Spur is an information security company. We provide solutions to help
our customers keep their data and their business operations secure.
This Privacy Notice (“Notice”) describes the manner in which Spur
collects, uses, maintains, and discloses information from users of our
website, prospective customers or job candidates, situations in which
Spur is a data controller, and from the use of our products and the
performance of our services (“Offerings”).
For purposes of this Notice, the terms “user,” “customer,” “you,” and
“your” are meant to refer to the individuals about whom we may collect
personal information, and at times may be used within the Notice
interchangeably.
If you have any questions or concerns about our use of your personal
information, then please contact us using the contact details provided
at the bottom of this Privacy Notice.
I. DATA COLLECTION AND USE
A. What Information Does Spur Collect?
Information collected and used by Spur may include, among other things,
the Internet Protocol (IP) address, browser information, device ID, the
type of computer and technical information about a user, such as the
operating system and the Internet service providers utilized and other
similar information, some of which may be considered personal
information in your jurisdiction.
From users who are required to login to gain access to a particular
website feature or Offering, we collect usernames, passwords, and other
login credentials that are used for the purpose of verifying user
authorization to access the feature or Offering.
Our site and our Offerings are not designed for or directed at children
18 years of age or younger. Spur will not intentionally collect or
maintain personal information from children 18 years of age or younger.
If we learn we have collected or received personal information from a
child 18 years of age or younger without verification of parental
consent, we will delete that information. If you believe we might have
any information from or about a child 13 years of age or younger, please
contact us via email at privacy@spur.us
B. Why Does Spur Collect This Information?
Spur processes information in the course of running our website,
processing payments, providing support, improving user experience,
running our infrastructure, preventing fraud, enforcing our legal
rights, sending marketing and other communications, processing
agreements, complying with our legal obligations, to achieve other
legitimate interests, and where users have provided consent. Personal
information, such as contact information, is collected from our website,
Offerings, partners, and where you have provided it directly to Spur.
C. With Whom Does Spur Share This Information?
We do not sell, trade, or rent the personal information we collect from
our website to others. When we collect personal information through our
Offerings, it is made available to the Spur customer who was the source
of the information and we use it as described in this Privacy Notice,
terms and conditions, or otherwise as directed by our customers. We may
use third party service providers or partners to help us operate our
business; provide, support, maintain, or secure our Offerings and our
website; or administer activities on our behalf, such as events or
marketing campaigns. It may be necessary to provide or allow access to
your personal information to these third-party service providers or
partners for those purposes. We provide information regarding our
business to our auditors and legal counsel. In some cases, the shared
information may contain personal information, but the auditors and legal
counsel may only use it for the purpose of providing their professional
services. We may also disclose your personal information as required by
law, such as to comply with a subpoena or similar legal process; or when
we believe that disclosure is necessary or appropriate to protect our
rights, protect your safety or the safety of others, investigate fraud,
or respond to a government request. We may transfer any information we
have about you in the event we sell or transfer all or a portion of our
business or assets.
II. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION (EEA Visitors Only)
If you are a visitor from the European Economic Area (EEA) and the
United Kingdom, Spur’s legal basis for collecting and using the personal
information collected will depend on the personal information concerned
and the specific context in which we collect it. In most circumstances,
we collect personal information (i) where it is needed for the
performance of a contract, (ii) where the processing of the personal
information is in our legitimate interests and not overridden by your
rights, or (iii) where you provide your consent. Other times, your
personal information may be collected in order for us (iv) to comply
with a legal obligation, (v) to perform a task for the public interest,
or (vi) for the protection of your or another’s vital interests. If we
collect and use your personal information in reliance on our legitimate
interests or those of any third party, we will make clear to you at the
relevant time through this notice or otherwise what those legitimate
interests are. Often times, legitimate interests involve our normal
day-to-day operations, such as the ability to operate our platform and
communicating with you as necessary to provide our services, responding
to your inquiries, or marketing. We may transfer personal information to
companies that help us provide our service. Transfers to subsequent
third parties are covered by the service agreements with our customers.
If you have questions about or need further information concerning the
legal basis on which we collect and use your personal information,
please contact us using the contact details provided at the bottom of
this Privacy Notice.
