Spiresindependent.co.uk ('Website') is provided by Spires Independent Ltd ('we'/'us'/'our'). In doing so, we
may be in a position to receive and process personal information relating to you. As the controller of this
information, we're providing this Privacy Notice ('Notice') to explain our approach to personal information.
This Notice forms part of our Terms and conditions, which governs the use of this Website.
We intend only to process personal information fairly and transparently as required by data protection law
including the General Data Protection Regulation (GDPR). In particular, before obtaining information from
you we intend to alert you to this Notice, let you know how we intend to process the information and (unless
processing is necessary for at least one of the 5 reasons outlined in clause 2 below) we'll only process the
information if you consent to that processing. The GDPR also defines certain 'special categories' of personal
information that's considered more sensitive. These categories require a higher level of protection, as
Of course, you may browse parts of this Website without providing any information about yourself and
without accepting cookies. In that case, it's unlikely we'll possess and process any information relating to
We'll start this Notice by setting out the conditions we must satisfy before processing your data. However,
you may wish to skip to clause 4, which summarises what we intend to collect. The Notice also explains
some of the security measures we take to protect your personal information and tells you certain things we
will or won't do. You should read this Notice in conjunction with the Terms and conditions.
Sometimes, when you take a new service or product from us, or discuss taking a new service or product but
decide against, we might wish to provide you with further information about similar services or products by
email or other written electronic communication. In that situation, we will always give you the opportunity to
refuse to receive that further information and if you change your mind please let us know. We'll endeavour to
remind you of your right to opt-out on each occasion that we provide such information.
1 Identity and contact details
1.1 Registered number: 7872142
1.2 Registered office: 33 Market Street, Lichfield, Staffordshire, WS13 6LA
2 When we're allowed to collect information from you
We will only collect personal information relating to you if one of the following conditions have been
2.1 You have clearly told us that you are content for us to collect that information for the certain
purpose or purposes that we will have specified.
2.2 The processing is necessary for the performance a contract that we have with you.
2.3 The processing is necessary so that we can comply with the law.
2.4 The processing is necessary to protect someone's life.
2.5 The processing is necessary for performance of a task that's in the public interest.
2.6 The processing is necessary for our or another's legitimate interest - but in this case, we'll balance
those interests against your interests.
3 How to consent
3.1 At the point of collecting the information, we'll endeavour to explain how we intend to use the
information and which of these purposes apply. If we rely on consent, we'll provide you with the
opportunity to tell us that you're happy to provide the information.
3.2 If at any point in time you change your mind and decide that you don't consent, please let us know
and we'll endeavour to stop processing your information in the specified manner, or we'll delete
your data if there is no continuing reason for possessing it.
3.3 If you don't consent to a particular bit of processing, we'll endeavour to ensure that the Website
and our service continue to operate without the need for that information.
4 Information we expect to collect from you
4.1 We envisage asking for the following types of information from you:
- Purpose and related details
- Email address
- Contact Number
We ask for this to enable us to respond to a request you may make in the ''contact us ''section on our website
It's necessary for the performance of a contract with you.
4.2 we may collect personal information about you from a number of sources, including the following:
4.2.1 from you when you agree to take a service or product from us, in which case this may include your contact details, date of birth, how you will pay for the product or service and your bank details.
4.2.2 from you when you contact us with an enquiry or in response to a communication from us, in which case, this may tell us something about how you use our services.
4.2.3 From documents that are available to the public, such as the electoral register.
4.2.4 From third parties to whom you have provided information with your consent to pass it
on to other organisations or persons - when we receive such information we will let you
know as soon as is reasonably practicable.
4.3 If you refuse to provide information requested, then if that information is necessary for a service
we provide to you we may need to stop providing that service.
4.4 At the time of collecting information, by whichever method is used, we'll endeavour to alert you
and inform you about our purposes and legal basis for processing that information, as well as
whether we intend to share the information with anyone else or send it outside of the European
Economic Area. If at any point you think we've invited you to provide information without
explaining why, feel free to object and ask for our reasons.
