Privacy Policy

    1. Introduction

    2. We are committed to safeguarding the privacy of our website visitors, app users, service users, individual customers and customer personnel.
    3. This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
    4. In this policy, "we", "us" and "our" refer to Spelga Software Limited. For more information about us, see Section 12.

    1. The personal data that we collect

    2. In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
    3. We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name and email address. The source of the contact data is you.
    4. We may process your website or app user account data ("account data"). The account data may include your account identifier, name, email address, account creation and modification dates, website or app settings and marketing preferences. The primary source of the account data is you and, although some elements of the account data may be generated by our apps.
    5. We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication data may include the communication content and metadata associated with the communication.
    6. We may process data about your use of our website, apps 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. The source of the usage data is our analytics tracking system.
    7. Please do not supply any other person's personal data to us, unless we prompt you to do so.

    1. Purposes of processing and legal bases

    2. In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
    3. Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, apps, services and business.
    4. Relationships and communications - We may process contact data, account data, customer relationship data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, app users, service users, individual customers and customer personnel, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
    5. Direct marketing - We may process contact data, account data, profile data, customer relationship data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent.
    6. Research and analysis - We may process usage data, service data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
    7. Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
    8. Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
    9. Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
    10. Legal claims - We may process your personal data 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.
    11. Legal compliance and vital interests - We may also process 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.

    1. Providing your personal data to others

    2. 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.
    3. 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.
    4. Your personal data held in our website database will be stored on the servers of our hosting services providers.
    5. 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.
    6. We may disclose app usage data to third party crash analytics services for the purposes of debugging errors in our apps. We currently use Microsoft's App Center (https://visualstudio.microsoft.com/app-center) for this purpose. No personal data is transmitted to the third party.

    1. International transfers of your personal data

    2. In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK, US and/or EU data protection law.
    3. We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
    4. ‌We may transfer your personal data from the European Economic Area (EEA) to the US and process that personal data in the US for the purposes set out in this policy during any period with respect to which the US is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the US to the EEA and process that personal data in the EEA for the purposes set out in this policy during any period with respect to which EEA states are not treated as third countries under US data protection law or benefit from adequacy regulations under US data protection law.
    5. ‌‌We may transfer your personal data from the UK to the US and process that personal data in the US for the purposes set out in this policy during any period with respect to which the US is not treated as a third country under UK data protection law or benefits from an adequacy decision under UK data protection law; and we may transfer your personal data from the US to the UK and process that personal data in the UK for the purposes set out in this policy during any period with respect to which the UK is not treated as a third country under US data protection law or benefit from adequacy regulations under US data protection law.
    6. The hosting facilities for our website and apps are situated in the UK and the US. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of these countries.

    1. Retaining and deleting personal data

    2. This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
    3. 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.
    4. We will retain your personal data as follows:
      1. contact data will be retained for a minimum period of 5 years following the date of the most recent contact between you and us, and for a maximum period of 2 years following that date;
      2. account data will be retained for a minimum period of 0 years following the date of closure of the relevant account, and for a maximum period of 1 year following that date;
      3. service data will be retained for a minimum period of 5 years following the date of termination of the relevant contract, and for a maximum period of 2 years following that date;
      4. communication data will be retained for a minimum period of 5 years following the date of the communication in question, and for a maximum period of 2 years following that date; and
      5. usage data will be retained for 5 years following the date of collection.
    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.

    1. Security of personal data

    2. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
    3. We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
    4. The following personal data will be stored by us in encrypted form: your name, contact information and password(s).
    5. Data that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
    6. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
    7. You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website or apps).

    1. Your rights

    2. In this Section 8, we have listed the rights that you have under data protection law.
    3. Your principal rights under data protection law are:
      1. the right to access - you can ask for copies of your personal data;
      2. the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
      3. the right to erasure - you can ask us to erase your personal data;
      4. the right to restrict processing - you can ask us to restrict the processing of your personal data;
      5. the right to object to processing - you can object to the processing of your personal data;
      6. the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
      7. the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
      8. the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
    4. These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
    5. You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

    1. Third party websites

    2. Our website includes hyperlinks to, and details of, third party websites.
    3. In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.

    1. Updating information

    2. Please let us know if the personal information that we hold about you needs to be corrected or updated.

    1. Amendments

    2. We may update this policy from time to time by publishing a new version on our website.
    3. You should check this page occasionally to ensure you are happy with any changes to this policy.

    1. Our details

    2. This website is owned and operated by Spelga Software Limited.
    3. We are registered in England and Wales under registration number 06930045, and our registered office is at Jubilee House, East Beach, Lytham St Annes, FY8 5FT.
    4. You can contact us:
      1. by post, to the postal address given above; or
      2. by email, using the email address published on our website.

    1. Data protection registration

    2. We are registered as a data controller with the UK Information Commissioner's Office.
    3. Our data protection registration number is ZB080778.