Spire or “we” is committed to protect and respect your privacy.
This Policy (and other documents referred to herein) describes what personal information we collect from you and how we process that information.
Personal information we collect about you
- We collect personal data from your visits to the Website including, but not limited to, traffic data, location data, weblogs, survey and contact forms, and other communication data. as well as the resources you access. The fact that we collect your personal information will facilitate your visit to the Website in the future, since we will be able to offer you relevant Content based on the location from which you access the Site.
- We will collect any information you provide us when you use our contact forms. The transmission of your personal data via our contact forms is not a regulatory or contractual requirement. However, please note that the fields marked with an asterisk (*) are mandatory because we need this information to answer your request. Other information or personal data that you share with us when completing our contact forms is at your sole discretion. When you contact us, we record and keep this correspondence.
- We use your personal data to send you direct marketing communications by e-mail, if you have selected this option in the corresponding form. You can unsubscribe at any time to stop receiving such communications.
How do we use your personal information?
Your personal data will be collected and processed for the following purposes:
- Provide the most appropriate Content and Resources according to your preferences.
- Answer your questions and requests when you contact us.
- Send you additional information, such as upcoming events or Spire newsletters, that may be of interest to you.
- Allow us to create, publish and improve the Content that is most relevant to you.
- Ensure that the Content provided through the Website is presented in the most efficient manner for you and best suited to your device.
- Allow you to benefit from the interactive features of our Website, whenever you wish.
- Develop and further improve the Website and the systems to better serve you.
When we collect personal data for other purposes, specific information is then issued to you when you provide us with this data.
Our use of your personal information as described above is permitted by applicable data protection law as it is:
- Necessary for our legitimate interests in the pursuit of the purposes outlined above; these interests can not, in any situation, prevail over the protection of your private life;
- In certain cases, necessary to the respect of our legal and regulatory responsibilities, such as the disclosure to the competent authorities, the regulators or the public institutions; or
- In certain cases, necessary for the performance of a task performed in the public interest and, in case of recourse to particular categories of personal data, necessary to establish, exercise or defend rights in the framework of legal action or for processing related to personal data that is clearly in the public domain;
- In certain circumstances, made with your consent, which you periodically transmit to us when, for example, you agree to receive marketing communications and news by e-mail.
The retention period of your personal data depends on the purpose of the processing of these data and the tool used for their processing. It is not possible to set out the different data retention periods in a reasonably understandable way in this Policy. The criteria used to determine the applicable data retention period are as follows: we will retain the personal information defined in this policy as long as (1) necessary to achieve the intended purposes, (2) as necessary for the purpose of our business relationship with you, (3) you consent to it and / or (4) as required by applicable data retention laws and regulations.
Third party communication
In order to facilitate the use of your information and to provide you with content and / or resources, we communicate your data to third parties. However, this communication will take place only in the following circumstances:
- Communication to Suppliers, Providers : Periodically, we may engage or use other companies to perform certain functions on our behalf. For example, this may be the case for the hosting and / or maintenance of the content of the Website, the provision of certain features on the Site or the provision of marketing services. The third-party recipients to whom we transmit your data will have access to them only to the extent necessary to perform their functions, and may not use your personal information for any other purpose. These recipients will be subject to contractual confidentiality obligations.
- Communication to government or law enforcement authorities if we determine, in our sole discretion, that we are legally required to do so.
IP addresses and cookies
We collect information about your computer, including (where possible), your IP address, operating system, and browser type, for system administration purposes. This is statistical data about the browsing habits and behaviors of our users who do not identify you or any other individual.
If you share your computer with others, we advise you not to select the “Remember me” option when it is offered by the Website.
Where are your personal information stored and processed?
As explained above in the section “Communication to third parties”, we communicate your personal data to suppliers, third-party service providers or agents. When we use a third-party provider, service provider or agent, your data remains under our control and means of verification are in place to ensure the adequate protection of your personal information.
We endeavour to take all reasonable steps to ensure that your personal data is securely processed in accordance with this Policy.
Although we are committed to taking steps to protect your personal information, you should be aware that the transmission of information over the Internet is not completely secure. We therefore cannot guarantee the security of your personal data communicated on the Website or to any third party and for this reason, any transmission of data is your sole responsibility. We will use strict operational procedures and adequate technical and organizational security measures to prevent unauthorized access, modification, deletion or transmission of such data.
Marketing Related Communications
We will send you communications for marketing purposes, by e-mail, only if you have consented.
In principle, a check box will be present in the forms we use to collect your personal information. If you agree to receive marketing communications, you will signify your agreement by checking this box. If marketing communications are sent to you by e-mail and you no longer wish to receive such communications, you can unsubscribe by clicking on the unsubscribe or unsubscribe link in the e-mail. You can also exercise your right to unsubscribe at any time by contacting us at email@example.com and providing the following information: your name, your e-mail address, your telephone number, marketing communications that you no longer wish to receive.
Changes to this Policy
The terms and conditions of this Policy may be amended from time to time. Any material changes to this Policy will be posted on this website or communicated to you via any other means available.
Questions, comments and requests regarding this Policy are welcome and should be sent by e-mail to our local data protection expert at firstname.lastname@example.org