Data controller and owner
Southerly Communications Ltd (t/a Spoon Behavioural Communications) 60 Cannon Street, London EC4N 6NP, United Kingdom. Owner contact email: email@example.com
Types of data collected
Mode and place of processing the data
Methods of processing
The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.
The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.
The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that the Data Controller suspend or remove the data.
The use of the collected data
The Data concerning the User is collected to allow the Owner to provide its services, as well as for the following purposes: SPAM protection, Contacting the User, Analytics and Managing contacts and sending messages. The Personal Data used for each purpose is outlined in the specific sections of this document.
Detailed information on the processing of personal data
Personal Data is collected for the following purposes and using the following services:
Google Analytics (Google Inc.)
Contact form (on website’s ‘contact’ page)
By filling in the contact form with their Data, the User authorises this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header. Personal Data collected: email address, first name and last name.
Managing contacts and sending messages
This type of service analyses the traffic of this Website, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.
Akismet (automattic inc.)
Additional information about data collection and processing
The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this Website or the related services. The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.
Additional information about user’s personal data
System logs and maintenance
For operation and maintenance purposes, this Website and any third party services may collect files that record interaction with this Website (System logs) or use for this purpose other Personal Data (such as IP Address).
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.
The rights of users
Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above. This Website does not support “Do Not Track” requests. To determine whether any of the third party services it uses honour the “Do Not Track” requests, please read their privacy policies.
Definitions and legal references
Personal data (or data)
Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.
Information collected automatically from this Website (or third party services employed in this Website), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using this Website, which must coincide with or be authorised by the Data Subject, to whom the Personal Data refers.
The legal or natural person to whom the Personal Data refers.
Data processor (or data supervisor)
Data controller (or owner)
The natural person, legal person, public administration or any other body, association or organisation with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
The hardware or software tool by which the Personal Data of the User is collected.
Small piece of data stored in the User’s device.