Privacy and cookies

BACKGROUND:

Spearfishing Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://www.spearfishing.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested on visiting our website.

Please note: we do not store credit card details nor do we share customer details with any third parties aside from the spearos and spearas who deliver our spearfishing training courses and holidays.

Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”	means an account required to access and/or use certain areas and features of Our Site;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

Information About us

Our Site is owned and operated by Spearfishing Limited, a Limited Company registered in England under company number 08666492.

Registered and main trading address: Unit H, St Austell Bay Business Park. Par Moor Road, Par, Cornwall. PL25 3RF

What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which We will always work to uphold:

The right to be informed about Our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
The right to access the personal data We hold about you. Part 13 will tell you how to do this.
The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that We Please contact us using the details in Part 15 to find out more.
The right to restrict (i.e. prevent) the processing of your personal data.
The right to object to us using your personal data for a particular purpose or purposes.
The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about Our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data We hold about you changes, please keep us informed as long as We have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

What Data Do You Collect and How?

Depending upon your use of Our Site, We may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about Our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data AND/OR personal data relating to children AND/OR data relating to criminal convictions and/or offences.

Data Collected	How We Collect the Data
Identity information including name, title, date of birth.	Through forms on our website, our customer service email and phone line, our social media channels, and in-person in our shop.
Contact information including address, email address, phone number, social profiles.	Through forms on our website, our customer service email and phone line, our social media channels, and in-person in our shop.
Business information including business name, job title, profession.	Through forms on our website, our customer service email and phone line, our social media channels, and in-person in our shop.
Profile information including preferences, interests, login details, purchase history.	Through forms on our website, our customer service email and phone line, our social media channels, and in-person in our shop.
Technical information including IP address, browser type and version, operating system.	Through cookies provided by Google Analytics.
Data from third parties including technical information and profile information.	Through cookies provided by Google Analytics.

Currently card details are NOT processed or stored on our website/server – the forms you see on our site are hosted remotely by our payment providers.

How Do You Use My Personal Data?

Under the Data Protection Legislation, We must always have a lawful basis for using personal data. The following table describes how We may use your personal data, and Our lawful bases for doing so:

What We Do	What Data We Use	Our Lawful Basis
Registering you on Our Site.	Identity, contact	Consent (you request that you are registered on our website)
Providing and managing your Account.	Identity, contact, business, profile, technical	Consent (you request that we provide account facilities)
Providing and managing your access to Our Site.	Identity, contact, business, profile, technical	Consent (you visit our site to use its facilities)
Personalising and tailoring your experience on Our Site.	Identity, contact, business, profile, technical, third party	Legitimate interests (we can display the most appropriate products and services to give you a better experience and to enable us to grow our business)
Administering Our Site.	Technical, third party	Legitimate interests (we can design and optimise the site, facilities, product and services and information based on visitor data, to give you a better experience and to enable us to grow our business)
Administering Our business.	Identity, contact, business, profile	Legitimate interests (we can use data on customers and orders to report on and optimise our business processes and gauge its performance)
Supplying Our products AND/OR services to you.	Identity, contact, business, profile	Consent, contract (we use your data to provide the products and services you have requested)
Managing payments for Our products AND/OR services	Identity, contact, business, profile. NB we do not process your card details on or through our site – all solutions, although seamless, are hosted by our third party providers.	Consent, contract (we may take your initial details to begin the payments process. Sensitive information such as card details is NOT processed on our systems).
Personalising and tailoring Our products AND/OR services for you.	Identity, contact, business, profile, technical, third party	Legitimate interests (we can offer the most appropriate products and services to give you a better experience and to enable us to grow our business.
Communicating with you.	Profile, contact	Consent, contract (to respond to your queries)
Supplying you with information by email that you have opted-in-to (you may opt-out at any time by contacting us or clicking on the unsubscribe link in any email or in your account area).	Identity, contact, business, profile.	Consent, legitimate interests (we can offer the most appropriate products and services to give you a better experience and to enable us to grow our business).

