Last Modified: June 9, 2021
This privacy policy (“Policy”) describes how Spruce Systems, Inc. (“Spruce”
+“Company”, “we”,“our”, “us”) collects, uses, shares, and stores personal
+information of Spruce’s services, including any associated features or
+functionalities, websites and user interfaces, as well as all content and
+software applications associated with our services (collectively, the
+“Services”).
By using the Services, you accept the terms of this Policy and our Terms &
+Conditions (“Terms”), and consent to our collection, use, disclosure, and
+retention of your information as described in this Policy. If you have not done
+so already, please also review our Terms. The Terms contain provisions that
+limit our liability to you and require you to resolve any dispute with us on an
+individual basis and not as part of any class or representative action. IF YOU
+DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS, THEN PLEASE DO
+NOT USE ANY OF THE SERVICES.
Please note that this Policy does not apply to information collected through
+third-party websites or sites that you may access through the Services, or that
+you submit to us through email, text message or other electronic message or
+offline.
If you are engaging with the Services from the European Union (EU), see our
+Notice to EU Data Subjects for our legal bases for processing and transfer of
+your data.
What We Collect#
We get information about you in a range of ways.
+Information You Give Us. Information we collect from you includes:
- Account registration or user information, such as your name, display name or
+social media account handles when you sign up for use of our Services;
- Feedback and correspondence, such as information you provide in your responses
+to surveys, when you participate in market research activities, report a
+problem with Services, receive customer support or otherwise correspond with
+us;
- Anonymized usage information, such as information about how you use the
+Services and interact with us; and
- Marketing information, such as your preferences for receiving marketing
+communications and details about how you engage with them.
Information We Get From Others. We may get information about you from other
+third party sources and we may add this to information we get from your use of
+the Services.
Information Automatically Collected. We may automatically record certain
+information about how you use our Services (we refer to this information as “Log
+Data“). Log Data may include information such as a user’s Internet Protocol (IP)
+address, device and browser type, the pages or features of our Services which a
+user browsed and the time spent on those pages or features, the frequency with
+which the Services are used by a user, search terms, the links on our sites that
+a user clicked on or used, referral url, and other statistics. We use this
+information to administer the Services and we analyze (and may engage third
+parties to analyze) this information to improve and enhance the Services by
+expanding features and functionality and tailoring to our users’ needs and
+preferences.
We may use cookies or similar technologies to analyze trends, administer the
+website, track users’ movements around the website, and to gather demographic
+information about our user base as a whole. Users can control the use of cookies
+at the individual browser level. For more information, please see the section
+entitled “Cookies Policy” below.
We may also use data analytics sites to help us offer you an optimized user
+experience.
Use of Personal Information#
To comply with law#
- We use your personal information as we believe necessary or appropriate to
+comply with applicable laws, lawful requests and legal process, such as to
+respond to subpoenas or requests from government authorities.
To communicate with you#
- We use contact and personal information in some circumstances, such as your
+social media information, to communicate to you about updates or changes to
+the use of our Services.
To optimize our platform#
- In order to optimize your user experience, we may use your personal
+information to operate, maintain, and improve our Services. We may also use
+your information to respond to your comments and questions regarding the
+Services.
With your consent#
- We may use or share your personal information with your consent, such as when
+you instruct us to take a specific action with respect to your personal
+information, or you opt into third party marketing communications.
For compliance, fraud prevention, and safety#
- We may use your personal information to protect, investigate, and deter
+against fraudulent, unauthorized, or illegal activity.
Sharing of Personal Information#
- We do not share or sell the personal information that you provide us with
+other organizations without your express consent, except as described in this
+Policy. We disclose personal information to third parties under the following
+circumstances:
Affiliates. We may disclose your personal information to our subsidiaries
+and corporate affiliates for purposes consistent with this Policy.
Business Transfers. We may share personal information when we do a business
+deal, or negotiate a business deal, involving the sale or transfer of all or a
+part of our business or assets. These deals can include any merger, financing,
+acquisition, or bankruptcy transaction or proceeding.
Compliance with Laws and Law Enforcement; Protection and Safety. We may
+share personal information for legal, protection, and safety purposes.
- We may share information to comply with laws.
- We may share information to respond to lawful requests and legal processes.
- We may share information to protect the rights and property of the Company,
+our agents, customers, and others. This includes enforcing our agreements,
+policies, and terms and conditions.
- We may share information in an emergency. This includes protecting the safety
+of our employees and agents, our customers, or any person.
Professional Advisors and Service Providers. We may share information with
+those who need it to do work for us. These recipients may include third party
+companies and individuals to administer and provide the Services on our behalf
+(such as customer support, hosting, email delivery and database management), as
+well as lawyers, bankers, auditors, and insurers.
If you are engaging with the Services from the European Union (EU), see our
+Notice to EU Data Subjects for our legal bases for processing and transfer of
+your data.
