Privacy Policy

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Privacy Policy

Last updated: December 12, 2023

SPOTIO, Inc. (“SPOTIO,” “Company,” “we,” or “us”) respects the privacy rights of our online visitors and mobile application users. This Privacy Policy applies to information that we collect about you through our websites, mobile sites, mobile applications, and other interactive features or downloads (collectively the “Sites”) which, in each case, link to or incorporate this Privacy Policy. We will not use or share your information with anyone except as described in this Privacy Policy.

This Privacy Policy explains how SPOTIO collects, uses, shares and protects (collectively, “process”) information about you as an individual user of our online services or mobile applications (the “Company Service”). This Privacy Policy also describes how you can access/change your information and make choices about how your information is used.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY ACCESSING OR USING THE COMPANY SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY ALL THE TERMS OF THIS PRIVACY POLICY AND OUR TERMS OF SERVICE. IF YOU DO NOT AGREE TO SUCH TERMS, EXIT THIS PAGE AND DO NOT ACCESS OR USE THE COMPANY SERVICE.

INTRODUCTION

1.1 The Company is committed to safeguarding the privacy of our website and Users (“Users” or “you”).

1.2 This policy applies where we are acting as a data processor with respect to your personal data; in other words, where in collaboration with others we determine what needs to happen with the personal data and the collection of personal data. The other party taking part in this determination is referred to as a data controller, which determines what data needs to be collected.

1.3 This Privacy Policy does not apply to (i) data collected by other entities or organizations or (ii) data collected by a third party website, or content or applications of third parties, that may be linked to or from or accessible from the Company Service. Such links are provided only as a convenience. If you use these links to such websites, you may leave the Company Service. Company does not control nor endorse any such third-party websites and we you should read the privacy policies of any such website as we are not responsible for such policies.

1.4 Terms of Service. Use of the Company Service is subject to the terms of our Terms of Service which is hereby incorporated and made part of this Privacy Policy. By using the Company Service, you agree to be bound by our Terms of Service.

1.5 We continually strive to find new ways to enhance your experience with the Company Service and we may modify this Privacy Policy from time to time to reflect changes in our privacy practices. You are encouraged to review this Privacy Policy periodically and to check the “Last Updated” date at the top of the Privacy Policy for the most recent version. If we make changes to this Privacy Policy, we will notify you here, by email, or by means of notice through the Website, the Application, or any other part of the Company Service. Any changes will be effective immediately upon the posting of the revised Privacy Policy

HOW WE USE YOUR PERSONAL DATA.

2.1 In this Section 2 we have set out:

a. the general categories of personal data that we may process;
b. the purposes for which we may process personal data; and
c. the legal bases of the processing.

2.2 Types and Uses of Collected Information. Company collects two types of information about you, “Personally Identifiable Information” and “Non-Personally Identifiable Information.”

2.3 Personally Identifiable Information. Personally Identifiable Information is information that identifies a specific person. When you engage in certain activities via the Company Service, including but not limited to creating an account, sending feedback, or otherwise participating in the Company Service (collectively, “Identification Activities”), we may ask you to provide certain information about yourself. If you elect to engage in an Identification Activity, we may ask you to provide us with certain personal information about yourself, such as your name, address, email address, telephone number and/or any other information you provide to us, to create your account of profile, send communications about them to you, and populate forms for future transactions. In the event you choose to not provide certain Personally Identifiable information, you may not be able to participate in all of the features of the Company Service.

a. if you enroll in the Company Service through a third party (such as Facebook or Google) then Company may receive Personally Identifiable Information from such third party and by using the Company Service, you consent to such receipt of Personally Identifiable Information and its use pursuant to this Privacy Policy by Company.

b. we may use or share Personally Identifiable Information to, including but not limited to, provide products and/or services to you, to enable Third-Party Providers to provide products and/or services to you, enhance the operation of the Company Service, improve our marketing and promotional efforts, analyze use of the Company Service, and tailor your experience with third parties as provided below in this Privacy Policy. We may also use Personally Identifiable Information to troubleshoot, resolve disputes, accomplish administrative tasks, contact you, enforce our agreements with you, including our Terms of Service and this Privacy Policy, comply with applicable law, and cooperate with law enforcement activities.

c. we may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.

d. we may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.

e. we may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address, profile pictures, and company name. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.

f. we may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.

g. we may process information contained in any inquiry you submit to us regarding goods and/or services (“inquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.

h. we may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include first and last names, an email address to be used as a login, billing contact information, credit card number and a password. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests.

i. we may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.

j. we may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.

k. we may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

l. in addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or] in order to protect your vital interests or the vital interests of another natural person.

m. if you wish to apply for a job on our website, we will collect Personally Identifiable Information such as your name, email address, phone number, insurance information, driver’s license, social security number and other information (“employment date”). We use the information collected within this area of the website to determine your qualifications for the position in which you have applied and to contact you to set up an interview.

n. please do not supply any other person’s personal data to us unless we prompt you to do so and you have that person’s authorization to provide such.