5 Using your personal information
5.1 Data protection, privacy and security are important to us, and we shall only use your personal
information for specified purposes and shall not keep such personal information longer than is
necessary to fulfil these purposes. The following are examples of such purposes. We have also
indicated below which GDPR justification applies, however it will depend on the circumstances of
each case. At the time of collecting we will provide further information, and you may always ask for
further information from us.
5.1.1 To help us to identify you when you contact us. This will normally be necessary for the
performance our contract.
5.1.2 To help us to identify accounts, services and/or products which you could have from us
or selected partners from time to time. We may do this by automatic means using a
scoring system, which uses the personal information you've provided and/or any
information we hold about you and personal information from third party agencies
(including credit reference agencies). We will only use your information for this purpose
if you agree to it.
5.1.3 To help us to administer and to contact you about improved administration of any
accounts, services and products we have provided before, do provide now or will or
may provide in the future. This will often be necessary, but sometimes the
improvements will not be necessary in which case we will ask whether you agree.
5.1.4 To allow us to carry out marketing analysis and customer profiling (including with
transactional information), conduct research, including creating statistical and testing
information. This will sometimes require that you consent, but will sometimes be exempt
as market research.
5.1.5 To help to prevent and detect fraud or loss. This will only be done in certain
circumstances when we consider it necessary or the law requires it.
5.1.6 To allow us to contact you by written electronic means (such as email, text or
multimedia messages) about products and services offered by us where:
184.108.40.206 these products are similar to those you have already purchased from us,
220.127.116.11 you were given the opportunity to opt out of being contacted by us at the
time your personal information was originally collected by us and at the
time of our subsequent communications with you, and
18.104.22.168 you have not opted out of us contacting you.
5.1.7 To allow us to contact you in any way (including mail, email, telephone, visit, text or
multimedia messages) about products and services offered by us and selected partners
where you have expressly consented to us doing so.
5.1.8 We may monitor and record communications with you (including phone conversations
and emails) for quality assurance and compliance.
22.214.171.124 Before doing that, we will always tell you of our intentions and of the
specific purpose in making the recording. Sometimes such recordings will
be necessary to comply with the law. Alternatively, sometimes the recording
will be necessary for our legitimate interest, but in that case we'll only
record the call if our interest outweighs yours. This will depend on all the
circumstances, in particular the importance of the information and whether
we can obtain the information another way that's less intrusive.
126.96.36.199 If we think the recording would be useful for us but that it's not necessary
we'll ask whether you consent to the recording, and will provide an option
for you to tell us that you consent. In those situations, if you don't consent,
the call will either automatically end or will not be recorded.
5.1.9 When it's required by law, we'll check your details with fraud prevention agencies. If you
provide false or inaccurate information and we suspect fraud, we intend to record this.
5.2 We will not disclose your personal information to any third party except in accordance with this
Notice, and in particular in these circumstances:
5.2.1 They will be processing the data on our behalf as a data processor (where we'll be the
data controller). In that situation, we'll always have a contract with the data processor as
set out in the GDPR. This contract provides significant restrictions as to how the data
processor operates so that you can be confident your data is protected to the same
degree as provided in this Notice.
5.2.2 Sometimes it might be necessary to share data with another data controller. Before
doing that we'll always tell you. Note that if we receive information about you from a
third party, then as soon as reasonably practicable afterwards we'll let you know; that's
required by the GDPR.
5.2.3 Alternatively, sometimes we might consider it to be in your interest to send your
information to a third party. If that's the case, we'll always ask whether you agree before
5.3 Where you give us personal information on behalf of someone else, you confirm that you have
provided them with the information set out in this Notice and that they have not objected to such
use of their personal information.
