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Privacy Notice

Last Updated: Sep 12, 2024

This Spotnana Website Privacy Notice (“Privacy Notice”) describes the various ways that Spotnana collects, uses and discloses information about you as you visit and interact with our public website, which we make available at www.spotnana.com (“Website”). 

The “Services” referred to herein means only the service we provide of making our Website available to the public, and other marketing and communication services or activities which we conduct by means of the Website; not including our web application at app.spotnana.com, and as the term is used in this Privacy Notice, the “Services” do not include any other services we may provide to you, either directly or indirectly. Specifically, this Notice does not address the processing of your personal data in connection with any travel platform services to which you may be given access through your employer or other Spotnana customer or technology partner, or related tools and related services, and which may be provided via our web app, our Spotnana mobile app, or other applications, that may be made available to you via a different internet location, e.g., app.spotnana.com or other URL/URI by Spotnana or by our technology partners (collectively, “Platform Services”). Another entity, such as your employer, may have primary responsibility for providing you with disclosures regarding the treatment and protection of your personal data (i.e., is the legal “controller” or California Consumer Privacy Act “business” with respect to your data). Our processing of your personal data in connection with any Platform Services to which you are granted access is addressed in one or more separate privacy disclosures that are provided either by us, and/or by our customer which grants you access to the Platform Services (for example, in connection with your employment with our customer) —  accordingly, please consult the applicable disclosures made available through the applicable service, network location, or platform through which you access the Platform Services. 

This Spotnana Website Privacy Notice is intended to help you understand:

  1. WHAT INFORMATION WE COLLECT
  2. HOW WE USE INFORMATION
  3. HOW WE SHARE INFORMATION
  4. HOW WE STORE INFORMATION
  5. HOW TO ACCESS AND CONTROL YOUR INFORMATION
  6. HOW WE TRANSFER INFORMATION INTERNATIONALLY
  7. ADDITIONAL IMPORTANT PRIVACY MATTERS
  8. HOW TO CONTACT US

Please take a moment to read this Privacy Notice carefully so that you can understand your rights and our responsibilities regarding your information. This policy also explains your choices about how we use information about you. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you. By using the Service, you agree to the collection and use of information in accordance with this Privacy Notice.

When we refer to “Spotnana” “we” or “us” in this Privacy Notice, we mean Spotnana Technology, Inc., Spotnana Technology Ltd. (UK), Spotnana Technology Private Limited (India), their subsidiaries, and/or other affiliated and/or related companies.  One of more of these companies is the developer, owner, and operator of the Website.

1.  WHAT INFORMATION WE COLLECT

Definitions

When you access or use the Services, we may collect information from and about you to provide a more personalized and relevant experience. Some information you provide us and some information we collect automatically. Other information we collect from different sources, including affiliated entities, business partners, and other independent third-party sources. When you use our Services by “clicking-through” from a referring website operated by a Spotnana business partner or other third party, those third-parties share information with us about your use of their services. “Personal Data” means data that, alone or in combination, allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address,and depending on the circumstances, other information such as your IP address, or other non-public information about you that is associated with or linked to you and/or the foregoing data. 

The types of Personal Data we collect vary according to the way you interact with us as a visitor to our Spotnana Website and user of the Services. We may correlate or associate the data that we collect via your accessing of the Website and your related use of the Services, with other data received from your enrollment into and/or use of the Platform Services. “Deidentified Data” means data that is collected, selected, excerpted, or altered in a manner that does not readily permit the identification of individual persons from the data. We collect Personal Data and Deidentified Data, as described below. We may also alter Personal Data in order to create Deidentified Data, and/or replace Personal Data with Deidentified Data. 

Information You Provide

When you use the Services, you may be asked to create, and/or to provide to us; or we may automatically gather, Personal Data such as a username, password, your first and last names, telephone numbers, business contact information, and identifiers of devices used to access our Services. 

User Content

The Services may include publicly accessible blogs, community forums, company representative chat/DM, and/or other communication and messaging features. The Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Services or other services. You should be aware that Personal Data which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform, or other publicly available online service or platform, or that you share in any other open forum, including that hosted by us on our Website, may be viewed and used by others without any restrictions. We are unable to control such uses of your information by others when you interacting with a social media platform, and by using such services you assume the risk that the Personal Data provided by you may be viewed and used by third parties for any number of purposes known only to them and which we do not monitor or control.