2.4 Non-Personally Identifiable Information.

a. Non-Personally Identifiable Information is information that does not identify a specific person. This type of information may include things like the Uniform Resource Locator (“URL”) of the website you visited before coming to the Company Service or otherwise participating in the Company Service, the URL of the website you visit after leaving the Company Service, the type of browser you are using, your Internet Protocol (“IP”) address, mobile carrier information, mobile device information, or general and/or aggregated location data that does constitute Personally Identifiable Information. We, and/or our authorized Third-Party Service Providers, may automatically collect this information when you visit or use the Company Service using electronic tools like Cookies and Web beacons or Pixel tags, as described below in this Privacy Policy. We use Non-Personally Identifiable Information to troubleshoot, administer the Company Service, analyze trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We may also share this information with our authorized Third-Party Service Providers to measure the overall effectiveness of our products and services.

b. Geolocation Data. We may use geolocation data which we track through mobile devices, which allows us to set your location, to track your progress and provide that information to you and your recipient, to send you promotions and offers, and to allow you (if you choose through any features we may provide) to share this information with other people. Except as otherwise permitted in this Privacy Policy, we will not share this information with third parties for any purpose and will only use this information for the sole purpose of providing you with the Services. You may at any time no longer allow our Services to use your location by turning this feature off at the mobile device level. We may associate your unique mobile device identifier with Service usage information and therefore with any Personally Identifiable Information you provide which may enable us to treat the combined information as Personally Identifiable Information. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.

c. Behavioral Advertising and Opt-Out. Targeted advertising (also known as Behavioral Advertising) uses information collected on an individual’s web or mobile browsing behavior such as the pages they have visited or the searches they have made. This information is then used to select which advertisements should be displayed to a particular individual on websites other than our website. For example, if you have shown a preference for football while visiting our website, you may be served an advertisement for football-related equipment when you visit a site other than our website. The information collected is only linked to an anonymous cookie identifier; it does not include any information that could be linked back to a particular person, such as their name, address or credit card number. The information used for targeted advertising either comes from us or through third party website publishers.

(i) We will not conduct targeted advertising using your Personal Information without your express consent as provided to us on our website. If at any time you would like to opt out of targeted advertising from us that occurs when visiting our third-party advertising publishers, please click here to access the NAI Opt-Out Page. Please note that this will opt you out of targeted ads from us and any other participating advertisers. If you opt out, you may continue to receive online advertising from us; however, these ads may not be as relevant to you.

(ii) In order for behavioral advertising opt-outs to work on your device, your browser must be set to accept cookies. If you delete cookies, buy a new device, access our Services from a different device, login under a different screen name, or change web browsers, you will need to opt-out again. If your browser has scripting disabled, you do not need to opt out, as online behavioral advertising technology does not work when scripting is disabled. Please check your browser’s security settings to validate whether scripting is active or disabled.

(ii) Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.

2.5 Compliance with Google API Services User Data Policy. The Company Service’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

PROVIDING YOUR PERSONAL DATA TO OTHERS.

3.1 We do not rent or sell your personally identifiable information to third parties. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text originator opt-in data and consent; this information will not be shared with any parties.

3.2 We may disclose your personal data to any member of our group of companies. This means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. We may also disclose your personal data to the company to which we are providing Services, the terms and conditions under which you may have created an account for.

3.3 Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

3.4 We may disclose your inquiry data to one or more of those selected third-party suppliers of services via APIs identified on our website for the purpose of enabling them to connect your account with their Services, if any. Each such third party will act as a data controller in relation to the inquiry data that we supply to it. Each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

3.5 Company has an obligation when providing any and all of your data to any third party is to ensure that the third party effectively processes the personal data in a manner consistent with our own policies. In the event of a compliance failure by such third-party Company may be liable for the third-party lack of compliance and shall take appropriate steps to remedy the situation including, but not limited to, ensuring that processing by the third party shall cease and taking steps to remediate unauthorized processing.

