal obligations in relation to the retention and deletion of
personal data.
6.2 Personal data that we process for
any purpose or purposes shall not be kept for longer than is necessary for that
purpose or those purposes.
6.5 Notwithstanding the other
provisions of this Section 6, we may retain your personal data where such
retention 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.
7. Amendments
7.1 We may update this policy from
time to time by publishing a new version on our website.
7.2 You should check this page
occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of changes to
this policy [by email or through the private messaging system on our website.
8. Your rights
8.1 In this Section 8, we have
summarised the rights that you have under data protection law. Some of the
rights are complex, and not all of the details have been included in our
summaries. Accordingly, you should read the relevant laws and guidance from the
regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data
protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to
processing;
(f) the right to data portability;
(g) the right to complain to a
supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to
confirmation as to whether or not we process your personal data and, where we
do, access to the personal data, together with certain additional information.
That additional information includes details of the purposes of the processing,
the categories of personal data concerned and the recipients of the personal
data. Providing the rights and freedoms of others are not affected, we will
supply to you a copy of your personal data. The first copy will be provided
free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any
inaccurate personal data about you rectified and, taking into account the
purposes of the processing, to have any incomplete personal data about you
completed.
8.5 In some circumstances you have
the right to the erasure of your personal data without undue delay. Those
circumstances include: the personal data are no longer necessary in relation to
the purposes for which they were collected or otherwise processed; you withdraw
consent to consent-based processing; you object to the processing under certain
rules of applicable data protection law; the processing is for direct marketing
purposes; and the personal data have been unlawfully processed. However, there
are exclusions of the right to erasure. The general exclusions include where
processing is necessary: for exercising the right of freedom of expression and
information; for compliance with a legal obligation; or for the establishment,
exercise or defence of legal claims.
8.6 In some circumstances you have
the right to restrict the processing of your personal data. Those circumstances
are: you contest the accuracy of the personal data; processing is unlawful but
you oppose erasure; we no longer need the personal data for the purposes of our
processing, but you require personal data for the establishment, exercise or
defence of legal claims; and you have objected to processing, pending the
verification of that objection. Where processing has been restricted on this
basis, we may continue to store your personal data. However, we will only
otherwise process it: with your consent; for the establishment, exercise or
defence of legal claims; for the protection of the rights of another natural or
legal person; or for reasons of important public interest.
8.7 You have the right to object to
our processing of your personal data on grounds relating to your particular
situation, but only to the extent that the legal basis for the processing is
that the processing is necessary for: the performance of a task carried out in
the public interest or in the exercise of any official authority vested in us;
or the purposes of the legitimate interests pursued by us or by a third party.
If you make such an objection, we will cease to process the personal
information unless we can demonstrate compelling legitimate grounds for the
processing which override your interests, rights and freedoms, or the
processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to
our processing of your personal data for direct marketing purposes (including
profiling for direct marketing purposes). If you make such an objection, we
will cease to process your personal data for this purpose.
8.9 You have the right to object to
our processing of your personal data for scientific or historical research
purposes or statistical purposes on grounds relating to your particular
situation, unless the processing is necessary for the performance of a task
carried out for reasons of public interest.
8.10 To the extent that the legal basis
for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary
for the performance of a contract to which you are party or in order to take
steps at your request prior to entering into a contract,
and such processing is carried
out by automated means, you have the right to receive your personal data from
us in a structured, commonly used and machine-readable format. However, this
right does not apply where it would adversely affect the rights and freedoms of
others.
8.11 If you consider that our
processing of your personal information infringes data protection laws, you
have a legal right to lodge a complaint with a supervisory authority
responsible for data protection. You may do so in the EU member state of your
habitual residence, your place of work or the place of the alleged
infringement.
8.12 To the extent that the legal basis
for our processing of your personal information is consent, you have the right
to withdraw that consent at any time. Withdrawal will not affect the lawfulness
of processing before the withdrawal.
8.13 You may exercise any of your
rights in relation to your personal data by written notice to us, in addition
to the other methods specified in this Section 8.
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 do not typically contain
any information that personally identifies a user, but personal information
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 - we use cookies to
identify you when you visit our website and as you navigate our website.
(b) status - we use cookies to help
us to determine if you are logged into our website.
(c) personalisation - we use cookies to
store information about your preferences and to personalise the website for you.
(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.
(e) advertising - we use cookies to
help us to display advertisements that will be relevant to you.
(f) analysis - we use cookies to help
us to analyse the use and performance of our website and services.
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.
11.3 We publish Google AdSense
interest-based advertisements on our website. These are tailored by Google to
reflect your interests. To determine your interests, Google will track your
behaviour on our website and on other websites across the web using cookies.]
OR [We publish Google AdSense advertisements on our website. To determine your
interests, Google will track your behaviour on our website and on other
websites across the web using cookies. This behaviour tracking allows Google to
tailor the advertisements that you see on other websites to reflect your
interests (but we do not publish interest-based advertisements on our website.
You can view, delete or add interest categories associated with your browser by
visiting: https://adssettings.google.com.
You can also opt out of the AdSense partner network cookie using those settings
or using the Network Advertising Initiative's multi-cookie opt-out mechanism
at: http://optout.networkadvertising.org.
However, these opt-out mechanisms themselves use cookies, and if you clear the
cookies from your browser your opt-out will not be maintained. To ensure that
an opt-out is maintained in respect of a particular browser, you may wish to
consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.
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?hl=en
(Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/
(Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);
(e) https://support.apple.com/kb/PH21411
(Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-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. Our details
13.1 This website is owned and operated
by Spesoft Limited.
13.2 We are registered in England and
Wales under registration number 05598529.
13.4 You can contact us:
(b) using our website contact form.
(d) by email, using the email address
published on our website from time to time.