Privacy Policy

 

Introduction

Spoke Technologies Ltd is committed to protecting your personal information.

Our Privacy Policy contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.

We may need to make changes to our Privacy Policy from time to time, so please check our website for updates.

This version of our Privacy Policy was last updated 14th March 2022

Who we are

We are Spoke Technologies Ltd, a UK limited company with registration number 10615811.

If you have any questions about our Privacy Policy or the information we collect or use about you, please send us an email at info@spokemarketplace.com or write to us at Spoke Technologies Ltd, 116 Old Street, London, EC1V 9BG

Information we collect and use

  • Information about you that we collect and use includes:

  • Information submitted through the enquiry forms on this website or through job applications.

  • This is mainly personal information such as your name, email address, CV, etc.

  • Information connected to the Spoke Technologies Ltd products or services that you may subscribe to and use.

  • Each of our products and services require different pieces of information about you in order for those products or services to work properly.

  • Information you allow us to access from other sources.

  • Instead of asking you to provide us with all your information we can often take this from third party providers. We will only ever do this with your explicit permission and we will always make such permission requests as transparent and easily-understood as we can

  • Information about your contact with us

  • Any correspondence you have with Spoke Technologies Ltd will be collected e.g. meetings, phone calls, emails / letters

  • Cookie information 

    Please read our cookie policy

How we collect your information

We may collect your personal information directly from you or from a variety of sources, including:

  • Our online services such as websites, social media and mobile device application (‘Apps’)

  • An application form for a product or service

  • Phone, email or written conversations with us

  • Third Party providers who enable us to collect information that they have about you, with your consent

We may also collect personal information about you from places such as business directories and other commercially or publicly available sources. An example of this is to check or improve the information we already hold, like your contact details if we have problems contacting you.

What we use your information for

We take your privacy extremely seriously. The very existence of Spoke Technologies Ltd is down to the importance we place on individuals being able to own and control their data. We will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so.

We will collect and use your information only where:

  • You have given us your explicit consent to send you information about products and services offered by Spoke Technologies Ltd

  • Doing so is necessary to provide the product or service you have requested. We will make this clear to you before you subscribe to a product or service.

  • It’s necessary for us to meet our legal and/or regulatory obligations

If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products or services, or that your use of these products or services be more limited.

We sometimes use computer systems to make automated decisions based on personal information that you have given us or have permitted us to collect from third parties about you. These automated decisions can affect the products, services or features we offer you now or in the future.

Our goal is that our products and services are tailored to your individual needs based on what we learn about you, using your data. 

Who we may share your information with

We may share your information with:

  • Anyone who works for us when they need it to do their job. All our employees are contractually obliged to uphold the privacy of your data as explained in this Privacy Policy.

  • Any organisation which supports any of our products or services that you use, when they need it to offer those products or services. All our third-party suppliers are contractually obliged to uphold the privacy of your data as explained in this Privacy Policy.

  • Our regulators and Supervisory Authority, the Financial Conduct Authority (FCA), the Information Commissioner’s Office for the UK (the ICO), Law enforcement, credit and identity check agencies for the prevention and detection of crime HM Revenue & Customs (HMRC). As is required by UK and worldwide law.

We will never sell your personal information to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure and only after obtaining your explicit consent.

Where your information is processed

Any of your personal information processed directly by Spoke Technologies Ltd is processed in the UK and European Economic Area (EEA).

Some of your personal information may at times be processed by the third parties we work with outside of the EEA.

Where your information is being processed outside of the EEA, we take additional steps to ensure that your information is protected to at least an equivalent level as would be applied by UK / EEA data privacy laws. We do this by putting in place legal agreements with our third-party suppliers and doing regular checks to ensure they meet these obligations.

How we protect your information

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.

How long we keep your information

We will keep your personal information only as long as it is necessary to provide you with our products or services while you are a customer.

If you have applied for a job at Spoke Technologies Ltd (through Motive Partners) we will keep your personal information throughout the application process.

  • If you are successful and become an employee, we will keep your personal information in line with our privacy policy for employees.

  • If you are unsuccessful, we will not keep identifiable personal information about you. We may anonymise your information to help us improve our recruitment processes.

We may also keep your information after this period but only where required to meet our legal or regulatory obligations. The length of time we keep your information for these purposes will vary depending on the obligations we need to meet, but the maximum length of time is usually 7 years.

Your individual rights

You have several rights in relation to your personal information:

  • The right to receive clear and easy to understand information on what personal information we have, why and who we share it with – we do this in our Privacy Policy and privacy notices.

  • The right of access to your personal information. If you wish to receive a copy of the personal information, we hold on you, you may make a data subject access request (DSAR).

  • The right to request that your personal information be rectified if your personal information is inaccurate or incomplete, you can request that it is corrected.

  • The right to request erasure if there is not a compelling reason for Spoke Technologies to continue to keep your information.

  • The right to restrict processing and so asking that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.

  • The right to data portability for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way.

  • The right to object to Spoke Technologies Ltd processing your personal information where: it’s based on our legitimate interests (including profiling); for direct marketing (including profiling); and if we were using it for scientific/historical research and statistics

  • The right related to automatic decision-making including profiling. You have the right to ask Spoke Technologies Ltd to give you information about its processing of your personal information, request human intervention or challenge a decision where processing is done solely by automated processes and to carry out regular checks to make sure that our automated decision making and profiling processes are working as they should.

    To exercise any of your rights, please contact us by emailing
    info@spokemarketplace.com

How to make a complaint

If you have a complaint, please contact us by emailing info@spokemarketplace.com and we will do our best to fix the problem. If you’re still not happy or you believe we have not handled your information as set out in our Privacy Policy you can refer your complaint to the Information Commissioner’s Office via their website (link https://ico.org.uk/ )

Third Party Processors 

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

“Digital Marketing Service Providers: We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.  Our appointed data processors include:

(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io.  Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.”