3.6 We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.7 We disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We’ll notify you when we’re asked to hand over your personal information in this way unless we’re legally prohibited from doing so. When we receive requests like this, we’ll only release your personal information if we have a good faith belief that the law requires us to do so.

3.8 If you provide your express consent, as part of your use of our Services, we may also publish your name, voice, likeness and other Personally Identifiable Information that is part of your account.

ABOUT COOKIES.

4.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

4.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session.

4.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

COOKIES THAT WE USE.

5.1 We use cookies for the following purposes:

(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website.

(b) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally.

THIRD PARTY SERVICES.

6.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

6.2 We may use third party service providers to improve the Services. We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. We use Google Places to return information about places using HTTP requires. Google Places service may collect information from you and your device for security purposes. The information gathered by Google Analytics and Google Places is held in accordance with Google’s privacy policy, which is available at: https://www.google.com/policies/privacy/.

MANAGING COOKIES.

7.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

7.2 Blocking all cookies will have a negative impact upon the usability of many websites.

7.3 If you block cookies, you will not be able to use all the features on our website.

WEB BEACONS & EMBEDDED SCRIPTS.

8.1 Web beacons are small graphic images or computer code called web beacons may be included in our web and mobile pages and messages. The web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored in a user’s computer hard drive, web beacons are embedded invisibly on website pages. We may use web beacons or similar technologies to better manage content on our Services by informing us what content is effective, counting users of the Services, monitoring how users navigate the Services, counting how many e-mails that we send were actually opened or how many particular articles or links were actually viewed. We do not connect the information gathered by web beacons to our customers’ personal information. We may use web beacons for the legitimate purpose of enhancing the Services we provide to you.

8.2 Embedded scripts are computer code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third-party service provider, is active only while you are connected to the Services and is deactivated or deleted thereafter. We may use embedded scripts for the legitimate purpose of enhancing the Services we provide to you.

ANALYTICS.

9.1 We continuously improve our websites and our products, and we utilize different third-party web analytics tools to help us do so. We are interested in how visitors use our websites, our desktop tools, our mobile applications, what they like and dislike, and where they have problems. Our products, desktop tools and mobile applications use analytical tools to understand feature usage patterns, to enhance and improve your product experience and offer you specific usage tips and guidance. In connection with normal business operations, as well as to increase functionality and enhance your user experience, this usage information may be linked to personal information that we have about individual users. We maintain ownership of this data and we do not share this type of data about individual users with third parties.

9.2 Our mobile applications will also use analytical tools to help gather non-personally identifiable data about download and application usage. We may use information such as IP addresses to determine the general geographic locations areas of our visitors, but this information is not correlated to personal information about individual users. The web beacons used in conjunction with these tools may gather data such as what browser a person uses, what operating systems are used, domain names, MIME types, what is downloaded, and what content, products and services are reviewed when visiting or registering for services at one of our websites or using one of our mobile applications.

9.3 This information is used solely to assist us in maintaining a more effective and useful websites and products for our customers. This data will not be shared with third parties without your prior consent or unless required by law.

SECURITY OF INFORMATION.

10.1 You may be able to access your Personally Identifiable Information via the Company Service with your password and username. This password is encrypted. We advise against sharing your password with anyone. If you access your account via a third-party site or service, you may have additional or different sign-in protections via that third-party site or service. You need to prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-in mechanism appropriately and limiting access to your computer, browser, or mobile device by signing off after you have finished accessing your account. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. If we believe that the security of your information may have been compromised, we may seek to notify you of that development.

10.2 We are committed to taking all reasonable precautions to safeguard the privacy of personal information which has been provided by its users. We use technical, contractual, administrative and physical security steps to protect your personal information. Security measures such as restricted access and the use of passwords and encryption have been adopted to protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Our employees have been trained to respect your privacy at all times and those employees with access to your personal information shall use your personal information strictly in accordance with this Privacy Policy. We will protect your credit card information by using industry standard encryption technology.

