Spotfront Privacy Statement
Last Updated: January 2020
Your privacy is important to us. This Privacy Statement (“Privacy Statement”) explains the personal data Spotfront, Inc. (“Spotfront,” “we,” “us,” or “our”) processes, how we process it, and for what purposes. This Privacy Statement covers the treatment of information collected on the website located at https://www.promoteiq.com (the “Site”) and the services, applications, and features made available at the Site (the “Services”).
This Privacy Statement does not apply to end user personal data processed by Spotfront’s PromoteIQ platform (“PromoteIQ Service Platform”). For the terms governing information collected through the PromoteIQ Service Platform, please review your Master Services Agreement with Spotfront (or such similar agreement as may be agreed to by you and Spotfront).
This Statement does not apply to third parties that Spotfront does not own or control. For example, if you are a customer of a retailer that has implemented the PromoteIQ Service Platform, please see the retailer’s privacy statement for their data collection, use, and sharing, and contact the retailer to exercise any data subject rights you may have.
Any order forms or additional agreements governing specific optional Spotfront features shall take precedence over the terms of this Privacy Statement to the extent of any differences, so please read such order forms or additional agreements carefully.
Personal Data We Collect
We receive and store certain types of information whenever visitors (“you,” “users”) interact with us through the Services. For example, Spotfront automatically receives and records traffic data on our server logs from your browser, including your IP address, Spotfront cookie information, and requested pages. Spotfront uses this traffic data to analyze trends and administer the Site. Our Site and Services also automatically collect usage information, such as the numbers and frequency of visitors to our Site and its components. This data is only used in the aggregate. This type of collective data enables us to figure out how often users use different parts of the Site and Services. In addition, we may provide statistical collective user information to our partners so that they understand how often people use specific components of our Site and Services, but such information does not identify you personally.
We collect the following categories of data automatically:
- Device and usage data. Data about your device and the product and features you use, including information about your hardware and software, how our services perform, and your settings.
- Browse history. Data about the webpages you visit and how you interact with them.
- Device, connectivity, and configuration data. Data about your device, your device configuration, and nearby networks. For example, data about the operating systems and other software installed on your device, including product keys. In addition, IP address, device identifiers (such as the IMEI numbers for phones), regional and language settings, and information about WLAN access points near your device.
- Error reports and performance data. Data about the performance of the products and any problems you experience, including error reports. Error reports (sometimes called “crash dumps”) can include details of the software or hardware related to an error, contents of files opened when an error occurred, and data about other software on your device.
- Troubleshooting and help data. Data you provide when you contact Spotfront for help, such as the products you use, and other details that help us provide support. For example, contact or authentication data, the content of your chats and other communications with Spotfront, data about the condition of your device, and the Services you use related to your help inquiry. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.
Information You Provide to Us
We receive and store any information you enter on the Site or through the Services or provide to us in any other way. You can choose not to provide us with certain information, but then you may not be able to take advantage of many of our features. The information you provide through the Site or Services is used for such purposes as responding to your inquiries regarding integration of the PromoteIQ Service Platform, customizing the content you see, communicating with you about our products, and marketing our Services and those of our partners to you. From time to time, we may ask that you provide your first name, last name, company name, email address, and information about whether you are a retailer, brand, vendor, or other. Further information may be required if you choose to purchase the PromoteIQ Service Platform, such as credit card and billing information. We collect the following categories of data directly from you:
- Name and contact data. Your first and last name, email address, phone number, and other similar contact data.
- Administrator data. This is information provided to Spotfront during sign-up, purchase, or administration of the PromoteIQ Platform Service. Administrator Data includes the name, address, phone number, and email address you provide, as well as aggregated usage data related to your account, such as the controls you select. It also includes passwords, password hints, and similar security information used for authentication and account access.
- Payment data. Data to process payments, such as your payment instrument number (such as a credit card number) and the security code associated with your payment instrument.
- Subscription and licensing data. Information about your subscriptions, licenses, and other entitlements.
- Location data. Imprecise data about your device’s location. For example, your location can also be inferred from a device’s IP address or data in your account profile that indicates where it is located with less precision, such as at a city or postal code level.
- Feedback. Information you provide to us and the content of messages you send to us, such as feedback, survey data, and product reviews you write.
Information from Other Sources
To improve our Services, we may receive behavioral, contextual, and demographic information about you from other sources and add it to our account information or other information we have about you. Like the information you provide to us, we do not share this information with anyone except authorized third parties in connection with providing you with our Services and we will not use this data to identify or locate you personally.
Information We Infer
We may derive information or draw inferences about you based on the other information we collect about you. For example, we may infer your location from our collection of your IP address.
