Effective Date: January 1, 2020
- Personal Data We Collect and Data Sources
- How We Use Personal Data
- Personal Data Shared by Spectro Cloud
- Spectro Cloud’s Security Posture & Measures Taken
- How Long Does Spectro Cloud Keep Your Data?
- Your Privacy Choices and Rights
- How to Contact Spectro Cloud
- Changes to the Policy
Covered Data Processing Activities
Information you provide to us
We may collect the following categories of information about you:
Contact and Professional Data: We may collect contact and/or professional data about you in person, through communications, and through our websites. For example, you provide your contact and professional information to us when you sign up to learn more about Spectro Cloud’s products and services, download content, register for an event, and visit our offices. If you attend an event, we may also receive contact and professional details about you when you choose to scan your attendee badge or by providing a business card or other method where you share Personal Data with us. Typically, contact data includes your name and contact methods, such as telephone number, email address, and mailing address, and professional data includes details such as the organization you are affiliated with, your job title, and industry.
Biographical, Community, and Support-related Data: We may also collect various types of biographical, community, and support-related Personal Data from you via our help center and community support forums. For example, if you register for an online community that we host, we may ask you to provide a username, photo and/or biographical information, such as your occupation, organization name and areas of expertise. Additionally, you may provide Personal Data to us when you create user-generated content (for example, by posting in a forum), provide Spectro Cloud with feedback, or when you participate in interactive features, trainings, online surveys, contests, promotions, sweepstakes, activities, or events. You may also be asked to provide contact information, a summary of the problem you are experiencing, and any other information that would be helpful in resolving a customer support request.
Job Applicant Data: You provide your contact and professional information, including your resume with educational and work background, when you apply for a job with Spectro Cloud. You may also provide us with sensitive information, like your Social Security Number or other government identifier, racial or ethnic origin, or other such Personal Data in connection with your job application.
Contract and Payment Data: We may receive contract details (like signatures) from you or your organization and use third party payment processing services to collect payment and billing information, which may contain Personal Data such as billing name, billing address and payment card details, in connection with some of our products and services.
Audio, Electronic, or Visual Data: If you attend a Spectro Cloud event, we may record some or all of that event, take photos at the event, and interview you at the event. We use this information for business and marketing purposes to better inform the public about Spectro Cloud, its events, and provide testimonials about our products and services.
Personal Data We Collect From Other Sources
In the course of doing business, we may receive Personal Data and other information from other third parties for our business or commercial purposes. This information varies and typically falls into a few categories:
- Business contact information (such as name, job title, business email, phone number, and address), social profile (such as LinkedIn or XING) including other details about your company;
- Third-party platform usernames and identifying information; and
- Details about you as a job candidate (which may include your name, resume, educational and work history, criminal history information, and feedback) as permitted under law.
We may receive business contact information that contains Personal Data for commercial purposes, including details about your company from third parties for marketing and business intelligence, such as analyzing business opportunities, identifying potential new customers, and providing our audience with more relevant content and advertising. Typically, we receive this information about you from a few sources, such as: (i) third-party marketing initiatives, such as events where we are a sponsor or website forms hosted by third parties that may provide content about us; (ii) when you consent to having your attendee badge scanned at an event hosted by us or another third party; (iii) companies such as information aggregators and entities from whom we have licensed business contact information; and (iv) referrals. In some situations, we may combine such business contact information with other non-personal and Personal Data we possess or that you have provided to us. For example, we may combine business contact details with details about your organization, such as its address or revenue range, and analyze this information for business opportunities or use this to send you tailored content.
We also may receive information from third-party platforms for various business purposes such as credit, program management, or technical reasons. For example, we may receive credit information about an enterprise that includes the names of individuals. If you participate in an open source project or our public bug bounty program, we may receive details about you, such as your username or pull requests, to help us manage your participation in the project or program and provide you with updates.
If you are a candidate applying for a job at Spectro Cloud, we may receive Personal Data about you from third parties for business purposes, such as through background checks (educational, employment, criminal, and financial information), publicly-available sources (like social media accounts, including LinkedIn for identifying candidates), feedback about your application and from interviews, and other third parties that may provide feedback about your application.
For our professional services work, as a processor or service provider, Spectro Cloud may receive Personal Data about you to perform its obligations under its contract with a third party. Spectro Cloud partners may also share your business contact information with Spectro Cloud as part of their recommendation to your company to become a Spectro Cloud customer. If Spectro Cloud is interested in partnering with, acquiring, investing in, or partners with, acquires, or invests in your employing or retaining company, Spectro Cloud may receive Personal Data about you through the (potential or completed) transaction for its business purposes.
