Last updated: May 25, 2018
Table of Contents
- Information we Collect
a. User Provided Information
b. User Generated Content and Public Information
c. Information Collected Through Your Access and Use of the Services
d. Information Third Parties Provide About You
e. Information You Provide About a Third Party
f. Geolocation Data
g. Information Collected from Couriers and Other Applicants
2. Use of the Collected Information
3. Disclosure of Information to Third Parties
a. Third Parties Providing Services on Our Behalf
b. Contests and Promotions
c. Legal Reasons
d. Business Transfer
4. Behavioral Advertising and Opt-Out
5. Third Party Content and Links to Third Party Services
6. Social Media Features
7. Changing Your Information and Cancelling Your Account
8. No Children
10. Your California Privacy Rights
11. Information Processed And Stored In The United States
12. Your Rights
13. Contact Us
1. Information We Collect.
a. User Provided Information.
Personal Information. We may ask you to provide us with certain categories of information such as personal information, which is information that could reasonably be used to identify you personally, such as your name, company, e-mail address, and mobile number (“Personal Information”). We may collect this information through forms in the Services, including account registration forms, contact forms, or when you otherwise interact with us. When you sign up to use the Services, you will be required to create an account profile that contains Personal Information. We collect this Personal Information for the purpose of carrying out or performing our contractual obligations with you in providing the Services, identifying and communicating with you, responding to your requests/inquiries and improving the Services. We also collect and use your Personal Information for a variety of business purposes, which are in our legitimate interests, as set out below.
You will not be subject to any decisions based solely on automated processing, including profiling.
b. User Content and Public Information.
The Services you subscribe may entail that we offer publicly accessible blogs or community forums or other ways to permit you to submit ideas, photographs, user profiles, writings, music, video, audio recordings, computer graphics, pictures, data, questions, comments, suggestions or other content, including Personal Information (collectively, “User Content”). We or others may reproduce, publish, distribute or otherwise use User Content online in any media or format (currently existing or hereafter developed) for our legitimate purpose of building and sharing case studies showing how customers are using the Services and reviewing the Services. Others may have access to this User Content and may have the ability to share it with third parties across the Internet. You should be aware that one core element of our Services is that any User Content you provide in these areas may be read, collected, and used by others who access them.
Please think carefully before deciding what information you share with others, including Personal Information, in connection with your User Content. We are not responsible for the accuracy, use or misuse of any content or information that you disclose or receive through the Services.
If you provide your express consent, as part of or services, we may also publish your name, voice, likeness and other Personal Information that is part of your User Content, and we may use the content, or any portion of the content, for advertising, marketing, publicity and promotional activities.
To request removal of your User Content from our blog or community forum or similar features, contact us as set forth in Section 13 below..
c. Application Content.
The Services offer you the ability to upload, post, display and submit ideas, photographs, video, graphics, pictures, data, questions, comments and other content to the Services, including Personal Information (collectively, “Application Content”). We may reproduce, publish, distribute or otherwise use the Application Content online in any media or format (currently existing or hereafter developed) for our legitimate purpose of making the Services available to you and to other members of your organization (within such parameters as are delineated by your organization’s administrator). You should be aware that any Application Content you provide in upload, post display or submit to the Services may be read, collected, and use by others who access them. We are not responsible for the accuracy, use or misuse of any Application content or information that you disclose or receive through the Services.
Please note that Company will not sell or, except as necessary to provide the Service, otherwise distribute your Application Content.
d. Information Collected Through Your Access and Use of the Services.
In addition to the information that you directly submit to us, we may use a variety of technologies that automatically collect information whenever you visit or interact with the Services (“Usage Information”). This Usage Information may include the browser that you are using, the URL that referred you to our Services, geolocation data (discussed below), all of the areas within our Services that you visit, and the time of day, among other information. We may use Usage Information for our legitimate purpose of, enhancing or otherwise improving the Services. In addition, we may anonymize certain Usage Information and utilize certain non-identifying information such as customer industry and location, number of users, geolocation of pins, sales prices, date/time of activities, including for example, responsiveness of downstream customers, in order to optimize the Services. For example, the Services may use this information to determine the optimal time to make contact with your potential customer leads and may further use this information to optimize work schedules and suggest sales management tactics and forecasting. In addition, you may utilize the Services in order to communicate with third parties. The Services may supervise and analyze your communications within the Services (including any communication methods you choose to integrate into the Services) for our legitimate purposes of providing and optimizing the Services. To the extent consent is required from a third party that is engaged in such monitored communications with you (e.g., using the Services to monitor telephone calls for quality control) you may need to secure any necessary consents and provide necessary notices to such third parties under any applicable laws. In addition, we collect your IP address or other unique identifier (“Device Identifier”) for your computer, mobile or other device used to access the Services (“Device”) for our legitimate purpose of forecasting selling points and potential customer churn and enhancing our Services. Usage Information may be non-identifying or may be associated with you. Whenever we associate Usage Information or a Device Identifier with your Personal Information, we will treat it as Personal Information.
