Shpun respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 

2. Important information and who we are Purpose of this privacy policy 

 This privacy policy aims to give you information on how Shpun collects and processes your personal data through your use of this website, including any data you may provide through this website. 

 This website is not intended for children, and we do not knowingly collect data relating to children. 

 It is important that you read this privacy policy together with any other privacy 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. We have a separate privacy policy that applies to our customers. 

For details of what cookies we use on our site, please our Cookie Policy. 

Controller 

 M A Fastmove Limited t/a Shpun is the controller and responsible for your personal data (collectively referred to as “Shpun”, “we”, “us” or “our” in this privacy policy). We are registered with the ICO under reference ZA572291. 

Contact details 

If you have any questions about this privacy policy, including any requests to exercise your legal rights, or our privacy practices, please contact our data privacy manager in the following ways: 

Full name of legal entity: M A Fastmove Limited  

Email address: info@shpun.co.uk 

Postal address: Orega Birmingham, 20 Colmore Circus Queensway, Birmingham, England, B4 6AT  

Telephone number: +44 (0) 121 3280011

You have the right to make a complaint at any time to the Information Commissioner’s Office (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. This version was last updated on 03/01/2024. 

It is important that the personal data we hold about you is accurate and current. Please keep us informed as appropriate if your personal data changes during your relationship with us. 

Third-party links 

This website may include links to third-party websites, and use plug-ins. 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 policies. When you leave our website, we encourage you to read the privacy policy of every website you visit. 

3. The data we collect about you 

Personal data, or personal information, means any information about a living individual from which that person can be identified directly or indirectly. 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, and your company name. 

• Contact Data includes email address(es) and telephone number(s). 

• Other Data includes any other personal data that you may provide as part of communicating with us.  
• Technical Data includes internet protocol (IP) address, 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. 

• Usage Data includes information about how you use our website. 

 

We may 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 would not be considered personal data in 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. 

4. 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, Other and Contact Data by filling in forms or by corresponding with us by post, telephone, or email. This includes personal data you provide when you: 
  • Contact Us by filling in the form available at Contact – Shpun; 
  • give us feedback or contact us about complaints. 
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. The cookies that we use at any particular time are set out in our Cookie Policy.  

 

5. 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 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 send you information about our services that you have requested or to maintain and keep our website secure and relevant or to let a potential purchaser of our business know about possible customers.  
• Where we need to comply with a legal obligation. 

 

To find out more about the types of lawful basis that we will rely on to process your personal data, please see further below. 

Generally, we do not rely on consent as a legal basis for processing your personal data. 

We do not currently carry out any automated decision making or profiling using personal data. 

Purposes for which we will use your personal data 

We have set out below, in a table format, a description of 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.  

 

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance and security, support, reporting and hosting of data)	Identity  Contact  Technical  Usage  Aggregated	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, and to prevent fraud)  Necessary to comply with a legal obligation
To deliver relevant materials and information to you if you fill in the Contact us form and to make contact with you.	Identity  Contact  Other	Necessary for our legitimate interests (for running our business, responding to enquiries,  growing, selling or merging our business and to inform our marketing strategy)

 
Marketing 

If in future we chose to undertake any unsolicited direct marketing, we will provide you with choices regarding certain personal data uses and provide an easy to way to unsubscribe or object to receiving further direct marketing. 

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 you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

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. 

However, please note that we may also process your personal data without your knowledge or consent, for example to work with regulatory authorities, where this is required or permitted by law. 

6. 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 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. 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 operating as our processors 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. 

7. International transfers 

If we transfer your personal data out of the UK, we will ensure a similar degree of protection is afforded to it by ensuring an appropriate safeguard is implemented. 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK. 

8. Data security 

We have put in place appropriate security measures 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. 

9. 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. 

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. 

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. 

10. Your legal rights 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are as follows: 

• Request access to your personal data. 
• Request correction of your personal data. 
• Request erasure of your personal data. 
• Object to processing of your personal data. 
• Request restriction of processing your personal data. 
• Request transfer of your personal data. 
• Right to withdraw consent. 

 

These are fully explained in the ICO guidance available at The rights of individuals | ICO  

If you wish to exercise any of the rights set out in the ICO guidance, please contact us in the first instance. 

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. 

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. 

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. 

 

THIRD PARTIES 

External Third Parties  

• Service providers acting as our processors including to provide IT and system administration services or provide you with requested information about our services. 
• Professional advisers acting as controllers including lawyers, bankers, accountants,  auditors and insurers who provide us with consultancy, banking, legal, insurance and accounting services. 
• Regulators and other official authorities.