Device Data, Usage Data, and Metadata We Collect
Explanation of Device Data, Usage Data, and Other Metadata and Technology Used
Like most websites, applications, and software across the Internet, Spectro Cloud systems collect certain Personal Data. This type of data collection allows us to better understand how individuals use our websites, products and services and how they perform. For example, we may collect metadata about you, including technical data about your performance or use of our website, products and services. We may also collect device data about you to help us determine that users from one type of device use our websites, products and services in different ways than users of a different type of device, which in turn allows us to improve our websites, products and services, such as through optimizing the screen size of Spectro Cloud mobile applications, or making sure our customers’ users have a more efficient user experience.
Essential cookies. Essential cookies are required for website functionality and security. For example, authentication, security, and session cookies may be required for our website or products to work.
Functional cookies. We may use functional cookies to help enhance our websites’ performance, for market research, or other analytics or advertising that is not tied to a specific individual. For example, we may use Google analytics to help us track how many individuals visited our website. We may also utilize HTML5 local storage cookies for the reasons described in this section. These types of cookies are different from browser cookies in the amount and type of data they store and how they store it.
Targeting or advertising cookies. We may use targeting and advertising cookies to help us understand our marketing efforts and to reach potential customers across the web. For example, we may contract with third-party advertising networks that may track your activity over time and across different channels, including our websites, email activity, and other websites and applications that display advertisements. They may use this tracking information to understand and predict your interests, to display an advertisement for Spectro Cloud on another website, or email you with a marketing communication for a Spectro Cloud product. Our website currently does not respond to “Do Not Track” signals from browsers or give users tools to manage cookie settings.
A second common technology we use to collect metadata that may be considered Personal Data is beacon technology. We may use beacons in our websites and in email communications to you. Beacons provide us with information about your activity and help us to improve our business operations and strategy, such as by understanding our email communications’ functionality and improving our websites and content. For example, if you click on a marketing email we send to you about a new product or service, the beacon will provide signals to us that you and your organization may be interested in learning more. If you would like to manage your email subscriptions with us, please visit the section below on Your Information Choices.
Spectro Cloud as a Business
As with most websites, whenever you visit a Spectro Cloud website or when you interact with Spectro Cloud promotional content, Spectro Cloud may receive both Personal Data about you from information-gathering tools and passive information collection on our websites, including Personal Data from our websites you visit or emails we send. This information collection typically includes information such as cookies, beacons, demographic information, company and role details, market research and publicly-available information, IP address, device and browser details, usage information, timestamps, pages viewed, searches, interaction with and action taken by you on our websites or content, as well as certain non-Personal Data.
We use the information we collect as a business to analyze and predict results arising from our sales and marketing efforts, improve the performance of our websites, products and services and customer support, identify potential customers, opportunities, and potential new product areas, ascertain trends, improve our websites’ functionality, improve our security, and provide us with general business intelligence, including through the use of machine learning technology. We may also combine the metadata and usage information collected from our websites with other information to help further the purposes described in the previous sentence.
Communicate with you about our products and services. We may use your Personal Data to send you transactional communications, notices, updates, security alerts, and administrative messages regarding our products and services that may be useful to you and your organization. We will respond to your questions, provide tailored communications based on your activity and interactions with us, and help you use our products and services effectively.
Support safety and security. We may use your Personal Data, including contact data and metadata, about you and your use of our products and services to verify accounts and activity, monitor suspicious or fraudulent activity, assist our customers in their monitoring of suspicious or fraudulent activity, and identify violations of policies regarding the use of our products and services. We also process Personal Data for other security reasons, such as to register visitors to our offices and to manage non-disclosure agreements that visitors may be required to sign.
Market and promote our products and services. We may use your Personal Data, including contact data and metadata, about how you use the products and services to send promotional communications that may be of specific interest to you and your organization, including by email and by displaying Spectro Cloud marketing communications on other companies’ websites and applications, as well as on third-party platforms like Facebook, Twitter, and Google. These communications are aimed at encouraging engagement and maximizing the benefits that you and your organization can gain from Spectro Cloud’s products and services, including information about new products and features, survey requests, newsletters, and events we think may be of interest to you and your organization.
Manage contests or promotions. Spectro Cloud may occasionally run contests or other special promotions, and if you register for one, we may process your Personal Data, such as contact information, biographical information, and contract-related data to perform our contract with you. Spectro Cloud may also use the Personal Data, such as contact data, collected in these contests and promotions to send you promotional material about Spectro Cloud or our partners.
Process payments. We may use Personal Data, such as contact information, contract-related data, financial information, biographical information, and payment information to process payments to the extent that doing so is necessary to complete a transaction and perform our contract with you or your organization.
Recruiting. We may use your Personal Data, such as contact, job applicant, and biographical data, to assess your application and to evaluate and improve the recruitment system, our application tracking and recruitment activities. We also may use your Personal Data to communicate with you regarding your application or opportunities at Spectro Cloud and to send you new hire and employee experience information. We may verify your information, including through reference checks and, where allowed, background checks.