How We Use Personal Data
Spotfront uses the data we collect to provide you the Services. In particular, we use data to:
- Provide our products, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data when it is required to provide the service or carry out the transactions you request.
- Improve and develop our products.
- Personalize our products and make recommendations.
- Advertise and market to you, which includes sending promotional communications, and presenting you relevant offers.
We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing research.
Spotfront may use information you provide us to create data segments, and these data segments are generally based on the websites that you visit. This data may include information about your interests or demographics. In addition to those you explicitly provide, this data can also be inferred or derived from other data we collect.
Our processing of personal data for these purposes includes both automated and manual (human) methods of processing. Our automated methods often are related to and supported by our manual methods. For example, our automated methods include artificial intelligence (AI), which we think of as a set of technologies that enable computers to perceive, learn, reason, and assist in decision-making to solve problems in ways that are similar to what people do. To build, train, and improve the accuracy of our automated methods of processing (including AI), we manually review some of the predictions and inferences produced by the automated methods against the underlying data from which the predictions and inferences were made.
When we process personal data about you, we do so with your consent and/or as required to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests of Spotfront as described in this section and in the Sharing of Information by Spotfront section of this Privacy Statement. When we transfer personal data from the European Economic Area, we do so based on a variety of legal mechanisms, as described in the International Users section of this Privacy Statement.
We use your data for the following business or commercial purposes, such as to:
- Provide our products. We use data to operate our products and provide you with our Services. For example, we use your data to authenticate you when logging on to the Services. Or, we may contact you by phone or email or other means to inform you when a subscription is ending or discuss your licensing account. We also communicate with you to secure our products, for example by letting you know when product updates are available.
- Product improvement. We use data to continually improve our products, including adding new features or capabilities. For example, we use error reports to improve security features, and usage data to determine what new features to prioritize.
- Product development. We use data to develop new products. For example, we use data, often de-identified, to better understand our customers’ needs, which can shape the development of new products.
- Customer support. We use data to troubleshoot and diagnose product problems, and provide other customer care and support services.
- Help secure and troubleshoot. We use data to help secure and troubleshoot our products. This includes using data to protect the security and safety of our products and customers, detecting breaches and malicious activities, troubleshooting performance and compatibility issues to help customers get the most out of their experiences, and notifying customers of updates to our products. This may include using automated systems to detect security and safety issues.
- Promotional communications. We use data we collect to deliver promotional communications. You can sign up for email subscriptions and choose whether you wish to receive promotional communications from Spotfront by email and telephone. For information about managing your contact data, email subscriptions, and promotional communications, see the How To Access and Control Your Personal Data section of this Privacy Statement.
- Relevant offers. Spotfront uses data to provide you with relevant and valuable information regarding our products. We analyze data from a variety of sources to predict the information that will be most interesting and relevant to you and deliver such information to you in a variety of ways.
- Transacting commerce. We use data to carry out your transactions with us. For example, we process payment information to provide customers with product subscriptions and use contact information to deliver the Services purchased.
- Reporting and business operations. We use data to analyze our operations and perform business intelligence. This enables us to make informed decisions and report on the performance of our business.
- Protecting rights and property. We use data to detect and prevent fraud, resolve disputes, enforce agreements, and protect our property. We may use automated processes to detect and prevent activities that violate our rights and the rights of others, such as fraud.
- Legal compliance. We process data to comply with law. We also process contact information and credentials to help customers exercise their data protection rights.
- Research. With appropriate technical and organizational measures to safeguard individuals’ rights and freedoms, we use data to conduct research, including for public interest and scientific purposes.
Cookies and Similar Technologies
We also use “web beacons” to help deliver cookies and gather usage and performance data. Our websites may include web beacons, cookies, or similar technologies from third-party service providers.
For more information on cookies, visit the Cookie section in Microsoft’s Privacy Statement.
Sharing of Information by Spotfront
Unless otherwise set forth in any additional agreements you enter into with Spotfront, we share your personal data only as described below.
We share your personal data with your consent or as necessary to complete any transaction or provide any product you have requested or authorized. For example, you may direct us to share your information in other ways, such as sharing personal data with certain third parties with your consent or at your direction, including if you provide us with the applicable information after we notify you that information will be shared in a particular manner. Remember that their use of your information will be governed by their privacy policies and terms.
If you use a Spotfront service by virtue of an organization you are affiliated with, such as an employer, or use an email address provided by such organization to access Spotfront services, we share certain data, such as interaction data and diagnostic data, to enable your organization to manage the service. When you provide payment data to make a purchase, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction.
