Updated -12th March 2021

This Privacy Policy applies to your use of the Spire mobile application, website, and technology platform (collectively, the “Spire Platform”) provided by Spire Solutions Limited. (“Spire,” “we,” “us” or “our”) a Company headquartered in Nigeria.

At Spire, we value the privacy of our users, members, testers, and others (collectively or individually "Users") who visit and use the Spire Platform and we are committed to protecting your personal data (i.e. any information you provide to us from which you can be identified) in accordance with this Privacy Policy

This Privacy Policy governs the information you provide to us or that we may learn from your use of the Spire Platform and tells you how we may collect, use, and in some instances share, this information.

By accessing or using the Spire Platform, participating in our surveys, or in any other services we provide (collectively, Services), and expressly consenting where required, you agree to be bound by this Privacy. If you do not consent to our Privacy Policy, then you must not access or use our Services.

PERSONAL DATA WE MAY COLLECT AND HOW WE MAY USE IT

Information we may collect

As a market research and analytics company, we collect information or Personal Data which might include your name, contact details, title, occupation and any other background information from you when you create a user account on the Spire Platform. If you do not expressly provide this information, you will not be able to create a user account on the Spire Platform.

We collect Personal Data which you choose to provide to us directly, and which might include your Biometric data; name, age, email, location, address, Income level, Employment data, Education, Professional qualifications, marital data, number of children, social media handles, Financial Data; account name and number, and other payment information when you agree to use our services and/or participate in our surveys and other ancillary services offered via the Spire Platform.

We may collect Personal Data through the use of cookies, tags, web beacons and other technologies. We may also collect unique device identifiers and may collect geolocation information if we have the appropriate legal basis to do so.

We may combine the information we receive from you with information we receive from other sources.

By using the Spire Platform or sending us information, you explicitly consent to Spire processing your personal data in accordance with this Privacy Policy.

How do we use the information we may collect

Per the terms of this Privacy Policy, we may process and use the information we collect from you for the following reasons:

• Marketing
• To enable our services
• Research and development
• Non-marketing communications
• Automated decision making
• For compliance with a legal obligation. This includes anti-fraud and anti-money laundering measures as well as tax and social security requirements.

As to client data we collect, we do not use the information for any purpose other than to fulfil our obligations to clients. We keep client information secure at all times and prevent the use and disclosure of it by our employees or any third parties.

HOW WE MIGHT SHARE YOUR INFORMATION

We may share your Personal Data with others such as:

• Our Clients and Partner Companies: names and demographic data only
• third party service providers, who process the information on our behalf to help run some of our internal business operations including email distribution, marketing service, Cloud storage and IT services, so that they can provide services to Spire;
• law enforcement authorities or other government bodies when we are required to do so in compliance with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies.
• If, in future, we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may disclose/transfer the information we have collected from you to the acquiring company.
• For compliance with a legal obligation. This includes anti-fraud and anti-money laundering measures as well as tax and social security requirements.

In addition to the above, we may share Personal Data about you with others to the extent you consent to such sharing.

DATA AND SECURITY PROTECTION

We understand the need for your personal data to remain secure and private and we have implemented appropriate technical and organizational security measures to protect your personal data from loss, misuse, data breaches, modification or destruction. Only authorized personnel and third parties will have access to any personal data provided by you, which is limited to the extent they need to do their job or provide their services. While we are committed to earning and keeping your trust with these precautions, we cannot guarantee that unauthorized persons will not obtain access to your information as any provided information is exposed to inherent risks associated with Internet usage.

If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Spire Platform or providing Personal Data to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Spire Platform. We may also post a notice on the Spire Platform if a security breach occurs.

Please note that while we take reasonable steps to verify your identity before granting User’s profile access, you also play an important part in securing your own data. To protect your privacy and security, you should never share your user account’s password with anyone. The responsibility for maintaining the secrecy of your unique password and account information is yours at all times.

RETENTION OF YOUR PERSONAL DATA

We will retain your information for as long as your account is active or as needed to provide you services and to fulfil the purposes for which the data was collected. We may keep data longer if we have a legal obligation to keep it or to maintain necessary records for legal, financial, compliance, or other reporting obligations, and to enforce our rights and agreements.

COOKIES AND SIMILAR TECHNOLOGIES

When you use the Spire Platform, we and our partners, affiliates, and/or service providers may send one or more cookies or similar technologies to your computer or other device to collect information on how you use the Spire Platform to enable us improve the quality of our services, the Spire Platform and the online experience of our visitors and users.

Once you have given your consent to use cookies we shall store a cookie on your computer or device to remember this for next time. If you wish to withdraw consent at any time you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, certain functionalities of the Spire Platform might not work properly if you do so.

We use the following groups of cookies:

• Required cookies: These cookies are necessary to enable the basic features of the Spire Platform to function, such as allowing images to load or allowing you to select your cookie preferences.
• Functional cookies: These cookies allow us to analyze your use of The Spire Platform to evaluate and improve our performance. They may also be used to provide a better customer experience on our Platform. For example, remembering your log-in details or providing us information about how our Platform is used.
• Advertising cookies: These cookies may be used to share data with advertisers so that the ads you see are more relevant to you, allow you to share certain pages with social networks, or allow you to post comments on our Platform.

LEGAL RIGHTS AVAILABLE TO NIGERIAN DATA SUBJECTS

Subject to applicable law, you may be entitled to certain rights regarding the personal data Spire maintains about you. For instance, you may have the right to request access to your information, obtain a copy of it as well as information about how we use it. You may have the right to request that we correct incorrect, inaccurate or out-of-date information about you. You may also have the right to request that we stop processing your information and/or withdraw your consent to such processing and to ask us to delete your information.

In the event that you no longer wish your data to be processed as described in this Policy, or if you wish to access, rectify, cancel or oppose such processing, please contact us at [email protected] Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

LINKS TO OTHER WEB SITES

Spire by the nature of its business connects you with different third parties through their offers and surveys. To this end, the Spire Platform will contain links to other platforms not administered by Spire.

Spire may provide your information to the third party so that we can facilitate the relationship between you and the third party. However, Spire is not responsible for the privacy practices or the content of any non-Spire platform to which a user is redirected from the Spire Platform. We are not responsible for the protection and privacy of any information you provide whilst visiting other websites and sites not governed by our Privacy Statement. We cannot control the content or security of such websites. We cannot be held responsible for any loss or damage incurred by a user as a result of visiting such websites. No links are intended to be, nor should be construed as, an endorsement of any kind by us of that other website.

CHILDREN

Spire understands the importance of protecting children's privacy, particularly in their online interactions and as such, the Spire Platform is not directed at children 18 years of age and younger. Spire therefore will not intentionally collect information about anyone under the age of 18 and requests that no such information be submitted to us.

CHANGES TO THIS PRIVACY POLICY

Please note that this Privacy Policy may be updated from time to time so please refer to this policy regularly. We will post any Privacy Policy changes on this page and notify you if we make material changes.

CONTACT

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