International Transfer#
The Company has offices outside of the EU and has affiliates and Services
+providers in the United States and in other countries.Your personal information
+may be transferred to or from the United States or other locations outside of
+your state, province, country or other governmental jurisdiction where privacy
+laws may not be as protective as those in your jurisdiction.
EU users should read the important information provided below about transfer of
+personal information outside of the European Economic Area (EEA).
How Information is Secured#
We retain information we collect as long as it is necessary and relevant to
+fulfill the purposes outlined in this Policy. In addition, we retain personal
+information to comply with applicable law where required, prevent fraud, resolve
+disputes, troubleshoot problems, assist with any investigation, enforce our
+Terms, and other actions permitted by law. To determine the appropriate
+retention period for personal information, we consider the amount, nature, and
+sensitivity of the personal information, the potential risk of harm from
+unauthorized use or disclosure of your personal information, the purposes for
+which we process your personal information and whether we can achieve those
+purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal information (so that it can
+no longer be associated with you) in which case we may use this information
+indefinitely without further notice to you.
We employ industry-standard security measures designed to protect the security
+of all information submitted through the Services. However, the security of
+information transmitted through the internet can never be guaranteed. We are not
+responsible for any interception or interruption of any communications through
+the internet or for changes to or losses of data. In order to protect you and
+your data, we may suspend your use of any of the Services, without notice,
+pending an investigation, if any breach of security is suspected.
Information Choices and Changes#
Accessing, Updating, Correcting, and Deleting your Information - You may
+access information that you have voluntarily provided through your account, and
+to review, correct, or delete it by sending a request to support@spruceid.com.
+You can request to change contact choices, opt-out of our sharing with others,
+and update your personal information and preferences.
Tracking Technologies Generally - Regular cookies may generally be disabled
+or removed by tools available as part of most commercial browsers, and in some
+instances blocked in the future by selecting certain settings. For more
+information, please see the section entitled “Cookies Policy” below.
CONTACT INFORMATION. We welcome your comments or questions about this
+Policy, and you may contact us at: support@spruceid.com.*
CHANGES TO THIS PRIVACY POLICY. We may change this privacy policy at any
+time. We encourage you to periodically review this page for the latest
+information on our privacy practices. If we make any changes, we will change the
+Last Updated date above. Any modifications to this Policy will be effective upon
+our posting of the new terms and/or upon implementation of the changes to the
+Services (or as otherwise indicated at the time of posting). In all cases, your
+continued use of the Services after the posting of any modified Privacy Policy
+indicates your acceptance of the terms of the modified Privacy Policy.
Eligibility#
If you are under the age of majority in your jurisdiction of residence, you may
+use the Services only with the consent of or under the supervision of your
+parent or legal guardian. Consistent with the requirements of the Children's
+Online Privacy Protection Act (COPPA), if we learn that we have received any
+information directly from a child under age 13 without first receiving their
+parent's verified consent, we will use that information only to respond directly
+to that child (or their parent or legal guardian) to inform the child that they
+cannot use the Services and subsequently we will delete that information.
Notice to California Residents#
Under California Civil Code Section 1789.3, California users are entitled to the
+following consumer rights notice: California residents may reach the Complaint
+Assistance Unit of the Division of Consumer Site of the California Department of
+Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by
+telephone at (916) 445-1254 or (800) 952-5210.
Personal Information
With respect to EU data subjects, “personal information,” as used in this
+Policy, is equivalent to “personal data” as defined in the European Union
+General Data Protection Regulation (GDPR).
Sensitive Data
Some of the information you provide us may constitute sensitive data as defined
+in the GDPR (also referred to as special categories of personal data).
Legal Bases for Processing
We only use your personal information as permitted by law. We are required to
+inform you of the legal bases of our processing of your personal
+information,which are described in the table below. If you have questions about
+the legal bases under which we process your personal information, contact us at
+support@spruceid.com.
Processing Purpose - Legal Basis
To communicate with you and to optimize our Services. These processing
+activities constitute our legitimate interests. We make sure we consider and
+balance any potential impacts on you and your rights before we process your
+personal information for our legitimate interests. We do not use your personal
+information for activities where our interests are overridden by any adverse
+impact on you (unless we have your consent or are otherwise required or
+permitted to by law).
We use your personal information to comply with applicable laws and our legal
+obligations.
Where our use of your personal information is based upon your consent, you have
+the right to withdraw it at any time by contacting us at support@spruceid.com.
Use for New Purposes#
We may use your personal information for reasons not described in this Privacy
+Policy, where we are permitted by law to do so and where the reason is
+compatible with the purpose for which we collected it. If we need to use your
+personal information for an unrelated purpose, we will notify you and explain
+the applicable legal basis for that use. If we have relied upon your consent for
+a particular use of your personal information, we will seek your consent for any
+unrelated purpose.
Your Rights#
Under the GDPR, you have certain rights regarding your personal information. You
+may ask us to take the following actions in relation to your personal
+information that we hold:
- Opt-out. Stop sending you direct marketing communications which you have
+previously consented to receive. We may continue to send you Services-related
+and other non-marketing communications.
