About this Policy

1.1 This policy explains when and why we collect personal information about our staff and customers, how we use it and how we keep it secure and your rights in relation to it.

1.2 We may collect, use and store your personal data, as described in this Data Privacy Policy and as described when we collect data from you.

1.3 We reserve the right to amend this Data Privacy Policy from time to time without prior notice. You are advised to check our website https://www.spyrys.co.uk regularly for any amendments (but amendments will not be made retrospectively).

1.4 We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Information Commissioner (http://www.ico.gov.uk). For the purposes of the GDPR, we will be the “controller” of all personal data we hold about you.

2. Who are we?

2.1 We are Spyrys Limited. We can be contacted at 5 Dunveth Business Park, Wadebridge PL27 7FE. 01208 813760

3. What information we collect and why.

Customer's name, address, telephone numbers, e-mail address(es).

  • Managing the customer's order, delivery and routine maintenance schedule.
  • Performing the Company's contracts with the Customer.
  • For the purposes of our legitimate interests in operating the Company.
  • We seek the customers consent through the completion of a quotation/order form, commissioning & warranty forms and ongoing job sheets..

Customer's name, address, telephone numbers, e-mail address(es).

  • Registering warranty information with manufacturers which may be outside of the EU.
  • We will seek the Customer's consent through completion of a warranty registration form and the customer may withdraw their consent at any time by contacting us by e-mail or letter.

Photos and videos of Customer's premises and hot tub.

  • Recording pre-delivery site visits for internal use.
  • Publicity images for the Company's website and social media pages and use in press releases.
  • Recording repairs undertaken for internal use.
  • No personally identifiable information is recorded with photos or used in marketing.

Potential customer's name, address, telephone numbers and e-mail address(es)

  • Creating and managing the Company's marketing database.
  • We will seek the potential customer's consent by asking them to complete a Customer Details Form.
  • The Customer may withdraw their consent at any time by contacting us by e-mail or letter to tell us that they no longer wish their details to be used.

Employee's name, address, email addresses, phone numbers and relevant qualifications and/or experience.

  • Managing employees in the Company for the purposes of our legitimate interests in operating the Company and complying with all relevant legislation.
  • New employees are asked to supply relevant information as required including tax/NI details, driving license and other qualifications.

Supplier's name, address, email addresses & phone numbers.

  • Managing the company's purchasing, delivery and routine maintenance schedule.
  • For the purposes of our legitimate interests in operating the Company
  • We seek the suppliers consent through their provision of contact details

Website Cookies

  • Cookies are sometimes used to improve the experience of a visitor to our website.
  • We may sometimes use cookies on this website to record aggregate statistical information about the visitors to our site and the use that our visitors make of the website.
  • No personally identifiable information is recorded.

4. How we protect your personal data

4.1 We will not transfer your personal data outside the EU without your consent, which is obtained through signature of manufacturer warranty registration forms.

4.2 Where personal information is stored on computer, we have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.

4.3 Where personal information is stored in paper form it is stored in filing cabinets in a locked office which only authorised staff have access to.

4.4 Please note however that where you are transmitting information to us over the internet this can never be guaranteed to be 100% secure.

4.5 For any payments which we take from you online or over the telephone we will use a recognised secure payment system.

4.6 We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.

5. Who else has access to the information you provide us?

5.1 We will never sell your personal data. We will not share your personal data with any third parties without your prior consent (which you are free to withhold) except where required to do so by law or as set out in the table above or paragraph 5.2 below.

5.2 We may pass your personal data to third parties who are service providers, agents and subcontractors to us for the purposes of completing tasks and providing services to you on our behalf. However, we disclose only the personal data that is necessary for the third party to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own purposes.

6. How long do we keep your information?

6.1 We will hold your personal data on our systems for as long as you are a Customer or Employee and for as long afterwards as it is in the Company's legitimate interest to do so or for as long as is necessary to comply with our legal obligations. We will review your personal data every year to establish whether we are still entitled to process it. If we decide that we are not entitled to do so, we will stop processing your personal data except that we will retain your personal data in an archived form in order to be able to comply with future legal obligations e.g. compliance with tax requirements and exemptions.

6.2 We securely destroy all financial information once we have used it and no longer need it.

7. Your rights

7.1 You have rights under the GDPR:

  (a) to access your personal data
  (b) to be provided with information about how your personal data is processed
  (c) to have your personal data corrected
  (d) to have your personal data erased in certain circumstances
  (e) to object to or restrict how your personal data is processed
  (f) to have your personal data transferred to yourself or to another business in certain circumstances.

7.2 You have the right to take any complaints about how we process your personal data to the Information Commissioner:


0303 123 1113.

Information Commissioner's Office
Wycliffe House
Water Lane
Cheshire SK9 5AF


For more details, please address any questions, comments and requests regarding our data processing practices to our Data Controller, Brian Kennelly.

Brian Kennelly
Managing Director

brian kennelly signature

Date: 21/5/18