Privacy Policy

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