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Spire Mobility Intelligence Application Privacy Policy

 

This mobile application is owned and managed by Spire Software Solutions Ltd, Westpoint Offices, Collinstown Lane, Co. Dublin K61 A0P9, Ireland.

Spire Software Solutions Ltd. respect Your right to privacy and We are committed to protecting Your personal data. This Privacy Policy informs You how We use, process, store or disclose any Personal Data that We collect from You or that You provide to Us by using this application and the services provided by it.

If We amend this policy, in whole or in part, any changes which affect You will be notified to You through the application before these new activities commence.

Please note that if You disagree with this Privacy Policy or any changes that are subsequently made to this policy then You should discontinue using Our Services.

Version created August 2019.

 

The Personal Data We Collect from You:

Personal Data means any information relating to You which allows us to identify you.

Specifically We may collect the below types of Personal Data:

Identity Data and Contact Data:: Name, User Name, Photo of User, Phone Number, Email, employer details, communications You may exchange with via chat or help services

Technical Data: Device information and Your IP address, information about Your Use of the app and the Services.

Location Data: Location Data of your device through GPS, Bluetooth and IP address.

 

How We Use the Data We Collect from You:

The Personal Data collected from You by the application is used by the data controller to manage the provision of roadside assistance, claims handling, performance management, reporting and the collected end- customer data.

Please note that We may process Your Personal Data without Your knowledge or consent, where this is required or permitted by law.

 

Data Security:

 

We  follow strict security procedures in the storage and disclosure of Your Personal Data and 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.

 

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.

We may disclosure Your information to trusted third parties for the purposes set out in this Privacy Policy. We require all third parties to have appropriate technical and operational security measures in place to protect Your Personal Data, in line with Irish and EU Law in relation to data protection.

 

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 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.

 

Data Transfers to Third Parties:

We may transfer Your data to third parties whom We have contracted with for the purposes of data processing and storage. Some of the Third Parties We use for these purposes are; VPS – Virtual Private Server, Mircosoft Azure, Google Cloud Platform

We require all third parties 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.

 

Data Transfer Outside the EEA:

Personal Data may be transferred or stored outside the EEA or any country where You are located in order to carry out the application Services or Spire’s other obligations.

 If Your Personal Data is to be transferred outside the EEA for the above reasons We ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer Your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.

Where We use certain service providers, We may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.

 

Data Retention:

In general, We expect to retain Your Personal Data for as long as it is necessary for the purposes for which it was obtained from the date of collection or where the subscription arrangement with Us has concluded or account has been deleted (which can be up to 7 years in some instances).

In relation to the end customer data, the data controller will determine the period for this data.

 

Your Legal Rights:

 

You have the right to:

Request access to Your Personal Data (commonly known as a "data subject access request"). This enables You to receive a copy of the Personal Data We hold about You and to check that We are lawfully processing it.

 

Request correction/rectification of the Personal Data that We hold about you. This enables You to have any incomplete or inaccurate data We hold about You corrected, though We may need to verify the accuracy of the new data You provide to us.

 

Request erasure of Your Personal Data – right to be forgotten. This enables You to ask Us to delete or remove Personal Data where there is no good reason for Us continuing to process it. You also have the right to ask Us to delete or remove Your Personal Data where You have successfully exercised Your right to object to processing (see below), where We may have processed Your information unlawfully or where We are required to erase Your Personal Data to comply with local law. Note, however, that We may not always be able to comply with Your request of erasure for specific legal reasons which will be notified to You, if applicable, at the time of Your request and will include statutory or regulatory requirements that We are obliged to comply with.

 

Object to processing of Your Personal Data where We are relying on a legitimate interest (or those of a third party) and there is something about Your particular situation which makes You want to object to processing on this ground as You feel it impacts on Your fundamental rights and freedoms.

 

Request restriction of processing of Your personal data. This enables You to ask Us to suspend the processing of Your Personal Data in the following scenarios: (a) if You want Us to establish the data's accuracy; (b) where Our use of the data is unlawful but You do not want Us to erase it; (c) where You need Us to hold the data even if We no longer require it as You need it to establish, exercise or defend legal claims; or (d) You have objected to Our use of Your data but We need to verify whether We have overriding legitimate grounds to use it.

 

Request the transfer of Your Personal Data to You or to a third party. We will provide to you, or a third party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with you.

 

Withdraw consent at any time where We are relying on consent to process Your personal data. However, this will not affect the lawfulness of any processing carried out before You withdraw Your consent. If You withdraw Your consent, We may not be able to provide certain services to you. We will advise You if this is the case at the time You withdraw Your consent.

 

 

Should You have any queries in relation to this Privacy Policy or wish to exercise Your legal rights then please contact Our Data Protection Officer (DPO ) using the details below:

Data Protection Officer, Spire Software Solutions Ltd, Westpoint Offices, Collinstown Lane, Co. Dublin K61 A0P9, Ireland.

Email: support@spiressl.com

If You have any data protection issues You have the right to make a complaint at any time to the Data Protection Commissioner (DPC), the Irish supervisory authority for data protection (www.dataprotection.ie). We would, however, appreciate the chance to understand and deal with Your concerns before You approach the DPC so should You have any issues in relation to Your Personal Data please contact Us in the first instance.

 

Westpoint Offices, Dublin Airport.

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