Privacy Policy

Spence & Partners Direct Marketing Privacy Notice


This statement sets out how Spence & Partners (Spence) handles personal information in compliance with the General Data Protection Regulation 2016/679 (the “Data Protection Legislation”).

We recognise that the correct and lawful processing of personal data is important and integral to our successful operations and to maintaining the trust of the people we deal with. We fully endorse and adhere to the principles set out under the Data Protection Legislation.

For the purposes of this statement, the term “personal data” shall refer to personal data.

Our Data Protection Team can be contacted at or at the following address:

Spence & Partners, Linen Loft, 27-37 Adelaide Street, Belfast, BT2 8FE.

Purpose and legal basis for processing the personal data

The personal data that Spence will hold but is not limited to your name, address, telephone number, email address and your place of work.

Spence will not share this information with any other parties other than with the companies within its group of businesses (3173 Limited, Dalriada Trustees Limited, Mantle Hosting Limited and Mantle Services Limited).

Spence holds and processes your data for the purpose of marketing the services of any one or all of the Group Companies to you at your business provided you have not opted out from receiving such communication.

Spence will hold and process your data for as long as it remains pertinent to market the Group Companies’ services to your business in accordance with our retention policy.

Spence, as data controller, will be processing data in accordance with its legitimate interest. We will therefore hold and process your data on this legal basis. You may object to the processing of your personal data on this basis and opt out at any time.

Individual Rights

Spence will fully respect your rights under the Data Protection Legislation including:

  • You have the right to make a subject access request for free and which can be made electronically.
  • You have the right to make a subject access request to verify the lawfulness of the processing we are carrying out.
  • We will respond to your subject access request within one month of you making it.
  • You have the right to withdraw consent to the use of your data and ask for your data to be erased.
  • You have the right to withhold personal data if disclosure would adversely affect the rights and freedoms of others.
  • You may obtain your personal information from us, except in limited circumstances.
  • You have the right to complain to the supervisory authority whose contact details are set out below.


Complaints relating to breaches of the Data Protection Legislation and/or complaints that an individual’s personal data is not being processed in line with the Data Protection Principles will be managed and processed by Spence’s Chief Operating Officer.

All complaints of dissatisfaction will also be processed in accordance with Group’s Complaints Process and should be sent to the Chief Operating Officer at:

Spence & Partners, Linen Loft, 27-37 Adelaide Street, Belfast, BT2 8FE.

Without prejudice to any administrative or judicial remedy, you have the right to lodge a complaint with the supervisory authority, the Information Commissioner’s Office (ICO), if you consider that the processing of your personal data infringes the principles of the Data Protection Legislation.

Their address is as follows:

Information Commissioner’s Office,
Wycliffe House,
Water Lane,

For more information you can visit

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