Privacy Policy.

Updated March 2020

Introduction

In order to provide you with personalized in-store experiences, Spoten and its subsidiaries and affiliates (collectively, “Retailers”) needs you to provide us with certain Personal Information about yourself. We take the privacy of this Personal Information very seriously. We provide this policy so that you can understand how we collect Personal Information from you, what Personal Information we collect, and how we use the Personal Information you provide.

From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes. Please revisit this Privacy Policy to stay updated on any changes. We will notify you by email (sent to the email address specified in your profile) of any material changes to our use of your Personal Information.

This Privacy Policy applies to Personal Information provided to us about or relating to you, and from which, either alone or when connected with other information to which we may have access, you can be individually identified ("Personal Information"). That Personal Information is described in more detail below.

Terms:

1. What Personal Information do we collect and how is it collected?

(a) Personal Information provided by you. We collect Personal Information by asking you questions about yourself. The Spoten profile will request Personal Information such as your age, gender and brand preferences. You may also provide us with Personal Information through any website mobile application provided to you by Spoten, using the Spoten API, or controlled by a Spoten retail partner. Spoten retail partners are third parties that set up their store with Spoten for Business.

When accessing Spoten for Business through a Spoten retail partner, the Personal Information you provide through the retail partner's website or mobile application ("Partner Site") will be subject to the retail partner's privacy policy. However, the Spoten Privacy Policy will apply to the Personal Information that is provided to Spoten in order to perform the Spoten Services.

(b) Personal Information automatically collected. While you use the Spoten Service, we automatically record information that your browser sends whenever you visit a website. For example, we may receive: the name of the domain and host from which you access the Internet, the Internet Protocol (IP) address of the computer you are using, the date and time you access our Service, which sections and items you view and/or purchase, and the Internet address of the website from which you accessed the Service. We do not store the IP address of the computer you are using. We use this information to measure the usage of our Services, and to understand how to serve you better. The most common sources of this Personal Information include:

  • Cookies

  • Service Analytics

  • Pixel tags or clear Graphics Interchange Format files, known as GIFs

  • Occasionally; retail partners, business partners, contractors, shared databases, and other third parties

We provide a summary description of each of these circumstances below:

Cookies: Cookies are small files that are sent to your computer's hard drive to tell us who you are when you are using our Service. Cookies help us to:

(1) Associate you with your Spoten Profile and enable you to update and modify your Spoten Profile;

(2) Speed navigation and provide you with personalized recommendations;

(3) Remember Personal Information you gave so you don't have to re-enter it;

(4) Determine the effectiveness of some of our marketing efforts and communications; and

(5) Count the total number of visitors, pages viewed, and the total number of banners displayed. Browsers are typically set to create cookies automatically. You can choose to have your browser notify you when cookies are being written to your computer or accessed, or you can disable cookies entirely. If you disable cookies, however, you will not be able to create a Spaces Profile, and therefore you will not be able to receive the benefit of the Spaces Service. Also, by not using cookies, features within our Spaces Retail Partners may not function properly.

Service Analytics: From time to time, we may work with one or more third party service providers to help us better understand how you use our Service. The service provider may place cookies on your computer to collect Personal Information. The Personal Information that is collected will tell us things like how you navigated around our Service, and how quickly we helped you to enter registration Personal Information. This Personal Information will help us to better serve you and provide you with more personalized offerings. Any third party service provider will be restricted from using your Personal Information for any other purpose, except on an aggregate, anonymous basis. With your privacy in mind, we will work toward engaging third party service providers who enable you to opt-out of their Personal Information collection processes.

Pixel tags or clear GIFs: To help us understand the effectiveness of select communications and marketing efforts, we may use "message format" and "message open" sensing technologies that use pixel tags or clear GIFs (which are also called web beacons). These technologies allow us to know if your e-mail program is able to accept HTML e-mails and, if it is, to: (1) send you e-mails in that format; and (2) determine if you have opened our e-mail messages.

Outside sources: We may periodically collect Personal Information about you from retail partners, business partners, contractors, and other third parties. This includes, but is not limited to, instances in which you affirmatively authorize those third parties to provide us with Personal Information. For example, retail partners may provide us with Personal Information about items you have purchased from them in the past so that we can provide better fit recommendations for you.

2. Why do we collect Personal Information?

We collect your Personal Information to provide you with the Spaces Services and to administer our business. It allows us to provide you with easy access to our products and services, with a particular focus on the items and programs that may be of most interest to you. Your Personal Information also allows us to communicate with you about special offers, promotions, and other marketing programs and news that may be of interest to you.

3. How do we use Personal Information?

Spaces uses your Personal Information to provide you with the Spoten Service, to provide you with a superior customer experience, and to administer our business.

We use your Personal Information to:

  • Create a Spoten Profile you can log into from any device;

  • Provide you with special offers, promotions, and other marketing programs and news that may be of interest to you;

  • Answer questions you ask of us regarding the service or recommendations;

  • Make communications necessary to notify you regarding security, privacy, and administrative issues;

  • Validate you are of legal age to use our services;

  • Test and improve our systems and services; and

  • Manage our business.

We will only keep your data for as long as necessary to carry out our services or as long as we are required by law. After this, your personal data will be deleted. We cannot remove your data when there is a legal storage requirement such as book keeping rules, or when there is a legal ground to keep the data, such as an on-going contractual relationship.

Non-personal data is used as described above and in other ways as permitted by applicable laws, including combining non-personal data with personal data.

