Privacy Policy

Last Updated: March 28, 2022

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This Privacy Policy describes how Sperta Inc. (“Sperta,” “us,” “we” or “our”) collects, uses and discloses information and what choices you have with respect to the information. We are committed to maintaining the confidentiality, integrity and security of your information. This Privacy Policy describes how we treat personal information when you visit www.sperta.com (the “Site") or use our Services (as defined below).

In this privacy policy, "you" and "your" refers to individual users of Sperta’s decision platform that helps financial services and tech companies automate decisions and manage fraud, credit, and compliance risks (including all tools and application programming interfaces used in connection therewith, the “Services”).

This Privacy Policy is incorporated into, and considered a part of, the Sperta Terms of Service located at https://www.sperta.com/legal/terms.

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1. APPLICABILITY OF THIS PRIVACY POLICY

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This Privacy Policy applies to the Services, the Site and other interactions you may have with Sperta (e.g., customer service inquiries, submission of forms, etc.). If you do not agree with the terms of this Privacy Policy, do not access or use the Services, the Site or any other aspect of Sperta’s business.

In using our Services, Customer will be collecting and managing information about its own customers (which information will be considered to be Customer Data) and routing that information to other services. The Customer Data may include, without limitation, the identity of the Customer’s customers (such as name, email address, mailing address and phone number), their ages, and information about their financial status (such as credit scores). A separate agreement governs delivery, access and use of the Services (the “Customer Agreement”), including the processing of any data or information created within, or submitted through, the Services (collectively, “Customer Data”). The organization (e.g., your employer, referred to herein as “Customer”) that entered into the Customer Agreement controls its instance of the Services and any associated Customer Data. Customer is responsible for (i) having its own policies regarding the collection, use and disclosure of Customer Data, (ii) obtaining any rights, permissions or consents from the applicable parties that are necessary for the lawful use of Customer Data in connection with the Services, (iii) ensuring that the transfer and processing of Customer Data under the Customer Agreement is lawful, and (iv) responding to and resolving any dispute related to Customer Data.

This Privacy Policy does not apply to any third-party applications or software that integrate or connect with the Services or the Site (“Third-Party Services”), or any other third-party products, services or businesses. We are not responsible for the privacy practices, security standards, or content of Third-Party Services. You should check the privacy policies of those Third-Party Services before providing your personal information to them. The fact that our Site or Services contain or direct you to such Third-Party Services does not mean we approve or endorse them.

2. YOUR CONSENT

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By submitting or making available Personal Data (as defined below) through the Services, Site or otherwise, you agree to the terms of this Privacy Policy and you expressly consent to the processing of Personal Data in accordance with this Privacy Policy.

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3. A NOTE ABOUT CHILDREN

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Our Site, as well the Services, are not intended for children under 18 years of age. We do not intentionally gather or process Personal Data about individuals who are under the age of 18. If we inadvertently hold or have access to Personal Data about anyone under 18, please let us know so we can delete it.

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4. TYPES OF PERSONAL DATA WE COLLECT

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Sperta collects various types of Personal Data and Anonymous Data from you when you register for an account with us or otherwise use or access our Services or Site, when you seek customer support, complete a survey or form, or otherwise interact with us. This information may be collected directly from you (for example, when you register for an account or complete a survey) or indirectly through your device or browser when you visit our Site. "Personal Data" means data that allows someone to identify you or your customers or prospective customers, including, for example, name, address, telephone number, credit card number and email address, as well as any other non-public information that is associated with or linked to any of the foregoing data. "Anonymous Data" means data about you that is not associated with or linked to your Personal Data. Anonymous Data does not permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described herein.

PERSONAL DATA YOU PROVIDE TO US

We collect Personal Data from you, which may include first and last name, email addresses, telephone number, company name and address, payment information and password, when you register for the Services. We also collect your email address when you submit it through the Site for the purposes of obtaining a demo. In addition, we collect Personal Data from you (such as your name, email address, phone number, resume information and LinkedIn profile link) if you use our Site to apply for a job with Sperta. If you provide us feedback or contact us for customer support or otherwise, we will collect your name and email address, as well as any other information provided to us during such interaction.

PERSONAL DATA COLLECTED BY THIRD PARTIES

We may receive Personal Data about you from other sources like (i) companies that provide services to us (such as payment processing services) in connection with the Services, (ii) the Customer, or (iii) from Google, if you choose to login through Google. Such third parties may supply us with Personal Data, such as your name and email and mailing address information or your login credentials for such service provider’s website or service, in order to (a) direct us to invite you to setup an account for our Services and/or (ii) to help us provide the Services.