In addition, tracking information is collected as you use our Services, including, but not limited to geolocation. Most GPS enabled mobile devices can define one’s location to within 50 feet. We collect this information for our legitimate purpose of providing customer support, sending promotions and offers, enhancing our Services, and for our internal business purposes of forecasting selling points and potential customer churn.
We may also collect Usage Information using the following methods or technologies to name a few:
Web Beacons. 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 Web pages. We may use web beacons or similar technologies for our legitimate purpose of better managing 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 tie the information gathered by web beacons to our customers’ personal information.
Embedded Scripts. An embedded script is computer code that is designed to collect information about your interactions with the Services, such as the links you click on. We may use embedded scripts for the legitimate purpose of enhancing the Services we provide to you. 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.
e. Information Third Parties Provide About You.
f. Information You Provide About a Third Party.
If you choose to refer people to our Services, we will ask you for the recipient’s name, phone number, delivery address and email address. We may send the recipient a one-time email inviting them to visit Spotio.com and provide promotions or an invitation to use the Services. We do not use this information for any other marketing purpose unless we obtain consent from that person or we explicitly say otherwise. Please be aware that when you enter the recipient’s email address through our Services, your name, e-mail address and physical address may be included in the communication sent to the recipient.
g. Geolocation Data.
We may associate your unique Mobile Device identifier or Service usage information with any Personal Information you provide, but we will treat the combined information as Personal Information.
h. Information Collected from Job Applicants.
If you wish to apply for a job on our website, we will collect Personal Information such as your name, email address, phone number, insurance information, driver’s license, social security number. 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.
2. Use of the Collected Information.
When you register for an account with us, we will send you a welcome email and promotional emails inviting you to use the Services. We will also communicate with you in response to your inquiries, to provide the Services you request, and to manage your account. We will communicate with you by email, telephone, push notification, and SMS or text message. We collect and use this Personal Information to take steps to carry out a contract with you or to fulfill our obligations under our agreement with you.
We use your information for our legitimate purpose of understanding which features of the Services are used most, to allow you to view your history, store your credit card information on a secure page, view any promotions we may currently be running, rate the Services, and to otherwise improve the Services and to determine which features we need to focus on improving, including usage patterns and geographic locations to determine where we should offer or focus services, features and resources. The credit card information you provide in your personal profile at sign-up for the payment that you owe to us is not stored by us, but is stored and used by our third party credit card processors who provide sufficient guarantees to implement appropriate technical and organizational standards to ensure the protection of such information in accordance with the applicable law.
We use your IP address for the legitimate purpose of helping diagnose problems with our computer server, and to administer our website(s). Your IP address is used to help identify you, but contains no personal information about you.
We will send you transactional-related communications in connection with the Services. These communications may include but are not limited to transactional summaries, maintenance notifications or other Services disruption notifications. Generally, you may not opt-out of these communications, which are not promotional in nature and are provided in furtherance of our transactional relationship.
In addition, we may use your Personal Information or Usage Information that we collect about you for our legitimate purpose of: (1) providing you with information or services or process transactions that you have requested or agreed to receive including to send you electronic newsletters, or to provide you with our special offers or promotional materials; (2) processing your registration with the Services, including verifying your information is active and valid; (3) improving the Services or our services, customizing your experience with the Services, or serving you specific content that is most relevant to you; (4) enabling you to participate in a variety of the Services’ features such as online or mobile entry sweepstakes, contests or other promotions; (5) contacting you with regard to your use of the Services and informing you of anychanges to the Services and/or the Services’ policies; (6) for internal business purposes regarding how the Services are being used, providing insight into customer needs and forecasting potential customer churn; and (7) for inclusion in our data analytics;.
3. Disclosure of Information to Third Parties.
a. Third Parties Providing Services on Our Behalf.
We use third party companies and individuals to facilitate our Services, provide or perform certain aspects of the Services on our behalf – such as third-parties to host the Services, design or operate the Services’ features, track the Services’ analytics, process payments, engage in anti-fraud and security measures, provide support, enable us to send you special offers, host our job application form, perform technical services, or perform other administrative services. We may provide vendors with access to user information, including Personal Information, and this information sharing is limited to only the information needed by the vendor to carry out the services they are performing for you or for us. Each of these vendors are under confidentiality obligations and are not permitted disclose or use Personal Information for any other purpose.
While we may use third party analytics service providers to evaluate and provide us with information about the use of the Services and viewing of our content, we do not share Personal Information with these analytics service providers, but they may set and access their own cookies, web beacons and embedded scripts on your Device and they may otherwise collect or have access to information about you, including non-personally identifiable information, for the legitimate purpose of enhancing the Services.
b. Contests and Promotions.
