Legal

 
 

 

SP3 London Cookie Policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

  • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

  • Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Name Cookie From Duration Purpose/Information
ss_cid SquareSpace 2 Years Identifies unique visitors and tracks a visitor's sessions on a site.
ss_cookieAllowed SquareSpace 30 Days Remembers if a visitor agreed to placing Analytics cookies on their browser if a site is restricting the placement of cookies.
ss_cpvisit SquareSpace 2 Years Identifies unique visitors and tracks a visitors sessions on a site.
ss_cvisit SquareSpace 30 minutes Identifies unique visitors and tracks a visitor's sessions on a site.
ss_cvr SquareSpace 2 Years Identifies unique visitors and tracks a visitor's sessions on a site.
ss_cvt SquareSpace 30 Minutes Identifies unique visitors and tracks a visitor's sessions on a site.
_ga Google Analytics 2 Years Used to distinguish users.
_gid Google Analytics 24 Hours Used to distinguish users.
_gat Google Analytics 1 Minute Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>.
AMP_TOKEN Google Analytics 30 Seconds to 1 Year Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, inflight request or an error retrieving a Client ID from AMP Client ID service.
_gac_<property-id> Google Analytics 90 Days Contains campaign related information for the user. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out. Learn more.
_hjClosedSurveyInvites Hotjar 365 days Hotjar cookie that is set once a visitor interacts with an External Link Survey invitation modal. It is used to ensure that the same invite does not reappear if it has already been shown.
_hjDonePolls Hotjar 365 days Hotjar cookie that is set once a visitor completes a survey using the On-site Survey widget. It is used to ensure that the same survey does not reappear if it has already been filled in.
_hjMinimizedPolls Hotjar 365 days Hotjar cookie that is set once a visitor minimizes an On-site Survey widget. It is used to ensure that the widget stays minimized when the visitor navigates through your site.
_hjShownFeedbackMessage Hotjar 365 days Hotjar cookie that is set when a visitor minimizes or completes Incoming Feedback. This is done so that the Incoming Feedback will load as minimized immediately if the visitor navigates to another page where it is set to show.
_hjid Hotjar 365 days Hotjar cookie that is set when the customer first lands on a page with the Hotjar script. It is used to persist the Hotjar User ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID.
_hjRecordingLastActivity Hotjar Session This should be found in Session storage (as opposed to cookies). This gets updated when a visitor recording starts and when data is sent through the WebSocket (the visitor performs an action that Hotjar records).
_hjTLDTest Hotjar Session When the Hotjar script executes we try to determine the most generic cookie path we should use, instead of the page hostname. This is done so that cookies can be shared across subdomains (where applicable). To determine this, we try to store the _hjTLDTest cookie for different URL substring alternatives until it fails. After this check, the cookie is removed.
_hjUserAttributesHash Hotjar Session User Attributes sent through the Hotjar Identify API are cached for the duration of the session in order to know when an attribute has changed and needs to be updated.
_hjCachedUserAttributes Hotjar Session This cookie stores User Attributes which are sent through the Hotjar Identify API, whenever the user is not in the sample. These attributes will only be saved if the user interacts with a Hotjar Feedback tool.
_hjLocalStorageTest Hotjar Under 100ms This cookie is used to check if the Hotjar Tracking Script can use local storage. If it can, a value of 1 is set in this cookie. The data stored in_hjLocalStorageTest has no expiration time, but it is deleted almost immediately after it is created.
_hjIncludedInPageviewSample Hotjar 30 minutes This cookie is set to let Hotjar know whether that visitor is included in the data sampling defined by your site's pageview limit.
_hjIncludedInSessionSample Hotjar 30 minutes This cookie is set to let Hotjar know whether that visitor is included in the data sampling defined by your site's daily session limit.
_hjAbsoluteSessionInProgress Hotjar 30 Minutes This cookie is used to detect the first pageview session of a user. This is a True/False flag set by the cookie.
_hjFirstSeen Hotjar Session This is set to identify a new user's first session. It stores a true/false value, indicating whether this was the first time Hotjar saw this user. It is used by Recording filters to identify new user sessions.
hjViewportId Hotjar Session This stores information about the user viewport such as size and dimensions.
_hjRecordingEnabled Hotjar Session This is added when a Recording starts and is read when the recording module is initialized to see if the user is already in a recording in a particular session.

