Privacy Policy

I am committed to processing personal information about my customers in ways that comply with my legal obligations as well as being clear with my customers about what happens with their personal information. Some of the key points of my privacy statement are:

I don’t sell your data to third parties

I do make it easy for you to manage your information, you can change your communication preferences at any time

I do use data to help me provide great customer service, which includes tailoring the information I share with you to help ensure that it’s relevant, useful and timely

You can correspond with me at Tracy Fance (Spirituality Ltd), 7 High View Avenue, Herne Bay, Kent, CT6 8DG England. I share your concern about the protection of your personal information and I’m committed to safeguarding your privacy.

This document covers information collected about you, whether via the website: or, through our customer service team or otherwise. Please read it carefully to understand how your personal information will be treated.

I will be the “controller” of the personal information which you provide to me or which I collect from you.

1. Personal information that I collect

I collect a range of personal information relating to you, including your:

  • name;
  • email address;
  • telephone number;
  • address;
  • IP address; and;
  • any other personal information that you choose to provide when you complete the online contact form or otherwise make contact with me.

2. How I use your personal information

I use your personal information as follows:

  • to maintain my relationship with you whilst you are a customer;
  • to process orders and provide agreed services to you;
  • for invoicing, processing payments, account set up and maintenance;
  • to communicate with you, including to respond to information requests /enquiries submitted and/or to obtain your feedback on any products and services;
  • for record keeping, statistical analysis and internal reporting and research purposes;
  • to ensure data security and to provide you with access to secure areas of the Websites;
  • to notify you about changes to any products and services;
  • to decide on and notify you about price changes;
  • to monitor the quality of any products and services;
  • for logistical purposes, including to plan and log delivery routes;
  • to investigate any complaint you make;
  • to provide evidence in any dispute or anticipated dispute between you and I;
  • to customise various aspects of the Website to improve your experience;
  • to pre-complete online forms on the Website. For example, if you have provided an address when using one service, the Website computers may automatically fill in that information on an order form for another service;
  • as I may otherwise consider necessary to support the operation of my Websites;
  • to obtain credit references, credit checks and for debt collection, fraud detection and prevention and risk management purposes;
  • to monitor and/or record telephone conversations to or from you in order to offer you additional security, resolve complaints, improve our service standards and for staff training purposes; and
  • to protect the rights, property, and/or safety of Spirituality Ltd, its personnel and others.

3. Marketing

I may send you direct marketing in relation to my own products and services by phone and post, as long as this is in line with any marketing preferences that you have provided to me.

I will only send you direct marketing in relation to my own products and services by email:

  • where you are an active client; or
  • where you have consented to this; or
  • where you have not objected to this, and I am marketing similar products and services to those which were the subject of a previous sale or negotiations of a sale to you.

Your agreement to the use of your personal information for direct marketing purposes is optional and if you choose not to consent, your visit to and use of the Website will not be affected.

You can choose to opt out of receiving direct marketing information from me at any time, through the ‘Unsubscribe’ link at the bottom of any email you receive, or by contacting the Customer Service Team:

    • by mail – Tracy Fance, Spirituality Ltd, 7 High View Avenue, Herne Bay, Kent CT6 8DG, England.
    • by email -
    • by telephone – 07946426621 or 01227 749759 
    • by filling in the enquiry form on the website.

4. Automated decision making/profiling

  • Google
  • I use Google for a variety of marketing services, including the Google Customer Match service which matches your email address as provided to me, with information held in your Google account (if you have one) in order to enable Google to show you adverts for my products and services when you are searching on Google, using Google’s search network, shopping function, on YouTube or on Gmail.
  • Other marketing services of Google’s I use include: Google Search which places our adverts within search results; Google Display Network which makes available to me advert space on third party websites; and Google Remarketing which places Tracy Fance's adverts on third party websites following a user having visited my website. These services use cookies (and in some instances information held in your Google account, if you have one) in order to build profiles about you, for the purpose of providing you with personalised adverts. See section below for further details on cookies.
  • You can find out more about how your personal information may be used in connection with Google’s advertising functions and options for opting out here:

