Privacy policy

This Privacy Policy explains how Spireway Global Ltd (trading as Vision360), a company registered in England & Wales (together "Spireway", "we", "us" or "our") collects, uses, discloses and safeguards personal data when you interact with our website at spirewayglobal.com and any related services (the "Services").

1. Who we are (data controller)

Spireway Global Ltd is the data controller for personal data processed through this website. You can contact us about this policy or exercise any of your rights below at privacy@spirewayglobal.com.

2. What is publicly visible on this website

Where we publish contact or company profile pages (for example under /vision360/conrec/[id] or /vision360/comrec/[id]), only the following limited business-context fields may be displayed publicly:

• Person's full name
• Job title
• Employer / company name
• Public LinkedIn profile URL
• General location (city / country)

Personal contact details are never publicly visible. Fields such as email address, telephone number and mobile number are intentionally hidden (visually blurred) on public pages and are not returned to browsers in a scrapable form. These details are held internally only for our own legitimate business communications and are not published, indexed by search engines, exposed via APIs, or transmitted to third parties for marketing purposes.

3. We do not sell personal data

Spireway Global does not sell, rent, license, trade or otherwise commercially transfer personal data to any third party under any circumstance. We are not a data broker. Our profile pages exist solely as a marketing and discoverability tool so that businesses and individuals can find us via search engines and AI answer engines and choose to contact us. They are not a lead-list product.

4. Personal data we collect

• Business contact data — name, job title, employer, work email, work phone number, LinkedIn profile URL, general location. Sourced from publicly available business information, direct interactions, or lawfully obtained B2B sources.
• Communications — messages, form submissions, meeting bookings, email correspondence.
• Technical data — IP address, browser/device information, pages visited, referring URL, and similar log data collected automatically.
• Account data — where you register for a client portal (email, hashed password, sign-in history).

5. How we use personal data (purposes & lawful bases)

• To operate this website and deliver our Services — legitimate interests and/or contract.
• To carry out B2B outreach and communicate with prospective and existing business customers about services likely to be of interest — legitimate interests. You can object at any time (see §9).
• To send transactional emails (account, proposals, confirmations) — contract.
• To send marketing emails where required by law — consent (you can unsubscribe at any time using the link in every marketing email).
• To secure the website, prevent fraud and comply with legal obligations — legitimate interests and legal obligation.

6. Sharing & sub-processors

We share personal data only with vetted service providers who process it on our behalf under written contracts (for example: hosting, email delivery, CRM, analytics, authentication). We do not disclose personal data to third parties for their own marketing.

7. International transfers

Where personal data is transferred outside the UK/EEA, we rely on appropriate safeguards such as UK/EU adequacy decisions or Standard Contractual Clauses, plus additional safeguards where required.

8. Retention

We retain personal data only for as long as necessary for the purposes described above, to comply with legal obligations, resolve disputes and enforce our agreements. Business contact records used for outreach are reviewed periodically and removed when no longer relevant.

9. Your rights

Subject to applicable law you have the right to access, rectify, erase, restrict or object to processing of your personal data, to data portability, and to withdraw consent at any time. To exercise any right, or to request removal of a public profile page featuring you or your company, email privacy@spirewayglobal.com and we will action reasonable requests promptly (and in any event within one month). You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk.

10. Cookies

We use a small number of strictly necessary cookies to operate the site and (where applicable) analytics cookies to understand aggregate usage. Non- essential cookies are only set with your consent.

11. Security

We use industry-standard technical and organisational measures — including encryption in transit, access controls, and hardened authentication — to protect personal data against loss, misuse and unauthorised access.

12. Changes to this policy

We may update this policy from time to time. The "last updated" date at the top will always reflect the latest version.

13. Contact

Spireway Global Ltd — privacy@spirewayglobal.com.