Duco Enterprise Systems Design Ltd. ("Spyre", "we", "us" or "our") respects your privacy. This Privacy Statement explains what personal data we collect when you use www.spyre.group and related Spyre websites and landing pages (the "Website"), attend our events or communicate with us, why we use it, who we share it with, how long we keep it, and the rights you have. It is written to meet the EU General Data Protection Regulation ("GDPR"), the UK GDPR, the Israeli Protection of Privacy Law, 5741-1981 and its regulations (including Amendment No. 13), and the California Consumer Privacy Act as amended ("CCPA").
1. Who is responsible for your data
The data controller is Duco Enterprise Systems Design Ltd., 3 Eli Cohen St., Tel Aviv, Israel. For any privacy question or request, write to privacy@spyre.group.
2. Summary
- We collect only what you give us through our forms, plus limited technical data needed to run the Website.
- We do not sell your personal data and we do not use it for automated decisions that affect you.
- Analytics and marketing cookies are used only if you accept them in our cookie banner. You can change your choice at any time.
- Form messages are deleted automatically after 24 months. You can unsubscribe from our newsletter with one click.
3. Personal data we collect
Data you give us:
- Contact, landing-page and event forms: name, business email, company, job title, phone number (optional), your message, and which page you contacted us from.
- Resource downloads (guides, checklists and tools): name, business email, company and job title.
- Newsletter: your email address and the date you subscribed.
- Events and meetings: registration details, and where relevant, dietary or accessibility needs that you choose to share.
- Correspondence: emails and other messages you exchange with our team.
- Contributors with a Spyre account: name, email, password (stored only in encrypted form), author bio, photo and LinkedIn link you choose to publish.
Data collected automatically: your IP address, browser type, device and pages requested, which our hosting and security providers process to deliver the Website and protect it from abuse. Where you consent, analytics and marketing tools also collect usage data (see Section 6).
Data from other sources: we may obtain business contact details (name, job title, company, professional profile) from publicly available professional sources such as LinkedIn, or from event organisers when you register for a joint event.
We do not ask for, and ask you not to send us, special categories of data (such as health, religion or political opinions), except accessibility or dietary needs you choose to share for an event.
4. Why we use your data and our legal basis
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Replying to your enquiry, sending a resource you requested, arranging a call or a proposal | Steps at your request before a contract (6(1)(b)) and our legitimate interest in responding to business enquiries (6(1)(f)) |
| Sending you a confirmation email and notifying our team of your request | Steps at your request before a contract (6(1)(b)) |
| Sending our newsletter | Your consent (6(1)(a)), which you can withdraw at any time |
| Delivering services to our clients and managing events | Performance of a contract (6(1)(b)) |
| Operating, securing and improving the Website; preventing fraud and spam | Our legitimate interest (6(1)(f)) |
| Website analytics and advertising measurement | Your consent (6(1)(a)) given through the cookie banner |
| Meeting legal, tax and regulatory duties; defending legal claims | Legal obligation (6(1)(c)) and legitimate interest (6(1)(f)) |
Where we rely on legitimate interest, we have balanced it against your rights, and you may object at any time (Section 9). Giving us your data is voluntary. However, without your name and email we cannot reply to an enquiry or send a resource.
5. Who we share your data with
We share personal data only as needed for the purposes above, and only with recipients bound by confidentiality and data-processing terms:
- Lovable: website hosting and application platform, including our database (operated on Supabase infrastructure), file storage and the delivery of our system emails.
- Cloudflare: content delivery and protection against attacks.
- Adobe Fonts: web fonts. Your browser loads font files from Adobe, which receives your IP address.
- YouTube (Google): only on articles that contain an embedded video.
- Analytics and advertising providers (such as Google Analytics, Google Ads and LinkedIn): only if you accept the relevant cookies. They may act as independent controllers under their own privacy policies.
- Professional advisers, authorities and successors: our lawyers, accountants and auditors; courts or authorities where the law requires it; or a buyer or successor in the event of a merger, acquisition or sale of assets, subject to this Statement.
We do not sell personal data and we do not share it for cross-context behavioural advertising without your consent.