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third-party cookies are likely to be analytical cookies or performance cookies or targeting cookies:

  • SquareSpace

  • Google Analytics

  • Hotjar

SP3 London Privacy Policy

Introduction

SP3 London Limited (company number 10572722) (“the Company”) 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, including 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.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1) Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how the Company collects and processes your personal data.

Our website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about

you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

The Company is the controller and responsible for your personal data (collectively referred to as “the Company”, "we", "us" or "our" in this privacy policy).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager, Shona Patel, in the following ways:

Full name of legal entity: SP3 London Limited (company number 10572722)

Email address: Shona@SP3london.com

Postal address: 9 Mansfield St, Marylebone, London W1G 9NY

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2) The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

·        Identity Data includes first name, maiden name, last name, username or similar identifier, marital   status, title, date of birth and gender.

 

·        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 (when using our website) internet protocol (IP) address, your 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 our website.

 

·        Profile Data includes your username and password, purchases or orders made by you, your           interests, preferences, feedback and survey responses. 

 

·        Usage Data includes information about how you use our website, products and services.

 

·        Marketing and Communications Data includes your preferences in receiving marketing from         us and our third parties and your communication preferences.

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.

We may occasionally collect Special Categories of Personal Data about you (this includes 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), as well as information about criminal convictions and offences. We will not collect any Special Categories of Personal Data about you or information about criminal convictions and offences through our website.

 

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3) How is your personal data collected?

We use different methods to collect data from and about you including through:

·        Direct interactions. You may provide us with any of the forms of personal data (as referred to in    paragraph 2, above) via our website, or by email, post, telephone (including by text), in writing or          in person, in relation to or in the course of:

·     enquiring about our products or services;

·     creating an account on our website;

·     requesting marketing to be sent to you;

·     the provision of any goods or services by us;

·     or as a result of any contract entered into between us;

·     gathering information about you for compliance purposes; or

·     giving us feedback or contacting us.

·        Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

·        Third parties or publicly available sources. We will receive personal data about you from various            third parties and public sources as set out below:   

Technical Data from the following parties:

(a)        analytics providers such as Google, some of which may be based outside the UK;

(b)        advertising networks, some of which may be based outside the UK; and

(c)        search information providers, some of which may be based outside the UK.

·     Contact, Financial and Transaction Data from providers of technical, payment and delivery services, some of which may be based outside the UK.

·     Identity and Contact Data from data brokers or aggregators, some of which may be based outside the UK.

·     Identity and Contact Data from publicly available sources, such as Companies House and the Electoral Register based inside the UK.

4) How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

·        Where we need to perform the contract we are about to enter into or have entered into with you.

·        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.

·        Where we need to comply with a legal obligation.

 

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity
(b) Contact		 Performance of a contract with you
To provide you with any goods or services including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us		 (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include notifying you about changes to our terms or privacy policy (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our goods or services)
To enable you to complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our goods or services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical		 (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical		 Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, goods or services, marketing, customer relationships and experiences (a) Technical
(b) Usage		 Necessary for our legitimate interests (to define types of customers for our goods and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications		 Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

 

Opting out

 

You can ask us or third parties to stop sending you marketing messages by contacting us at any time.

 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of entering into a contract with us or other transactions

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5) Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4, above, with.

·        External Third Parties as set out in the Glossary.

·        Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.            Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to        our business, then the new owners may use your personal data in the same way as set out in this    privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6) International transfers

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

·        We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data

·        Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7) Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

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.

8) Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting

requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those

purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights (below) for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9) Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data (see paragraph 10 for more details). If you wish to exercise any of those rights, please contact u

No fee usually required

You will not have to pay a 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. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right 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 any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10) Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

External Third Parties

·        Service providers acting as processors based inside and outside the UK who provide IT and system            administration services.

·        Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors   and insurers based inside and outside the UK who provide consultancy, banking, legal, insurance       and accounting services.

·        HM Revenue & Customs, government agencies, regulators and other authorities acting as   processors or joint controllers based in the UK who require reporting of processing activities in        certain circumstances.

·         Providers of services acting as processors or joint controllers such as surveyors, builders, suppliers           of materials and other contractors providing goods or services in relation to any contract entered into between us. (such parties could be based inside or outside the UK).

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

·        If you want us to establish the data's accuracy.

·        Where our use of the data is unlawful but you do not want us to erase it.

·        Where you need us to hold the data even if we no longer require it as you need it to establish,          exercise or defend legal claims.

·        You have objected to our use of your data but we need to verify whether we have overriding            legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.