Privacy Policy

Last Updated: October, 2021

Spire (“we”, “our” or “us”) provides this Privacy Policy (our “Policy”) to inform you of our policies and procedures regarding the collection, use and disclosure of information we receive when you visit our website or use our applications or any part of our services (together with our website and our applications, the “Service”). The entity granting you access to Spire’s software (“Organization”) is a Spire customer that collects and processes your personal data.

Information Collection

Spire processes data you and/or the Organization inputs into the Software for the purpose of recruiting, training, and/or managing you. Such data may include, but is not necessarily limited to, candidate data, employee data, contractor data, student data, training data, performance data and compensation data.

Personally Identifiable Information

Personal Content that may personally identify you (“Personal Identifiable Information”) shall be used pursuant to this Policy. We do not claim ownership of the Personal Identifiable Information provided to us in the use of the Service.

Non Personally Identifiable Information

Personal Content that does not personally identify you (“Non Personal Identifiable Information”) may be collected by us in the following ways:

  • Information that your browser sends when you use our Service (“Log Data”). This Log Data may include, but is not limited to, your computer’s Internet Protocol address, location, browser type, the web page you were visiting before you access the Service and information you search for using the Service.
  • When you use our Service, we may use cookies to support the website’s intended functionality. A “cookie” is a very small text document stored by your browser locally on your device, if your browser is configured to allow this. Such a cookie may contain an identifier and additional information necessary. We use “session ID cookies” to enable certain features of the Service, to better understand how you interact with the Service and to monitor web traffic routing and aggregate usage of the Service. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the website you visit. If you do not accept cookies, however, you may not be able to use all portions or all functionality of the Service.
  • We may use automated devices and applications, for example Clickstream or Google Analytics, to evaluate usage of our Services. We use these tools to help us improve our Services, performance and user experience.

Usage of Data

Spire will process the data only in accordance with the agreement between Spire and the Organization, including, but not necessarily limited to, providing technical or functional support, and ensuring the security of the Software. Please contact the Organization with any questions about its use of your personal data.

Information Sharing and Disclosure

1. Service providers

We may use third-party partners to operate and maintain our Software and deliver our products and services in accordance with the agreement we have with the Organization. Third-party service providers are contractually restricted from using or disclosing your personal data except as necessary to perform services on our behalf or to comply with legal requirements. Depending on contractual requirements and applicable law, data can be processed in the United States, European Union, United Kingdom, Singapore, or any other jurisdiction determined by the European Commission to have a suitable level of data protection, or any other jurisdiction determined by the Organization to host their data in accordance with our agreement with the Organization.

2. Legally compelled disclosures

We may disclose your personal data if required to do so by law or subpoena or if we believe that such action is necessary to: (a) conform to law applicable to Spire or our partners; (b) comply with a judicial or court order, or comply with legal processes served on us or Affiliated Parties; or (c) protect and defend our rights and property, Websites, and/or the users of the Websites.

4. Worldwide transfer and processing of Personal Data (applies unless otherwise agreed in writing between you or the Organization and Spire)

Spire may use your data for the purposes described herein and per the agreement between Spire and the Organization. Your data may be processed and transferred in and to the United States and other countries and territories listed herein, which may have different privacy laws from your country of residence, and which may afford varying levels of protection for your personal data. Regardless of the laws in place in these countries, we will treat the privacy of your information in accordance with this Privacy Policy and the agreement between Spire and the Organization.

Links to Third Party Sites

Our Service may contain links to third party websites and applications. However this Policy applies only to the Service. We do not exercise control over providers of information, or over banners, other advertisements, or links, if any, from within the Service. These other sources may place their own cookies or other files on your computer, collect data or solicit personal information from you, and they follow different rules regarding the use or disclosure of the information that you submit. We encourage you to read the privacy policies and other terms of the other sources before using their services.

Processing or Transfer

We use third party services in delivery of the Service, such as cloud or internet-based storage and data processing solutions. Such third party services are subject to confidentiality obligations and may use your Personal Content only for fulfilling their obligations to us.
Your Personal Content may be processed, maintained or transferred outside of your state or country, where the privacy laws may not be as protective as those in your jurisdiction.

Privacy of minors

Our Services are not meant to be used by persons under 18, as such, We do not knowingly collect personal data from children under the age of thirteen on our Websites. If we become aware that we have inadvertently received personal data from a visitor under the age of thirteen on a Website, we will delete the information from our records.


The security and privacy of personal data is of utmost importance to Spire. We use commercially reasonable and industry-standard physical, managerial, and technical safeguards to preserve the integrity and security of your personal data.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private.

Contact and Queries

The Organization is a data controller. A “data controller” determines the purposes for which and the means by which personal data is processed. Spire is a data processor of your personal data. A “data processor” processes personal data only on behalf of the controller. All queries regarding your personal data should be directed to the Organization.