4. With whom do we share Personal Information?

Protecting the privacy and security of your Personal Information is a priority at Spoten.

EXCEPT AS OTHERWISE DESCRIBED IN THIS PRIVACY POLICY, SPACES DOES NOT SELL OR RENT YOUR PERSONAL INFORMATION TO THIRD PARTIES.

Spoten may share a copy of your Spoten Profile, which may include your email address (if provided) with: (i) our retail partners, so they can better personalize their stores to you; (ii) service providers, subcontractors, and agents who perform services on our behalf; and (iii) to third parties in certain business relationships, such as, but not limited to, co-branded offerings where we may offer a service or feature that is co-branded by Spaces and the third party. If you provide Personal Information in connection with a co-branded service or feature, that Personal Information may be shared between Spoten and the third party. Spoten’s treatment of that Personal Information is governed by this privacy policy, but the third party's treatment of your Personal Information will be subject to the third party's privacy policy.

In addition, Spaces may share any of your Personal Information with third parties as follows:

  • Law Enforcement Officials and as Required by Law. Spoten may release any or all of your Personal Information to third parties when we determine, in our reasonable judgment, that it is necessary to (a) comply with the law, regulation, legal process, or enforceable governmental request; (b) enforce or apply the terms of any of our policies or user agreements; or (c) protect the rights, property or safety of Spaces, our employees, our customers, users, or others.

  • Sales, Mergers, and Acquisitions. If Spoten becomes involved in a merger, acquisition, or any form of sale of some or all of its business or assets, your Personal Information may be provided to the entities and advisors involved, and your Personal Information may be transferred to a third party in connection with consummation of any such transaction. We will provide notice if your Personal Information becomes subject to a different privacy policy as a result of any such transaction.

5. How do we secure your Personal Information; Transfers of Personal Information?

We take appropriate security measures, including physical, technological, and procedural measures, to help to safeguard your Personal Information and to prevent unauthorized access and disclosure. In addition, we use industry-standard technology, such as edge-protection devices and encryption in the transmission of certain sensitive Personal Information, designed to prevent unauthorized persons from gaining access to your Personal Information and Spoten Profile, and, as technology develops, we intend to take additional measures to improve security. No method of transmission over the Internet, or method of electronic storage, however, is 100% secure. Therefore, we cannot guarantee its absolute security.

We operate globally and may transfer your Personal Information and Spoten Profile to individual companies and customers of Spoten as part of the services offered by Spaces to its customer base.

6. How do we respect your choices about your Personal Information?

When you interact with our Service in certain ways, you may be eligible to receive certain marketing-related and promotional communications as well as special offers (collectively "Promotional Communications") from Spoten or third parties with whom Spoten has a business relationship and those communications may include advertisements. The most common of these circumstances may include:

  • Creating a Spoten Profile

  • Signing up to receive newsletters or email notices

  • Entering a sweepstakes or a contest

If, at any time, you wish to no longer receive Promotional Communications from Spoten, you will be able to follow instructions provided with the Promotional Communication or within our Service in connection with Promotional Communications. Even if you opt-out of receiving Promotional Communications, you may continue to receive e-mails relating to the Spoten Profile update Personal Information, and/or other security or business-related communications. Although the primary purpose of these emails is not to provide you with promotional material, they may contain within them some promotional material.

Spoten provides you with the ability to access, correct, change or delete the Personal Information in your Spoten Profile at any time. Please be advised that Spoten may periodically archive Personal Information it has collected and there may be times that such archived information cannot be permanently removed from our systems.

7. Whom do I contact if I have questions or concerns?

If you have any questions about this Privacy Policy, you can fill out our contact form on any of our websites, or please contact us at comercial@spoten.com.br. To request to have all your Personal Information deleted, please contact us at comercial@spoten.com.br

8. Additional Terms

Personal Information collected from visitors from outside the United States: If you are interacting with Spoten from outside the United States or Brazil and provide us with any Personal Information, please note, in order for us to provide the Spoten Service or otherwise communicate with you as set forth in this Privacy Policy, it will be necessary for your Personal Information to be transferred, stored, and processed within the United States. The data protection laws in the United States may not be as comprehensive as those in your country. By doing business or interacting with Spoten, you are consenting to the transfer of your Personal Information to facilities located in the United States and other facility locations selected by Spoten.

Children's and Minor's Privacy: The Spoten Service is not designed to attract minors, in particular children under the age of 16. Spaces does not market to or knowingly collect Personal Information from anyone under the age of 16. Children should always get permission from their parents before sending any Personal Information about themselves (such as their names, email addresses, and phone numbers) to anyone over the Internet.

Please be advised that whenever you click on links and banners that take you to a third party website, you will be subject to the third party's privacy policies, not Spoten’s. This Privacy Policy applies solely to Personal Information collected by Spoten.

If you are a resident of Brazil, you are entitled to request and obtain from us once a calendar year information about the Personal Information we have shared, if any, with other businesses for their own direct marketing use. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g requests made in 2020 will receive information regarding 2019 sharing activities). To obtain this information please send an email message to comercial@spoten.com.br with "Request for Brazil Privacy Information" in the header of your message. Please note that only information regarding the sharing of Personal Information with third parties for their own direct marketing uses is covered by this requirement.

By doing business with or interacting with Spoten in the manner described in this Privacy Policy at any time on or after the Effective Date, you are accepting the practices described in this Privacy Policy and you expressly consent to the application of this Privacy Policy to the collection, storage, use and disclosure of your Personal Information as described.

Have questions about our Terms? Get in touch.