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Privacy Policy
Last Updated: May 6, 2021


This Spotnana Privacy Statement (“Privacy Statement”) describes the various ways that Spotnana collects, use and share information about you. In particular, this Privacy Statement 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 Statement 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 Statement. 
When we refer to “Spotnana” “we” or “us” in this Privacy Statement, we mean Spotnana Technology, Inc., Spotnana Technology BV (Netherlands),  Spotnana Technology Ltd., , their subsidiaries, other affiliated and/or related companies, as applicable the developer, owner and operator of the Spotnana Web App available at www.Spotnana.com,  the Spotnana Mobile App made available by us (together with the Spotnana Web App, collectively, the “Spotnana Apps”), and the related tools and related services (the “Services”). Unless otherwise defined in this Privacy Statement, terms used in this Privacy Statement have the same meanings as in our Terms and Conditions of Service Agreement. 

1. WHAT INFORMATION WE COLLECT


  • Definitions When you access or use our Services, we 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 third-party Spotnana Apps or when you visit third-party Spotnana Appss via our Services, those third-party Spotnana Appss may share information with us about your use of their service. We require certain information to provide our Services to you. For example, you must have an account in order to purchase, subscribe to or interact with the Services. When you choose to share such information with us, we collect and use it to operate our Services. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, travel preferences, specific expenses, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. The types of Personal Data we collect vary according to the way you interact with us, for example if you are an Authorized User using our Spotnana Services, or if you are a Client of Spotnana or a visitor to our Spotnana Apps. The Personal Data that we collect from Authorized Users or Clients is “Client Data”, and the Personal Data that we collect from our Spotnana Apps visitors apart from through the Spotnana Services is “Other Information”. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
  • Information You Provide. Our Services include the Spotnana Web App located at www.spotnana.com and the Spotnana Mobile App made available by us. When you use the Services, you will provide information that could be Personal Data, such as your username, first and last names, password, billing addresses, telephone numbers, business contact information, payment card and financial account information and identifiers of devices used to access our services. Tools. The Services may include tools such as a budget or travel planning applications. When you use such tools, you may provide your Personal Data or that of another individual.
  • Tools The Services may include tools such as a budget or travel planning applications. When you use such tools, you may provide your Personal Data or that of another individual.
  • User Content The Services may include publicly accessible blogs, community forums, or private 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 otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when 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.
  • Financial Information We use Chase Merchant Services, PayPal and Stripe for payments processing (e.g., credit card information is passed through to Chase Merchant Services, PayPal and/or Stripe in a secure manner for the purposes of charging transactions). To see the Chase Merchant Services Privacy Policy, please go to https://merchantservices.chase.com/online-privacy-policy, to see the PayPal Privacy Policy, please go to https://www.paypal.com/us/webapps/mpp/ua/privacy-full, and to see the Stripe Privacy Policy, please go to https://stripe.com/privacy.
  • Company Submitted Information Some uses of the Service may allow an administrator at your company to provide us with your Personal Data.
  • Spotnana Web App Visitors. If you visit or use the Spotnana Web App, you can fill out web forms, sign up for a newsletter, ask for a demo, register for an event, or take a survey. The specific Personal Data requested on these forms will vary based on the purpose of the form and will be treated as Other Information. 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 We automatically receive and record Other Information from your use of the Services, including but not limited to: app usage, your IP address browser type, Internet service provider, referring/exit pages, operating system, date/time stamp, clickstream data, and cookie information. This information is used to optimize your user experience. 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 not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.
  • Browser and Device Information. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, IP address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type, add-ons, and version and the name of the webSpotnana Apps or app you are using. We use this information to ensure that the Spotnana Apps and Services function properly.
  • Log Information. When you use the Spotnana Apps, certain information is automatically collected in system logs about how you interact with the Spotnana Apps, such as your online activity, search terms, pages you visit, date and time of access, and cookie information. When you use our Services, we also may collect information about your online activity, such as trips viewed, travel reservations made, and other actions within our Application. When you download and use one of our Applications, we and our service providers may track and collect Application usage data, such as the date and time the Application on your device accesses our servers and what information and files have been downloaded to the Application based on your mobile device's identifier.
  • Cookies Spotnana uses a variety of cookies and similar technologies in the Spotnana Web App and Services to help us collect Other Information. For more details about how we use these technologies, and the opt-out opportunities available to you, please see our Cookie Policy.
  • Pixel Tags Pixel Tags (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags 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. We currently do not provide Personal Data to any ad networks for use outside of the 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.
  • Mobile Services We may also collect Anonymous Data from your mobile device if you have downloaded our Spotnana Mobile App. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the Spotnana Mobile App, and information about the type of device you use. In addition, in the event our Spotnana Mobile App crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Spotnana Mobile App. This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.
  • Analytics We use third party analytics services, including but not limited to Google Analytics (“Analytics Services”), to help analyze how users use the Spotnana Apps and Services. We use the information we get from Analytics Services only to improve the Spotnana Apps and Services. The information generated by the Cookies or other technologies about your use of the Spotnana Apps and Services (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services 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 Service’s ability to use and share Analytics Information is restricted by such Analytics Service’s Terms of Use and Privacy Policy. By using the Spotnana Apps and Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at privacy@spotnana.com.
  • Other People’s Data If you decide to invite a third party to participate in the Services, or to create an account, we will collect your and the third party’s names and e-mail addresses in order to send an e-mail and follow up with the third party. We rely upon you to obtain whatever consents from the third party that may be required by law to allow us to access and upload the third party’s name and e-mail address as required above. You or the third party may contact us at legal@spotnana.com to request the removal of this information from our database. The e-mail that is sent to the third party will come from your e-mail address so that the third party will know that you want to invite him or her to the Services.
  • Third-Party Data We may receive Personal and/or Anonymous Data about you from companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Services. Our Services may also include features that allow you to connect third-party services such as features that allow you to log into our Services via an existing social media account. Your interactions with these features are governed by the privacy policy of the company providing it. These third-party services may supply us with Personal Data. We may add this information to the information we have already collected from you via our Services in order to improve the Services we provide. As a travel management platform, when we conduct fraud monitoring, prevention and detection 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. If you disclose any Personal Data relating to other people to us or to our service providers in connection with our Services, you represent and warrant that you have the authority to do so and to permit us to use the information in accordance with this Privacy Statement and/or any other agreements we may have with you. 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, such as identifying nearby hotels or airports. Most mobile devices allow you to control or disable the use of location services for applications in device settings menu.




2. HOW WE USE THE INFORMATION


While we consider the collection and processing of your information to be in our legitimate business interests we take your privacy rights seriously. We use information about you for a number of purposes. 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 Client Data you to provide the Services to you, including to create, maintain and secure accounts, to complete travel bookings process payment transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the Services. Client Data will be used by Spotnana in accordance with Client’s instructions, including any applicable terms in our agreements with our Customers, and as required by law. Spotnana is a processor of Personal Data and Client is the controller.
  • 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 treat it as Other Information.
  • To communicate with you about the Services. We use your contact information to send transactional communications via email or chat and within the Services, including confirming your purchases, reminding you of subscription expirations, ensuring accurate and timely payments are processed, responding to your comments, questions and requests, providing customer support, and sending you technical notices, product updates, security alerts, and administrative messages.
  • To market, promote, and drive engagement with the Services. 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 Facebook and Google. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, events and other information we think may be of interest to you. We also communicate with you about new product offers, promotions and contests.
  • Conducting surveys and collecting feedback about our Services. We do this to pursue our legitimate interests to 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. We also use your information to provide requested assistance (either originated from you, or a person acting legitimately on your behalf) and to offer proactive support in case of itinerary changes.
  • 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 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 De-Identified Personal Information. We may aggregate and/or de-identify Personal Data such that it is no longer considered Personal Data. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual. We engage in these activities based on our legitimate interest.
  • 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 the Services, with your permission.
  • Accomplishing Our Business Purposes. We use Other Information to provide Services to you (i.e., to perform our contract with you or the company that you work for or are associated with), to comply with our legal obligations, and to pursue our legitimate interests. Our business purposes include:
    • Data analysis to improve the efficiency of our Services, develop new products and services, enhance, modify, and maintain our current products and Services, as well as undertaking quality and safety assurance measures;
    • The security of the Spotnana Apps and Services to protect the safety, integrity of our customers, including monitoring, detecting, and preventing fraud, cyberattacks, attempts to commit identity theft, and unauthorized or illegal use of the Spotnana Apps or Services;
    • Identification of usage trends, for example, understanding which parts of our Services are of most interest to users;
    • Determine the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users;
    • Operate and expand our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests;
    • Audits to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
    • Improve, enhance, and develop the Spotnana Apps and Services, including to perform analytics, conduct research, identify trends, improve our algorithms, develop and improve the content, design, usability and quality of the Spotnana Apps and 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 and 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. This means we collect and use your information only where: We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services; It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests; You give us consent to do so for a specific purpose; or We need to process your data to comply with a legal obligation. 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. 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 though, in some cases, this may mean no longer using 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, such as communications relating to your Account. 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 to facilitate user interaction within the Services. We will not directly reveal user email addresses to other users.
  • Our Client. In the event that the Services have been made available to you by our Client (i.e., your employer for example), we may share your Personal Data with such Client. Personal Data may include travel bookings and details, travel status, travel expenses, profiles, current locations (based on itinerary), travel preferences, payments and transactions history. Travel bookings designated as business purpose are accessible by the Authorized User’s employer. Please note that the information we provide will be subject to the receiving customer's privacy policy. We are not responsible for the privacy and security practices of our customers.
  • Information Shared with Our Agents. We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Data with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Data or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Data with our Agents.
  • Service Providers. We share Personal Data with a limited number of our service providers. We have service providers that provide services on our behalf, such as website hosting, billing services, business analytics, distribution of surveys or sweepstakes programs, data analysis, credit card payment processors, information technology and related infrastructure, customer service, email delivery, identity verification, auditing, and fraud protection.
  • Business Partners and Providers of Travel Services. We share Personal Data with third-party business partners when this is necessary to provide our Services. Examples of third parties to whom we may disclose Personal Data for this purpose are airlines, hotels, rail, rental car companies, travel networks and agencies in order to make the travel bookings you requested. Other third parties include payment processing services. Please note that the information we provide may be subject to the receiving third party's privacy policy. We are not responsible for the privacy and security practices of these third parties.
  • 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 Statement.
  • 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 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 these 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, 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 will share your Personal Data with any relevant party you have granted us permission to share with.
  • Information Shared with Authorities. We may also need to disclose Personal Data in response to lawful requests by public authorities, 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


Keeping your information secure is a top priority for us. To that end we comply with industry-standard best practices to secure your 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 through 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.

  • Account Information. We retain your personal information only as long as necessary to accomplish the business purpose for which it was collected or to comply with our legal and contractual obligations, plus 1 year, 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 your account is deactivated or disabled, some of your information and the content you have provided will remain.
  • Marketing information If you have elected to receive marketing emails from us, we retain Other Information about your marketing preferences unless you specifically ask us to delete such information. We retain Other Information 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. You can 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 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 cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. For example, if you believe a Services account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy. 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 already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided below. When you make such requests, 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, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (where applicable). If you object to information about you being shared with a third-party app, please disable the app or contact your administrator to do so.
  • Opt Out of Communications. You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your Service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages in your account settings.
  • Send “Do Not Track” Signals. Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. We support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
  • 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, this applies to some of your information, but not to all of your information. Should you request it, we will provide you with an electronic file of your basic account information and the information you create on the spaces under your sole control. Please note that if you use our Services on behalf of an organization that is our customer (e.g., your employer), that customer may be responsible for fulfilling any of your rights listed above or elsewhere in this Privacy Statement.




6. HOW WE TRANSFER DATA INTERNATIONALLY


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 and we will ensure a similar degree of protection is afforded to it 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) to a country which does not offer adequate protection but whose transfer has been governed by the Standard Contractual Clauses of the European Commission (according to EU Commission Decision 87/2010/EC or any future replacement) or by implementing other appropriate cross-border transfer solutions to provide adequate protection. You may request a redacted copy (from which commercial information that is not relevant has been removed) of such Standard Contarctual 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 Statement.

  1. European Privacy Rights
    If required by applicable law (e.g. because the Spotnana entity using this privacy statement has its registered seat in a country of the European Economic Area (“EEA”) or 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. Kindly note further that if you request that Spotnana deletes your Personal Data, you will not be able to continue to use any Spotanana services that require Spotnana’s use of your Personal Data.
    If Soptnana 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 another recipient. Spotnana will carefully consider your request and discuss with you how it can best fulfill it
    Furthermore, you can request from Spotnana that Spotnana restricts your Personal Data from any further processing in any of the following events: (i) you state that the Personal Data Spotnana has about you is incorrect, subject to the time Spotnana requires to check the accuracy of the relevant Personal Data, (ii) there is no legal basis for Spotnana processing your Personal Data and you demand that Spotnana restricts your Personal Data from further processing, (iii) Spotnana no longer requires your Personal Data but you state that you require Spotnana to retain such data in order to claim or exercise legal rights or to defend against third party claims, or (iv) in case you object to the processing of your Personal Data by Spotnana based on Spotnana’s legitimate interest, subject to the time required for Spotnana to determine whether it has a prevailing interest or legal obligation in processing your Personal Data.
    As applicable under French law, you can also send us specific instructions regarding the use of your Personal Data after your death.
    You may contact our Data Protection Officer at dpo@spotnana.com . 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.
  2. 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.

    For purposes of the California Consumer Privacy Act, we do not "sell" (as such term is defined in the CCPA) the personal information we collect. California residents may make a request pursuant to their rights under the CCPA by contacting us as set forth below. We will verify your request using the information associated with your account, including email address. Government identification may be required.

    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, as, for example, some of your content may have been reposted by another user.




7. 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 Policy 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 Statement. We will notify you when we change this Privacy Statement. We may change this Privacy Statement from time to time. If we make significant changes in the way we treat your Personal Data, or to the Privacy Statement, we will provide notice to you on the Services or by some other means, such as email or an in-app notice. Please review the changes carefully. If you agree to the changes, simply continue to use our Services. Your continued use of our Services after the revised policy has become effective indicates that you have read, understood, and agreed to the current version of this Privacy Statement. If you object to any of the changes to our terms and you no longer wish to use our Services, you may close your account(s). Unless stated otherwise, our current Privacy Statement applies to all information that we have about you and your account. 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.




8. 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 ATTN: Data Protection Officer 12 Greenway Plaza, Suite 1100 Houston, TX 77046 Please include your name, address, and/or email address when you contact us.