Last Updated: September 23, 2020
For purposes of this Policy:
“Consumer”, “You”, “Your” includes any natural person acting individually or associated with an entity who is located in the EU or Switzerland for which Spekit provides products and/or services.
“Personal Data” includes any information, including Sensitive Data, that is (i) about an identified or identifiable individual or entity, (ii) received by Spekit in the U.S. from the EU or Switzerland, and (iii) recorded in any form.
“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (including trade union-related views or activities), sex life (including personal sexuality), information on social security measures, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposition of such proceedings, or the sentence of any court in such proceedings (including administrative proceedings and criminal sanctions).
1. The identity of the controller
You are hereby informed that Data that you provide are subject to an automated data processing whose controller is Spekit or its subsidiaries.
2. Collection of Data
We may collect Data about Our client, prospects and visitors.
Your Data are collected when you install, access, or use the Services, and when you otherwise interact with us.
Data We collect falls into the following categories:
- Identifying information and civil status
- Information about your company and current position
- Login information
- Location information
These Data are gathered directly from you via the Data collection form or indirectly through automated methods.
We may combine Data you provide Us with Data that are collected through automated methods.
Spekit does not collect Sensitive Data from its consumers.
2.1. Information you provide to Us
We process Data you provide directly to Us, in particular when you complete a data collection form.
For example, we collect Data when you create an account, use the Services, participate in a contest or promotion, request customer support or otherwise communicate with Us.
The Data may include the following data as well as any other type of information that we specifically request you to provide to Us through Our collection forms, such as:
- email address
- postal address
- phone number
- information about your company and current position.
2.2. Data We collect automatically when you use the Services
When you access or use Our Services, we automatically collect the following information about you:
- Log Information: We log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to Our Services
- Device Information: We collect information about the computer or mobile device you use to access Our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information
- Location Information: We may with your consent collect information about the location of your device each time you access or use one of Our mobile applications. If you initially consent to Our collection of location information, you may be able to subsequently stop the collection of these Data through your device operating system settings. You may also stop Our collection of location information by following the standard uninstall process to remove Our mobile applications from your device
- Connected Salesforce instance and user information: In order to use Our Services you may be required to connect to a Customer Relationship Management (CRM) system (e.g. Salesforce), in which event Spekit is given permission to access the CRM system in order to provide Our Services.
2.3. Information we collect automatically through Cookies and other tracking technology
A “cookie” is a small text file that is placed onto an Internet user’s web browser or device and which is used to record information related to the navigation or the use of a device or a website.
A “web beacon” is a small object or image that is embedded into a web page, application, or email and is used to track activity. They are also sometimes referred to as pixels and tags (also known as “tracking pixels”). It may be used in Our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. For more information about cookies, and how to disable them, please see “Your Choices” below.
Some of the cookies are used for the exclusive purpose of enabling or facilitating communication or are strictly necessary for the provision of Our Services.
These are essentially of session cookies for authenticating and connecting to the Services, as well as memorizing navigation items during a session.
You have the ability to decline cookies by changing the settings on your browser but this might prevent you from benefiting from some elements of the Services. You can also consult or destroy cookies if you wish, since they are stored on your hard disk.
We may also use these technologies for other purposes than the Services operation such as:
- To improve Our Services
- To remember you, for your convenience, when you visit Our Services
- To provide you with advertising tailored to your interests
2.4. Data We collect from other Sources
We may also obtain information from other sources and combine that with information we collect through Our Services. For example, if you connect a Spekit account with your social media account, we may have access to certain information from the company that owns or operates the social media account in accordance with the authorization procedures determined by such social media company. As another example, if you participate in a Spekit Referral program, we may collect information related to you and/or your referral.
Additionally, Spekit may receive information about you from other third parties whom you have authorized to share your information or who collect information in connection with co-branded offerings.
2.5. Third Party Cookies
When you access or use Our Services, one or more cookies from third party are likely to be placed on your equipment.
We inform you that We have no access and cannot exercise any control over third party cookies. However, we shall ensure that the partner companies agree to process the information collected on Our Services in compliance with the Regulations and undertake to implement appropriate measures for securing and protecting the confidentiality of the Data.
3. How we use the Data
We may use information about you for the following purposes:
- Provide, maintain and improve Our Services
- Provide and deliver the Services you request, process transactions and send you related information, including confirmations and invoices
- Send you technical notices, updates, security alerts and support and administrative messages
- Respond to your comments, questions and requests and provide customer service;
- Communicate with you about products, services, offers, promotions, rewards, and events offered by Spekit and others, with your prior consent, and provide news and information we think will be of interest to you
- Monitor and analyze trends, usage and activities in connection with Our Services;
- Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests
- Process and deliver contest entries and rewards
- Link or combine with information we get from others to help understand your needs and provide you with better service and
- Carry out any other purpose for which the information was collected, and which is necessarily contemplated by the collection of such information or is otherwise explicitly mentioned in the process of collection
According to the Regulation, each Data processing is performed on one of the following legal basis:
- Your consent
- The performance of the Service subscribed by you
- The legitimate interests pursued by Us or by a third party, except where such interests are overridden by your interests or your fundamental right and freedoms
4. How we share your Data
The following persons may receive the Data:
- Our subsidiaries
- Our Data processor
- Our trading partners
In connection with a joint marketing campaign, seminar, Spekit product offering or other product or service offered by Spekit in conjunction with a third party, we may share your information with any third parties participating in such offering and such parties may use this information for their direct marketing purposes. Please see “Your Rights to Information about Sharing” below for more information about this sharing.