10.3 Please be aware that no data transmission over the Internet or via e-mail is completely secure and therefore we cannot guarantee protection of all personal information in all cases. For example, we cannot guarantee protection against interception, misappropriation, misuse, or alteration, or that your information will not be disclosed or accessed by the unauthorized acts of others. Consequently, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. If you provide us with your credit card number, you should not send it electronically unless the email is encrypted, or your browser indicates that the access to our website is secure. Materials posted to online forums such as bulletin boards or chat rooms are public, not secure, and may be viewed by anyone. Any personal information you post may be collected and used by anyone and may result in unsolicited messages from other parties.

Public Areas. We may provide areas on the Company Service where you can publicly post information about yourself or can communicate with others such as on forums. This information may be accessible by other users and companies and may appear on other websites or web searches, and therefore this information could be read, collected, and used by others. We have no control over who reads your postings or what other users may do with the information you voluntarily post, so please use caution when posting any content or providing anything that could be deemed personal information.
DATA STORAGE IN THE EU

Information we collect, including, Personally identifiable Information, from Customers located in the European Union will be processed and stored in the European Union. Your Personally Identifiable information may be subject to access requests from governments, courts, or law enforcement in the EU according to laws of the EU or jurisdictions within the EU. By using the Services or providing us with any information, you consent to the processing and storage of your information in the EU.

Additional terms that apply to some residents of the European Economic Area (EEA)

In addition to the rights already recorded above, if you are based in the EEA, you may have the following additional rights in relation to the personal information we hold about you, in accordance with The General Data Protection Regulation 2016/67.

Additional Rights.

13.1 In this Section 13, we have summarized the rights that you may have under data protection laws in the EEA. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

13.2 Your principal rights under data protection laws in the EEA are:

a. the right to access;

g. the right to rectification;

c. the right to erasure;

d. the right to restrict processing;

e. the right to object to processing;

f. the right to data portability;

g. the right to complain to a supervisory authority; and

h. the right to withdraw consent.

13.3 You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

13.4 You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed.

13.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully process. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.

13.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

13.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.

13.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

13.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

13.10 To the extent that the legal basis for our processing of your personal data is:

(a) consent; or

(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

13.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

13.12 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.

13.13 You may access your personal information that we hold by contacting us using the contact details contained in Section 12 above. We will provide you with a copy of the personal information we keep about you. However, we reserve the right to charge you a reasonable amount for providing copies of any personal information you request, to take into account the time, cost and effort involved.

13.14 You may request that the personal information we hold about you be corrected by contacting us. If we do not agree to your request for a correction, you may then request that we take reasonable steps to attach to the information a statement of the correction sought but not made.

13.15 Please be aware that some of these rights may be limited or unavailable where we have an overriding interest or legal obligation to continue to process the data, or where data may be exempt from disclosure.

RIGHTS, CALIFORNIA PRIVACY RIGHTS AND NOTICE TO CANADIAN RESIDENTS.

14.1 California’s “Shine the Light” law, California Civil Code § 1798.83, requires certain businesses to respond to requests from California customers (those who have an established business relationship with us) asking about the business’ practices related to disclosing Personal Information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose Personal Information of customers to third parties for the third parties’ direct marketing purposes unless the customer first affirmatively agrees to the disclosure (opt-in) or if the customer has exercised an option to opt-out of such information-sharing (opt-out).

14.2 We have opted for this alternative approach, and we do not share Personal Information of customers information to third parties for the third parties’ direct marketing purposes without your permission.

14.3 Company collects various types of Personal Information about you online, as described in this Privacy Policy. Under California and Canadian law, SPOTIO customers who are residents of California or Canada may request certain information about our disclosure of personal information during the prior calendar year to third parties for their direct marketing purposes. To make such a request, please write to us at the address below.

RETAINING AND DELETING PERSONALLY IDENTIFIABLE INFORMATION.

15.1 This Section 15 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

15.2 Personal data that we process for any purpose or purposes shall be kept until such time as we receive a request for deletion from you.

15.3 Notwithstanding the other provisions of this Section 10, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject.

16. AGE. The Service is meant for those at least eighteen (18) years of age. Use of the Service by anyone under this age is a violation of the Terms of Service. We do not knowingly collect Personal Information from anyone under the age of 18. If we discover that we have collected Personal Information from a person under 18, we will delete it as soon as reasonably possible. If you are a parent or guardian of a minor under the age of eighteen (18) and believe he or she has disclosed Personal Information to us, please contact us at [email protected].

17. CONTACT US. If you have any questions or requests regarding this Privacy Policy or your Personal Information or Usage Information, please contact our Data Protection Officer: [email protected].