Privacy Policy
At the Spiral Hub we are committed to safeguarding and preserving the privacy of visitors to our website.
This Privacy Policy provides you with details of how we collect and process your personal data through your use of our site (thespiralhub.com) and how we use cookies on our website.
We update this Policy from time to time so please do review this Policy regularly.
The Spiral Hub Ltd. is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our contact details are:
Full name of legal entity: The Spiral Hub Ltd.
Email address: hello@thespiralhub.com
Postal address: Evolution House, Iceni Court, Delft Way, Norwich, Norfolk NR6 6BB
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at hello@thespiralhub.com.
Data we collect about you
Personal data
Personal data means any information capable of identifying an individual. It does not include anonymized data.
We may process certain types of personal data about you as follows:
- Identity Data may include your first name and last name.
- Contact Data may include your billing address, email address and telephone numbers.
- Financial Data may include your bank account details.
- Transaction Data may include details about payments between us and other details of purchases made by you.
- Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and your communication preferences.
Where we are required to collect personal data by law, or under the terms of the contract between us, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
Aggregated data
We may process Aggregated Data from your personal data but this data does not reveal your identity and is, therefore, not personal data.
An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
Sensitive data
We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.
How we collect your personal data
We collect data about you through a variety of different methods including:
- Direct interactions: You may provide data by filling in forms on our site or by communicating with us by post, phone or email, including when you:
- Purchase our products or services;
- Request to be added to the waiting list for our products or services;
- Request resources or marketing be sent to you;
- Complete an online survey; or
- Give us feedback.
- Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies.
- Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties: MailChimp, Thinkific, Calendly, LinkedIn, Stripe, any other online tools used to facilitate our product/service
- Analytics providers such as Google based outside the EU
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside OR outside the EU.
How we use your personal data
We will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where we need to perform the contract between us;
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests; and
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email. You have the right to withdraw consent to marketing at any time by emailing us at hello@thespiralhub.com OR by clicking ‘Update your preferences’ at the bottom of any marketing emails sent to you.
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant. We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data.
Purpose/Activity | Type of data | Lawful basis for processing |
|---|---|---|
To register you as a new customer | Identity Contact | Performance of a contract with you |
To process and deliver your order including:
| Identity Contact Financial Transaction Marketing & Communications | Performance of a contract with you Necessary for our legitimate interests to recover debts owed to us |
To manage our relationship with you which will include:
| Identity Contact Profile Usage Marketing & Communications | Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services |
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity Contact Technical | Necessary for our legitimate interests for running our business, provision of administration and IT services, and network security |
To deliver relevant website content to you | Identity Contact Profile Usage Marketing & Communications 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, products/services, marketing, customer relationships and experiences | Technical Usage | Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy |
Marketing communications
You will receive marketing communications from us if you have:
- requested information from us or purchased goods or services from us; or
- if you provided us with your details and asked us to keep you updated; and
- in each case, you have not opted out of receiving that marketing.
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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us at hello@thespiralhub.com.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing. We may process your personal data without your knowledge or consent where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 3:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers
- Government bodies that require us to report processing activities.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Credit or Debit Card Data
We do not collect or store your full credit or debit card information when you make a payment online. All credit card transactions are processed securely through Stripe, and at no point does The Spiral Hub receive your full credit or debit card information or store this.
Therefore, your card information is completely secure and protected by Stripe and none of our employees have any access to your full credit or debit card number, payment platform profile or security code whatsoever.
Data Security
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions, and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required too.
Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers. After six years your data will be securely destroyed.
In some circumstances, we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at hello@thespiralhub.com.
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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
Third-Party Links
This website includes 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 notice of every website you visit.
Use of Cookies
Cookies provide information regarding the computer used by a visitor. We may use cookies where appropriate to gather information about your computer to assist us in improving our website.
You can adjust the settings on your computer to decline any cookies if you wish. This can be done within the “settings” section of your computer.
For more information, please read the advice at AboutCookies.org.