USAGE INFORMATION

We collect information related to how you use the Services and our Site. Such information may include Personal Data like your IP address, search terms entered, pages viewed, device, browser and operating system type and version. We may also use cookies, web beacon technology and other identifiers to identify your device, conduct fraud prevention and management services, distinguish you from other visitors, record your IP address and operating system, understand your use of our Site, determine the address of a referring website and determine the time and date of your visit. This information is used for fulfilling contracts with our business partners and to help us better serve you by improving our Services and providing you with more relevant content. Like most Internet services, we automatically gather this Personal Data and store it in log files each time you visit the Site, use the Services or access your account on our network. See below for additional details.

COOKIES AND OTHER IDENTIFIERS

When you interact with the Site or the Services, we and our service providers (including advertising partners) may use industry standard identifiers, such as cookies, to collect information about your activities on our Site and your website usage behavior in order to improve our Services and/or to provide you with more personalized information and services, including targeted offers.

A cookie is a small data file that is placed on the hard drive of your computer when you visit a website. These cookies may contain information (such as a unique user ID) that is used to track your usage of our Site and your other website usage behavior. A number of cookies we use last only for the duration of your web or Services session and expire when you close your browser or exit the Services. Other cookies are used to remember you when you return to the Site or Services and will last for longer. We refer to cookies and similar technologies as "Identifiers."

We use Identifiers to:

Remember that you have visited us before; this means we can identify the number of unique visitors we receive;
Optimize your user experience by customizing the Site and/or Services for you;
For advertising and marketing purposes (such as retargeting ads – see below for additional details);
Collect anonymous statistical information about how you use the Site and/or Services (including how long you spend on the Site or Services) and where you have come to the Site or Services from, so that we can improve the Site and Services; and
Gather information to inform our sales and marketing decisions.

Most browsers are automatically set to accept cookies, but you may refuse to accept cookies from our Site at any time by activating the setting on your browser which allows you to refuse cookies. Note that if you choose not accept cookies, this may impair the usability of our Site and you may not be able to take advantage of some of the features of our Services. Further information about the procedures to follow in order to disable cookies can be found on your Internet browser provider's website. You may wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html to learn more about how to adjust or modify your browser settings on commonly used browsers. If you use different devices to access our Site, you will need to ensure that each browser on each device is adjusted to reflect your cookie preferences.

Our service providers may use targeting or advertising Identifiers to collect or receive information about you from our Site, Services and elsewhere and may use that information to provide measurement services and to serve advertisements to you that they believe are more relevant to you and your interests based on content you have viewed. Third-party advertisers may also use this information to measure the effectiveness of their advertisements. We do not control these Identifiers, but you may choose to opt out of them. Opting out of third party targeting or advertising cookies does not necessarily mean that you will not see our advertising on third party websites, only that this advertising will not be targeted to you through the use of third party cookies. For more information about third-party advertising networks and similar entities that use these technologies, see www.aboutads.info/consumers, and to opt-out of such ad networks’ and services’ advertising practices, go to www.aboutads.info/choices.

Do Not Track: Your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. Like many websites and online services, Sperta does not respond to “Do Not Track” signals or other similar mechanisms from a visitor’s browser.

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5. PURPOSE OF PROCESSING AND LEGAL BASIS FOR PROCESSING

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We collect and process your Personal Data for the following purposes and legal bases:

To facilitate the creation of and secure your account on our network and/or identify you as a user in our system;
To provide customer support and respond to your inquiries, comments, questions and requests;
To provide, improve, develop, protect, fix and promote our Site, current Services and any future products and services;
For billing, account management and other administrative services;
To prevent abuse of the products and services we offer;
As required by applicable law, legal process or regulation;
To understand how you use our Site and Services and to customize and improve the quality of your experience when you interact with us, the Site or our Services;
To send you administrative email notifications, such as security or support and maintenance advisories;
To send, with your consent, marketing and advertising communications;
To fulfill any purpose for which you share it;
To carry out other lawful purposes about which we have notified our users; and
For any other purposes with your consent.

We may create Anonymous Data records from Personal Data by excluding information that renders the data personally identifiable. Sperta may use Anonymous Data for any lawful business purpose.

If you provide feedback on the Services or Site, we may use such feedback for any purpose, provided we will not associate such feedback with your Personal Data. We will collect and store any information contained in such communication and will treat the Personal Data in such communication in accordance with this Privacy Policy.

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6. DISCLOSURE OF YOUR PERSONAL DATA

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We do not sell, license or share your Personal Data with unaffiliated third parties for their own marketing purposes. And except as otherwise stated in this Privacy Policy, we do not sell, trade, share, or rent the Personal Data we collect to third parties. You expressly consent to the sharing of Personal Data as described in this Privacy Policy.

SERVICE PROVIDERS: We sometimes use third-party service providers to act on our behalf, for example to help us process payments, enhance and personalize your experience with us, or to deliver our advertisements. These service providers are only allowed to use your Personal Data in connection with the specific service they provide on our behalf and are obligated not to disclose or use it for any other purpose.