Other purposes for our legitimate interests: Where required by law or where we believe it is necessary to protect our legal rights, interests, or the interests of others, we may use your Personal Data in connection with legal claims, compliance, regulatory, and audit functions, protecting against misuse or abuse of our products and services, and protecting personal property or safety.
Other purposes with your consent: We may use your Personal Data if you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote our products and services, with your permission.
Service Providers. For all categories of information that we collect, we may share Personal Data with our service providers for various business purposes, including, but not limited to, auditing interactions with users, debugging our websites, products and services, security purposes, internal research and gleaning insights through machine learning, short-term uses such as credit verification, payment processing, IT services, quality control and safety, as well as to perform other services on our behalf. For example, we may use service providers to help us proctor and score Spectro Cloud certification exams or host our customer relationship management system.
Event Sponsors. If you choose to register for or attend an event or webinar that we host (such as a Spectro Cloud customer conference), enter a contest or raffle with us and a sponsor, or download content (such as a whitepaper) from our website, then we may share your contact information, content interest information or other activity data, and any other information, including Personal Data, collected in the course of these activities for commercial purposes with those sponsors. In many cases, you intentionally disclose your details by providing your information to these sponsors through consent via a registration form or by scanning your badge at the applicable sponsor’s booth. The treatment of this information is subject to each of these third parties’ respective privacy statements.
Partners and Resellers. We may share your Personal Data, such as contact information, business details, and content interest and activity details, with our partners and resellers for business purposes, such as to carry out our business or for joint marketing efforts to reach our customers and prospective customers. In many cases, you intentionally disclose your details by providing your information to these sponsors through consent via a registration form.
Protection of Rights, Security and Fraud Detection. For all categories of data we collect, we may share your Personal Data with third parties for business purposes to protect our customers, users, secure our physical and intellectual property, and to prevent or investigate security or fraudulent attempts against our users through our platform.
Law Enforcement and Legal Requests. For all categories of data we collect, we may share Personal Data to comply with applicable law or respond to valid legal requests, such as a subpoena, from law enforcement or other authorities.
With our Affiliates, Related to Corporate Transactions, and Provision of Professional Services. For all categories of data we collect, we may share Personal Data among our affiliates and subsidiaries for business purposes, including any service providers and agents that work on our behalf. For example, we may share your Personal Data with support service providers with whom we have in place agreements to protect your Personal Data. We may also share your information as required for us to carry out a corporate transaction, such as a merger or sale of assets of all or part of our company. We will also share your Personal Data with our professional service providers (for example, our auditors, insurance providers, financial service providers, and legal advisors) as needed for us to run our business.
Platform Analytics Data. We may share metadata (for example, unique identifiers and usage data) collected through our platform with analytics service providers for our business purposes, such as to provide a better user experience and generally help make our products and services better.
Advertising and Marketing. We may share your Personal Data, such as metadata and contact data, with third-party advertising and marketing providers, and advertising networks and social networks, including Google, Facebook and LinkedIn, to allow us to better reach our customers and prospective customers, and to sell our products and services. In some circumstances we may ask you to consent to directly disclosing your Personal Data with these third parties prior to sharing your Personal Data, such as via a consent banner on our website. For specific details on these companies’ privacy practices, please refer to their privacy policies.
Anonymous or De-identified Usage Data. We may share anonymized or aggregated usage data or security threat information with third parties or the public. For example, this may include sharing trends regarding organizations’ use of Spectro Cloud’s products and services to customers and prospective customers in our reports.
Spectro Cloud Community, Help Center, and Other User Generated Content. We may make available a community forum, as well as blogs and other means for you to post information on our websites. This is publicly-available information that you choose to share and it may be read, collected, and used by others that visit these websites. Except for username (which may be your real name) and the details that you choose to include in your profile, the categories of data shared in these circumstances will depend on what you choose to provide.
Recruitment Data. When you apply for a job at Spectro Cloud, we may share your Personal Data, including applicant data, biographical information, and other Personal Data we possess with our affiliate companies for business reasons, such as human resource management and internal reporting; our service providers for business reasons, such as the recruitment platform and to manage background checks; and law enforcement or government authorities, or as otherwise necessary to comply with law.
Spectro Cloud Social Media Outlets
Spectro Cloud’s websites may use social media features, such as the Facebook “like” button, the Instagram “heart” button, Twitter sharing features, and other sharing widgets (“Social Media Features”). You may be given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third-party social media network in order to share content with others within your network. Social Media Features are either hosted by the respective social media network, or hosted directly on our websites. To the extent the Social Media Features are hosted by the respective social media networks and you click through to these from our website, the latter may receive information showing that you have visited our website. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our websites with your social media profile.
