Privacy Policy

Spire Capital Ltd Data Protection Policy

This website is maintained by Spire Capital Ltd. We fully respect your right to privacy. Any personal data you provide will be used for the purpose for which you supply it and will be treated with the highest standards of security and confidentiality, strictly in accordance with the Data Protection Acts and applicable EU directives. It will only be shared, if necessary, in accordance with law and where you have given consent.

This statement relates to our privacy practices in connection with this website. Some technical terms used in this statement are explained at the end of this page.

The General Data Protection Regulation (GDPR) (EU) 2016/679

is a regulation in EU law on data protection and privacy for all individuals within the European Union. It also addresses the export of personal data outside the EU. The GDPR aims primarily to give control to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU.

What is “personal data”?

Personal data means data relating to a person who is or can be identified either from the data itself or in conjunction with other information that is in, or is likely to come into, the possession of Spire Capital Ltd. It covers any information that relates to an identifiable, living individual. This data can be held on computers or in manual files.

Data Controller

A “data controller” means a person who, either alone or with others, controls the contents and use of personal data. Spire Capital Ltd is a data controller. Address is The Masonry, 151, 156 Thomas St, Usher’s Island, Dublin, D08 PY5E.

 Spire Capital Ltd obligations

Our obligations under the The General Data Protection Regulation are that:

• Data must be obtained and processed fairly.
• Data must be accurate, complete and where necessary, kept up to date.
• Data must have been obtained only for one or more specified, explicit and legitimate purpose.
• Data must not be further processed in a manner incompatible with that purpose.
• Data must be adequate, relevant and not excessive in relation to the purpose for which they were collected or are further processed.
• Data must not be kept for longer than is necessary for that purpose.
• Appropriate security measures must be taken against unauthorised access to, or unauthorised alteration, disclosure or destruction of the data, in particular where the processing involves the transmission of data over a network, and against all other unlawful forms of processing. Spire Capital Ltd employs the most appropriate physical and technical measures, including staff training and awareness and these are reviewed regularly.
• We owe a duty of care to the data subjects concerned, i.e. we must take care not to cause any of our customers damage or distress by, for example, maintaining inaccurate information on our files, or disclosing personal data to someone who is not entitled to this data.

Spire Capital Ltd takes its obligations very seriously and adopts the strongest line in relation to the misuse of customer information by any of its staff. Any breach of trust with regard to the confidentiality of information is treated as serious misconduct under the Disciplinary Code and can lead to sanctions up to and including dismissal.

Collection and use of personal information

This website does not collect any personal data, apart from information that you volunteer (for example, when filling a form and registering to become a member) and your IP address. Any information you provide in this way is used only for the use for which you provide it, such as:

• if you send us a message through forms on our website or correspond with us by telephone in writing or otherwise;
• if you subscribe to our Newsletter;
• If you participate in a discussion board in the comment section or social media functions;
• if you enter a competition, promotion or survey;
• if you report a problem to us;

Information we receive from other sources.

Others may post, write about and ‘tag’ you, or link to your profile through the social networks or comment section. You and others may post content that includes information about you on our website.

Customers and partners may provide data to us.

We sometimes work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers) and may receive information about you from them. At present these services are:

• Google Analytics
• Google GSuite
• Sumo
• Google Cloud Platform
• Mailchimp
• Unbounce
• Hubspot

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information in the following ways:

• to send you information about your account, your personal investment and other relevant information
• to authenticate you and send you the specific information you requested
• to alert you of relevant opportunities and activities (including, without limitation, newsletters, product updates)
• to allow you to stay in touch with our investment consultants,
• to send you newsletters which you may either elect to receive or may be interested in given your e-mail information and/or profile and/to provide you with any other information or services you request that we provide.

Except as set out in this Data Protection Policy or otherwise agreed by you, we will not share your personal information with third parties (such as marketing companies) or use your personal information other than for our internal purposes.

We do not store credit card details.

We monitor for and try to prevent security breaches.