In response to a request for information if we are required by, or believe disclosure is required by, any applicable law, regulation or legal process, including in connection with lawful requests by law enforcement, national security, or other public authorities;
In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of Our business to another company; and
With your consent or at your direction, including if we notify you through Our Services that the information you provide will be shared in a particular manner and you provide such information.
We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.
5. The period of Data retention
Data are retained in a form that allows your identification for a period no longer than is necessary for the purposes for which they are obtained and processed.
For more information, please refer to the period retention specified onto our Data collection forms.
6. Data transfer
We inform you that Data could be transferred outside European Union or Switzerland only with adequate safeguards.
All transfers of data from consumers of the European Union shall be made to:
- a country recognized by the European Commission as providing an adequate level of protection
- a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission
All transfers of data from consumers of Switzerland shall be made to:
- a country recognized by Switzerland as providing an adequate level of protection
- a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the Switzerland
We are committed to taking appropriate measures designed to keep your Data secure. Our technical, administrative and physical procedures are designed to protect Data from loss, theft, misuse and accidental, unlawful or unauthorized access, disclosure, alteration, use and destruction. We follow generally accepted standards to protect the data submitted to Us, both during transmission and once it is received. If you have any questions about the security of your data, you can contact Us at firstname.lastname@example.org.
8. Your rights
We provide our customers and their authorized agents with the ability to access, delete and transfer Personal Data. In order to exercise these rights you must login to your account to confirm your identity, which helps us ensure that Personal Data is only made accessible to appropriate parties. Customers will not receive discriminatory treatment for exercising their rights and can return to the service after deleting their data.
This section lists the privacy-related rights (“Rights”) we extend to all Spekit customers. Your right to know and right to deletion are not absolute and are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Data if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Data, your account with us or the security of our systems.
Right to Know – You have the right to know and access the Personal Data we collect, use, disclose, and sell about you.
Right to Deletion – You have the right to request that we delete any Personal Data we have collected from you or maintain about you. We may save Personal Data when permitted by applicable law including, without limitation, when the data is needed for a legal purpose.
Right to Rectification – If you are a registered Spekit user you may modify certain of your Personal Data by logging into our Site using your username and password and visiting the “Profile” page. Registered Spekit users may also access the “Account” page to view their subscriptions or email email@example.com to manage licenses.
Right to Opt-Out of the Sale of Your Personal Data– You have the right to opt-out of having your Personal Data sold. Spekit does not sell or rent Personal Data to third parties.
Right to Non-Discrimination – Spekit will not discriminate against those who exercise their Rights. Specifically, if you exercise your Rights, we will not deny you goods or Services, charge you different prices or rates for goods or Services or provide you a different level or quality of goods or Services.
Right to Portability –You have the right to receive your Personal Data in a structured, commonly used and machine-readable format. Spekit will assist in the transmission of such data to another entity, upon request, to the extent technically feasible.
You may exercise your rights by contacting Us in writing, with a proof of your identity, at the address provided in the “Contact Us” section below or at the address provided in our Data collection form.
Especially regarding promotional or sales communications, you may opt out of receiving promotional or sales communications from Spekit by following the instructions provided in those communications or by sending an email to firstname.lastname@example.org.
Finally, you have the right to lodge a complaint with a supervisory authority.
9. Your California Privacy Rights
Spekit collects various types of personal data about you during our customer relationship. In particular, we have collected the following categories of personal data from consumers within the last twelve (12) months:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal Data does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal data listed above from the following categories of sources:
- Directly from our clients or their agents.
- Indirectly from our clients or their agents.
- Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically.
- From third parties that interact with us in connection with the services we perform.
Use of Personal Data
We may use or disclose the personal data we collect for one or more of the following business purposes:
- To fulfill or meet the reason for which the data is provided.
- To provide you with information, products or services that you request from us.
- To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
- To improve our website and present its contents to you.
- For testing, research, analysis and product development.
- As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us is among the assets transferred.
We will not collect additional categories of personal data or use the personal data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Data
We may disclose your personal data to a third party for a business purpose. When we disclose personal data for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal data confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal data for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories
Category F: Internet or other similar network activity.
Category G: Geolocation data.
We disclose your personal data for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal data in connection with products or services we provide to you.
In the preceding twelve (12) months, we have not sold any personal data.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal data. This section describes your CCPA rights and explains how to exercise those rights.
- Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain data to you about our collection and use of your personal data over the past 12 months. Once we receive and confirm your verifiable consumer request, if specified, we will disclose to you:
- The categories of personal data we collected about you.
- The categories of sources for the personal data we collected about you.
- Our business or commercial purpose for collecting or selling that personal data.
- The categories of third parties with whom we share that personal data.
- The specific pieces of personal data we collected about you (also called a data portability request).
- If we sold or disclosed your personal data for a business purpose, two separate lists disclosing:
- sales, identifying the personal data categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal data categories that each category of recipient obtained.
- Deletion Request Rights
You have the right to request that we delete any of your personal data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal data from our records, unless an exception applies.
We may deny your deletion request if retaining the data is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that data that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- U.S. Mail: 3301 Lawrence Street Suite #3 Denver, CO. 80205; or
- Email: email@example.com
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Recourse, Enforcement and Dispute Resolution
If you have any questions or concerns, please write to us at the address listed below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data.
10. Changes to this Policy
11. Contact Us
3301 Lawrence Street Suite #3
Denver, CO. 80205