Privacy Policy

Spruce Collective Privacy Policy

Introduction

Welcome to Spruce Collectives' privacy policy.

Spruce Collective respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we process and look after your personal data when you visit our website.

It also tells you about your privacy rights and how the law protects you.

Please also use the Glossary (found in section 11) to understand the meaning of some of the terms used in this privacy policy.

1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Spruce Collective collects and processes your personal data through your use of this website and the types of data we hold that relates to you, including any data you may provide through this website when you sign up to our newsletter, purchase any products or services or take part in a prize draw or competition. Spruce Collective is aware of its obligations under the UK General Data Protection Regulation (“UK GDPR”) and is committed to processing your data securely and transparently.  

This website is not intended for children under the age of 16 (or such other age as may be determined by law) and they should not access our website. We do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data and what your rights are under data protection legislation.

Controller

Celtic Luck Ltd (registered with company number 16321487) is the controller and responsible for your personal data (collectively referred to as “Spruce Collective”, "we", "us" or "our" in this privacy policy). This means that we are responsible for deciding how we hold and use personal information about you. We are registered with the Information Commissioner’s Office with registration number ZB950007.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, gender

• Contact Data includes billing address, delivery address, email address and telephone number.
• Financial Data includes bank account details and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, photographs and video recordings, details (and copies) of your communications and interactions with us.  
• Usage Data includes information about how you use our website, products and services, including any personal data necessary to deliver a prize.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data under UK data protection law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you, save to the extent that you voluntary disclose this information to us, for example, as part of surveys that we circulate. Special category data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data, criminal convictions and offences.

We may collect the minimum amount of personal data to enable you to enter into any prize draw and competition and allow us to run the promotion. If you are a winner, it may be necessary to collect more detailed information from you in order to award your prize to you. You will be notified of this at the time we notify you if you have won.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services or to enter you into a competition). In this case, we may have to cancel a product or service you have with us or refuse your entry to a competition. We will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see information about the cookies we collect, and how they are used in section 4 below.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:

1. analytics providers;
2. advertising networks;
3. search information providers; and
4. social media platforms, including where you interact with us on those platforms and access our content.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside and outside the UK.

4. How we use your personal data

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, for example, to prevent fraud and enable us to give you the best customer experience. We make sure that we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests and do not process personal data for activities where our interests are overridden by the impact on you.
• Where we need to comply with a legal obligation.

Where we rely on consent in order to use your personal data for a specified reason. To find out more about the types of lawful basis that we will rely on to process your personal data, please see the Glossary below.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us, as set out in section 10 below.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

If you have entered into a competition or you are the winner of the competition, your name may be published on Spruce Collective’s website, along with any photograph or videos provided to us. Your participation is not compulsory and so if you do not wish to have your name or photograph published on the website, you should contact us using the contact details set out in section 10 of this privacy policy as soon as reasonably possible after you have completed your entry (and prior to the closing date of the competition). Your participation in the competition or chances of winning will not be affected in any way.

If you do not wish to participate in any publicity and contact us as set out above, we may still have to provide your details to regulatory authorities, including for example, the Advertising Standards Authority (“ASA”) as proof that the competition has been properly administered and the prize awarded. This is a legal requirement we must comply with. If you require detail of how the ASA will use and process your personal data, please let us know.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with this privacy policy, where this is required or permitted by law.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what which products or competitions may be of interest to you and where we consider sending you relevant marketing communications in relation to such products or competitions. We will do this where we consider that we have a legitimate interest in doing so and you have not asked us to stop.

You will also receive marketing communications from us if you have requested information from us, opened an account, purchased goods or services from us, entered a competition or prize draw and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time using the contact details set out in section 10.

Where you opt out of receiving these marketing messages, you will still receive service-related communications that are essential for administrative or customer services purposes (including updates to our various terms and conditions and checking that your details are correct), and such opt out will not apply to personal data provided to us as a result of any additional product/service purchase/competition entry, warranty registration, product/service experience or for other legitimate reasons.

Automated Decision Making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Cookies

Cookies are small text files which is sent by a website, accepted by a web browser and then placed on your hard drive, and are generally used to make a user's experience more efficient. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

We use cookies to personalise content and ads, provide social media features, analyse traffic to our website, and helps you avoid having to re-enter information during your visit or on subsequent visits. We share information about your use of our website with our social media, advertising and analytics partners.

The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission.

This website uses different types of cookies. Some cookies are placed by third party services that appear on our pages.

You can at any time change or withdraw your consent from the Cookie Declaration on our website. Please note that cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. If you clear all cookies, this will also remove the cookie that remembers your cookie preferences every time you visit our website. If you use incognito or private browsing mode, you will have to refresh your cookie preferences every time you visit the website.  

There are four types of cookies and technology:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Outlined below is how and why we use these cookies in practice.

5. Disclosures of your personal data

We may share your personal data with the parties set out below, for the purposes set out in the table included under the heading “Purposes for which we will use your personal data” above.

• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. We may also share your personal data with our professional advisers in these circumstances and the prospective purchaser’s or target’s professional advisers, for the purposes of the transaction only. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We may have to share your personal data outside the United Kingdom (“UK”) and/or the European Economic Area (“EEA”). Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK GDPR and UK data protection laws, we will ensure that a similar degree of protection is afforded to it by ensuring that safeguards are implemented in compliance with data protection laws including: the EU Commissions' Standard Contractual Clauses and the UK Addendum to these, the UK's International Data Transfer Agreement and/or the EU-U.S. Data Privacy Framework with the UK Extension to this. You can request more information on the safeguards we rely on or ask to obtain a copy of these by getting in touch with us using the contact details set out below.

7. Data security

We have put in place appropriate security measures to protect the security of your personal data, including 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. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

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.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Where we process personal data for marketing purposes or with your consent, we process the data until you ask up to stop, or opt-out, and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data.

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 and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us.

In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with data protection laws. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

As referred to above, not all of these rights are absolute and there may be situations in which you cannot exercise them or they are not relevant. If you wish to exercise any of these rights, please contact us using the contact details set out in section 10.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Email: support@sprucecollective.co.uk

Address: CELTIC LUCK LTD, CASTLE HOUSE, CASTLE STREET, GUILDFORD, SURREY, GU1 3UW

Contact number: 0330 223 1373

We are the data controller unless otherwise specified.

You have the right to make a complaint at any time to the ICO (ICO), the UK regulator 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.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review and may update this privacy policy at any time either by emailing you (should we make substantial updates) or by posting updates on the websites from time to time. This version was last updated on 23rd June 2025.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example, a new email address or address.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

11. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Consent means processing your personal data if you have given your explicit agreement.

THIRD PARTIES

External Third Parties

• Service providers and business partners based in (and outside) the UK who provide IT and system administration services, such as Webflow, companies that host our data, process secure payments, send newsletters and marketing messages, support email and messaging services, serve online behavioural advertising, advertising agencies, fraud prevention agencies.
• Professional advisers including lawyers, bankers, auditors and insurers based in (and outside) the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators, law enforcement agencies and courts, and other authorities such as the Gambling Authority, GAMSTOP and the Advertising Standards Authority who require reporting of processing activities in certain circumstances.

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