(Effective Date: 25. May 2018)
Last updated: 26. July 2023
Thank you for visiting our Spearline Labs Ltd website, this website explains how Spearline collects, uses, stores, shares and secures your information.
Spearline – Who are we?
Spearline is the business name for Spearline Labs Limited. Our head office is located in North Street, Skibbereen, County Cork, P81 H102, Ireland.
As Spearline is registered and headquartered in Ireland, our Regulatory Authority is the Data Protection Commissioner.
Spearline – What do we do?
Spearline Testing provides a toll and toll-free number testing service.
Privacy Statement
Acknowledgement
Please read this Privacy notice carefully
By using our site & its features, engaging in in Communications, Your represent that you have Read, Understood and Accept this Privacy notice
At Spearline, we understand and take data privacy obligations seriously.
This Privacy Policy explains how we collect, use and retain personal information, including information collected through websites, platforms, blogs, apps (including but not limited to messaging services), and our correspondence with you (for example, by email) and when providing you with our products and services.
Spearline’s Data Management Framework is compliant with the GDPR legislation, which became operative across the EU on May 25th, 2018 and applies to all offices and branches of Spearline, all staff and volunteers of Spearline and all contractors, suppliers, and other people working on behalf of Spearline. It applies to all data that the company holds relating to identifiable individuals.
This Privacy Statement sets out how and why we collect your personal data, the legal basis for the collection, and your rights as a data subject under GDPR.
1. Applicability
This privacy statement applies when you are European resident and:
– Access and interact with the Spearline website and its features
– Communicate with us in any manner, through webforms, email, telephone or if you get in contact through our social media accounts
– If we or our website interacts with our approved third party providers, such as distributors, contractors, internet service providers, advertisers, analytics providers, online and offline data providers and other related service-providers
2. Disclosures
List of the categories of personal data information and the disclosure of:
- a) the business or commercial purpose of collecting or sharing information
- b) the categories of sources from which the information was collected
- c) the categories of third parties with whom we share the information
2.1 What is Spearline’s legal basis for using and sharing your data
| Legal basis | |
| 1. Consent | You may agree or explicitly consent to the collection and use of your data as set out in this privacy statement, when you tick the “Yes, I’m in” or the “I opt-in” options on the Spearline website. If you no longer wish to receive marketing emails or correspondence from us, please send an email to Spearline through info@spearline.com with “UNSUBSCRIBE” in the subject line, or click the ‘Unsubscribe’ button in the footer of any marketing email you receive from us. |
| 2: Contract | We may use your personal data to fulfill contractual obligations or in circumstances where you have asked us to do something before the contract, such as providing a quote or demo. |
| 3: Legal Obligation | We may use your data in circumstances where it is necessary because we have to comply with a legal obligation, under Irish or EU law. |
| 4: Legitimate Interests | We may use your data for our legitimate interests. This can include business purposes, like (i) where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our customers (ii) to identify and prevent fraud (iii) to enhance the security of our network and information systems (iv) to better understand how people interact with our websites (v) to determine the effectiveness of promotional campaigns and advertising. If you object to us using your data in this way, please contact us in writing, at Data Protection Specialist, Spearline HQ, Skibbereen, County Cork, P81 H102, or by email to privacy@cyara.com specifying the nature of your request. |
| 5: Vital Interests | We may use your data in circumstances where, for example, it could save a person’s life and the processing is necessary. |
| 6: Public Interests | We may process your personal data if it is in the exercise of official authority, or in the public interest. |
2.2 Categories of Identifiers
| Personal data may be collected when you: | Which data we may collect? |
| 1. Browsing our website | – Browser information – IP and Device information – Clickstream data – Location |
| 2. Fill out contact forms on our website | – Name – email address – phone number – Your Job title – Online Identifiers as listed under “1. Browsing our website” |
| 3. Register for a Spearline content download | – Name – email address – Your Job title – Online Identifiers as listed under “1. Browsing our website” |
| 4. Subscribe to receive emails and newsletters | – Name – email address – Online Identifiers as listed under “1. Browsing our website” |
