Privacy Policy Last update 28/04/2024

This privacy notice for Cross Marketing, S.L (“we”, “our” or “us”), describes how and why we might collect, store, use and/or share (‘process’) your information when you use our services (‘Services’), such as when you:

• Visit our website at https://spinsavvy.co.uk/, or any website of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. See 1. What Information Do We Collect?

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more under: How we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Lear more under: When and with whom we share your personal information.

How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. Learn more under: How we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more under: about your privacy rights.

How do you exercise your rights? Contact us and we will consider and act upon any request in accordance with applicable data protection laws.

What Information Do We Collect?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you express and interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Sensitive information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operations system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).

Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tell us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

What Legal Bases Do We Rely On To Process Your Information?

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interest. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

When And With Whom Do We Share Your Personal Information?

We may share your data with 3rd party vendors, service providers, contractors, or agents (‘third parties’) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

When we use google analytics. We may share your information with Google Analytics to track and analyse the use of Services. 

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merge, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

How Long Do We Keep Your Information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in back up archives), then we will securely store your personal information and isolated it from any further processing until deletion is possible.

How Do We Keep Your Information Safe?

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However despite our safeguards and efforts to secure your information, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Do We Collect Information From Minors?

The Site or the Services are not designed to attract children under the age of 18. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 18. If we learn that we have collected Personal Information from a child under 18, we will use commercially reasonable efforts to delete that information as quickly as possible. If you believe that we might have any such information, please contact us at contact@spinsavvy.co.uk

Contact Us. We try to make this Privacy Policy simple and easy to understand. However, if you have any question you may contact us at: contact@spinsavvy.co.uk