Last Updated: January 24th, 2018
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.
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 company located to the United States and that has adhered to the EU-U.S. Privacy Shield Framework
- 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 company located to the United States and that has adhered to the Swiss-U.S. Privacy Shield Framework
- 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 email@example.com.
8. Your rights
You have – at any time – a right of access, rectification, opposition on legitimate grounds and limitation where appropriate, as well as the right to define guidelines related to the fate of your Data after your death.
You also have the right to receive Data which you have provided to Us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller.
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. We inform you that you also may update, correct or delete by yourself your account information by logging into your online account.
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. 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 in accordance with the Privacy Shield Principles.
In the event we are unable to resolve your concern, you may contact JAMS, which provides an independent third-party dispute resolution body based in the United States, and they will investigate and assist you free of charge. A binding arbitration option may also be available to you in order to address residual complaints not resolved by any other means. Spekit is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (“FTC”).
10. Changes to this Policy
11. Contact Us
2301 Blake Street
Denver, CO. 80205