| 5 Provide your contact details to us through industry events or social media | – Your name – Your job title – Your company name – Your address(es) – Your email address(es) – Your contact phone number(s) – Employment details which you have provided |
| 6. Become a user of one of our services | – Your name – Your job title – Your company name – Your company address(es) – Your company email address(es) – Your contact phone number(s) – Passwords (encrypted) – Employment details which you have provided – Records of Service offering subscriptions |
| 7. Apply or process your job application | – Your name – Your Date of birth – Your current job title – Your address(es) – Your email address(es) – Your contact phone number(s) – Employment details which you have provided – Passwords (encrypted) |
| Disclosure | Description |
|---|---|
| 1. Categories of sources from which the information is collected |
|
| 2. Is the information sold? | No |
| 3. Is the information shared | Some. Spearline Labs Ltd may share IP addresses or other identifiers to our partners. In some instances this may constitute a “sharing” of your personal information under the GDPR. |
| 4. Is this “sensitive” personal information | Yes, to the extent the information may include, especially for Job application processes: Date of birth, gender, ethnicity, religious beliefs and other data which may constitute sensitive personal information under the GDPR |
| 5. Business or commercial purpose for collecting and/or sharing the information | – Contract fulfilment requirements Using data may including analysing, troubleshooting, consultation, testing, automated testing, automated decision making and profiling – We collect the information to identify, better understand and communicate with you. – We collect the information for the reason of cybersecurity, incident response, risk mitigation purposes, to provide customer care, for legal, record keeping and compliance purposes – For other purposes communicated to you at the time of collection |
| 6. Categories of Third parties we may share your information with |
|
2.3 How long do we keep the information:
Spearline Labs Ltd keeps data only as long as reasonably necessary and to the original purpose for which we collected the information. We base our criteria in determining appropriate retention periods on regulatory, legal and contractual requirements as well as business needs and the expectation of our customers.
3. Your rights under GDPR
| Right to be informed | Our policies providing you with Information relating to the processing of personal data are easily accessible and easy to understand, and that clear and plain language is used. |
| Right to access | You have the right to ask us for copies of your personal information. |
| Right to rectify | You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. |
| Right to erasure | You have the right to ask us to erase your personal information in certain circumstances. |
| Right to Restrict processing | You have the right to ask us to restrict the processing of your personal information in certain circumstances |
| Right to Data portability | You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. |
| Right to Object | You have the right to object to the processing of your personal information in certain circumstances. |
| Right in relation to automated decision making and profiling | You have the right to not be subject to a decision based solely on automated processing. Processing is “automated” where it is carried out without human intervention and where it produces legal effects or significantly affects you. Automated processing includes profiling. |
3.1 Exercising your rights
You may exercise your rights by contacting us at privacy@cyara.com specifying the nature of your request.
Or alternatively by mail
Data Protection Specialist,
Spearline HQ,
Skibbereen,
County Cork,
P81 H102
You are not required to pay any charge for exercising your rights. If you make a request, we have 30 days to respond to you.
To process your request, we must be able to verify your identity in order to do so. As part of the verification process we may ask for contact information and an additional identifier depending on your relationship with us. We will then compare the information with the data points we have on file for you to verify your identity.
3.1.1 In the case of a complaint
If you are dissatisfied with how your data request is dealt with by Spearline, please contact our Data Protection Specialist so we rectify it.
You may wish to make a complaint to the Office of the Data Protection Commissioner via any of the following means:
Telephone : +353 (0) 761 104 800 or LoCall 1890 252 231
Email : info@dataprotection.ie
Postal Address: Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23, County Laois
3.2 Does Spearline sell any information?
We do not sell, trade, or rent users’ or customers’ personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates, and advertisers for the purposes outlined above.