We share personal data among Microsoft-controlled affiliates and subsidiaries. We also share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets.
Finally, we will retain, access, transfer, disclose, and preserve personal data, when we have a good faith belief that doing so is necessary to do any of the following:
- Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
- Protect our customers, for example, to prevent spam or attempts to defraud users of our products, or to help prevent the loss of life or serious injury to anyone.
- Operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks.
- Protect the rights or property of Spotfront, including enforcing the terms governing the use of the services.
For more information about data we disclose in response to requests from law enforcement and other government agencies, please see our Law Enforcement Requests Report.
Please note that some of our products include links to or otherwise enable you to access products of third parties whose privacy practices differ from those of Spotfront. If you provide personal data to any of those products, your data is governed by their privacy policies.
Our Retention of Personal Data
Spotfront retains personal data for as long as necessary to provide the products and fulfill the transactions you have requested, or for other legitimate purposes, such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types, the context of our interactions with you or your use of Services, actual retention periods can vary significantly.
How to Access and Control Your Personal Data
You can also make choices about the collection and use of your data by Spotfront. You can control your personal data that Spotfront has obtained, and exercise your data protection rights, by contacting Spotfront or using various tools we provide. In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law. How you can access or control your personal data will also depend on the ways you interact with us. You may exercise these rights, such as the right to access and control your personal data that Spotfront has obtained, with tools Spotfront provides to you, which are described below, or by contacting Spotfront. For instance:
- If Spotfront obtained your consent to use your personal data, you can withdraw that consent at any time.
- You can request access to, erasure of, and updates to your personal data.
- You may have the right to port your data elsewhere. You can use tools Spotfront provides to do so, or if none are available, you can contact Spotfront for assistance.
You can also object to or restrict the use of your personal data by Spotfront. For example, you can object at any time to our use of your personal data:
- For direct marketing purposes.
- Where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party.
You may have these rights under applicable laws, including the EU General Data Protection Regulation (GDPR), but we offer them regardless of your location. In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law.
- Spotfront account. If you wish to access, edit, or remove the profile information and payment information in your Spotfront account, change your password, add security information or close your account, you can do so by visiting the Spotfront account website.
Not all personal data processed by Spotfront can be accessed or controlled via the tool above. If you want to access or control personal data processed by Spotfront that is not available through your Spotfront account, you can always contact Spotfront at the address in the How to Contact Us section. We will respond to requests to control your personal data within 30 days.
Products provided by your organization—notice to end users
If your organization, such as your employer or service provider, is administering your use of Spotfront products, contact your organization to learn more about how to access and control your personal data.
If you use a Spotfront product or use an email address to access Spotfront products, and that product or email address was provided by an organization you are affiliated with, such as an employer, that organization can:
- Control and administer your Spotfront account, including controlling privacy-related settings of the product or product account.
- Access and process your data, including the interaction data, diagnostic data, and the contents of your communications and files associated with your Spotfront accounts.
If your organization provides you with access to Spotfront products, your use of the Spotfront products is subject to your organization’s policies, if any. You should direct your privacy inquiries, including any requests to exercise your data protection rights, to your organization’s administrator. Spotfront is not responsible for the privacy or security practices of our customers, which may differ from those set forth in this Privacy Statement.
We may also send e-mails with service updates, news, or promotions. If you do not want to receive marketing e-mail from us, please contact us at email@example.com or click the unsubscribe button on the applicable e-mail.
As needed, we use Administrator Data to contact you to provide information about your account, subscriptions, billing, and updates to the Services or PromoteIQ Service Platform, including information about new features, security, or other technical issues. We also contact you regarding third-party inquiries we receive regarding use of the Services or PromoteIQ Service Platform, as described in your agreement.
You cannot unsubscribe from these non-promotional communications. We may also contact you regarding information and offers about other products and services, or share your contact information with Spotfront’s partners. When such a partner has specific services or solutions to meet your needs, or to optimize your use of the Services or PromoteIQ Service Platform, we may share limited, aggregated information about your organization’s account with the partner. Spotfront will not share your confidential information or contact information with the authorized partner unless we have sufficient rights to do so. You can manage your contact preferences or update your information in your account profile.
Personal data collected by Spotfront may be stored and processed in your region, in the United States, and in any other country where Spotfront or its affiliates, subsidiaries, or service providers operate facilities. We take steps to ensure that the data we collect under this Privacy Statement is processed according to the provisions of this statement and the requirements of applicable law wherever the data is located.
