capSpire respects your privacy and is committed to protecting your personal information (hereinafter referred to as your personal data). This privacy statement will inform you as to how we look after your personal data when you visit our website www.capspire.com (the “Website”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This privacy statement is provided in a layered format so you can click through to the specific areas set out below.
Please refer to the Glossary at the end of this privacy statement for definitions of key terms, access to relevant links, and important information about the entities with whom we may share your personal data.
This privacy statement aims to give you information on how capSpire collects and processes your personal data through your use of this Website, including any personal data you may provide when you fill out a form on our Website to enquire about our services, meet us at an event, subscribe to our newsletter, download a white paper, or purchase a product, as well as any data you may provide when you use our services. This Website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy statement together with any other privacy statement or fair processing statement we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy statement supplements the other statements and is not intended to override them.
capSpire is made up of different legal entities, details of which can be found using the link located in the Glossary. This privacy statement is issued on behalf of the capSpire Group so when we mention (“capSpire“, “we“, “us” or “our“) in this privacy statement, we are referring to the relevant company in the capSpire Group responsible for processing your data.
The capSpire Group company that employs (or has entered into a contract for services with) you is primarily responsible for the processing of your personal data and will be the data controller for the purposes of the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) or other applicable data protection laws.
capSpire is a global IT consultancy organization, with its headquarters located in the USA. capSpire LLC is the parent company of the capSpire Group. capSpire has operations in Asia-Pacific, Canada, Europe, the United Arab Emirates and the United States of America.
We have adopted the GDPR as our global standard for data protection. This standard is implemented into our operations and serves as the baseline for data protection practices across all capSpire Group entities, regardless of jurisdiction. The GDPR is widely recognized as one of the most comprehensive data protection frameworks globally, with many jurisdictions aligning their laws to similar principles. Adopting GDPR as a baseline enables us to follow globally aligned best practices while ensuring compliance with other data protection legislation in the countries where we operate.
While GDPR often meets or exceeds the requirements of various local laws, we recognize that some jurisdictions impose more stringent obligations. In such cases, additional measures will be implemented to meet those specific legal requirements. This approach ensures that our operations comply with both GDPR and any more demanding regional regulations. Your individual rights, however, might differ based on the data controller processing your personal data, your location and on the rights available to you under the laws of the country in which you reside.
Please refer to the ‘Your legal rights’ section for details on the rights available to you under the GDPR (where applicable). If you need further information, you will find the contact details for our Privacy Team in the ‘How to contact us’ section at the end of this privacy statement.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy statement.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor do we collect any information about criminal convictions and offenses.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw your consent to receive marketing communications at any time by contacting us using the details provided in the ‘How to contact us’ section below.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. If you would like more information about the specific legal basis we rely on to process your personal data where more than one ground has been identified in the table below, please contact us using the details provided in the ‘How to contact us’ section below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a new customer | (a) Identity (b) Contact (c) Technical | Performance of a contract with you |
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (e) Technical | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation |
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | Necessary for our legitimate interests (to develop our products/services and grow our business) |
To improve operational efficiency, through the implementation of AI powered solutions. | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | Necessary for our Legitimate Interests in improving operational efficiency by saving time and resources |
To process job applications submitted via our Careers Portal | (a) Identity | (a) Necessary for our legitimate interests to assess and manage job applications and recruitment processes. |
To retain candidate data for consideration in future recruitment opportunities | (a) Identity | (a) Consent (where you have agreed for us to retain your data) |
If you apply for a role through our Careers Portal, we will collect and process your personal data for the purposes of managing our recruitment activities. This includes assessing your suitability for roles, communicating with you during the selection process, and fulfilling legal or contractual obligations. The types of personal data we may collect include your Identity (such as name, title, and date of birth), Contact details (such as email address and phone number), and Profile information (such as employment history, education, qualifications, and any other details you provide in your CV or application materials).
