Privacy Policy

This privacy policy (“Privacy Policy”) governs how we, Spott (“Spott” “we”, “our” or “us”) use Personal Information (defined below) that we collect, use, receive and store pertaining to you (“User”, “you”) as further described below.

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Information.

This Privacy Policy may be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below. If there will be any significant changes made to the use of your Personal Information in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

INTRODUCTION

We have implemented this Privacy Policy because your privacy, and the privacy of other users, is important to us. This Privacy Policy explains our online information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Services. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, or other contact information.

TERMS OF USE

This Privacy Policy forms part of our Terms of Use which is available at https://spottme.com/tou/ (“Terms”). Any capitalized but undefined term in this Privacy Policy shall have the meaning given to it in the Terms.

CONSENT AND MODIFICATION

You are not legally obligated to provide us Personal Information, and you hereby confirm that providing us Personal Information is at your own free will. By using platform and the services available thereunder (the “Services”), you consent to the terms of this Privacy Policy and to our collection, processing and sharing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not access or otherwise use the Services. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the Website, and your continued use of the Services thereafter means that you accept those changes.

WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Data we collect	Why is the data collected and for what purposes?	Legal basis (GDPR only)	Consequences of not providing the data
*When you browse or visit our Website*
Cookies, analytic tools and log files For more information, please read our cookies policy, available at: Cookies Policy	To customize our Website and Services for your needs.	Legitimate interest (e.g., when using essential or functionality cookies).	Cannot collect and store the information Cannot use or access some parts of the Website
	To improve our Website and Services.	Consent.	Cannot improve our Website to better suit your needs.
*When you use our Platform.*
First and last name Email address Phone number Nationality Gender Date of Birth Your password for your Amazon account Any other Personal Data you choose to share with us through the App, Site, or otherwise	To provide you with insurance related information and quotes. To share your personal data with third party service providers for you to receive insurance quotes and information. To call you with insurance quotes and information. To send marketing communications.	Consent Legitimate interest.	Cannot process your request for an insurance quote, or send you insurance information or quotes. Cannot send marketing communications.
*When you sign up for our newsletters / email list*
Full name Email address Phone number Any other data you decide to provide/supply	To add you to our mailing list. To send you newsletters or other marketing communications.	Our legitimate interests (following your request) Consent	Cannot add you to our mailing list Cannot send you marketing communications
When we engage with Third Party Services
First and last name Email address Physical Address Phone number Nationality Any other relevant information related to your insurance policy	To receive data from Third Party Services based on the data collected from you when you use the Platform, in order to analyze your profile and improve our Services to you and our other Users.	Our legitimate interests (to provide you with our Services)	Cannot provide you the full scope of our Services
When we acquire your Personal Data from third-party sources (such as lead-generation companies)
Full name Email address Phone number Location	To contact potential customers and send them marketing issues.	Consent	We will not be able to get in touch with you and send you marketing materials
When we use the personal data of our service providers and suppliers
Full name Email address Company name Job position Phone number Any other Personal Data provided to us in connection with the services.	To contact our service providers. Processing the order of the applicable service.	Processing is necessary for the performance of a contract to which the service provider is a party to, or in order to take steps at the request of the service provider prior to entering into a contract with us. Our legitimate interests	Cannot communicate with you Cannot process the order of the service
When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn, etc.)
Full name Email address Phone number Social media profile Any other data you decide to provide/supply	To reply and/or respond to your request or question. To establish a first business connection/discussion.	We have a legitimate interest to respond your enquiry (e.g., send you more information about Spott)	Cannot reply or respond to your request

Finally, please note that some of the abovementioned Personal Information may also be used for fraud detection and prevention, and for security purposes.

HOW WE PROTECT AND STORE YOUR INFORMATION

- Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. Nevertheless, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
- Retention of your Personal Information. Your Personal Information will be stored until we delete the record and we proactively delete it or you send a valid deletion request, in some circumstances we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.

HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your information as follows:

To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Information in connection with the foregoing events.
Where you have provided your consent to us sharing the Personal Information (e.g., where you provide us with marketing consents or opt-in to optional additional Services or functionality); and
Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information is disclosed.

If you want to receive the list of recipients of your Personal Information, please make your request by contacting us at privacy@spott.co.

ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL INFORMATION

- We will use your Personal Information to provide and improve our Site, to send you marketing/advertisement communications that we believe may be of interest to you, to contact you in connection with the Site and certain programs or offerings that you may have registered for, and to identify and authenticate your access to the parts of the Site that you are authorized to access.
- We may use your designated email address to: (i) send you updates or news regarding the Site and our products; and/or (ii) respond to a “Contact Us” or administrative request (for example, to change your password).
- We may transfer your Personal Information to our local or foreign subsidiaries or affiliated companies for the purpose of storing or processing such information on our behalf. Such information may be transferred to other countries (including the US). We require that these parties agree to process such information in compliance with our Privacy Policy.
- We may share your Personal Information with our third party service providers and partners, but only to assist us with our business operations and to provide our Site and Services to you and other users. Such information may be transferred to other countries. We use commercially reasonable efforts to only engage or interact with third party service providers and partners that post a privacy policy governing their processing of Personal Information.

We may disclose your Personal Information or any information you submitted via the Site if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our Terms, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Spott, our users, yourself or the public.

USE BY CHILDREN

We do not offer our products or Services for use by children. If you are under 18, you may not use the Website, or provide any information to the Website without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children.

USER RIGHTS; HOW CAN I DELETE MY ACCOUNT?

Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

You have a right to access Personal Information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
You have the right to request that we rectify any Personal Information we hold that is inaccurate or misleading;
You have the right to request the erasure/deletion of your Personal Information (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;
You have the right to object, to or to request restriction, of the processing;
You have the right to data portability. This means that you may have the right to receive your Personal Information in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
You have the right to object to profiling;
You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
You also have a right to request certain details of the basis on which your Personal Information is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

Should you ever decide to delete your Account, you may do so by emailing info@ Spott.co. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS

The Site may enable you to interact with or contain links to your Third Party Account and other third party websites d Services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with. Spott uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using the Services, you grant Spott and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with Plaid’s end user privacy policy which can be found at the following link: https://plaid.com/legal/.

LOG FILES

We make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We may use such information to analyze trends, administer the Site, track users’ movement around the Site, and gather demographic information.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Our Site utilizes “cookies”, anonymous identifiers and other tracking technologies in order to for us to provide our Site and present you with information that is customized for you. A “cookie” is a small text file that may be used, for example, to collect information about activity on the Site. Certain cookies and other technologies may serve to recall Personal Information, such as an IP address, previously indicated by a user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

GOOGLE ANALYTICS

The Site uses a tool called “Google Analytics” to collect information about use of the Site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this Site. We use the information we get from Google Analytics to maintain and improve the Site and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes Information specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your Information from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

ACCESS/ACCURACY

To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. If you would like to delete or correct any of your other Personal Information that we may be storing, you may submit an access request by sending an email to info@Spott.co. Your email should include adequate details of your request.

SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

California Information Request Rights. California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@spott.co. Please note that we will respond to one request per customer each year.

Our California Do Not Track Notice. We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party web sites or online services. We may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a customer uses the Website.

Deletion of Content from California Residents. If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or personal information you have publicly posted. If you wish to remove such content or personal information and you specify which content or personal information you wish to be removed, we will do so in accordance with applicable law. Please be aware that after removal you may not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or personal information you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the Information protection laws, or if you wish to exercise your rights, we encourage you to first contact us at info@Spott.co.

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Last updated: March 2022