6. Cookies and similar technologies
When you first visit, a cookie banner lets you accept all, reject all, or choose by category:
- Essential (always on): needed for the Website to work, for example to remember your cookie choice or to keep contributors signed in.
- Analytics (off unless you accept): helps us understand how visitors use the Website.
- Marketing (off unless you accept): measures the results of our advertising.
No analytics or marketing tools load until you accept them. Your choice is stored on your device together with the date and the version of the notice you saw. You can change or withdraw it at any time with the round cookie button in the bottom-left corner of every page. Withdrawing your consent does not affect processing that took place before.
7. International transfers
Spyre is based in Israel, which the European Commission recognises as providing adequate protection. Some of our providers process data in the United States or other countries. Where data leaves the European Economic Area, the UK or Israel, we rely on an adequacy decision (including the EU-U.S. Data Privacy Framework where the provider is certified) or on the European Commission's Standard Contractual Clauses, together with additional safeguards where needed.
8. How long we keep your data
- Form messages and leads: deleted automatically 24 months after submission, unless they become part of an ongoing client relationship.
- Newsletter: until you unsubscribe. After that we keep only a record that you opted out, so we do not contact you again.
- Client and contract records: for as long as the law requires, generally 7 years for tax and accounting records.
- Contributor accounts: until the account is removed. Published articles may remain on the Website with the author's name.
- Website content change history: 12 months.
- Cookie choice: stored on your device until you clear it or we update this notice.
9. Your rights
Depending on where you live, you have the right to:
- Access your personal data and receive a copy;
- Correct inaccurate or incomplete data;
- Delete your data ("right to be forgotten");
- Restrict how we use it;
- Object to processing based on legitimate interest, and to direct marketing at any time;
- Data portability: receive the data you gave us in a machine-readable format;
- Withdraw consent at any time, without affecting earlier processing;
- Complain to a supervisory authority. In Israel this is the Privacy Protection Authority. In the EU, it is the authority in your country of residence or work. In the UK, it is the Information Commissioner's Office.
To exercise a right, email privacy@spyre.group. We may ask for information to confirm your identity. We reply within one month. Where a request is complex, we may extend this by up to two further months and will tell you why. Requests are free unless they are clearly unfounded or excessive.
Unsubscribing: every newsletter email contains a personal unsubscribe link that removes you from the list immediately.
10. Additional information for California residents
In the last 12 months we have collected these categories of personal information: identifiers (name, email, IP address); professional information (company, job title); internet activity (pages viewed, and with consent, analytics data); and inferences about your business interests. We collected them from the sources and for the purposes described in Sections 3 and 4, and disclosed them to the recipients in Section 5. We do not sell personal information, and we do not "share" it for cross-context behavioural advertising unless you accept marketing cookies. We do not knowingly sell or share the data of people under 16. You have the right to know, delete and correct your personal information, to opt out of sale or sharing, and to limit the use of sensitive personal information (we do not use it). We will not discriminate against you for exercising these rights. You or an authorised agent may submit a request to privacy@spyre.group. We respond within 45 days, and may extend this once by 45 more days with notice.
11. Security
We protect personal data with appropriate technical and organisational measures. These include encrypted connections (HTTPS), encrypted storage, role-based access limited to authorised staff, access rules at database level, regular backups and automatic deletion under our retention rules. We maintain the security measures required by the Israeli Protection of Privacy (Data Security) Regulations, 5777-2017. No system is completely secure. If a breach is likely to put your rights at risk, we will notify you and the relevant authorities as the law requires.
12. Children
The Website is meant for business professionals and is not directed at children under 16. We do not knowingly collect their data. If you believe a child has given us personal data, contact us and we will delete it.
13. Links to other websites
The Website may link to other websites and social networks, such as LinkedIn, Facebook, X and YouTube. Their own privacy policies apply, and we are not responsible for how they handle your data.
14. Changes to this Statement
We may update this Statement from time to time. We will change the "Last updated" date above, and where changes are significant we will tell you on the Website or by email. If a change affects the cookies we use, we will ask for your cookie choice again.
15. Contact us
Duco Enterprise Systems Design Ltd.
3 Eli Cohen St., Tel Aviv, Israel
Email: privacy@spyre.group
