Privacy policy.
Last Updated: Feb 24th, 2022
1. Overview
This notice describes the personal data we collect via the 10Spot, Inc. (“10Spot”, “we,” “our,” “us,”) services, how the data is used and shared, and your choices regarding this data.
1.1. Scope
This notice applies to users of 10Spot’s services, including users of 10Spot’s apps, features, or other services, and visitors of 10Spot’s websites.
This notice describes how 10Spot and its affiliates, collect and use personal data. This notice applies to all users of our apps, websites, features or other services, unless covered by a separate privacy notice.
Our websites and services may contain links to and from the services or websites of third parties. If you follow a link to any of these services or websites, please note that these services or websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these services or websites.
1.2. Data Controller
10Spot is the data controller for the personal data collected in connection with use of 10Spot’s services.
2. Data Collection
As you visit our website or use our Services, we collect Personal Data about you and the Services you use.
Sources of Data Collection.
10Spot collects:
· Data provided by users to 10Spot, such as during account creation;
· Data automatically collected during use of our services, such as usage and device data;
· Data from other sources, such as 10Spot partners.
The following data is collected by or on behalf of 10Spot:
2.1. Data Provided by Users
You may give us information by using our services, such as when you create an account, use our app, or submit online forms through our websites.
The categories of Personal Data include:
Identifiers;
Personal information under California Civil Code section 1798.80;
Commercial information;
Internet activity information;
Visual or audio information;
· Inferences drawn from any of the above information categories.
The sensitive categories of Personal Data include:
· Account log-in information;
· Financial account information;
· Geolocation data.
If you provide us or our service providers with any Personal Data relating to other individuals, you represent that you have the authority to do so, and, where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Policy. If you believe that your Personal Data has been provided to us improperly, or want to exercise your rights relating to your Personal Data, please contact us by using the information in the “Contact Us” section below.
2.2. Data Automatically Collected During Use of Our Services
Device and Usage Information. Like many website operators, we may collect information that your browser sends whenever you visit our websites or access our Services.
This includes Log Data, such as your computer’s IP address, browser type, browser version, the pages of our websites that you visit, the time and date of your visit, the time spent on those pages and other statistics, and whether you reached our page via a social media or email campaign. This information may be collected via several technologies, including cookies, web beacons, clear GIFs, canvas fingerprinting and other means.
2.3. Data Collected from Other Sources
If you access our Services through third parties, with whom we have partnered, or if you share content from our Services to a third-party service, the third-party service will send us certain information about you if the third-party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third-party service. 10Spot may combine the data collected from these sources with other data in its possession.
3. How We Use Personal Data
We collect and process your Personal Data for the following purposes:
Providing our websites and services (including necessary functionality for both): We process your Personal Data to perform our contract with you for the use of our websites and services and to fulfill our obligations under the applicable terms of use and service;
Promoting the security of our websites and services: We process your Personal Data by tracking use of our websites and services, creating aggregated non-personal data, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies to the extent it is necessary for promoting the safety and security of the services, systems and applications;
Managing user registrations: If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of service;
Handling contact and user support requests: If you fill out a web form or request user support, or if you contact us by other means including via a phone call, we process your Personal Data to perform our contract with you and to the extent it is necessary for fulfilling your requests and communicating with you;
Sending out invites or alerts: We process Personal Data when you send invitations which link to our Services to others, or when you instruct us to send you email or text notifications as part of our Services;
Managing payments: We process your Personal Data to verify and collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you;
Developing and improving our websites and services: We process your Personal Data to analyze trends and to track your usage of and interactions with our websites and services to the extent it is necessary for developing and improving our websites and services and providing our users with more relevant content and service offerings;
Assessing and improving user experience: We process device and usage data as described in Section 2.2 above, which in some cases may be associated with your Personal Data, to analyze trends and assess and improve the overall user experience to the extent it is necessary for developing and improving the service offering;
Identifying user opportunities: We process your Personal Data to assess new potential user opportunities to ensure that we are meeting the demands of our users;
Displaying personalized advertisements and content: We process your Personal Data to conduct marketing research, advertise to you, provide personalized information about us and to provide other personalized content based upon your activities and interests (please see the "Your Privacy Choices" section below, to learn how you can control the processing of your Personal Data by 10Spot for personalized advertising purposes);
Sending marketing communications: We may process your Personal Data or device and usage data, which in some cases may be associated with your Personal Data, to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, SMS, MMS, or push notifications) about us and our affiliates and partners, including information about our Services or promotions (please see the “Your Privacy Choices” section below, to learn how you can control the processing of your Personal Data by 10Spot for marketing purposes); and
Complying with legal obligations: We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws, to protect against misuse or abuse of our websites, protect personal property or safety, pursue remedies available to us, and limit our damages, comply with judicial proceedings, court orders or legal processes, respond to lawful requests, or for auditing purposes.
If we need to collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide the required Personal Data when requested, we may not be able to perform our contract with you.
4. Data Sharing and Disclosure
Some of 10Spot’s products, services, and features require that we share data with others at a user’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.
To Others upon Your Instruction. We may share your data with others, as instructed by you and with your consent. The settings you choose for your content will determine how much information is shared, with whom, and when.
Affiliates and Service Providers. We share your information with our third-party service providers and any subcontractors as required to offer you our products and services.
The service providers we use help us to:
run, operate and maintain our Services through third party platform and software tools;
perform content moderation and crash analytics;
run email and mobile messaging campaigns;
perform marketing analytics;
provide measurement services;
provide payment attribution; and,
provide technical and customer support.
Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) in accordance with their own privacy policy. These external service providers do not share your financial information, like credit card numbers, with us, but may share limited information with us related to your purchase, like your zip code.
Aggregated Data. We may also aggregate or otherwise strip information of all personally identifying characteristics and may share that aggregated, anonymized data with third parties or publish it. This data does not personally identify you and helps us to measure the success of the Services and its features and to improve your experience. We reserve the right to make use of any such aggregated data as we see fit.
Third Party Links and Websites. Our websites may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any data to these websites.
Partnered Businesses. We may share your Personal Data with third-party businesses with whom we have partnered, such as local restaurants, bars, and shops, so you can redeem your 10Spot credit there, or participate in their promotions.
Disclosures Required by Law. We may be required to disclose your data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your Personal Data in order to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
Professional Advisers. In individual instances, we may share your Personal Data with professional advisers acting as service providers, processors, or joint controllers - including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
Third Parties Involved in a Corporate Transaction. If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.
5. Cookies
To make our websites and services work properly, we sometimes place small data files called cookies on your device. A cookie is a small text file that a website saves on your computer or mobile device when you visit the website. It enables the website to remember your actions and preferences (such as login, language, or other preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the website or browse from one page to another.
Google Analytics. We may use Google Analytics. We use the information we get from Google Analytics only to improve the websites. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.
You may wish to restrict the use of cookies. Please be aware that some of the features of our website may not function correctly if you disable cookies.
Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:
6. “Do Not Track” Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. We do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.
7. Security and Data Retention
We implement a variety of security measures to maintain the safety of your Personal Data when you enter, submit, or access your Personal Data. For example, when possible, we use encryption to transfer and store data. We further limit access to this data using access controls and confidentiality commitments.
However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be reasonable procedures to protect the confidentiality, security, and integrity of personal data obtained through our websites or Services, we cannot ensure or warrant the security of any information you transmit to us.
We retain information from or about you for so long as necessary to fulfill the purposes outlined in this Privacy Policy. When the information is no longer necessary for these purposes, we delete it or keep it in a form that does not identify you, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.
8. Your Privacy Choices
8.1. Your Rights
You may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:
Access your Personal Data held by us;
Know more about how we process your Personal Data;
Erase or delete your Personal Data, to the extent permitted by applicable data protection laws;
Restrict our processing of your Personal Data, to the extent permitted by law;
Object to our processing of your Personal Data. Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
Opt-out of certain disclosures of your Personal Data to third parties; and
Not be discriminated against for exercising your rights described above.
8.2. Additional Disclosures for California, Colorado or Virginia Residents
We have listed the privacy rights for several U.S. state jurisdictions below, but we understand you may have additional rights in your jurisdiction. You may contact us directly at any time about exercising your data protection rights. We will consider your request in accordance with applicable laws.
Certain state laws require that we detail the categories of Personal Data that we disclose for certain “business purposes,” such as to service providers that assist us with securing our services or marketing our products.
We disclose the following categories of Personal Data for our business purposes:
Identifiers;
Personal information under California Civil Code section 1798.80;
Commercial information;
Internet activity information;
Visual or audio information; and
Inferences drawn from any of the above information categories.
Sensitive Categories of Personal Data:
· Account log-in information;
· Financial account information; and
· Geolocation data.
Several jurisdictions grant state residents certain rights, including the right to access specific types of Personal Data, the right to learn how we process Personal Data, the right to know whether and how we disclose or sell Personal Data, the right to opt out of any sale of Personal Data, the right to request deletion of Personal Data in certain circumstances, and the right not to be denied goods or services for exercising these rights.
California law further permits you to request information regarding the disclosure of your Personal Data to third parties for the third parties’ direct marketing purposes.
We do not disclose your Personal Data to third parties for the third parties’ direct marketing purposes.
In the preceding twelve months we have not sold Personal Data.
For information on how to exercise your rights, please refer to Section 8.3 below.
If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us using the information in the “Contact Us” section below and provide us with a copy of the consumer’s written authorization designating you as their agent. We may need to verify your identity and place of residence before completing your rights request.
8.3. How to Exercise Your Rights
To exercise your rights, please contact us by using the information in the “Contact Us” section below. Your Personal Data may be processed in responding to these rights. We will respond to all legitimate requests in a timely manner and in accordance with applicable laws, and will contact you if we need additional information from you in order to honor your request or verify your identity.
8.4. Your Preferences for Marketing Communications
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all of these communications from us by following the unsubscribe instructions provided in any email we send, by replying or texting ‘STOP’ if you receive 10Spot SMS or MMS communications, or you can contact us using the contact details provided in the “Contact Us” section below. You will still continue to receive service-related messages concerning products and services you have purchased (unless we have indicated otherwise).
9. International Data Transfers
Any data that you provide to us may be accessed, shared or processed by our offices, located in the United States, and service providers located in the United States, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract).
This may entail a transfer of your Personal Data across international borders. The data protections standards may differ and be lower than the standards enforced in your jurisdiction.
We maintain appropriate safeguards as required by applicable law for any Personal Data transferred internationally, and as required by applicable law, will seek your consent prior to such transfers.
10. Children’s Privacy
Our Services are not directed to persons under 13. We do not knowingly collect Personal Data from children under 13. If you become aware that a child has provided Personal Data to us, please contact us as described in this privacy notice. If we become aware that a child under 13 has provided us with Personal Data, we will take steps to remove any such information.
11. Updates to this Notice
We may change our Privacy Policy at any time. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version.
12. Contact Us
If you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please contact us at the following contact details: