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(Version 1.0, May 2018)

When you use our Website, we collect and process personal data about you. This document helps you understand what personal information we collect about you, how we collect it, what we use it for, and what rights you have regarding your personal data.

When we talk about “Spire,” “we,” “us” or “our,” we mean Spire Business Communications Limited and our associated companies. We also use “Policy” to refer to this Privacy Policy and “Website” to refer to our applications and all of Spire’s websites, like www.spirecom.com etcSpire Business Communications Limited is the entity responsible for processing your personal data.
1  Personal data – what we collect and what we use it for
1.1  Master data

When you request information of our products and services we will automatically generate a personal account for you on our internal ‘CRM software’ Customer Relationship Management software and collect the following personal data about you (the “Master Data”):
• Your name.
• Your email address.
• The name of the company you work for.
• Your contact telephone number

This information is mandatory, which means that it will not be possible to send you details of the service or product you have requested without it. You can choose to add further personal data to your profile. The additional data you can add is your company name, company sector, number of employees in the business and when you may be considering implementing these services or products. This additional information will be part of the initial questionnaire and will also be part of the Master Data.

1.2  Information in reviews and ratings
When you write a review about Spire and post it on our Website, we collect the information you put in your review. This includes:
• Which company you review ie Spire Communications or Spire Business Management Services.
• The type of service experiences your review concerns.
• The headline and content of your review
• Your rating of your Service Experience with the company (1-5 stars)
• The date of your review and, if you update your review, the date on which it is edited
• A reference number or order ID (if you or the company provides one

Please don’t share any sensitive personal documents or information with us, either concerning yourself or others

1.3  Cookies
Our Website uses cookies. Cookies identify your computer or device rather than you as an individual user, and are used for different purposes.
Read more about which cookies the Website uses and for which purposes below (in 8)

1.4  Your IP address, browser settings and location
When you visit the Website, we register your computer’s IP address and browser settings. The IP address is the numerical address of the computer used to visit the Website. Browser settings can include the type of browser you use, browser language, and time zone. We collect this information so that we can trace the computer used in cases of misuse or unlawful actions in connection with visits to or use of the Website. We also use the IP address to approximate your location (at city level) and so that we know which sets of our Terms & Conditions apply to your use of our Website.

1.5  Newsletters and digest emails
We collect the information you provide us with when you subscribe to receive our newsletters, digest emails or similar (we collect your name, email address and newsletter preferences). If you no longer wish to receive our newsletters, digest emails or similar, you can unsubscribe by following the instructions within the correspondence we send to you

1.6  For what purposes do we use your personal information?
We will use the information you provide to us to:
• Provide our services to you, including displaying your reviews, and providing you with access to your profile and our Website
• Identify you as a registered user when you log in to the Website and re-visit the Website
• Verify the legitimacy of your reviews
• Improve the Website and our services
• Invite you to leave more reviews
• Respond to your questions and provide related customer service
• Pass on a message from the company you reviewed via the Website
• Contact you if your review is flagged by other users or companies and, if necessary, ask you to provide documentation to verify your review or experience
• Send you our newsletters
• Inform you when other users find your review helpful or otherwise provide feedback concerning your review
• Engage in various internal business purposes, i.e data analysis, audits, fraud monitoring and prevention, developing new products and services, improving or modifying the Website, , identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities
• Comply with legal requirements and legal process, requests from public and governmental authorities, relevant industry standards and our internal policies
• Enforce our Terms and Conditions.
• Protect our operations or those of any of our affiliates
• Protect our rights, privacy, safety or property and/or that of our affiliates, you or others
• Allow us to pursue available remedies or limit any damages that we sustain
We will also use the information in other ways for which we provide specific notice at the time of collection

1.7  On what legal basis do we process your personal data?
We need to process your personal information in order to:
• Perform our contract with you (see Article 6.1.b of the GDPR)
• Comply with our legal obligations (see Article 6.1.c of the GDPR) and operate an online review platform in compliance with, for example, the Unfair Commercial Practices Directive, ICPEN’s guidelines on online reviews and endorsements, The Consumer Protection from Unfair Trading Regulations 2008, The Competition and Markets Authority’s guidance on online reviews and endorsements, the Danish Consumer Ombudsman’s Guidelines on publication of user reviews, the Danish Marketing Practices Act etc.
• Pursue legitimate business interests of our own related to operating the Website and providing our services to you, or to pursue the legitimate interests of third parties as long as your interests and fundamental rights do not override those interests (see Article 6.1.f of the GDPR).
• For the establishment, exercise or defence of legal claims, where necessary (see Article 9.2.f of the GDPR)
Some of these grounds for processing your personal data overlap, so there may be several reasons which justify us processing your personal information.
In those limited circumstances where you have expressly given your consent to us to process your personal data (see Article 6.1.a of the GDPR), for example, when subscribing to our newsletters, you are free to revoke your consent at any time. However, please be aware that we may have the right to continue to process your information if it can be justified on one of the other legal bases mentioned above.
You have the right to object to how we process your personal information, or ask us to restrict the processing. Please see below, at 13, for more details.
If you would like more information about our legal basis for processing your personal information, please contact our Data Protection Officer (DPO) emailing privacy@spiretechgroup.com

2  Disclosure of personal information
2.1  Disclosure of personal information on the Website
We are an open review platform and we share your review on our Website so that others can read about your experience with a specific product or service. When you write a review, we will disclose your review, your name and company.
We recommend that you exercise care in deciding which information to make available for disclosing on the Website, and be aware that depending on the level of information provided, you may or may not be anonymous.
Social Networks

2.2  Disclosure to other services, websites and companies
One of our main goals is to increase the exposure and availability of reviews on the Website. We therefore permit other services to show reviews created on the Website. This increases the potential audience for your reviews.
The categories of third party services and companies who can show your review(s) are:
• Search engines, including Google and Bing
• Other similar websites where, such as Spires assessment, it will be relevant for users to search for reviews.
• Facebook and Linkedin “If your review has been shared on the Social Network”
Once you submit your review, it is published on the Website. This means that the following information is disclosed:
• Your review(s), (see 1.2, above)
• Your name and the additional data you choose to add such as your sector.

2.3  Other disclosures
In addition to the above, we disclose your personal information to the following parties and in the following circumstances:
• To Spire subsidiaries and other companies within the Spire group of companies
• To comply with laws or to respond to claims, legal process (including but not limited to subpoenas and court orders) and requests from public and government authorities
• To cooperate with regulatory bodies and government authorities, including but not limited to Trading Standards, The Competition and Markets Authority, and the Danish Consumer Ombudsman, in connection with investigations or case referrals
• To third parties in connection with enforcement of our Terms and Conditions and Guidelines
• To third parties in order for us to protect our operations or those of our affiliates
• To third parties in order for us to pursue available remedies, or limit damages that we may sustain
• To third parties in order for us to investigate, prevent or take action regarding suspected or actual prohibited activities, including but not limited to fraud and misuse of our Website
• To a third party in the event of any reorganization, merger, acquisition, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in connection with any bankruptcy or similar proceedings)

3  Data controller
3.1  Information for which we are the data controller
We are the data controller of the Master Data you enter to create and maintain your profile, which includes but is not limited to your name, telephone number(s) and email address, as well as the registration of your IP address

3.2  Information for which you are the data controller
You are the data controller for the content you choose to disclose on the Website.

4  Links to websites
Our Website contains links to other websites. Our inclusion of such links does not imply that we endorse those websites. We do not control the content of those third party websites, and assume no responsibility for the third party or their policies or practices.
We encourage you to review the privacy policies for these third party websites because their procedures for collecting, handling and processing personal data will be different from ours.

5  Data processors and transfer of personal information outside the EU
We may use external companies to maintain the technical operation of the Website and our services. These companies are data processors for the personal data for which we are the data controller. By accepting this Policy, you agree that we may also allow the data for which you are the data controller to be processed by these data processors.
Should we decide to use external companies, we will have data processing agreements in place with the data processors and it follows from these agreements that they must act solely in accordance with our instructions. By accepting this Policy, you authorize us to instruct the data processors to process data in accordance with the Policy and for the purposes of using the Website.

The data processors have taken reasonable technical and organizational measures to protect against the information being accidentally or illegally destroyed, becoming lost or deteriorating, and to protect against the information being disclosed to unauthorized persons, being misused, or in other ways being processed in violation of data protection laws.

On your request – and possibly in return for remuneration at the data processors’ applicable hourly rates at any time for such work – the data processors must supply you with sufficient information to demonstrate that the above-mentioned technical and organizational safety measures have been taken.

Some of these data processors and third party services will be located outside of the European Union, such as in the US. You consent to us using data processors in unsecure third countries provided that there is a legal framework governing the transfer of your personal data and ensuring adequate protection of it, for example if the data processor is part of the EU-US Privacy Shield framework.

6  Data retention
We keep the Master Data and other personal data you provide, including your reviews, for as long as you have an Account or as needed to provide you with information of our services. If you choose to close your Account please note that all your reviews will not be deleted. We will delete this information upon your request and we will only save a log with the following information: your name, email address and the date of the deletion of your Account. We will keep the log for 3 years. All other information will be deleted.

7  Security measures
We use reasonable organizational, technical and administrative measures to protect your personal information within our organization and we regularly audit our system for vulnerabilities. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of the information you transmit to us. Emails sent via the Website may not be encrypted, and we therefore advise you not to include any confidential information in your emails to us.

8  Cookies
The Website uses cookies and similar technologies (“Cookies”). By using our Website, you accept that we use Cookies as described below.

8.1  What types of Cookies do we use?
Cookies are small pieces of information that the Website places on your computer’s hard disk, on your tablet or on your smartphone. Note that HTML5 introduced Web Storage that has a similar nature to Cookies, and that we therefore consider that as a Cookie in the following.
Cookies contain information that the Website uses to make the communication between you and your web browser more efficient. Cookies identify your computer or device rather than you as an individual user.
We use session cookies, persistent cookies, HTML5 sessionStorage and HTML5 localStorage session cookies and HTML5 sessionStorage objects are temporary in nature and are deleted when you exit your web browser. Persistent cookies are permanent in nature and are stored and remain on your computer until they are deleted. Persistent cookies expire or auto delete after a certain period of time, which is set per cookie, but are renewed each time you visit the Website. HTML5 localStorage objects are permanent in nature and remain on your computer until they are deleted.

8.2  What do we use Cookies for?
We use Cookies for:
Generating statistics
Measuring Website traffic such as the number of visits to the Website, which domains the visitors come from, which pages they visit on the Website and in which overall geographical areas the visitors are located.
Monitoring Website performance and your use of our Website
Monitoring the performance of the Website, our applications and how you use our Website and applications.
Authentication and improving the functionality of our Website
Optimizing your experience with the Website, which includes remembering your username and password when you return to the Website, and remembering information about your browser and preferences (e.g. which language you prefer).

Quality assurance
Ensuring the quality of reviews and to prevent misuse or irregularities in connection with writing reviews and using the Website.
Targeted advertisements
Displaying relevant advertisements on the Website, including interest-based advertisements, which we believe are of interest to you. We may use third parties to provide these advertisements when you visit the Website and other websites. These third parties may use Cookies alone or in conjunction with web beacons or other tracking technologies to collect information about your use of our Website and other websites.

8.3  Third party Cookies
Third party Cookies are set by third party websites – not our Website. When you visit our Website, the following third party Cookies may be set:
• Facebook cookies, set when you log in to our Website with Facebook
• Google cookies, set when you log in to our Website with Google
• Google AdSense cookies, set when displaying relevant targeted advertisements on our Website. Some cookies may be set as DoubleClick, which is part of Google.

