Privacy and GDPR Policy

This is our privacy statement. Please read it with care.

We are committed to protecting your individual and business privacy. We collect information about you to provide you with the best possible service. We will not e-mail you in the future unless you have given us your consent.

If you are registering as a consumer we will only use the information that we collect about you lawfully (in accordance with The UK Data Protection Act 1998) and according to The UK Which? Web Trader Code of Practice. We will give you the chance to refuse any marketing email from us or from another trader in the future. If you do not wish to receive information about our products, services or special offers, please e-mail us at

The only information we will collect about you includes your name, address, phone number and email address and only with your prior consent. The information we hold will be accurate and up to date. The personal information that we hold will be held securely in accordance with our internal security policy.

Questions/comments about privacy?
If you have any questions/comments about privacy, you should email us at

GDPR Statement We are committed to protecting and respecting your privacy. This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

1. Definitions

Data controller - A controller determines the purposes and means of processing personal data.

Data processor - A processor is responsible for processing personal data on behalf of a controller.

Data subject – Natural person

Categories of data: Personal data and special categories of personal data

Personal data - The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies. Special categories personal data - The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs. Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

2. Who are we? SPIRAL STAIRS DIRECT is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: or Tel: 0121 351 1533. For all data matters contact our Customer Service Team on 0121 351 1533.

3. The purpose(s) of processing your personal data We use your personal data for the following purposes: PROCESSING OF ORDERS INCLUDING DELIVERY AND INVOICE ADDRESSES

4. The categories of personal data concerned With reference to the categories of personal data described in the definitions section, we process the following categories of your data: • Personal data: Order and Payment data relating to products purchased. We do NOT store any payment data. Any Payment data including credit and debit card information is processed by a third party payments gateway and not held in storage or recorded by Spiral Stairs Direct We have obtained your personal data from our online store and this information is not accessible to the general public. Your data will be shared only for the purpose of completing your order / contract, for example with delivery companies, or factories who are delivering directly to you, or credit card payment processing ie banks or a payment gateway.

5. What is our legal basis for processing your personal data (article 6 of GDPR)?

Our lawful basis for processing your general personal data:

☐ Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract PROCESSING OF AN ORDER AND COMPLETION OF THE ORDER

☐ Processing necessary for compliance with a legal obligation COMPLETION OF AN ORDER

6. Sharing your personal data Your personal data will be treated as strictly confidential, and will be shared only with DELIVERY COMPANIES WHERE RELEVANT IN ORDER TO COMPLETE AN ORDER, MANUFACTURERS IN ORDER TO COMPLETE AN ORDER, ORDER PROCESSING.

7. How long do we keep your personal data? We keep your personal data for no longer than reasonably necessary for a period of 10 YEARS in order to FACILITATE ANY WARRANTY CLAIMS OR SIMILAR, AND IN ACCORDANCE WITH OUR LEGAL OBLIGATIONS TO GOVERNMENT BODIES.

8. Providing us with your personal data We require your personal data as it is a contractual requirement, or a requirement necessary to enter into a contract.

9. Your rights and your personal data Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;

• The right to request that we correct any personal data if it is found to be inaccurate or out of date;

• The right to request your personal data is erased where it is no longer necessary to retain such data;


• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);

• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

• The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).



12. Further processing If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

13. Changes to our privacy policy Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

14. How to make a complaint regarding personal data To exercise all relevant rights, queries or complaints please in the first instance contact our Customer Service Team on 0121 351 1533. If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.