SPIRAL LEAF

Privacy & Cookies Policy 

Introduction

This Privacy Policy outlines Spiral Leaf and the Namesco Hosting Platform (" we ", " our " or " the Company ") practices with respect to information collected from users who access our website at https://www.spiralleaf.co.uk (" Site "), or otherwise share personal information with us (collectively: " Users ", " you ", " your ").

Grounds for data collection

Processing of your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter 'Personal Information' is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject. When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy. Users are encouraged to carefully read the Privacy Policy and use it to make informed decisions.

What information is collected?

Two types of data and information are collected from Users. The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (Non-personal Information). The identity of a User from which the Non-personal Information was collected is not known. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc). The second type of information is Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

• Device Information: we collect Personal Information from your device. Such information includes geo-location data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site
• Email address
• First name and last name
• Phone number
• Address, Town/State, City, County/Province, Postal Code/ZIP
• Usage Data
• Registration information: when you register to use the Site you will be asked to provide certain details such as: full name; email or physical address, and other information.

How is information received about you?

We receive your Personal Information from various sources:

• When you voluntarily provide us your personal details in order to register on our Site;
• When you use or access our Site in connection with your use of our services;
• From third party providers, services and public registers (for example, traffic analytics vendors).

What information is collected?

Your information is never rented, sold, or shared with third parties except as described in this Privacy Policy. Your information may be used for the following:

• Conducting statistical and analytical purposes, intended to improve the Site.
• To provide and maintain the Site's Service, including to monitor the usage of the Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data you provide can give You access to different functionalities of the Service that are available to you as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Service.
• To contact You: to contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: to attend and manage your requests to us.
• For business transfers: we may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service users is among the assets transferred.
• For other purposes : we may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
• We may share Your personal information in the following situations:
• With Service Providers: we may share Your personal information with Service Providers to monitor and analyse the use of our Service, to contact you.
• For business transfers: we may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
• With Affiliates: we may share Your information with Our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with us.
• With business partners: we may share Your information with our business partners to offer you certain products, services or promotions.
• With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.
• With Your consent : we may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party providers, who may be located in different jurisdictions across the world, for any of the following purposes:

• Hosting and operating our Site:
• Providing you with our services, including providing a personalised display of our Site;
• Storing and processing such information on our behalf;
• Serving you with advertisements and assist us in evaluating the success of our advertising campaigns and help us re-target any of our users;
• Providing you with marketing offers and promotional materials related to our Site and services;
• Performing research, technical diagnostics or analytics.

Information may be disclosed in good faith if it is believed that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

User Rights

You may request to:

1. Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information.
2. Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
3. Request rectification of your personal information that is in our control.
4. Request erasure of your personal information.
5. Object to the processing of personal information by us.
6. Request to restrict processing of your personal information by us.
7. Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. If you wish to exercise any of the aforementioned rights, or receive more information, please contact info@spiralleaf.co.uk.

Retention

Your personal information will be retained for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations.

Incomplete or inaccurate information may be rectified, replenished or removed, at any time and at the Company's discretion.

COOKIES

Together with trusted partners cookies and other technologies are used in related services, including when you visit our Site or access our services.

A 'cookie' is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Site's services.

The Site uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;

b. 'persistent cookies ' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;

c. 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyse our web access.

Cookies do not contain any information that personally identifies you, but Personal Information stored about you may be linked, by the Company, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

A tool called 'Google Analytics' is used to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. The information received from Google Analytics is only to improve the Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. Information collected through the use of Google Analytics is not combined with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third party collection of information

This policy only addresses the use and disclosure of information collected from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, you are encouraged to read the terms and conditions and privacy policy of each third party that you choose to disclose information to.

This Privacy Policy does not apply to the practices of companies our of the Company's ownership or control, or to individuals who are not employed or managed by the Company, including any of the third parties which the Company may disclose information as set forth in this Privacy Policy.

How is your information safeguarded?

Every care is taken to implement and maintain the security of the Site and your information. Reasonable steps are taken to safeguard information, responsibility cannot be taken for the acts of those who gain unauthorised access or abuse our Site, and no warranty is made, express, implied or otherwise, that the Company will prevent such access.

Transfer of data outside the EEA

Please note that some data recipients may be located outside the EEA. In such cases your data will be transferred only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

Advertisements

A third-party advertising technology may be used to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser). You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

Marketing

Personal Information, such as your name, email address, telephone number, etc. may be used by the Company or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you.

Out of respect to your right to privacy the means to decline receiving further marketing offers is included in the marketing materials. If you unsubscribe your details will be removed including your email address or telephone number from our marketing distribution lists.

Please note that even if you have unsubscribed from receiving this Site's marketing emails, other types of important email communications may be sent to you without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

Corporate transaction

Information in the event of a corporate transaction will be shared (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

Minors

The Site is not designed for or directed at children although the content is designed to be educational. Under no circumstances should this service be used by minors without prior consent or authorisation by a parent or legal guardian. No Personal Information is every collected from minors knowingly. If a parent or guardian becomes aware that his or her child has provided Personal Information without their consent, please contact info@spiralleaf.co.uk.

Updates or amendments to this Privacy Policy

Rights are reserved to periodically amend or revise this Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgement and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

Contact

If you have any general questions about the Site or the information collected about you and how it is used, please contact info@spiralleaf.co.uk.

Last Modified 20 December 2022.