TRUST & PRIVACY
01 · GENERAL PRIVACY NOTICE
Below, you find information about how we process your personal data (the Privacy Notice) and our use of cookies on this website.
SCOPE
What does this Privacy Notice cover?
The protection of personal data is important to Spiro, including all branches in Uganda, Rwanda, Kenya, Tanzania, Cameroon, Nigeria, Togo, Benin, Dubai and India (referred to as Spiro, us, our or we). Safeguarding personal data is essential to everything we do, including for visitors to our websites and physical premises and other parties in contact with Spiro.
Spiro processes personal data when you choose to interact with us: when you visit our website and its subpages, visit Spiro offices, interact with us on social media such as Facebook and LinkedIn, or exercise your rights under the General Data Protection Regulation (GDPR) and applicable local data protection regulations.
Spiro acts as the data controller for the processing activities described below. Separate privacy notices may cover specific services, products, customers, individuals and financial institutions where needed.
You can find service- or product-specific information in the Privacy Notice – Spiro Products.
Spiro also acts as a data processor for some services. For those services, please refer to the relevant data controller’s privacy notice—often your bank—for information about how personal data is processed.
WEBSITE
The data generated when you visit
When do we collect personal data?
When you visit Spiro websites, including their subpages, your browser sends certain personal data to our web server for technical reasons.
What kind of personal data?
Technical, browser and analytical information may be collected to operate the site, maintain security and continually improve our services.
IP address
Date and time of the server request
Time-zone difference
Subject of the request, including the specific page
Operating system and access status or HTTP status code
Data volume transmitted
Referrer URL
Browser, language and browser-software version
Analytical and statistical data used to improve our services and websites
What is the purpose?
To provide the website’s functionality, optimize the website, secure our information technology systems and direct visitors to relevant webpages and portals.
What is the legal basis?
Spiro has a legitimate interest in registering and analysing activities and statistics relating to use of the Spiro website, to ensure and improve usability and related services, under Article 6(1)(f) of the GDPR.
Who are the recipients?
We may share pseudonymized or aggregated data with third-party vendors to improve website usability and perform statistical analysis.
What is the storage period?
Retention periods are based on business needs and local legal requirements. We retain personal data for as long as necessary for the processing purpose for which it was collected and any other permissible, related purpose.
PHYSICAL VISITS
At Spiro offices and physical locations
When do we collect personal data?
When you visit a Spiro physical location, including through video surveillance (CCTV).
What kind of personal data?
Identification information such as your name, address, email address, phone number and position in an organization; your reason for visiting; and CCTV recordings from our physical premises.
What is the purpose?
We use CCTV and visitor information to maintain a high level of safety and security at our physical premises.
What is the legal basis?
We have a legitimate interest in registering your identity and the reason for your visit and in ensuring the resilience and safety of our premises under Article 6(1)(f) of the GDPR. CCTV also supports our legal obligation to safeguard our systems under Article 6(1)(c).
Who are the recipients?
We share CCTV recordings only with the police, courts or competent national investigation authorities on the basis of a specific request.
What is the storage period?
CCTV recordings are stored for 30 days on a rolling basis.
SOCIAL MEDIA
When you interact with Spiro online
When do we collect personal data?
When you interact with us through social media, including Facebook and LinkedIn.
What kind of personal data?
Your user identity, profile name, profile picture and published information; IP addresses; activity such as likes, comments and tags; and messages or other communications.
What is the purpose?
To carry out marketing activities, respond to you, support brand communication and conduct potential recruitment.
What is the legal basis?
Spiro’s legitimate interests in making content available, recruitment research, branding and marketing under Article 6(1)(f) of the GDPR.
Who are the recipients?
Spiro acts as a joint controller with Facebook and LinkedIn for relevant processing.
What is the storage period?
The data is erased when the content is deleted or when you withdraw your response to our content.
DATA SUBJECT REQUESTS
When you exercise your data rights
When do we collect personal data?
When you exercise one or more data subject rights set out in the GDPR.
What kind of personal data?
Identification information; a national identification number or copy of identification if specifically requested; and details of your request, such as access, rectification, erasure, restriction or data portability.
What is the purpose?
To handle your submitted request, identify you, verify your identity and assess the request.
What is the legal basis?
We have a legitimate interest in assessing your request so that we can meet our legal obligations under the GDPR, including Article 6(1)(f).
Who are the recipients?
We may share your request across the Spiro Group and with third parties when necessary.
What is the storage period?
