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In.Spiritu Ltd - Privacy Policy

Last updated: 04/05/2025

1. Introduction

This Privacy Policy explains how IN.SPIRITU LTD ("we", "our", "us") collects, uses, shares and protects your personal information. We are committed to ensuring the privacy and security of your personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable privacy laws.

Company Details:

  • Company Name: IN.SPIRITU LTD
  • Registered Address: COOPER BUILDINGS, SHEFFIELD SCIENCE PARK, ARUNDEL STREET, SHEFFIELD, S1 2NS
  • ICO Registration Reference: ZB830848
  • Data Protection Officer: phill@enablefinance.com

2. Information We Collect

We may collect and process the following categories of personal data:

2.1 Information you provide to us

  • Identity data (name, title, date of birth)
  • Contact data (address, email address, telephone numbers)
  • Financial data (bank account details, payment card details)
  • Transaction data (details about payments to and from you)
  • Profile data (username and password, purchases, preferences, feedback)
  • Marketing and communications data (preferences in receiving marketing from us)

2.2 Information we collect automatically

  • Technical data (IP address, browser type and version, time zone setting, operating system and platform)
  • Usage data (information about how you use our website, products and services)

2.3 Information we receive from other sources

  • We may receive personal data about you from various third parties and public sources.

3. How We Use Your Information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
  • Where we need to comply with a legal or regulatory obligation
  • Where you have given consent

3.1 Purposes for processing

We have set out below a description of the ways we plan to use your personal data:

  • To register you as a new customer
  • To process and deliver your order
  • To manage our relationship with you
  • To administer and protect our business and website
  • To deliver relevant website content and advertisements to you
  • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  • To make suggestions and recommendations to you about goods or services that may be of interest to you

4. Legal Basis for Processing

Our legal basis for processing your data includes:

  • Contractual necessity: Processing necessary for the performance of a contract with you or to take steps at your request before entering into a contract
  • Legal obligation: Processing necessary for compliance with a legal obligation
  • Legitimate interests: Processing necessary for our legitimate interests or those of a third party, provided your interests and fundamental rights do not override those interests
  • Consent: Processing based on your consent

5. 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.

To determine the appropriate retention period for personal data, we consider:

  • The amount, nature, and sensitivity of the personal data
  • The potential risk of harm from unauthorised use or disclosure of your personal data
  • The purposes for which we process your personal data
  • Whether we can achieve those purposes through other means
  • The applicable legal requirements

6. Data Sharing

We may share your personal data with:

  • Service providers acting as processors based in the UK and EEA who provide IT and system administration services
  • Professional advisers including lawyers, bankers, auditors and insurers
  • HM Revenue & Customs, regulators and other authorities
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes.

7. International Transfers

Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we use certain service providers, we may use specific contracts approved for use in the UK or EU which give personal data the same protection it has in the UK and Europe.

8. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including:

  • The right to request access to your personal data
  • The right to request correction of your personal data
  • The right to request erasure of your personal data
  • The right to object to processing of your personal data
  • The right to request restriction of processing your personal data
  • The right to request transfer of your personal data
  • The right to withdraw consent
  • The right to lodge a complaint with the Information Commissioner's Office (ICO)

If you wish to exercise any of these rights, please contact our Data Protection Officer.

10. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top of this Privacy Policy.

12. Contact Details

If you have any questions about this Privacy Policy or our privacy practices, please contact our Data Protection Officer:

  • Email address: phill@enablefinance.com
  • Postal address: IN.SPIRITU LTD, COOPER BUILDINGS, SHEFFIELD SCIENCE PARK, ARUNDEL STREET, SHEFFIELD, S1 2NS

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.