We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) through the Services that may require registration. By participating in a Promotion, and agreeing to official rules that govern that Promotion, your Personal Information may be used for our legitimate purpose of allowing the sponsor of the Promotion to use your name, voice and/or likeness in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, Personal Information may be disclosed to third parties or publicly on our website in connection with the administration of such Promotion, including, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.
c. Legal Reasons.
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, preserve, transfer and disclose your information (including Personal Information), including disclosure to third parties such as government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process; (ii) to protect and/or defend the Terms of Service for online and mobile Services or other policies applicable to any online and mobile Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of Spotio, our Services or any third party; (iv) to protect the safety of the public for any reason; (v) to detect, prevent or otherwise address fraud, security or technical issues; or (vi) to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity. Further, we may use IP address or other Device Identifiers to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers or law enforcement agencies, including disclosing such information to third parties, for our legitimate purposes identified in the foregoing sentence. Such disclosures may be carried out without notice to you.
d. Business Transfer.
4. 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.
[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.
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.
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.
5. Third Party Content and Links to Third Party Services.
The Services may contain content that is supplied by a third party, and those third parties may collect website usage information and your Device Identifier when web pages from any online or mobile Services are served to your browser. In addition, when you are using the Services, you may be directed to other sites or applications that are operated and controlled by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third parties. For example, if you click on a banner advertisement, the click may take you away from one of our websites onto a different website. These other websites may send their own cookies to you, independently collect data or solicit Personal Information and may or may not have their own published privacy policies. When you leave our website or Services, please be sure to read the privacy statements of all third party websites or applications before submitting any Personal Information to third parties.
6. Social Media Features.
7. Changing Your Information and Cancelling Your Account.
You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your Personal Information changes, or if you no longer desire our Services, you may correct, delete inaccuracies, or amend information by making the change on our member information page or by contacting us through [our Data Protection Officer as set forth below in Section 13]. We will make such requested changes in our then active databases without undue delay.
You may also cancel or modify your account or the communications that you have elected to receive from the Services by following the instructions contained within an e-mail or by logging into your user account and changing your communication preferences.
We will retain your Personal Information and Usage Information (including geolocation) only for as long as needed to fulfill the purposes for which we are processing your Personal Information and Usage Information unless the law requires or permits us to retain such Personal Information or Usage Information for a longer period. Even after your account is terminated, we will retain your Personal Information and Usage Information (including geolocation, delivery history, credit card information and transaction history) as needed to comply with our legal and regulatory obligations, and as necessary to resolve disputes, conclude any activities related to cancellation of an account (such as addressing chargebacks from your credit card companies), investigate or prevent fraud and other inappropriate activity, or to enforce our agreements.
8. No Children.
Our Services are not directed toward minors, and no person under 18 (and certainly no children under 13) are allowed to register with or use the Services. 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 privacy@Spotio.com.
The Personal Information and Usage Information we collect is securely stored on Amazon Web Services databases, and we implement appropriate technical and organizational measures to ensure and to be able to demonstrate that processing is performed in accordance with the standards required by the applicable law, taking into account the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity to your rights and freedoms . These measures include security practices such as encryption, firewalls and SSL (Secure Socket Layers) for protecting your information – such as any portions of your credit card number which we retain (we do not ourselves retain your entire credit card information) and geolocation information. However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that information you supply won’t be intercepted while being transmitted to us over the Internet or wireless communication, and any information you transmit to Spotio is at your own risk. We recommend that you not disclose your password to anyone.
10. Your California Privacy Rights and Notice to Canadian Residents.
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).
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.
Alternatively, you may send us an email at firstname.lastname@example.org with the words “California Privacy Rights” in the subject line.
Spotio does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (“DNT”) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.
Spotio offers interactive services which allow you to post content to share publicly. At any time you can delete or remove content you have posted using the deletion or removal options within our services. If you have questions about how to remove content in a specific service or if you would like additional assistance with deletion you can contact support.
11. Information Processed And Stored In The United States.
Information we collect, including, Personal Information, will be processed and stored in the United States. Your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By using the Services or providing us with any information, you consent to the processing and storage of your information in the United States.
12. Your Rights as an EU Individual.
If you reside in a member state of the European Union or European Economic Area, you have certain rights with respect to Personal Information concerning you, including the right to:
- request access to and obtain a copy of your Personal Information;
- request rectification of your Personal Information if it is no longer accurate or erasure of your Personal Information if our retention is no longer necessary for the purposes for which it was collected, and if other conditions are met;
- restrict or object to the processing of your Personal Information in certain circumstances; and
- data portability (if applicable) to request a copy of your Personal Information in electronic form and transmit it for use in another party’s service.
If you wish to exercise any of your rights in relation to your Personal Information please send your request to us using the details set out in the “Contact Us” section below. We will consider and act upon any request in accordance with applicable data protection laws.
13. Contact Us.
Attn: Lane Buckman
14114 Dallas Parkway Suite 640
Dallas, TX 75254
E-mail address: email@example.com