III. COOKIES AND SIMILAR TECHNOLOGIES
We may also use cookies, web beacons, and other tracking technologies
(such as scripts and tags) on our website to function properly, to
personalize or customize the user’s experience (based on preferences or
geography, for example) on our website, and to gather information about
a user’s browsing habits. We use third party service providers to help
us implement and utilize these technologies.
IV. OFFERINGS
The vast majority of the information utilized in our Offerings is
metadata. Metadata may include how and when a device or network is being
used, login times and attempts, registry keys, types and versions of
operating systems, browsers, and information about software
applications. In some cases, that includes personal information as it
may appear within the metadata, such as that associated with usernames,
filenames, file paths, and machine names. To the extent Spur Offerings
include personal information, Spur generally has obtained that
information from its third-party service providers or partners, which
often are corporate entities. Spur typically has no direct relationship
or contact with an individual whose personal information we may collect
or receive from a third-party service provider or partner and
subsequently analyze and use. Consequently, any inquiries about the
specific processing of your personal information via Spur Offerings
should be directed to our service providers or partners. We do not use
any personal information collected through our Offerings to contact or
market products or services to these individuals. We also do not provide
any personal information obtained through the Offerings to third parties
for the purpose of contacting or marketing products or services to these
individuals.
V. HOW WE PROTECT YOUR INFORMATION
The security of customer data and your personal information is not only
important to us, it is our mission. We adopt data collection, storage
and processing practices and security measures to protect against
unauthorized access, alteration, disclosure or destruction of customer
data and your personal information. We follow generally accepted
practices to protect customer data and the personal information
collected and submitted to us, both during transmission and once we
receive it. If you have questions about the security of your personal
information collected through our Offerings or website, you can contact
us at privacy@spur.us
VI. INTERNATIONAL DATA TRANSFERS
Spur’s mission is global, and, therefore, we may store information in
the United States and other locations worldwide where we or our service
providers have facilities. Information that you submit via the site may
be transferred to, and stored at, a destination outside of the EEA. For
example, this may happen if one or more of our servers or service
providers is located in a country outside the EEA. By submitting your
personal information, you agree to this transfer, storing or processing.
If we transfer your information outside the EEA in this way, we will
take steps to ensure that your privacy rights continue to be protected.
VII. RETENTION OF PERSONAL INFORMATION
We will retain your personal information for as long as needed to
fulfill the purpose for which we collected it and for a reasonable
period thereafter in order to comply with audit, contractual, or legal
requirements, or where we otherwise have a legitimate interest in doing
so. We will retain and use your information as necessary to comply with
our legal obligations, resolve disputes, and enforce our agreements. We
may retain aggregated or de-identified data indefinitely or to the
extent allowed by applicable law. We may retain personal information
preserved in automatically generated computer back up or archival copies
generated in the ordinary course of our information technology systems
procedures.
VIII. YOUR DATA PROTECTION RIGHTS
If you are a resident of the European Economic Area, United Kingdom, or
Switzerland, your data protection rights are as follows: • You may
access, correct, update or request deletion of your personal
information, • You may object to processing of your personal
information, ask us to restrict processing of your personal data, or
request portability of your personal information • You have the right to
opt-out of marketing communications we send to you at any time • If Spur
has collected and currently processes your personal information with
your consent, then you may withdraw your consent at any time
(withdrawing your consent will not affect the lawfulness of any
processing we conducted prior to your withdrawal, nor will it affect the
processing of your personal information conducted in reliance on lawful
processing grounds other than consent) • You have the right to complain
to a data protection authority about Spur’s collection and use of your
personal information You can exercise these rights by contacting Spur by
email at privacy@spur.us
IX. CHANGES TO THIS PRIVACY NOTICE
Spur may update this Privacy Notice at any time to reflect changes to
our information practices. If we make material changes in how we use
your personal information, we will notify you by email if feasible or by
means of a notice on this website. We encourage you to periodically
review this page for the latest information on our privacy practices.
X. CONTACTING US
If you have any questions about this Privacy Notice or our privacy
practices, please contact us: privacy@spur.us