Right of Access

A person has a right to be given a copy of his/her personal data. This subject access request (SAR) must be in writing through the postal service and is free of charge. You can make a subject access request by writing to info@spirecapital.ie. Your request should be as specific as possible, to enable us to identify where the particular data is held and also include evidence of your own identity such as a photocopy of your passport or photocopy of your driving license. A response to your access request will issue to you as soon as is possible and in any event within forty days.

Data Protection Acts set out a small number of circumstances in which your right to see your personal records can be limited. This is necessary in order to strike a balance between the rights of the individual, on the one hand, and some important needs of civil society, on the other hand. For example, the right of access to medical data is restricted in some very limited circumstances, where the health and mental well-being of the individual might be affected by obtaining access to the data. Your right to obtain access to examination results and to see information relating to other people is also curtailed.

Right of rectification or deletion

Under section 13 b) of the GDPR a person has a right to have his/her personal data corrected, if inaccurate, or erased, if there is not a legitimate reason for retaining the data. Spire Capital Ltd makes every effort to ensure that your personal data is accurate and only retained for as long as it is required. If you have reason to believe that your personal data held by Spire Capital Ltd is not accurate or should no longer be retained you can write to Spire Capital Ltd on the issue setting out clearly what personal data is at issue and the reasons why you consider it to be inaccurate and/or why Spire Capital Ltd should no longer retain it. There is no fee for this service. Write to Spire Capital Ltd, The Masonry, 151, 156 Thomas St, Usher’s Island, Dublin, D08 PY5E.

Right to revoke permission

Under section 13 c) of the GDPR a person has a right to revoke his/her permission to use their personal data at any time not affecting the legitimacy of the usage of such data prior to the revocation.

Concerns over Data Protection

If you are concerned that an official has accessed your personal information illegally and or that your personal data may have been disclosed to a 3rd party illegally you can make a formal written complaint to:

Spire Capital Ltd, The Masonry, 151, 156 Thomas St, Usher’s Island, Dublin, D08 PY5E.

The matter will be investigated by Spire Capital Ltd and you will be notified regarding the outcome of the investigation as soon as possible.

Information we routinely collect

We may collect the following information from each user of this site:

• Statistical information (IP address and hostname, web browser version, Spire Capital pages visited etc.).
• The previous website address from which you reached us, including any search terms used.
• Other information submitted in forms, for example if you submit your personal details when requesting or submitting an online form.
• The date and time you access our site.

Cookies

Cookies are small pieces of information, stored in simple text files, placed on your computer by a website. Some cookies can be read by the website on your subsequent visits. The information stored in a cookie may relate to your browsing habits on the webpage, or a unique identification number so that the website can ‘remember’ you on your return visit. Other cookies are deleted when you close your browser and only relate to the working of the website. Generally speaking, cookies do not contain personal information from which you can be identified, unless you have furnished such information to the website.

Cookies may be set in a number of places on this website:

• When you first visit this website, you will see a message informing you about the privacy statement. If you click the ‘Hide this message’ button, a Cookie will be set which records this action.
• Cookies are created to capture information for use with website analytics. They help to provide Spire Capital with accurate statistics to provide a better service.

Most browsers allow you to turn off Cookies or to customise your settings for cookies. To find out how to do this, see the ‘Help’ menu on your browser. Please note that if you turn off cookies or change your settings, some features on Spire Capital Ltd may not work correctly.

Links

This website may contain links to other websites. Spire Capital Ltd is not responsible for these sites or for the privacy statements of other websites.

Notification of Change

Spire Capital Ltd reserves the right to amend this statement at any future date and will post any substantive changes here.

Glossary of technical terms used

Web Browser

A web browser is the piece of software you use to read web pages. Examples are Microsoft Internet Explorer, Chrome, Safari, Mozilla Firefox and Opera.

IP Address

Your IP address identifies your computer (or your internet service provider’s computer) in internet protocol code (for example 123.456.78.90). Every computer connected to the web has a unique IP address, although the address may not be the same every time a connection is made