5. Legal basis for processing

  • In terms of the legal bases we rely on to process your personal information, these are as follows:
    • where you have provided your consent: for direct marketing communications in respect of our own products and services, including in respect of marketing communications sent by electronic means (e.g. email and SMS);
    • for the performance of a contract with you (such as a contract for the provision of goods and services) or to take steps at your request prior to entering into this contract;
    • to comply with legal obligations, including in relation to health and safety and environmental legislation, performing anti- money laundering, terrorism prevention and sanctions screening checks, complaints and investigations or litigation;
    • to protect your vital interests or the vital interests of another person, e.g. where you or they are seriously injured or ill, or
    • for our legitimate interests in:
        • management of your account (including processing payments) and my relationship with you, and communicating with you
        • operating my website
        • sending direct marketing in respect of my own products and services where you have not provided your consent and the marketing communication is sent by non-electronic means (e.g. post or telephone); processing orders and supplying my products and services; and
        • my internal business purposes which may include processing for the purposes of: record keeping, research, reporting and statistics, data security, to ensure the quality of my products and services, investigating and responding to queries and complaints, obtaining credit references and credit checks, providing payment performance data to credit reference agencies, changing my pricing, debt collection, fraud detection and prevention, risk management, recruitment and training of my personnel, and protecting my rights, property and safety (and that of others). You can object to processing carried out on the basis of our legitimate interests at any time by emailing;
        • See also “Your Rights – The right to object”.

6. How I share your personal information

  • In addition, I may share your personal information with:
    • third party providers in order for us to process payments that are due to us, in doing so we provide bank card details to such providers;
    • third party advertising partners, such as Google in order for them to assist me in providing you with targeted adverts (as explained above);
    • my accountants, auditors, lawyers or similar advisers when I ask them to provide us with professional advice;
    • any Government Department, public body or other third party where I believe in good faith that the law requires this; in the interests of public health and safety; or in order to protect the rights, property, or safety of Spirituality, its employees or others;

7. How long I keep your personal information

  • I retain your personal information for no longer than is necessary for the purposes for which the personal information is collected. When determining the relevant retention periods, I will take into account factors including:
    • legal obligation(s) under applicable law to retain data for a certain period of time;
    • statute of limitations under applicable law(s);
    • (potential) disputes, and;
    • guidelines issued by relevant data protection authorities.
  • Otherwise, I securely erase your information once this is no longer needed.

8. Cookies

  • I collect information directly from you in a number of ways. One way is through the use of ‘cookies’. Most websites use cookies in order to make them work, or to work more efficiently, as well as to provide information to the owner of the website. They help me to understand how my customers and potential customers use my website so I can develop and improve the design, layout, content and function of the site. Cookies are small text files that are placed on your computer’s hard drive by websites that you visit. They save and retrieve pieces of information about your visit to the website – for example, how you entered the site, how you navigated through the site and what information and documentation was of interest to you. This means that when you go back to a website, it can give you tailored options based on the information it has stored about you on your last visit.

    Some of the cookies are used to simply collect information about how visitors use our website and these types of cookies collect information in an anonymous form.

    Where there is a login process relating to buying products or services from me I also use cookies to store personal registration information so that you do not have to provide it to me again on subsequent visits.

    The rules about cookies on websites have recently changed. If you are uncomfortable with the use of cookies, you can disable cookies on your computer by changing the settings in the preferences or options menu in your browser. You can set your browser to reject or block cookies or to tell you when a website tries to put a cookie on your computer. You can also delete any cookies that are already stored on your computer’s hard drive. However, please be aware that if you do delete and block all cookies from my website, parts of the site will not work. This is because some of the cookies I use are essential for parts of the website to operate. Likewise, you may not be able to use some products and services on other websites without cookies.

    To find out more about cookies, including seeing what cookies have been set and how to manage and delete them, visit

    If you do not wish to accept cookies from this website, please leave this site immediately and then delete and block all cookies from this site.

8. Links to third party websites

  • My websites contains links to other internet websites. Unless otherwise explicitly stated, I am not responsible for the privacy practices or the content of such websites, including such sites‘ use of any personal information. Nevertheless, in the event you encounter any third party associated with this website (or who claims association with my websites) who you feel is improperly collecting or using information about you, please contact; we will be happy to forward your message to the third party.