Spotnana Website Users

While visiting the Website, you may use our Services in order to fill out web forms, sign up for a newsletter, ask for a demo, register for an event, take a survey, or receive other information or Services which we provide via the Website. The specific Personal Data requested on these forms will vary based on the purpose of the form, and will be treated in accordance with this Privacy Notice. For example, when you respond to our emails or surveys, we collect your email address, name, and any other information you choose to include in your email or response.

Information We Collect Automatically

When you use the Website, we automatically receive and record information about you which, alone or when combined with other information we receive about you from your use of the Services, may comprise Personal Data. Such information is typically collected automatically and stored in system logs which record how you interact with the Services, such as your online activity, search terms, pages or Services you visit or use, referring/exit pages, date and time of access, and cookie information (discussed further below).

We also collect Personal Data automatically in order to conduct fraud monitoring, and fraud and abuse prevention and detection activities. In conjunction with these activities, we may also receive Personal Data about you from our business partners, financial service providers, identity verification services, and publicly available sources as necessary to confirm your identity and prevent fraud, and/or abuse of and technology-based attacks on our Website, and/or our other data storage and processing systems.

Other information which we collect automatically may include but not be limited to: your Internet service provider, clickstream data, and other information collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, IP address, screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, browser add-ons and plug-ins that you have installed, and the version of the Services that you are visiting or using. This information is used to ensure that the Services function properly, to optimize your experience and improve the user interface, and that of other users in receiving the Services, to focus and improve our marketing efforts, and/or to perform user analytics related to these purposes. Generally, the Services automatically collect usage information, such as the number and frequency of users of the Services. We may use this data in aggregate form, that is, as a statistical measure, but we do not process this data in a manner so as to directly identify you personally. This type of aggregate data enables us, and third parties we authorize, to figure out how often individuals use parts of the Services so that we can analyze and improve the Services, and our marketing efforts related to other services we provide.

Interest-Based Advertising Practices

When you visit our Website, we and certain third-party advertising companies engaged by us, collect information about your online activities over time to provide you with advertising about products and services tailored to your individual interests. You may see Spotnana ads or promotions on other websites or mobile apps based on information related to your visit to our Website, as well as information received from third parties, because we participate in advertising networks. These advertising networks may place or recognize a unique cookie on your browser (including through the use of pixel tags), which we use to recognize you and your device; we may also similarly place cookies or other data on your device to identify you and your device, as described below. We and our advertising partners use these technologies, along with information we collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practices, and to learn how to opt out of some personalized advertising in desktop and mobile browsers on the particular device on which you are accessing this Privacy Notice, please visit http://optout.aboutads.info/#, http://optout.networkadvertising.org/#, and http://www.youronlinechoices.eu.

  • Cookies – Spotnana uses a variety of cookies and similar technologies in the Services which enable us to provide and manage the Services, and to automatically collect Personal Data. To view the opt-out opportunities available to you, please refer to our cookie consent utility which you can reach by clicking on the toggle/slider icon displayed in the corner of your browser.
  • Pixel Tags – Pixel Tags (also referred to as clear Gifs, Web beacons, or Web bugs) are tiny graphic images with a unique identifier, similar in function to cookies, that are used to track online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether emails have been opened to ensure that we are sending only messages that are of interest to our users. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. Advertisements served through the Services may be targeted to users who fit a certain general profile category, may be based on Anonymous Data inferred from information provided to us by a user, may be based on the Services usage patterns of particular users, or may be based on your activity on Third Party Services. To increase the effectiveness of ad delivery, we may deliver a file pixel tag from an ad network to you through the Services. These pixel tags allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and pixel tags from the ad network’s servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their Spotnana Apps.
  • Analytics – We use third party analytics services, including but not limited to Google Analytics (“Analytics Providers”), to help analyze how users use the Services. We use the information we get from Analytics Providers to improve the Services, and to assess and improve the effectiveness of our marketing activities. The information generated by the cookies or other technologies about your use of the Services (the “Analytics Information”) is transmitted to the Analytics Providers. The Analytics Providers use Analytics Information to compile reports on user activity. The Analytics Providers may also transfer the Analytics Information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Provider’s ability to use and share Analytics Information is restricted by such Analytics Provider’s Terms of Use and Privacy Notice. By using the Spotnana Apps and Services, you consent to the processing of data about you by Analytics Providers in the manner and for the purposes set out above. For a full list of Analytics Providers, please contact us at privacy@spotnana.com.
  • Other People’s Data – We do not permit users to use or engage Services in other than their own names, and on their own behalf. We rely upon each user to provide only their own Personal Data to us, and not to provide us with any Personal Data belonging to a third party.