5.4 We may allow other people and organisations to use personal information we hold about you in
the following circumstances:
5.4.1 If we, or substantially all of our assets, are acquired or are in the process of being
acquired by a third party, in which case personal information held by us, about our
customers, will be one of the transferred assets.
5.4.2 If we have been legitimately asked to provide information for legal or regulatory
purposes or as part of legal proceedings or prospective legal proceedings.
5.4.3 We may employ companies and individuals to perform functions on our behalf and we
may disclose your personal information to these parties for the purposes set out above,
for example, for fulfilling orders, delivering packages, sending postal mail and email,
removing repetitive information from customer lists, analysing data, providing marketing
assistance, providing search results and links (including paid listings and links) and
providing customer service. Those parties will be bound by strict contractual provisions
with us and will only have access to personal information needed to perform their
functions, and they may not use it for any other purpose. Further, they must process the
personal information in accordance with this Notice and as permitted by the GDPR.
From time to time, these other people and organisations to whom we may pass your
personal information may be outside the European Economic Area. We will take all
steps reasonably necessary to ensure that your personal information is treated securely
and in accordance with this Notice and the GDPR.
6 Protecting information
6.1 We have strict security measures to protect personal information.
6.2 We work to protect the security of your information during transmission by using appropriate
technology to encrypt information you input.
6.3 We reveal only the last five digits of your credit card numbers when confirming an order. Of
course, we transmit the entire credit card number to the appropriate credit card company during
6.4 We maintain physical, electronic and procedural safeguards in connection with the collection,
storage and disclosure of personally identifiable customer information. Our security procedures
mean that we may occasionally request proof of identity before we disclose personal information
6.5 It is important for you to protect against unauthorised access to your password and to your
computer. Be sure to sign off when you finish using a shared computer
7 The internet
7.1 If you communicate with us using the internet, we may occasionally email you about our services
and products. When you first give us personal information through the Website, we will normally
give you the opportunity to say whether you would prefer that we don't contact you by email. You
can also always send us an email (at the address set out below) at any time if you change your
7.2 Please remember that communications over the internet, such as emails and webmails
(messages sent through a website), are not secure unless they have been encrypted. Your
communications may go through a number of countries before they are delivered - this is the
nature of the internet. We cannot accept responsibility for any unauthorised access or loss of
personal information that is beyond our control.
8 Further information
8.1 If you would like any more information or you have any comments about this Notice, please either
write to us at Data Protection Manager, Spires Independent Ltd, 33 Market Street, Lichfield,
8.2 Please note that we may have to amend this Notice on occasion, for example if we change the
cookies that we use. If we do that, we will publish the amended version on the Website. In that
situation we will endeavour to alert you to the change, but it's also your responsibility to check
regularly to determine whether this Notice has changed.
8.3 You can ask us for a copy of this Notice by writing to the above address or by emailing us at
individuals. It does not apply to information we hold about companies and other organisations.
8.4 If you would like access to the personal information that we hold about you, you can do this by
not normally a fee for such a request, however if the request is unfounded, repetitive or excessive
we may request a fee or refuse to comply with your request. You can also ask us to send the
personal information we hold about you to another controller.
8.5 We aim to keep the personal information we hold about you accurate and up to date. If you tell us
that we're holding any inaccurate or incomplete personal information about you, we will promptly
write to us at the address above to update your personal information. You have the right to
complain to the Information Commissioner's Office if we don't do this.
8.6 You can ask us to delete the personal information that we hold about you if we relied on your
consent in holding that information or if it's no longer necessary. You can also restrict or object to
our processing of your personal information in certain circumstances. You can do this by emailing
8.7 We will tell you if there is a breach, or a likely breach, of your data protection rights.
Privacy notice about necessary information
We have asked for personal information from you. This information is necessary for one of the reasons
specified in the General Data Protection Regulation.
For more information, please read our full privacy notice at www.spiresindependent.co.uk/privacy
If you have any concerns, please contact us using the details provided in our privacy notice.