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PRIVACY POLICY

 

Effective Date: Dec 14, 2018

 

Note: This document is only available in English, as it's the official language of commerce for our clients (B2B) and in the regions we operate. Any translated copies are not valid.

 

This Privacy Policy applies to the Spate Inc owned and operated websites and its subdomains (“Sites”). Spate Inc (Spate, “we,” or “us”) knows that you care how information about you is used and shared. This Privacy Policy explains what information of yours will be collected by Spate when you access the Sites and Spate Services, how the information will be used, and how you can control the collection, correction and/or deletion of information. We will not use or share your information with anyone except as described in this Privacy Policy. Capitalized terms that are not defined in this Privacy Policy have the meaning given them in our Terms. The use of information collected through our Sites shall be limited to the purposes under this Privacy Policy and our Terms of Service to customers.

 

Information We Collect on Our Own Behalf.

 

(a) Our Service: We may collect personally identifiable information about you, such as your full name, phone number, email address, or similar, when you register for an account. If you choose to purchase a product from us, we or our third-party payment processors will collect your payment information. When you use the Spate website or Services, we may receive certain information about you as described below. We may send you service and other emails, as related to your account and the operation of our site and services. If you no longer wish to receive these emails, you may opt out of them by canceling your account and/or via unsubscribe links included in the emails, as appropriate.

 

(b) Cookies And Tracking Technologies: Technologies such as: cookies, beacons, tags and scripts are used by Spate. These technologies may be used in analyzing usage patterns for our sites and services, administering the Sites, tracking your movements around the Sites and to gather demographic information about our user base as a whole. We use cookies to remember users’ settings as well as for authentication and analytics. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Site(s), but your ability to use some features or areas of our Site(s) may be limited.

 

We may use our own internal tools to track interactions with the website, such as click/touch, page content and other interactions with the system. Outside of the minimum of information required for site authentication and access control, we do not store or track your IP address or any additional, personal, information.

 

We may use any of Google Analytics, Google Tag Manager and Google AdWords (Conversion Tracking) to track information about your behavior on our website. For more information or to opt-out of these tools and their tracking services, please visit the respective website(s) of these vendors or contact us at privacy@spate.nyc.

 

 

Access And Retention Of Data.

 

An individual who is a current or former Spate customer who seeks access or wishes to correct, amend or delete inaccurate personal data should direct his query to privacy@spate.nyc. We provide self administration tools to our users to update and maintain their own personal information (eg. name, email address and position) and periodically may encourage them to check that the information is correct and up to date and update it if it is not.

 

We will retain personal data we for our customers for as long as needed to provide our services, and make sure it is removed and safely deleted within 30 days if it is no longer necessary. Outside of providing access to our website and services, Spate may also retain this personal information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

 

How We Use Your Information.

 

(a) We use the information that we collect to operate and maintain our Sites and the Spate Service and to respond to your questions and concerns. The legal basis is art. 6(1)(f) of the EU General Data Protection Regulation (GDPR).

 

(b) If you have given your consent, we may use the information that we collect to send you marketing communications via email.

 

(c) We also use the information that we collect to maintain and improve our service and website.

 

 

How We Share Your Information.

 

(a) Personally Identifiable Information: Spate will not rent or sell or otherwise share your personally identifiable information to or with others. We may store personal information in locations outside the direct control of Spate (for instance, on servers or databases owned by hosting providers such as Google).

 

(b) Non-Personally Identifiable Information: We may share non-personally identifiable information (such as anonymous usage data, referring pages and URLs, platforms, number of clicks, etc.) with third parties or service providers for analysis of usage patterns for our Service(s) and Site(s). We may publish non-personally identifiable information in an anonymized, abstracted and/or aggregated form, in the context of discussing usage patterns for our Service(s) and Site(s).

 

(c) Instances Where We Are Required To Share Your Information: Spate will disclose your information where required to do so by law, if subject to subpoena or other legal proceeding or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Spate, our users or others.