We transfer personal data from the European Economic Area, the United Kingdom, and Switzerland to other countries, some of which have not yet been determined by the European Commission to have an adequate level of data protection. For example, their laws may not guarantee you the same rights, or there may not be a privacy supervisory authority there that is capable of addressing your complaints. When we engage in such transfers, we use a variety of legal mechanisms, including contracts, to help ensure your rights and protections travel with your data. To learn more about the European Commission’s decisions on the adequacy of the protection of personal data in the countries where Spotfront processes personal data, see this article on the European Commission website.
California Consumer Privacy Act
If you are a California resident, we process your personal data in accordance with the California Consumer Privacy Act (CCPA). This CCPA section of our Privacy Statement contains information required by the CCPA and supplements our Privacy Statement.
Sale. We do not sell your personal data. So, we do not offer an opt-out to the sale of personal data.
Rights. You have the right to request that we (i) disclose what personal data we collect, use, disclose, and sell and (ii) delete your personal data. You may make these requests yourself or through an authorized agent. If you use an authorized agent, we may request information from the agent demonstrating that the agent is acting on your behalf, such as a power of attorney or other agreement between you and the agent. You may exercise these rights by contacting Spotfront at the address in the How to Contact Us section, or by emailing us at firstname.lastname@example.org. If you do not have an account, you may exercise your rights by contacting us as described above. We may ask for additional information, such as your country of residence, email address, and phone number, to verify your identity before honoring your request.
You have a right not to receive discriminatory treatment if you exercise your CCPA rights. We will not discriminate against you if you exercise your CCPA rights.
Personal Information Processing. In the table below, we outline the categories of personal data we collect, the sources of the personal data, our purposes of processing, and the categories of third-party recipients with whom we share the personal data. For a description of the data included in each category, please see the Personal Data We Collect section.
|Category of Personal Data||Sources of Personal Data||Purposes of Processing (Collection and Sharing with Third Parties)||Third-Party Recipients|
|Name and contact data||Interactions with users and partners with whom we offer co-branded services||Provide our products, respond to customer questions, and marketing||Service providers|
|Credentials||Interactions with users and organizations that represent users||Authentication and account access||Service providers|
|Demographic data||Interactions with users and purchases from data brokers||Provide and personalize our products, product development, and marketing||Service providers|
|Payment data||Interactions with users and financial institutions||Transact commerce, process transactions, fulfill orders, and detect and prevent fraud||Service providers, banks, payment processors, and entities that provide financial services|
|Subscription and licensing data||Interactions with users and organizations that represent users||Provide, personalize, and activate our products, customer support, and marketing||Service providers|
|Usage data||Interactions with users, including data Spotfront generates through those interactions||Provide and personalize our products, product improvement, product development, marketing, and troubleshooting||Service providers and user-directed entities|
|Feedback||Interactions with users||Provide our products, product improvement, product development, customer support, and troubleshooting||Service providers|
While the table above contains the primary sources and purposes of processing for each category of personal data, we also collect personal data from the sources listed in the Personal Data We Collect section. Similarly, we process all categories of personal data for the purposes described in the How We Use Personal Data section, such as meeting our legal obligations, developing our workforce, and doing research.
Disclosure of personal data for business or commercial purposes. As indicated in the Sharing of Information by Spotfront section, we share personal data with third parties for various business and commercial purposes. The primary business and commercial purposes for which we share personal data are the purposes of processing listed in the table above. However, we share all categories of personal data for the business and commercial purposes in the Sharing of Information by Spotfront section.
Use of Spotfront by Children
Spotfront is not intended for children 16 or under. If you are under 18, you may use the Site and Services only with the supervision of your parent or guardian.
Conditions of Use
Your use of the Site and Services and any possible dispute over privacy are subject to this Privacy Statement and our Terms and Conditions, including limitations on damages, arbitration of disputes, and application of Washington state law.
Changes to this Privacy Statement
We update this Privacy Statement when necessary to provide greater transparency or in response to:
- Feedback from customers, regulators, industry, or other stakeholders.
- Changes in our products.
- Changes in our data processing activities or policies.
When we post changes to this statement, we will revise the “last updated” date at the top of the statement and describe the changes on our change history page. If there are material changes to the statement, such as a change to the purposes of processing of personal data that is not consistent with the purpose for which it was originally collected, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this Privacy Statement to learn how Spotfront is protecting your information.
How to Contact Us
If you have any questions or concerns regarding privacy at Spotfront, please send us a detailed message to email@example.com or to Spotfront, Inc. at 584 Broadway, Suite 603, New York, NY 10012. Your privacy is important to us and we will make every effort to resolve your concerns.
For information on Microsoft’s privacy practices, go to Microsoft’s Privacy Statement.