We are the Controller in respect of your personal data.
 
Our full name: Spirtrade Limited (company number 10917784)
Post: 8 Hermitage Street, London W2 1BE, United Kingdom
Email: info@spiritrade.com
Platform: www.spiritrade.com
 
2. We are collecting your personal data for the following purpose(s):
 
2.1 to process any orders which you place through the Platform;
 
2.2 to find out what you and other customers like;
 
2.3 to take payment and to provide you with any refunds;
 
2.4 to provide you with any customer support and handle any cancellation or refund requests;
 
2.5 to ensure that content from the Platform is presented in the most effective manner for you and for your computer; and
 
2.6 to meet any legal or regulatory obligations which we have, to enforce or apply the Platform terms and conditions or this Privacy Notice or to protect our rights or the rights of any third party e.g. we may provide your personal information to law enforcement agencies for fraud prevention purposes or we may use your personal data to prevent you from making further orders.
 
3. The legal basis for processing your personal data: we process your personal data either on the basis of your consent, where this has been given unambiguously, or on the basis that it is necessary for the performance of a contract between you and us (if you would like to purchase or sell a product via the Platform), or on the basis that it is necessary for the purposes of the legitimate interests pursued by us in operating and making available the Platform.
 
4. The recipients or categories of recipients of your personal data are:
 
4.1 Our third party suppliers who help us to fulfil any order made via the Platform e.g. our warehouse providers. and third party payment processor and escrow agents
 
4.2 our third party suppliers who help us maintain the Platform and run our business e.g. our hosting provider, website developers, marketing agencies and our IT support team; and
 
4.3 credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud, verify your membership application or investigate any breach of these terms and conditions and Privacy Policy.
 
4.4 We may also disclose your personal data to any prospective buyer of our business or assets.
 
5. We are committed to protecting the information we receive from you. We follow reasonable technical and management practices to help protect the confidentiality, security and integrity of data stored on our system. While no computer system is completely secure, we believe the measures we have implemented reduce the likelihood of security problems to a level appropriate to the type of data involved.
 
6. We do not propose to transfer your personal data outside of the European Economic Area.
 
7. The personal data will be stored for [six years after your close your account with us].
 
8. You have the right to request from us access to and rectification or erasure of personal data or to restriction of processing concerning you or to object to our processing of the data as well as the right to data portability.
 
9. If we are relying on your consent to process data, you may withdraw your consent at any time by notice to us.
 
10. You have the right to complain to the Information Commissioner’s Office about the manner in which or otherwise in respect of the manner in which we process your personal data.
 
11. Your provision of personal data to us is a contractual or legal requirement. If you do not supply your personal data to us, we will be unable to verify your membership application form and you will not be able to trade on our platform.
 
12. Our Platform uses local storage. A local storage is a file created by a website in your device. Cookies are just one type of local storage, but there are others. It is important that you know them so you can block them or delete the data stored by them: Browser local storage. Some websites use the browser’s “sessionStorage” and “localStorage” to store data; “sessionStorage” is stored temporarily, but the “localStorage” is persistent. You may erase them by deleting your browser’s history; your browser help function will tell you how.