3.3 Using Sensitive Personal Information
We do not process your sensitive personal information for the purpose of deriving characteristics about you. We instead only use sensitive personal information, if at all, for those permissible purpose under the GDPR
3.4 Marketing
Email marketing: we may send you emails about our website, products update, news, blogs, or other updates. We may also use your email to inform you about changes in the website, platform, survey you about your usage, or collect your opinion.
4. Cookie Policy
Spearline may collect and share your information through the use of cookies and related technologies (including flash cookies, pixels, tags, software development kits, application program interfaces and web beacons, for the purpose of identifying and authorising users, preventing fraud, enhancing our sites and features and to tailor content to you.
4.1 What are cookies
Cookies are small files used by web servers to save browsing information, allowing websites to remember your device, browser preferences, and associated online activity
Like most websites, we use cookies and similar technologies to remember things about you so that we can provide you with a better experience.
- Cookies are small data files stored on your browser or device. They may be served by the entity that operates the website you are visiting (“first-party cookies”) or by other companies (“third-party cookies”). For example, we partner with third-party analytics providers, like Google, which set cookies when you visit our websites. This helps us understand how you are using our Services so that we can improve them.
- Pixels are small images on a web page or in an email. Pixels collect information about your browser or device and can set cookies.
- Local storage allows data to be stored locally on your browser or device and includes HTML5 local storage and browser cache.
- SDKs are blocks of code provided by our partners that may be installed in our mobile applications. SDKs help us understand how you interact with our mobile applications and collect certain information about the device and network you use to access the application.
Types of Computer Cookies
There are three types of computer cookies: session, persistent, and third-party.
These virtually invisible text files are all very different.
4.1.1 Categories of cookies
| Categories of Cookies | What do they mean and what are they for? |
| Session cookies | Session cookies only retain information about a user’s activities for as long as they are on the website. Once the web browser is closed, the cookies are deleted. This allows us to process your requests and verify your identity after you have logged in, as you move through our Sites and Features |
| Permanent cookies | Permanent cookies, also known as ‘persistent cookies’, remain in operation even after the web browser has closed. For example, they can remember login details and passwords so web users don’t need to re-enter them every time they use a site. The law states that permanent cookies must be deleted after 12 months. |
| Essential cookies | Our sites and features would not work properly without essential cookies. As example, we and our third party providers may use essential cookies to identify and authenticate users of our sites and features. We also use essential cookies to enforce our Terms and Conditions and maintain the security of our Sites and Features |
| Performance cookies | Collect information about how visitors use our Sites and Features, for example, which pages users visit most often and error messages received by users from our web pages. Performance cookies don’t collect information that identify visitors and the information these cookies collect is aggregated and anonymized |
| Third-party cookies | Third-party cookies are installed by third parties with the aim of collecting certain information from web users to carry out research into, for example, behaviour and demographics. They are commonly used by advertisers who want to ensure that products and services are marketed towards the right target audience. |
| Advertising cookies | These cookies may be placed by an advertising network with our permission to deliver advertisements relevant to visitors based on the visitors interest. Those cookies remember that you have visited our website and this information may be shared with other organisations, such as advertisers |
4.1.2 Categories of other tracking technologies
| Other tracking technologies | What do they mean and what are they for? |
| Embedded Scripts / Web beacons | Is a small graphic image or programming code that may be included in our webpage and is only active while you are connected to the Sites and Features. We may use this to collect information about how you interact with our Sites and features. |
| Third Party Ad Servers | May serve advertisements, provide us with data collection, reporting, ad response measurement and analytics, These third parties may view, edit or set their own cookies. They may also collect information concerning your online activity over time and across different websites. The information they may collect includes the other sites you have visited or applications that have downloaded to your mobile devices and other information about you or your device in order to help analyse and service targeted advertisement. |
| Third party analytics | We may use third party analytics service providers to evaluate and provide us with information about the sites and features. These vendors may have their won tracking technologies on your device and they may otherwise collect or have access to information about you. This information may be stored and shared by these vendors to process your transaction and provide access to sites and features. We may also use this information for internal review and a analysis of the sites and features |
4.2 Your Choices
We provide you with the ability to exercise controls and choices regarding your information
Please read below more about those rights under the GDPR
4.2.1 Control Cookie preferences
In many instances you can turn off cookies through your web browser (please read your browser manual or help pages for instructions).