With your permission and/or where permitted by law, We may also use your personal data for marketing purposes, which may include contacting you by email AND/OR text message with information, news, and offers on Our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with Our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

We will only use your personal data for the purpose(s) for which it was originally collected unless We reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If We do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If We need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, We will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, We may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights

How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data	How Long We Keep It
Identity information including name, title, date of birth.	As long as required to process your enquiry, deal with your order; to meet our legal requirements (e.g. tax); whilst we have permission to send marketing information to you; for the duration of you having an account with us (you can ask for it to be deleted at any time).
Contact information including address, email address, phone number, social profiles.	As long as required to process your enquiry, deal with your order; to meet our legal requirements (e.g. tax); whilst we have permission to send marketing information to you; for the duration of you having an account with us (you can ask for it to be deleted at any time).
Business information including business name, job title, profession.	As long as required to process your enquiry, deal with your order; to meet our legal requirements (e.g. tax); whilst we have permission to send marketing information to you; for the duration of you having an account with us (you can ask for it to be deleted at any time).
Profile information including preferences, interests, login details, purchase history.	As long as required to process your enquiry, deal with your order; to meet our legal requirements (e.g. tax); whilst we have permission to send marketing information to you; for the duration of you having an account with us (you can ask for it to be deleted at any time).
Technical information including IP address, browser type and version, operating system.	This information is stored in our Analytics account but is not used to identify a specific user so is not deleted.
Data from third parties including technical information and profile information.	This information is stored in our Analytics account but is not used to identify a specific user so is not deleted.

How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer your personal data within the UK. This means that it will be fully protected under the Data Protection Legislation. The exception to this is if you book a spearfishing holiday or tuition outside of the UK. In these circumstances to process your booking we have to send your details to the location that you have chosen and/or to your tutor if they are located outside of the UK.

Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

We customer data with limited third parties such as Google to perform services on our behalf.
If We sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that We have used it, as specified in this Privacy Policy.
In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may share your personal data with our spearos and spearas for the provision of holidays and tuition.

Klarna

In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.

General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy

How Can I Control My Personal Data?

In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your personal data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

Can I withhold information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict Our use of Cookies. For more information, see Part 14.

How Can I Access My Personal Data?

If you want to know what personal data We have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.

We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, We aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date We receive your request. You will be kept fully informed of Our progress.

How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products AND/OR services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

The following first-party Cookies may be placed on your computer or device:

Name of Cookie	First / Third Party	Provider	Purpose
wp-settings-1 wp-settings-time-1	First		These are set for logged in users i.e. who have registered with the site, to allow their use of their account.
woocommerce_cart_hash woocommerce_items_in_cart wp_woocommerce_session_	First		To keep track of cart data, WooCommerce makes use of these 3 cookies. The first two cookies contain information about the cart as a whole and helps WooCommerce know when the cart data changes. The final cookie (wp_woocommerce_session_) contains a unique code for each customer so that it knows where to find the cart data in the database for each customer. No personal information is stored within these cookies.
wfwaf-authcookie	First		This cookie is used by the Wordfence firewall to perform a capability check of the current user before WordPress has been loaded. This is only set for users that are able to log into the site. This cookie allows the Wordfence firewall to detect logged in users and allow them increased access. It also allows Wordfence to detect non-logged in users and restrict their access to secure areas. The cookie also lets the firewall know what level of access a visitor has to help the firewall make smart decisions about who to allow and who to block.
APISID CONSENT HSID LOGIN_INFO PREF SAPISID SID SSID VISITOR_INFO1_LIVE YSC _ga	Third		These are cookies set by Youtube if you visit a page in which there is a Youtube video embedded, to track usage of its website.

Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products AND/OR services offered through it.

The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.

The analytics service(s) used by Our Site use(s) the following Cookies:

Name of Cookie	First / Third Party	Provider	Purpose
_ga	Third	Google	This is used to distinguish one user from another. It may record your IP but we do not use this information to try to identify a specific user. The cookie is used to show us how many visits are made to the website, what pages are popular and so on.

In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings. These links may help:

Chrome: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Guides for other browsers: https://www.whatismybrowser.com/guides/how-to-enable-cookies/

Adjusting cookie settings:

How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: enquiries@spearfishing.co.uk

Telephone number: 01726 213290

Postal Address:

Unit H, St Austell Bay Business Park. Par Moor Road, Par, Cornwall. PL25 3RF

Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if We change Our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 28th June 2024.