- Access. Provide you with information about our processing of your personal
+information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to
+you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of
+our processing of your personal information that impacts your rights.
You can submit these requests by email to support@spruceid.com. We may request
+specific information from you to help us confirm your identity and process your
+request. Applicable law may require or permit us to decline your request. If we
+decline your request, we will tell you why, subject to legal restrictions. If
+you would like to submit a complaint about our use of your personal information
+or response to your requests regarding your personal information, you may
+contact us at support@spruceid.com or submit a complaint to the data protection
+regulator in your jurisdiction.
Cross-Border Data Transfer#
Please be aware that your personal data will be transferred to, processed, and
+stored in the United States. Data protection laws in the U.S. may be different
+from those in your country of residence. You consent to the transfer of your
+information, including personal information, to the U.S. as set forth in this
+Policy by visiting our site or using our Services.
Whenever we transfer your personal information out of the EEA to the U.S. or
+countries not deemed by the European Commission to provide an adequate level of
+personal information protection, the transfer will be based on a data transfer
+mechanism recognized by the European Commission as providing adequate protection
+for personal information.
Please contact us if you want further information on the specific mechanism used
+by us when transferring your personal information out of the EEA.
Assignment and Third Parties#
Assignment#
Your information will remain subject to the terms of this Privacy Policy even if
+the Services undergo an organizational transition. However, we may transfer your
+information to a successor entity upon a merger, consolidation, or other
+reorganization in which our Services participate or to a successor
+not-for-profit assignee or licensee of all or substantially all of our Services’
+assets. You hereby consent to such transfers and our Services may assign and
+transfer all of the rights, benefits, duties, and obligations of this Privacy
+Policy, under the circumstances described in this paragraph.
Accessing Third-Party Sites from our Site#
Our Services may provide links to websites of other organizations or companies
+that may offer materials and services as well as links to other sites. In using
+our Services or the linked sites of other organizations or companies, you may
+have the option to sign up for email lists operated by these organizations or
+companies. If you choose to request that your address be removed from the
+organizations’ or companies’ lists, we cannot control whether or not they will
+immediately stop using your address. To stop receiving communications from these
+organizations or companies, you should contact them directly.
Application of This Privacy Policy#
This Privacy Policy applies only to the privacy of users of our Services. If you
+follow links and move from our Services to external websites owned or operated
+by other entities or individuals, you should read the privacy policies of those
+external websites carefully. The terms by which the owners or operators of those
+websites manage your information could differ from how our Services manages your
+information. Our Services are not responsible for the practices of these third
+parties.
Cookies Policy#
We understand that your privacy is important to you and are committed to being
+transparent about the technologies we use. In the spirit of transparency, this
+policy provides detailed information about how and when we use cookies.
Do we use Cookies?#
No, but we reserve the right to in the future. We and our marketing partners,
+affiliates, and analytics or site providers may use cookies, web beacons, or
+pixels and other technologies to ensure everyone who uses the Services has the
+best possible experience.
What is a Cookie?#
A cookie (“Cookie”) is a small text file that is placed on your hard drive by a
+web page server. Cookies contain information that can later be read by a web
+server in the domain that issued the cookie to you. Some of the cookies will
+only be used if you use certain features or select certain preferences, and some
+cookies will always be used. You can find out more about each cookie by viewing
+our current cookie list below. We update this list periodically, so there may be
+additional cookies that are not yet listed. Web beacons, tags and scripts may be
+used in the Services or in emails to help us to deliver cookies, count visits,
+understand usage and campaign effectiveness and determine whether an email has
+been opened and acted upon. We may receive reports based on the use of these
+technologies by our site/analytics providers on an individual and aggregated
+basis.
Why use cookies?#
We may generally use Cookies for the following purposes:
- To recognize new or past customers.
- To improve our Services and to better understand your visits on our platforms.
- To serve you with interest-based or targeted advertising.
- To observe your behaviors and browsing activities over time across multiple
+websites or other platforms.
- To better understand the interests of our customers and our website visitors.
We may also use functional Cookies and Cookies from third parties for analysis
+and marketing purposes. Functional Cookies enable certain parts of the site to
+work properly and your user preferences to remain known.
If you want to learn more about cookies, or how to control, disable or delete
+them, please visit http://www.aboutcookies.org for detailed guidance. In
+addition, certain third party advertising networks, including Google, permit
+users to opt out of or customize preferences associated with your internet
+browsing.
We may link the information collected by Cookies with other information we
+collect from you pursuant to this Policy and use the combined information as set
+forth herein. Similarly, the third parties who serve cookies in our Services
+may link your name or email address together with information they collect,
+which may include past purchases made offline or online, or your online usage
+information. If you are located in the European Economic Area, you have certain
+rights that are described above under the header “Notice to EU Data Subjects”,
+including the right to inspect and correct or delete the data that we have about
+you.
+
+