How to Opt-out of the Sale/Sharing of your Personal Information

You may opt-out of our sale/sharing of your personal information by submitting an opt-out request via the “Do Not Sell or Share My Personal Information” link here, or by contacting us at privacy@spotnana.com.

Data Removal

You, or the third party, may contact us at privacy@spotnana.com or at the address below in order to request the removal of Personal Data from our database. 

Third-Party Data

We may receive Personal Data about you from companies that assist us, either in providing our Services, or in conducting the analytics described above. This information may be provided by way of these companies’ co-branded or private-labeled websites, or via these companies’ offering of their products and/or services in a manner which augments our Services. Our Services may also include features that allow you to connect third-party services, for example, features that allow you to access, or authenticate to, our Services via an existing social media account on a third-party platform, service, or website. When you interact with these third-party features, your use of these features are governed by the terms and policies (including the privacy and data protection policies) of the company that provided the feature. These third-party services may supply us with Personal Data. We may add such Personal Data to the information we have already collected from, or about, you via our Services, in order to improve the Services we provide, or for any of the other purposes described above.

Geolocation 

When you use certain features of the Services, we may collect certain information like IP address, device information, or log information to estimate your location (e.g., city or state) and to offer you an improved user experience and provide you with personalized location-based services. Most mobile devices allow you to control or disable the use of location services by mobile applications or internet browsers in the device’s settings menu. However, we may still monitor, and log, your inferred location based on the other data described above which permits us to determine your approximate or actual location, in order to carry out the purposes above.

2. HOW WE USE THE INFORMATION

While we consider the collection and processing of your information to be in our legitimate business interests. We use information about you for a number of purposes which we consider to be necessary to our legitimate interests that we pursue. Below are the specific purposes for which we use the information we collect about you.

  • To provide the Services and personalize your experience. We use Personal Data to provide the Services to you, provide user support related to these Services, and to operate, maintain, and improve the Services. 
  • For research and development. We are always looking for ways to make our Services smarter, faster, more secure, integrated and useful to you. To that end, we use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns, and areas for integration and improvement of the Services. To the extent you may choose to provide us with feedback, suggestions, or recommendations about your experience, we collect that information and may treat or use it as Personal Data; unless we process such information in order to render it Deidentified Data.
  • To communicate with you about the Services. We use your contact information to send transactional communications via email or chat, and otherwise within or regarding the Services,  to respond to your comments, questions, and requests, provide customer support, and send you technical notices, product updates, security alerts, and administrative messages.
  • To market, promote, and drive engagement with the Services, and our other service offerings which may not comprise or be hosted on the Website. We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email and by displaying ads on other companies’ websites and applications, as well as on platforms like LinkedIn, Facebook, and Google. These communications are aimed at driving engagement and maximizing what you get out of the Services. We may also communicate with you about new product offers, promotions and contests.
  • Conducting surveys and collecting feedback about our Services and other offerings. We conduct these communications in order to better understand if the Services are helpful to you and to evaluate the effectiveness of any updates we provide.
  • Customer support. We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services.
  • For safety and security. We use information about you and your service to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service terms, notices, and policies.
  • To protect our legitimate business interests and legal rights. Where required by law, where we believe it is in our legitimate business interest, or where it is necessary to protect our legal rights, interests, and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger, or sale of a business.
  • Aggregated and Deidentified Personal Information. We may de-identify your Personal Data so that it no longer comprises your Personal Data. Provided that this data no longer directly or indirectly identifies you or any other individual, we  may analyze and use this to generate other data for our use, which we may use and disclose for any purpose. We engage in these activities to further our legitimate interests.
  • With your consent. We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote our services, with your permission.
  • Accomplishing Our Business Purposes. We use Personal Data to provide Services to you, to comply with our legal obligations, and to pursue our legitimate interests and business purposes. Our business purposes include: 
    • Conducting data analysis to improve the efficiency of our Services, develop new products and services, and enhance, modify, and maintain the Services as well as other services that we provide; as well as undertaking quality and safety assurance measures with respect to our Services;
    • Maintaining the security of the Services in order to protect the safety and integrity of the data of our users and customers; including by monitoring, detecting, and preventing fraud, cyberattacks, attempts to commit identity theft, and unauthorized or illegal use of the Services;
    • Identification of usage trends, for example, understanding which parts of our Services are of most interest to users, and which parts users find relatively useful and/or easy to use; or less useful/more difficult to use;
    • Determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users;
    • Operating and expanding our business activities, for example, understanding which parts of our Services and other services are of most interest to our users so we can focus our energies on meeting our users’ interests;
    • Undergoing and conducting audits to verify that our internal processes function as intended, as well as in order to address legal, regulatory, and/or contractual requirements;
    • Improving, enhancing, and developing the Spotnana Services, including to perform analytics, conduct research, identify trends, improve our algorithms, develop and improve the content, design, usability and quality of the Services.
  • Additional purposes. We may process your information for any other purpose disclosed to you in connection with our Services from time to time. If we intend to process your Personal Data for a purpose other than that set out above, we will provide you with information prior to such processing,  including the grounds we intend to rely on in determining that such processing is permissible, and we will obtain your consent where necessary.
  • Legal basis for processing (for EEA users): If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. We collect and use your information only where: 
    • we need it to operate, or to provide you the Services;
    • provide customer support and personalized features and to protect the safety and security of the Services; 
    • the processing is necessary for the purposes of our legitimate interests, and these interests are not overridden by your data protection interests; such as for research and development, or to protect the security of the Services, or to comply with a legal obligation or is .
    • If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. 
    • Right to object to our processing conducted on the basis of a legitimate interest. Where we are using your information because we or a third-party (e.g., your employer) have a legitimate interest to do so, you have the right to object to that use by contacting us at the address below; although, in some cases, this may result in restrictions on how we permit you to use the Services

3. HOW WE SHARE INFORMATION

We may share your information with our third-party service providers, to comply with legal obligations, to protect and defend our rights and property, or with your permission. Below are the specific ways we share information we collect about you.

  • Communications with Us. As part of the Services, you may occasionally receive text, email and other communications from us; in the event that we communicate with you through text, standard messaging rates apply.
  • User Profile Information. User profile information including your username and other information you enter may be displayed to other users of Services to facilitate user interaction within the Services. We will not directly reveal user email addresses to other users.
  • Information Shared with Our Agents. We contract with other entities that perform certain tasks on our behalf and at our direction (our “Vendors”). We may need to share Personal Data with our Vendors in order to provide products or services to you. Unless we tell you differently, our Vendors do not have any right to use Personal Data or other information we share with them beyond what is necessary to assist us in providing the Services. By using the Services, you consent to our sharing of Personal Data with our Agents.
  • Service Providers. We engage service providers to perform functions and provide services for us in the United States and other countries. For example, we use a variety of third-party service providers who perform services for us and help us operate our Services and to help us understand the use of our Services. Such services include website hosting, data analysis, error and incident prevention, detection and investigation of fraud and other prohibited activities, error tracking, site analytics, reporting, information technology services and related infrastructure, customer service, advertising analytics and campaigns, search engine optimization, and email delivery. We may share Personal Data with such service providers subject to obligations consistent with this Privacy Notice and any other appropriate confidentiality and security measures, and on the condition that the third parties use such Personal Data only on our behalf and pursuant to our instructions (provided that such service providers may use other non-personal data for their own benefit).
  • Business Partners. We share Personal Data with third-party business partners when this is necessary to provide our Services. 
  • IP Address Information. While we collect and store IP address information, that information is not made public. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Notice.
  • Aggregate Information. We share Aggregate Information and Anonymous Data with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non-Personal Data about you that they have independently developed or acquired.
  • Interest-Based Advertising. We may allow third-party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Data (such as demographic information and past purchase history) we have collected with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit other websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the Spotnana Apps to facilitate the transmittal of information that may be useful, relevant, valuable, or otherwise of interest to you.
  • Information Disclosed Pursuant to Business Transfers. In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.
  • Information Disclosed for Our Protection and the Protection of Others. We also reserve the right to access, read, preserve, and disclose any information as it reasonably believes is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce our Terms of Service, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security, or technical issues, (iv) respond to user support requests, or (v) protect our rights, property, or safety, or those of our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
  • Information We Share with Your Consent: We may share your Personal Data with any relevant party you have granted us permission to share with.
  • Information Shared with Authorities. We may also be required to disclose Personal Data in response to lawful requests by public authorities, for example for law enforcement or national security reasons, or when such action is necessary to comply with a judicial proceeding or court order, or when otherwise required by law. We do not offer an opportunity to opt out from this category of disclosure.