9. Security

  • I use reasonable security methods to protect the personal information that I process, including Internet standard encryption technology (“SSL“ or “Secure Socket Layer“ technology) to encode personal information that you send to us through our Websites. SSL works by using a private key to encrypt data that‘s transferred over the SSL connection. To check that you are in a secure area of the Website before sending personal information to us, please look at the bottom right of your website browser and check that it displays an image of a closed padlock or an unbroken key.
  • However, please note that whilst we take appropriate technical and organisational measures to safeguard the personal information that you provide to me, no transmission over the Internet can be guaranteed to be secure. Consequently, please note that I cannot guarantee the security of any personal information that you transfer to me over the Internet.

10. Your rights

  • The following section explains your rights. The various rights are not absolute and each is subject to certain exceptions or qualifications.
  • I will grant your request only to the extent that it follows from my assessment of your request that I am allowed and required to do so under data protection laws. Nothing in this Privacy Statement is intended to provide you with rights beyond or in addition to your rights as a data subject under data protection laws.

10.1. The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how I use your personal information and your rights. This is why I'm providing you with the information in this Privacy Statement.

10.2. The right of access

You have the right to obtain a copy of your personal information (if I'm processing it), and other certain information (similar to that provided in this Privacy Statement) about how it is used.

This is so you’re aware and can check that I'm using your personal information in accordance with data protection law.

I can refuse to provide information where to do so may reveal personal information about another person or would otherwise negatively impact another person‘s rights.

10.3. The right to rectification

You can ask me to take reasonable measures to correct your personal information if it is inaccurate or incomplete. E.g. if we have the wrong date of birth or name for you.

10.4. The right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal information where there’s no compelling reason for me to keep using it or its use is unlawful. This is not a general right to erasure; there are exceptions, e.g. where we need to use the information in defence of a legal claim.

10.5. The right to restrict processing

You have rights to ‘block’ or suppress further use of your personal information when I'm assessing a request for rectification or as an alternative to erasure. When processing is restricted, I can still store your personal information, but may not use it further. I keep lists of people who have asked for further use of their personal information to be ‘blocked’ to make sure the restriction is respected in future.

10.6. The right to data portability

You have rights to obtain and reuse certain personal information for your own purposes across different organisations. This enables you to move, copy or transfer your personal information easily between our IT systems and theirs (or directly to yourself) safely and securely, without affecting its usability. This only applies to your personal information that you have provided to me, that we are processing with your consent or to perform a contract which you are a party to (such as pay and compensation services), which is being processed by automated means.

10.7. The right to object

You have the right to object to certain types of processing, on grounds relating to your particular situation, at any time insofar as that processing takes place for the purposes of legitimate interests pursued by Spirituality Ltd or by a third party. We will be allowed to continue to process the personal information if I can demonstrate “compelling legitimate grounds for the processing which override [your] interests, rights and freedoms” or I need this for the establishment, exercise or defence of legal claims.

10.8. Rights in relation to automated decision making and profiling

You have the right not to be subject to a decision based solely on automated processing (including profiling), which significantly affects you, subject to some exceptions. Where this is the case, you have the right to obtain human intervention, voice your concerns and to have the decision reviewed.

11. Updating this statement

I review the privacy practices from time to time. I ask that you bookmark and periodically review this page for updates to the Privacy Statement. I reserve the right to modify this policy effective seven (7) days after the posting of the revised Privacy Statement.

12. Contact us

For further information regarding these rights, about this Privacy Statement generally or to make a complaint please contact our Data Protection Officer at; or by calling 07946426621 or 01227 749759.

Please provide as much information as possible to help me to identify the information you are requesting, the action you are wanting me to take and why you believe this action should be taken.

Before assessing your request, I may request additional information in order to identify you. If you do not provide the requested information and, as a result I am not in a position to identify you, I may refuse to action your request.

I will generally respond to your request within one month of receipt of your request. I can extend this period by an additional two months if this is necessary taking into account the complexity and number of requests that you have submitted.

I will not charge you for such communications or actions I take, unless:

You request additional copies of your personal data undergoing processing, in which case I may charge for our reasonable administrative costs, or

you submit manifestly unfounded or excessive requests, in particular because of their repetitive character, in which case I may either: (a) charge for our reasonable administrative costs; or (b) refuse to act on the request.

If after contacting Tracy Fance (Spirituality Ltd) you are still unhappy you may also complain to the Information Commissioner, all contact details are available on the Information Commissioner‘s Website:

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