8.4  Deletion of cookies
You can delete the cookies already on your device. You can typically delete cookies from the Privacy or History area, available from the Settings or Options menu in the browser. In most browsers, the same menu can be reached through the Ctrl+Shift+Del keyboard shortcut or Command+Shift+Del if you’re on a Mac.
If you do not accept Cookies from our Website, you may experience inconvenience in your use of the Website, and you may be prevented from accessing some of its features.
9  Access and insights into the personal data we have about you
If you have an Account on our website, you can log in to your Account and see what information we have about you.
If you don’t have an Account, you can email privacy@spirecom.com and request information about your personal data. Upon receiving your request, we will let you know what personal information we have about you, how we collect the information, the purpose for which we process your personal data, and who we share your personal information with.
10.  Correction and deletion of your personal data
If any of the Master Data or other personal information that we have about you in our capacity as a data controller is incorrect or misleading, you can instruct us to correct this information by emailing us at privacy@spirecom.com. We recommend that you clearly detail the correction(s).Otherwise, you are welcome to call us to assist with correcting your information via the telephone on 0800 0210100.
You may at any time correct or delete any content and personal information on the Website for which you are the data controller (see 3.2). If your personal information changes, or if you no longer wish to appear on the Website, this information can be deleted by contacting us as mentioned in the previous paragraph.
If your Account is deleted, all the data associated with your Account will be deleted, with the exception of your reviews, name and company name. If specifically requested we will remove your review(s) however will retain your name and company name for 5 years with an instruction within our CRM system not to contact you with any future advertising related correspondence.
We reserve the right to block access to your Account and/or delete it if the Account or the content associated with your Account or your review(s) on the Website is, in our assessment, discriminating, racist, sexually oriented, unethical, threatening, offensive, harassing or otherwise violates applicable laws, third party rights or our Terms and Conditions, or is inconsistent with the purpose of the Website. If we block access to or delete your Account, we will inform you of the reason for blocking or deleting your Account by sending an email to the address you provided when you created your Account.

11  Other rights
In addition to the rights set out above concerning your personal data, you also have the following rights:
• You also have the right to object to the processing of your personal data and have the processing of your personal data restricted.
• In particular, you have an unconditional right to object to the processing of your personal data for direct marketing purposes.
• If our processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing of data carried out before you withdrew your consent. You may withdraw your consent by emailing us at privacy@spirecom.com.
In some circumstances, these rights may be limited or conditional. For example, whether or not you have the right to data portability in a particular case depends on the specific circumstances of the processing activity.

12  Children’s information
Our Website is not intended for children. If you become aware that a child under the age of 13 has provided us with their personal information, please contact us.
13 Our Data Protection Officer
We have a Data Protection Officer (DPO). If you have any questions about the data processing activities performed by us, you are welcome to contact our DPO by email at privacy@spiretechgroup.com

14  Changes to this Policy
We reserve the right to make changes to this Policy. The date shown at the start of this Policy indicates when it was last revised. If we make material changes to it, we will provide notice through our Website, or by other means, to give you the opportunity to review the changes before they come into effect. If you object to our changes, you can close your account. Your continued use of our Website after we publish or send a notice about the changes to the Policy will mean that you accept and agree to the updated Policy

15  Contact information and where to send questions or complaints
If you have questions or concerns about our Policy, how we process your personal information, or would like us to correct your personal information, feel free to contact us at:  privacy@spiretechgroup.com
You can also reach us by post.
If contacting us does not resolve your complaint, you have further options, for example you may always lodge your concern with the Information Commissioners Office https://ico.org.uk/concerns

Our contact details are:
Data Protection Officer – Paul Valentine
C/o Spire Business Communications Limited
County House, St Marys Street, Worcester WR11HB