We process this data on the basis of our legitimate interests in recruiting suitable candidates, compliance with legal obligations (such as verifying the right to work), and, where applicable, your consent (e.g. for retaining your data for future opportunities or processing special category data). Your data may be shared with internal HR personnel, hiring managers, and trusted third-party service providers who support our recruitment processes, all of whom are subject to appropriate confidentiality and data protection obligations. We retain candidate data only for as long as necessary for the recruitment process and, where consent is provided, for future opportunities. You have the right to access, rectify, or erase your personal data, and to object to or restrict its processing. For more information on your rights under the GDPR and how to exercise them, please refer to the sections titled ‘Your legal rights’ and ‘How to contact us’.
capSpire has implemented Artificial Intelligence (AI) technologies which, for example, help with improving capSpire’s operational efficiency. capSpire complies with its Artificial Intelligence Usage Policy and this privacy statement when personal data is involved.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms.
We may use your Identity, Contact, Technical, Usage and Profile data (see Section 2 above for more information) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, if you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside of our organization for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the Website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service purchase or other transactions.
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 you would like an explanation of how processing for a new purpose is compatible with the original purpose, please contact us using the details provided in the ‘How to contact us’ section below.
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with Internal Third Parties and External Third Parties, each as defined in the Glossary, for the purposes set out in the table in Section 4 above. For the avoidance of doubt, we require all third parties to respect the security of your personal data and to treat it in accordance with applicable data protection laws. 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.
This Website may include links to third-party websites, plug-ins or applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy statement of every website you visit.
We also use certain third-party tools, such as LinkedIn Analytics, which may collect information about your interaction with our Website. LinkedIn Ireland Unlimited Company acts as an independent data controller for this processing. For more information, please refer to LinkedIn’s privacy documentation.
We share your personal data within the capSpire Group. This will involve transferring your data outside the European Economic Area (EEA). If you would like further information about the specific mechanism we use when transferring your personal data outside the EEA, please contact us using the details provided in the ‘How to contact us’ section below.
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We 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. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a personal data breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. When acting as data controller in respect of your personal data, capSpire will comply with such rights:
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 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. 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.
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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You can read more about the specific rights you have on the website of your country’s information regulator.
We have appointed a Privacy Team who are responsible for overseeing questions in relation to this privacy statement. If you have any questions about this privacy statement, including any requests or information on how to exercise your legal rights, please contact Privacy Team using the details set out below.
Email privacy@capspire.com
Postal Address: 11 E. 5th Street, Suite 500, Tulsa, Oklahoma 74103, USA9
Please clearly state that your query relates to a privacy or data protection matter to help us direct your request appropriately.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
capSpire Group means capSpire LLC and its affiliated companies that are part of the same corporate group. This includes entities that are directly or indirectly owned or controlled by capSpire LLC or its parent companies.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Personal data means is any information relating to an identified or identifiable natural person (called a “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
Other companies in the capSpire Group acting as joint controllers or processors, depending on the nature of the relationship with one another, and who are based in jurisdictions such as Ireland, India, Australia, Germany, Singapore, Canada, the U.K. and the United Arab Emirates and provide IT and system administration services and undertake leadership reporting.
External service providers or agencies: Such as HR and payroll processors, benefits administrators, IT service providers and occupational health providers. This may include platforms such as Zoominfo (for CRM and business operations) and Monday.com (for project and task management).
Regulatory and legal authorities: To fulfil legal obligations, including responding to requests from law enforcement or tax authorities, subject to due process to verify the request’s legitimacy and lawfulness.
Professional advisors: Including auditors, legal counsel, and consultants, all bound by confidentiality or non-disclosure agreements.
Parties involved in the restructure or sale of our business: As part of business restructuring or sale (e.g., mergers or acquisitions) under a confidentiality or non-disclosure agreement; or in the event that all or any part of capSpire’s business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners of the business.
Other parties: We may also share your personal data with other third parties and, where required by applicable data protection laws, we will inform you of such sharing before your data has been shared. We may also share your personal data with any organization you explicitly ask us to share your information with (for example mortgage providers).
We may share your personal data with Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy statement.
Changes to the Privacy Statement and Your Duty to Inform us of Changes
This version was last updated on 30 June 2025. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