 

(d) What Happens In The Event Of A Change Of Control: We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as names and email addresses, and other User information related to the Spate Service and Site(s) may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

 

Storage and Processing.

 

Your information collected through the Spate Service and/or Site(s) may be stored and processed in the United States, in secure cloud facilities as provided by our hosting provider (Google).

 

 

How We Protect Your Information.

 

Spate is concerned with protecting your privacy and data, but we cannot ensure or warrant the security of any information you transmit to Spate or guarantee that your information on the Spate Site(s) and Service(s) may not be accessed, disclosed, altered or destroyed by breach of any of our industry standard physical, technical or managerial safeguards. When you enter sensitive information (such as log in credentials) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). However, no method of transmission over the Internet or method of electronic storage. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site, you can contact us at security@spate.nyc or privacy@spate.nyc. We may use an outside payment and credit card processing company to bill you if you purchase services. The company do not retain, share, store or use personally identifiable information for any other purposes.

 

Privacy Shield.

 

Spate complies with the EU GDPR framework as set forth by the European Union regarding the collection, use, and retention of personal data from European Union member countries. We adhere to the requirements of notice, choice, onward transfer, security, data integrity, access and enforcement.

 

 

 

Compromise of Personal Information.

 

In the event that personal information is compromised as a breach of security, Spate will promptly notify our customers and relevant legal authorities as appropriate, in compliance with all applicable law.

 

 

Your Choices About Your Information.

 

For current Spate customers, you can review, correct, update or delete inaccuracies to the information about you that Spate keeps on file by logging into your account to update your name and contact information.

 

Alternately (if you are unable to log in or for former Spate customers), you can contact us directly at privacy@spate.nyc. We will acknowledge your request within seventy-two (72) hours and handle it promptly.

 

Data protection law gives you a range of rights in connection with our processing of your personal data. In this regard, you have the right to request that we rectify or delete the personal data or restrict the processing of your personal data, if you think they are inaccurate. Furthermore, you have the right to object against the processing based on our legitimate interests as a legal basis. We are required to assess and act on your request. Additionally, you also have the right to data portability if it should become relevant. You have a right to lodge a complaint with your local supervisory authority.  If you have any questions about this Privacy Policy or your rights under data protection law, you can contact our Data Protection Officer: privacy@spate.nyc.

 

Enforcement and Dispute Resolution.

 

 Spate commits to resolve complaints about your privacy and our collection or use of your personal information. EU Data Subjects with questions or concerns about the use of their Personal Data should contact us at: privacy@spate.nyc.

 

Our Retention Of Your Information.

 

(a) If you have an account with Spate, we will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

 

(b) If you are a visitor to the Spate Sites we may retain your information for as long as necessary but no longer than one (1) year after your last visit to our Sites.

 

Children’s Privacy.

 

Protecting the privacy of young children is especially important. For that reason, Spate does not knowingly collect or solicit personal information from anyone under the age of 13. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at privacy@spate.nyc

 

 

Notification Procedures.

 

It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email, written or hard copy notice, or through conspicuous posting of such notice on the Service, as determined by Spate in its sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in this Privacy Policy.

 

 

Links to Other Web Sites.

 

We are not responsible for the practices employed by websites or services linked to or from the Spate Service(s) or Site(s), including the information or content contained therein. Please remember that when you use a link to go from the Spate Service(s) or Site(s) to another website or service, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies.

 

 

Changes to Our Privacy Policy.

 

All changes to this Privacy Policy are effective when they are posted on this page. When we change the policy in a material manner, we will let you know via email and/or a prominent notice on our Site, prior to the change becoming effective and update the ‘effective date’ at the top of this page.

 

If you have any questions about this Privacy Policy, the practices of this Site, or your dealings with this website, please contact us at privacy@spate.nyc, or send mail to:

 

SPATE
50 Eldridge, 8th Floor
New York, NY 10002