Please consider that if you turn-off your cookies, not all features of our website might be available to you
4.2.2 Control your browser
You may be able to disable and manage some cookies through your browser settings. If you use multiple browsers on the same device, you may have to manage your settings for each browser individually.
4.2.3 Analytics Provider Opt-outs
You can use your browser controls as explained above or, for some of our providers (eg: Google), you can use their individual opt-out mechanisms
4.2.4 Third Party Services
Our approved third-party providers will only collect, use, and disclose your information to the extent necessary to allow them to perform the services they provide to us.
Users may find advertising or other content on our Site that links to the sites and services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties.
However, third-party services have their own privacy policies.
We recommend that you read their privacy policies to understand how these providers will handle your personal information for these providers.
Our third-party advertisers use cookies to track your prior visits to our websites and elsewhere on the Internet in order to serve you targeted ads. For more information about targeted or behavioural advertising, please visit https://www.networkadvertising.org/understanding-online-advertising.
4.2.5 Interest-Based Advertising
You have a number of options to control or limit how our partners and we use cookies and similar technologies, including for advertising.
- Click on the
Cookie Settings
to access the Spearline Preference Center. - Although most browsers and devices accept cookies by default, their settings usually allow you to clear or decline cookies. If you disable cookies, however, some of the features of our services may not function properly.
- To prevent your data from being used by Google Analytics, you can install Google’s opt-out browser add-on.
- For information on how our advertising partners allow you to opt out of receiving ads based on your web browsing history, please visit http://optout.aboutads.info/.
European users may opt out of receiving targeted advertising through the European Interactive Digital Advertising Alliance. - To opt-out of ads on Facebook, LinkedIn, Twitter, or Google that are targeted to your interests, use your Facebook settings, LinkedIn settings, Twitter settings, and Google Ads settings.
- You can also opt-out of tracking by many companies using cookies via the Network Advertising Initiative Consumer Opt-Out.
- In case you have any questions about the third-party partners and their cookies policy, you may contact them directly.
- Check your mobile device for settings that control ads based on your interactions with the applications on your device.
For example, on your iOS device, enable the “Limit Ad Tracking” setting, and on your Android device, enable the “Opt-out of Ads Personalization” setting.
4.2.6 Cross device tracking
Please use the links mentioned above to get more information about cross-device tracking and how to opt-out.
4.2.7 Email opt-out
If, at any time, you wish to opt-out or “Unsubscribe” from receiving commercial emails related to our sites and services, you may
(a) Use the “Unsubscribe”-link at the bottom of our commercial email you have received OR
(b) Email us
Please remember that
(a) even if you opt-out from receiving commercial emails (such as newsletters), Spearline reserves the right to send transactional or relationship communications to you
– If we need to contact you regarding your account status
– Technical support
– Product information
– Changes in Terms and Conditions
– and any other matter that may affect our service to you
(b) certain services can only be provided to you, if information is provided/shared. If you elect not to provide such information or opt-out of having your information shared, you may not be able to receive certain content or/and information.
5. Changes to this policy
Spearline reserves the right to make changes to this Privacy Policy from time to time.
Notice may be provided by posting notice of such changes on our website or by other means (ie: Newsletter), consistent with applicable law.
The effective date will be stated at the top and last updated date on the bottom of this Privacy notice.
You should regularly check this page for any changes to the Privacy notice.
6. Contact us
While a Data Protection Officer is not mandatory, Spearline is committed to protecting your data and have appointed the following representative as your point of contact :
If you wish to exercise your rights or have any questions about our use of cookies, please contact us at
Email: privacy@cyara.com
Or alternatively by mail
Data Protection Specialist,
Spearline HQ,
Skibbereen,
County Cork,
P81 H102