4. HOW WE STORE AND SECURE INFORMATION

  • While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission via the Internet; or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
  • Personal Data Retention. We retain your Personal Data only as long as necessary to accomplish the business purpose for which it was collected or to comply with our legal and contractual obligations, and then securely dispose of that information. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
  • Information You Share on the Services. If we provide you with the option of creating a website account, and this account is deactivated or disabled, some of your website account profile information and the content you have provided will remain.
  • Marketing information If you have elected to receive marketing emails from us, we retain Personal Data about your marketing preferences unless you specifically ask us to delete such information. We retain Personal Data derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

5.  HOW TO ACCESS AND CONTROL YOUR INFORMATION

In accordance with applicable law and depending on where you reside, you may have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests.

  • Access and Update Your Information. Our Services and related documentation give you the ability to access and update certain information about you from within the Service. Some Services may allow you to update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.
  • Deactivate Account. You can deactivate your access to the Services at any time.
  • Delete Your Information. Our Services and related documentation give you the ability to delete certain information about you, or an instance of that information, from within the Service. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
  • Request That We Stop Using Your Information. In some circumstances, you may ask us to stop accessing, storing, using and otherwise processing your information. For example, depending on the circumstances, you can request that we delete your website-related account (if any) as provided in this Privacy Notice. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has previously taken place. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided above (“How to Opt-out of the Sale/Sharing of Your Personal Information”). When you make requests pertaining to your website-related personal information, we may need time to investigate and facilitate your request. If there is a delay or dispute as to whether we have the right to continue using your information, to the greatest extent feasible we will restrict any further use of your information while your request is pending.
  • Opt Out of Communications. You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, texting a “STOP” instruction when we have communicated with you via SMS with your consent, updating your email preferences within your Service account settings menu, or by contacting us as provided below in order to have your contact information removed from our promotional list or registration database. Even after you opt out from receiving promotional messages from us, you may continue to receive transactional messages from us regarding our other Spotnana services that do not pertain to the website Services. You can opt out of some notification messages in your account settings.
  • Data portability. Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context and the Services which you use, this right may apply to some of your information. Under these circumstances, should you request it, we will provide you with an electronic file of your basic website Services account information (if any) and the information you created under your sole control.

6. HOW WE RESPOND TO DO NOT TRACK/GLOBAL PRIVACY CONTROL SIGNALS

We support Do Not Track/Global Privacy Control browser signals. (Some browsers have incorporated “Do Not Track” (DNT) or “Global Privacy Control” (GPC) features that can send a signal to the websites you visit indicating you do not wish to be tracked (“Do Not Track” or other Global Privacy Control may be a preference that you can set in your web browser to inform websites that you do not want to be tracked; it may be supported by some websites. You may investigate the process for enabling or disabling Do Not Track/Global Privacy Control by visiting the Preferences or Settings page/sections of your favorite web browser(s).)

7. HOW WE TRANSFER DATA

As part of a global group of companies, Spotnana has affiliates and third party service providers within, as well as outside the EEA. Therefore your Personal Data may be transferred, used, processed or stored in the United States or any other country where Spotnana operates or maintains facilities or call centers, including jurisdictions that may not have data privacy laws that provide protections equivalent to those provided in your home country. When we transfer personal data outside of the EEA, we will do so in accordance with applicable law/by implementing appropriate safeguards. Transfers of personal data are made: (a) to a country recognized by the European Commission as providing an adequate level of protection; or (b) pursuant to International Transfers Standard Contractual Clauses of the European Commission (according to European Commission Implementing Decision (EU) 2021/914 of 4 June 2021 or any future replacement) or by implementing other appropriate cross-border transfer solutions to provide adequate protection. Impacted data subjects may request a redacted copy (from which commercial information that is not relevant has been removed) of such Standard Contractual Clauses by sending a request to privacy@spotnana.com.

By using our Services, you understand that your Personal Data may be transferred to our facilities and those third-parties with whom we share it as described in this Privacy Notice.

  a. European Privacy Rights
If required by applicable law (e.g., because you are within a country of the EEA), we adhere to the following rights described below.
You can request from Spotnana access at any time to information about which Personal Data Spotnana processes about you and the correction or deletion of such Personal Data. Please note, however, that Spotnana can or will delete your Personal Data only if there is no statutory obligation or prevailing right of Spotnana to retain it. If you make a request that Spotnana delete your Personal Data, this will limit your ability to use any Services provided by Spotnana that rely on Spotnana’s use of such Personal Data.

If Spotnana uses your Personal Data based on your consent or to perform a contract with you, you can further request from Spotnana a copy of the Personal Data that you have provided to Spotnana. In this case, please contact privacy@spotnana.com and specify the information or processing activities to which your request relates, and whether the Personal Data should be sent to you or your designee. Spotnana will consider your request and communicate with you how it can be fulfilled. Depending on how you communicate the request to us, verification that you or your delegate/agent have the necessary authority to make the request pertaining to your Personal Data may be required.