Your interactions with Social Media Features are governed by the privacy policies of the respective companies that provide the Social Media Features.
Security is a critical priority for Spectro Cloud. We maintain a comprehensive information security program that contains industry-standard administrative, technical, and physical safeguards designed to prevent unauthorized access to Personal Data. However, no security system is perfect, and due to the inherent nature of the Internet, we cannot guarantee that data, including Personal Data, is absolutely safe from intrusion or other unauthorized access by others. You are responsible for protecting your password(s) and maintaining the security of your devices.
Spectro Cloud’s websites are not directed at minors under the age of 18, and we do not knowingly collect Personal Data from minors. If we learn that we have collected the Personal Data of a minor, we will take steps to delete the information as soon as possible.
We will retain your Personal Data for a period of time that is consistent with the original purpose of the data collection, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We determine the appropriate retention period for Personal Data by considering the amount, nature and sensitivity of your Personal Data processed, the potential risk of harm from unauthorized use or disclosure of your Personal Data and whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).
Your Privacy Choices
In the above sections, we describe how we may collect, use and share your Personal Data for providing relevant content and advertising. Below, we describe how you may unsubscribe, opt-out, or otherwise modify settings related to our processing of your Personal Data.
Direct Email Marketing. If you wish to withdraw from direct email marketing communications from Spectro Cloud, you may click the “unsubscribe” button (if included in our emails) or contact us at firstname.lastname@example.org. Please note, you cannot unsubscribe from critical transactional emails that are related to our provision of our online Service (such as those related to security and your Spectro Cloud account).
Direct Marketing – Phone or Postal Mailings. If you wish to withdraw from phone call or postal mail marketing communications from Spectro Cloud, please request to do so by contacting us at email@example.com.
Your European Privacy Rights
European Union Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (“GDPR”), requires us as the data controller of the website to provide additional and different information about our data processing practices to data subjects in the European Economic Area (“EEA”). If you are accessing our website from a member state of the EEA, the following additional policies apply to you.
Legal Basis of Processing. If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have a legal basis for doing so under applicable EU laws. This means we collect and use your Personal Data only where:
- We need it to operate and provide you with our products and services, provide customer support and personalized features, and to protect the safety and security of our products and services;
- It satisfies a legitimate interest of Spectro Cloud’s (which is not overridden by your data protection interests), such as for research and development, to provide information to you about our products and services that we believe you and your organization may find useful, and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to comply with a legal obligation.
Your Personal Data may be collected, transferred to, and stored by us in the United States, and by our affiliates and third parties that are based in other that are not subject to an adequacy decision by the European Commission or your local legislature and/or regulator, and that may not provide for the same level of data protection as your jurisdiction, such as the European Economic Area. We ensure that the recipient of your Personal Data offers an adequate level of data protection, for example, by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses for the transfer of data as approved by the European Commission (as described in Article 46 of the GDPR). As a U.S.-based company, Spectro Cloud, Inc. is subject to U.S. laws and must comply with them), provide good customer service, or improve our products and services. In these cases, we will ensure that your privacy and other fundamental interests do not override our legitimate interests.
Your California Privacy Rights
If and to the extent the California Consumer Privacy Act of 2018 (“CCPA”) applies and you are a California resident, you have the right to understand and request that we disclose how we collect, use, disclose, and sell your Personal Data to the extent permitted by applicable law. For further information, please contact us via firstname.lastname@example.org or the telephone number listed in the section below.
Your Rights Over Your Personal Data
Depending where you are located, you may have certain legal rights regarding your Personal Data under the GDPR, CCPA or other applicable law or regulation.
These may include the right to:
- Access your Personal Data
- Request that your incorrect Personal Data be updated or deleted
- Request that your Personal Data be deleted
- Restrict the use of your Personal Data
- Object to certain uses of your Personal Data
- Receive a copy of your Personal Data in an electronic and machine-readable format
- Be exempt from automated decision-making
- Receive the categories of sources from whom we collected your Personal Data
We will not discriminate against you for exercising the above rights.
If you would like to make a request and exercise your rights described above, please contact us via email@example.com or the telephone number listed in the section below. Since there no reasonable way for us to verify information for which we are a service provider to our customers, we will not respond to any requests in relation to data we hold on behalf of our customers.
If you would like to contact us with questions or concerns about our privacy policies and practices, you may contact us via any of the following methods:
Telephone Number (USA): (408) 418-8868
Spectro Cloud, Inc.
1731 Technology Dr, Suite 590
San Jose, CA 95110
If you are not able to access our form, you may request that a copy be provided to you in an alternative format by calling (408) 418-8868 (USA telephone number) or emailing firstname.lastname@example.org.