We delete data subject requests five years after receiving them.
MARKETING & PRODUCT
Data used across our services
We provide marketing information through communication channels such as calls, one-to-one activations with our sales team and our social media pages.
Product data
Log and usage data is service-related diagnostic, usage and performance information automatically collected by our servers, including IP address, device information, browser type and crash dumps.
Device data
Information about your computer, phone, tablet or other device may include IP address, device identifiers, location and operating system.
Location data
Precise or approximate location data may be based on GPS and IP address. You can opt out through your device settings.
IoT devices
IoT devices in Spiro vehicles and energy infrastructure support critical analytics for business operations.
DATA SOURCES & RECIPIENTS
Where data comes from and who may receive it
Where does your personal data come from?
Personal data is mainly obtained from you. Spiro will not use it for purposes that are incompatible with the original purpose without your explicit consent.
Who is engaged when Spiro processes your personal data?
Data may be disclosed to other entities in the SPIRO MOBILITY HOLDCO DMCC Group, external data processors such as AWS, relevant supervisory authorities and external consultants or lawyers.
TRANSFERS & SECURITY
Safeguards across countries and systems
Transfers to countries outside India and Africa
Transfers take place subject to appropriate safeguards, including adequacy decisions by the Data Protection Board of India or African commissions, Standard Contractual Clauses, or specific legal bases under Article 49(1) of the GDPR.
Security
Spiro has adopted technical, legal and organizational measures that comply with applicable legislation to protect personal data from being destroyed, lost, altered or unlawfully disclosed.
ENFORCING YOUR RIGHTS
Your rights as a data subject or data principal
Depending on applicable law, you have the right to:
Request information about the personal data we process
Rectify your personal data
Request erasure of your personal data, subject to national-law limitations
Object to or restrict processing
Object unconditionally to processing for direct marketing
Withdraw consent at any time
Request data portability
Complaints
You may lodge a complaint with the Data Protection Board of India or the data protection authority in your African country of residence.
Benin — APDP
Togo — IPDCP
Rwanda — DPO
Uganda — PDPO
Nigeria — NDPC
Kenya — ODPC
Tanzania — PDPC
Cameroon — ANTIC
CONTACT US
Contact the Data Protection Officer
For privacy questions or to exercise your rights, contact the Spiro Data Protection Officer.
dpo@spironet.com
02 · COOKIE POLICY
This Cookie Policy explains how Spiro uses cookies and similar technologies when you visit our website.
Your cookie choices
Our website uses cookies and similar technologies to improve browsing, personalise content and ads, provide social media features, and analyse traffic. This policy is updated continuously, and protecting your online data is a priority for Spiro.
MANAGE MY CHOICES
01 · THE BASICS
What are cookies?
A cookie is a small computer file or tracker that is deposited and read when visiting a website, using a mobile app, reading an email, installing or using software — regardless of the type of terminal used.
When consulting a website, cookies may send information to your browser and allow it to send information back to the original website, for example a session ID or language choice.
Cookies do not allow us to identify you directly. They gather specific information about your device, browser, interactions with the website or app and, in some cases, your geographical position. The technologies used may link several devices used by you when there is sufficient probability that they belong to you.
02 · DATA
What data is collected via cookies?
Cookies and similar technologies may collect:
• Device information, such as operating system, browser type and screen resolution
• IP address and general geographic location
• Website usage data, such as pages visited, time spent and click patterns
• Interaction data with our services, such as chat usage and preferences selected
• Advertising interaction data, such as views, clicks and conversions
• Login or session identifiers for authenticated users
Some of this information may be linked with your account or other identifiers, and may be considered personal data under applicable laws.
03 · COOKIE TYPES
Technical cookies
Technical cookies enable or facilitate electronic communication — including detecting connection errors, identifying connection points and maintaining website security — or provide services you specifically request, such as screen-display preferences, saved form information, user-account access, chat or chatbot functionality.
These cookies are necessary for the proper functioning of our website. You may not object to their use and your consent is not required, as services on our website rely on them.
04 · COOKIE TYPES
Social cookies
Social cookies are used for advertising and analytics, including showing you Spiro ads when you are connected to social networks such as Facebook, Instagram, X (Twitter), LinkedIn or Pinterest, and helping us understand engagement with our ads on those networks.
They also make the website more interactive by allowing social-network interaction and embedded content, such as YouTube videos. Social networks may identify you through integrated application buttons or track your browsing when you have an active session on their service.
