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
Use of the Collected Information
Disclosure of Information to Third Parties
- a. When You Agree to Receive Information from Third Parties
- b. Third Parties Providing Services on Our Behalf
- c. Contests and Promotions
- d. Legal Reasons
- e. Business Transfer
Behavioral Advertising and Opt-Out
Third Party Content and Links to Third Party Services
Social Media Features
Changing Your Information and Cancelling Your Account
Your California Privacy Rights
Information Processed And Stored In The United States
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 us 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.
b. User Content and Public Information.
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 through customer support. In some cases, we may not be able to remove your User content, in which case we will let you know if we are unable to do so and why.
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 or offline in any media or format (currently existing or hereafter developed) in order to make 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 and our third-party service providers 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, all of the areas within our Services that you visit, and the time of day, among other information. We may use Usage Information for a variety of purposes, including to enhance or otherwise improve the Services. 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”). 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 various purposes, including to provide customer support, to send promotions and offers, to enhance our Services, and for our internal business purposes.
We may also collect Usage Information using the following methods or technologies to name a few:
Cookies. A cookie is a data file placed on a Device when it is used to access the Services. A Flash cookie is a data file placed on a Device via the Adobe Flash plug-in that may be built-in to or downloaded by you to your Device. Cookies and Flash Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our web pages. Cookies work by assigning a number to the user that has no meaning outside of the assigning website.
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. Web beacons or similar technologies help us better manage content on our Services by informing us what content is effective, count users of the Services, monitor how users navigate the Services, count how many e-mails that we send were actually opened or to count 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. 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 and may collect additional information such as resume, gender, and your ethnicity. 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 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 use your information to understand 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. The credit card information you provide in your personal profile at sign-up is not stored by us, but is stored and used by our third party credit card processors in order for them to process payment that you owe to us.
We use your IP address to help 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.
Please note that information submitted to the Services via a “contact us” or other similar function may not receive a response.
3. Disclosure of Information to Third Parties.
a. When You Agree to Receive Information from Third Parties.
b. 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. We may provide vendors with access to user information, including Personal Information, 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 obligated not to 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.
c. 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, you are agreeing to official rules that govern that Promotion, which may contain specific requirements of you, including, 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 the public 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.
d. 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, all in our discretion. Such disclosures may be carried out without notice to you.
e. Business Transfer.
We may share your information, including your Personal Information and Usage Information with our parent, subsidiaries and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process.
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.
If 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 customer support. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.
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) for as long as your account with the Services is active and as needed to provide you services. 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, 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, to enforce our agreements, and for other business reason. After a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymized data will be solely for analytic purposes.
8. No Children.
Our Services are not directed toward minors, no one 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 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 use standard, industry-wide, commercially reasonable 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 you do at your own risk. We recommend that you not disclose your password to anyone.
10. Your California Privacy Rights.
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 unless you provide us with permission at the time you provide such customer information.
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. Although we offer deletion capability for our services, you should be aware that the removal of content may not ensure complete or comprehensive removal of that content or information posted through the services.
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. Contact Us.