Privacy Policy

 1. General Information 

• 1.1.  We are Spinnaker International Ltd registered in the UK (2516654) and located at Saltash Parkway, Saltash, Cornwall, UK. We provide security technology services to the EU and global markets.
• 1.2.  Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:
  • GDPR@spinnaker.co.uk / 01752 850 300 

• 1.3.  This privacy notice discloses the privacy practices for Spinnaker International Ltd. This privacy notice applies to information collected by websites, platforms and other systems that we operate including spinnaker.co.uk, cashtrack.org, crimetag.net as well as information supplied to us through the course of normal business via other channels.
  It will notify you of the following: 
  • What personally identifiable information is collected from you through the website or other
  • electronic means, how it is used and with whom it may be shared.
  • What choices are available to you regarding the use of your data.
  • The security procedures in place to protect the misuse of your information.
  • How you can correct any inaccuracies in the information.
• 1.4.  We are the sole owners of the information collected through the websites listed above. We only have access to/collect information that you voluntarily give us via email, post, fax or other direct contact from you. We will not sell or rent this information to anyone. 
  • We will use your information to respond to you, regarding the reason you contacted us.
  • We will not share your information with any third party outside of our organization, other than as necessary to fulfil your request, e.g. to supply a service
  • If you gave us consent to contact you for marketing then we may contact you via email in the future to tell you about special events, new products or services, or changes to this privacy policy.

2. Personal data 

• 2.1.  Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
  “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
• 2.2.  How we use your information
  This privacy notice tells you how we, Spinnaker, will collect and use your personal data for [outline further information on services and activities that you collect personal data, for example: cookies, profiling, complaints, subscriptions, etc.)]
• 2.3.  Why does Spinnaker need to collect and store personal data?
• 2.4.  In order for us to provide you with a service we need to collect personal data for correspondence purposes and/or detailed service provision. In any event, we are committed to ensuring that the information we collect, and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
• 2.5.  Will Spinnaker share my personal data with anyone else?
• 2.6.  We may pass your personal data on to third-party service providers contracted to Spinnaker in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Spinnaker’s procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
• 2.7.  How will Spinnaker use the personal data it collects about me?
• 2.8.  Spinnaker will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Spinnaker is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
• 2.9.  Under what circumstances will Spinnaker contact me?
• 2.10.  Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
• 2.11.  Can I find out the personal data that the organisation holds about me?

• 2.12.  Spinnaker at your request, can confirm what information we hold about you and how it is processed. If Spinnaker does hold personal data about you, you can request the following information: 
  • Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
  • Contact details of the data protection officer, where applicable.
  • The purpose of the processing as well as the legal basis for processing.
  • If the processing is based on the legitimate interests of Spinnaker or a
    third party, information about those interests.
  • The categories of personal data collected, stored and processed.
  • Recipient(s) or categories of recipients that the data is/will be disclosed to.
  • If we intend to transfer the personal data to a third country or international
    organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
  • How long the data will be stored.
  • Details of your rights to correct, erase, restrict or object to such processing.
  • Information about your right to withdraw consent at any time.
  • How to lodge a complaint with the supervisory authority.
  • Whether the provision of personal data is a statutory or contractual
    requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
  • The source of personal data if it wasn’t collected directly from you.
  • Any details and information of automated decision making, such as profiling,
    and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
• 2.13.  What forms of ID will I need to provide in order to access this?
  Spinnaker accepts any one of the following forms of ID when information on your personal data is requested: 
  • Passport
  • Driving licence
  • Birth Certificate
  • Utility bill (from last 3 months)

3. Information Collection, Use and Sharing 

• 3.1.  In order to use our services and websites, a user might be required to first complete a registration form. During registration a user is required to give certain information (such as name, email address and mobile telephone number). This information is used for the following purposes: 
  • Contact you about the products/services on our site in which you have expressed interest
  • Authenticate you when accessing information.
• 3.2.  We may request information from you in connection with an order with us for products or services. To buy from us, you must provide contact information (like name and shipping address) and financial information (like credit card number, expiration date, bank account details). This information is used for billing purposes and to fulfil your orders. If we have trouble processing an order, we’ll use this information to contact you.
• 3.3.  At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights: 
  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that Spinnaker refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
    All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

3.4. Information we collect and process from you is as follows: 

Cookies	We use “cookies” on our websites and applications. A cookie is a piece of data stored on a site visitor’s hard drive to help us improve your access to our site and identify repeat visitors to our site.  For instance, when we use a cookie to identify you, you would not have to log in a password more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site.  Usage of a cookie is in no way linked to any personally identifiable information on our site.
Sharing	We share aggregated demographic information with our partners and advertisers. This is not linked to any personal information that can identify any individual person.  We sometimes use outside companies to ship orders, perform credit checks, process payment and bill users for goods and services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes beyond filling your order. We may partner with other parties to provide specific services connected with your order.  When the user signs up for these services, we will share names, or other contact information that is necessary for the third party to provide these services. These parties are not allowed to use personally identifiable information except for the purpose of providing these services.
Links	This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.

4. Consent 

• 4.1.  By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.
• 4.2.  Consent is required for Spinnaker to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
• 4.3.  You may withdraw consent or ask us about the data we store at any time by contacting us via the email address above or phone number given on our website.

5. Disclosure 

• 5.1.  Spinnaker will not pass on your personal data to third parties without first obtaining your consent or through the lawful, legitimate processing of your data in connection with the services we provide to you.
• 5.2.  The following third parties will receive your personal data for the following purpose(s) as part of the processing activities. More detail about the specific parties and the data they receive can be requested from Spinnaker using the contact details above. 
  • 5.2.1.  Mobile network operators who give access to their radio and data network.
  • 5.2.2.  Financial institutions and banks to process payments.
  • 5.2.3.  Internet service providers who provide access to data networks.
  • 5.2.4.  Infrastructure partner who provide data location facilities.

6. Retention period 

6.1. Spinnaker will process personal data for as long as we are contracted to provide services to you and will store any personal data for up to 12 months thereafter. We will keep limited personal data about you for legislative and regulatory needs for up to 6 (six) years.  

7. Complaints 

7.1. In the event that you wish to make a complaint about how your personal data is being processed by Spinnaker (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Spinnaker’s data protection representatives Data Protection Officer / GDPR Owner using the contact details above.