Please consult the relevant social-network privacy policies to understand how they use information collected through these features and how to express your preferences. The use and storage of social cookies is subject to your consent.
05 · COOKIE TYPES
Third-party cookies
In addition to social cookies, we may use cookies provided by third-party analytics, advertising or service providers, such as Google Analytics, YouTube or Meta. These cookies help us analyse site usage, measure ad effectiveness, or deliver content and services through embedded elements.
We recommend reviewing the privacy and cookie practices of these providers directly, as they may collect and process personal data according to their own policies.
06 · COOKIE TYPES
Personalised advertising cookies
These cookies improve the relevance of advertisements and content on this site and on third-party media. When we send promotional messages or display them, our aim is to provide advertisements and offers that are relevant to your needs or likely to interest you.
They may process data relating to personal preferences, interests in our products or services, and consumption habits. This automated processing can show relevant offers at the right time, discard offers unlikely to interest you, or limit the number of times you see the same advertisement.
The data may come from different sources and be interconnected, including our customer files, navigation data, third parties and data on vehicle use. Regulations define the use of such tools as profiling. The use and storage of these cookies is subject to your consent.
07 · COOKIE TYPES
Content personalisation cookies
Subject to your consent, these cookies improve your browsing by making the editorial content presented to you more relevant. We collect information about how you use the website — such as pages visited, features you interact with, content viewed and preferences selected — to adapt content more specifically to your expectations.
08 · COOKIE TYPES
Analytics cookies
Analytics cookies analyse website traffic and user experience, or collect aggregate signals about the flow of visits, such as language choice, the previous page visited, time of visit and cookie choices.
They may process data relating to pages visited, time spent, the browser you use, and your use of the chat or chatbot. The data may also be used to create algorithms and profiles that help analyse potential interests and preferences for our products and services, and may be combined with other information such as our customer database.
Use and storage are generally subject to your consent. Under certain conditions, cookies may be placed or read without consent when their sole purpose is to analyse the content you visited.
09 · CONSENT
How is your consent obtained and stored?
When you first visit our website, a dedicated information banner asks you to agree to, refuse, or make choices about the use of cookies. You may withdraw consent or change your choices at any time — for example by accepting only certain types of cookies — using our dedicated cookie-management tool: MANAGE MY CHOICES.
Cookies that are necessary for the website to function are not subject to your consent and cannot be deactivated in the cookie-management tool. You may prevent their use through browser settings, but the quality of your experience may suffer.
When you accept or refuse all or part of the cookies, we keep a record of your preferences for up to six months. During that period, we will not request action from you again. After that period, we will ask you to consent to or refuse cookies again.
10 · CONTROLS
How can you manage cookies?
If you do not want cookies stored or read on your device, a refusal cookie will be stored to record your objection. If you delete that refusal cookie, we will no longer recognise your choice and you will need to set preferences again the next time you visit.
You have several options for managing cookies, including blocking their use and deleting them. A cookie-management tool is provided on this website so you can manage preferences by cookie type at any time: MANAGE MY CHOICES.
You may also manage cookies through browser settings. Most browsers accept cookies by default, but you can choose to accept all cookies, refuse them systematically, or choose which cookies you accept depending on their origin. You can also regularly delete cookies from your device through your browser.
Please note: disabling certain cookies — especially functional or technical cookies — may affect your experience. Some features such as login, language preferences or other functionality may not work properly or may be unavailable.
BROWSER SETTINGS
Cookie controls in your browser
More information on managing cookies is available from the most commonly used browsers.
11 · YOUR RIGHTS
How can you exercise your other rights?
We comply with applicable data-protection laws and governance principles across all jurisdictions in which we operate. In accordance with applicable personal-data-protection legislation, you have the right to access, rectify, object to, restrict and delete your personal data.
For more information on protecting your personal data, see the General Privacy Notice in this Trust Centre. For questions or concerns about our use of cookies or personal-data practices, contact privacy@spironet.com.
Last update: April 2025
03 · DATA SUBJECT RIGHTS
If you wish to exercise your rights under applicable data-protection laws, complete this form in full. Use a separate submission for each right and product or service. Incomplete forms may lead to delays or rejection.
Before you submit
Fields marked with an asterisk (*) are mandatory. We may verify your identity before fulfilling a request. For assistance, contact dpo@spironet.com.
Proof of ID upload
Attach your ID document above (PDF, JPG or PNG, maximum 10MB each, up to 3 files). Uploads are stored privately and are only accessible to our data-protection team.