Furthermore, also subject to verification of the authority of yourself or your delegate/agent, you may request that Spotnana restricts further processing of your Personal Data to the extent that you accurately advise us that: (i) the Personal Data Spotnana has about you is incorrect; (ii) there is no legal basis for Spotnana’s processing of your Personal Data or that Spotnana’s legal obligation to conduct, or legitimate interest in, the processing such data is overridden by your interests or fundamental rights and freedoms which require protection of personal data; or (iii) you require Spotnana to retain such data in order to claim or exercise legal rights or to defend against third party claims; or (iv) you object to the processing of your Personal Data by Spotnana for direct marketing purposes; or to our processing based on Spotnana’s legitimate interest (whereupon we will suspend such processing at least until we demonstrate compelling legitimate interests for the processing which override your interest, rights, and freedoms.

You may also lodge a complaint with the EU/EEA data protection authority for your country or region where you have your residence, place of work, or where an alleged infringement of applicable data protection law occurs.

    b. California
California Consumer Privacy Act Privacy Statement (“CCPA Statement”)
The California Consumer Privacy Act (CCPA) affords California residents certain rights regarding categories of personal information that we collect, use, and disclose when we are acting in the capacity as a “business.”

Subject to certain limitations, CCPA provides California residents the right (i) to request to know more details about the categories or specific pieces of personal information we collected, including how we use the information and the categories of third parties to whom we disclose this information; (ii) to request the categories of sources from which we collect personal information; (iii) to access or delete their personal information; (iv) to opt out of any “sales” of personal information that may be occurring; and (v) to not be discriminated against for exercising these rights.

For purposes of compliance with the CCPA, in addition to the further details as described herein, we make the following disclosures: In the preceding 12 months, we may have collected and disclosed the following categories of personal information for one or more business purposes: identifiers, personal information (as defined in the California customer records law), characteristics of classifications protected by California or federal law, commercial information, internet or electronic network activity information, geolocation data, audio, electronic, or similar information, such as call recording, professional or employment information, and inferences drawn from other personal information to create a profile.

For a more detailed explanation of the Personal Data we have collected about you, please refer to “Information You Provide to Us,” “Information Automatically Collected,” and “Third Party Data” sections of this Privacy Statement. We use and disclose the information we collect for the business purposes described in this policy, please refer to “How We Use The Information” section above.

If you are a resident of California, under 18, and have an Account on our Services, you may ask us to remove content or information that you have posted to our Services by writing to privacy@spotnana.com. Please note that your request does not ensure complete or comprehensive removal of the content or information under all circumstances.

8. ADDITIONAL IMPORTANT PRIVACY MATTERS

  • Minimum Age. The Services are not directed to individuals under 16. We do not knowingly collect Personal Data from children under 16. If we become aware that a child under 16 has provided us with Personal Data, we will take steps to delete such information. If you become aware that a child has provided us with Personal Data, please contact our support services.
  • Links to Other Sites. Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s website. We strongly advise you to review the Privacy Notice of every site you visit. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
  • Changes to this Privacy Notice. We may change this Privacy Notice from time to time, and will provide notice to you by posting the revised Privacy Notice on the website, and if feasible by some other means (for example, if you maintain a website Services account), such as email. Please review the changes carefully. If you agree to the changes, simply continue to use the Services. Your continued use of our Services after the revised policy has become effective indicates that you have read, understood, and agreed to the then-current version of this Privacy Notice. If you object to any of the changes to our terms and you no longer wish to use the website Services, you may discontinue the use of the website Services, and close your website Services account(s) (if we support the creation of accounts, and you have created an account). Unless stated otherwise, our then-current Privacy Notice applies to all information that we have obtained about you via your website Services account, and all other information that we have obtained about you via your use of the website Services. Using our Services after a notice of changes has been communicated to you or published on our Services shall constitute consent to the changed terms or practices where legally permissible.

9. CONTACT US

Contacting us: If you have any questions, please don’t hesitate to contact us at:

+1 866-296-7768

privacy@spotnana.com

or via postal mail: 

ATTN: Privacy Team

115 Broadway 

Floor 5 

New York, NY 10006

 

Please include your name, address, and/or email address when you contact us. To the extent that you include such information, it will be processed by us as Personal Data in accordance with this Privacy Notice.