CHANGES TO OUR BUSINESS: Your Personal Data may be transferred to another organization if, for example, we transfer the ownership or operation of the Services because we have merged with or have been acquired by another organization, or if we liquidate our assets. In those cases, the new company’s use of your Personal Data will still be subject to this Privacy Policy and the privacy preferences you have expressed to us.

SAFETY AND SECURITY: We may disclose your Personal Data to third parties if we determine that such disclosure is reasonably necessary to: (a) protect any person from death or serious bodily injury; (b) prevent fraud or abuse of our site, Services or users or other illegal activity; (c) protect our rights, property, safety, or interest; or (d) perform a task carried out in the public interest. We reserve the right to report to the appropriate law enforcement or government agencies any information that we believe may be evidence of criminal activity or violation of any applicable law.

TO COMPLY WITH LAWS: If we receive a request for information, we may disclose your Personal Data and other information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. For example, we may be required to share certain information to respond to a subpoena or similar judicial process.

ANONYMOUS DATA: Sperta may share Anonymous Data for any lawful business purpose, including publicly and with our partners (like publishers, advertisers or connected sites). For example, we may share Anonymous Data publicly to show trends about the general use of our Services.

WITH CONSENT: We may share your Personal Data with third parties when you have given us consent to do so.

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7. CHOICE/OPT-OUT

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Sperta offers you the choice of receiving different types of communication and information related to our company, products and services. You may subscribe to e-newsletters or other publications, and you may also elect to receive marketing communications and other special offers from us via email. If at any time you would like to change your communication preferences, we provide unsubscribe links and an opt-out mechanism for your convenience. You may also access and manage your preferences from your account. If you opt-out of these messages, you will still receive emails from us about your account, and other pertinent information related to your use of the Services (e.g., transactional communications, changes/updates to features of the Services, technical and security notices). These communications are considered part of the Services and your account, which you cannot opt-out from receiving.

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8. DATA CHANGES

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PERSONAL DATA CHANGES/DELETION

You may change certain aspects of your Personal Data within your account. In addition, you may e-mail us at support@sperta.com to request any changes or updates to your Personal Data. When updating or making a request regarding your personal information, we may ask you to verify your identity before we can act on your request.

You may request deletion of your account information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it. See the section titled “Data Retention” below for additional details.

ACCESS TO DATA CONTROLLED BY OUR CUSTOMERS

Sperta has no direct relationship with the individuals whose Personal Data is contained within the Customer Data processed by the Services. An individual who seeks to access, correct or delete such information should direct their request to the Customer.

DATA RETENTION

Sperta will retain data we process for as long as needed to provide services to our Customer or otherwise in accordance with applicable law. Sperta will retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

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9. CALIFORNIA PRIVACY RIGHTS

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California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your personal information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Data with third parties for the third parties’ direct marketing purposes. If you are a Consumer and which to much such a request, please submit your request to support@sperta.com.

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10. SECURITY

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Sperta takes security of data very seriously. Sperta will use commercially reasonable and industry standard technical and organizational measures designed to prevent unauthorized access, use, alteration or disclosure of Personal Data. These measures take into account the sensitivity of the Personal Data we collect, process and store. Given the nature of communications and information processing technology, Sperta cannot guarantee that Personal Data during transmission through the Internet or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on third-party sites.

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11. RIGHT TO CONTROL AND ACCESS YOUR INFORMATION

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Under applicable law, you may have, among others, the rights (under the conditions set out in applicable law): (i) to check whether and what kind of Personal Data we hold about you and to request copies of such data, (ii) to request correction, supplementation or deletion of your Personal Data that is inaccurate or processed in non-compliance with applicable requirements, (iii) to request us to restrict the processing of your Personal Data, (iv) in certain circumstances, to object for legitimate reasons to the processing of your Personal Data or to revoke consent previously granted where such revocation has no effect on the lawfulness of the processing prior to the revocation, (v) to request data portability, (vi) to know the identities of third parties to which your Personal Data are transferred, and (vii) to lodge a complaint with the competent authority.

Sperta makes good faith efforts to provide individuals with access to their Personal Data, although there may be circumstances in which Sperta is unable to comply with your request, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question or where it is commercially proprietary. If Sperta is unable to comply with your request we will provide you with an explanation of why that conclusion has been made and provide a point of contact for further inquiries.

If you want to learn more about the Personal Data that Sperta has about you, or you would like to update or change that information, please contact us by email at support@sperta.com.

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12. TRANSFER OF DATA OUTSIDE YOUR COUNTRY

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To provide you with the Services, we may store, process, and transmit data in the United States and locations around the world—including those outside your country. By using the Services, you consent to have your information transferred to us and our facilities in the United States, Europe or elsewhere, including those of third parties as described in this Policy.

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13. CONTACT INFORMATION

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Sperta welcomes your comments or questions regarding this Privacy Policy. Feel free to email comments or questions to us at privacy@sperta.com or 353 Kearny Street, San Francisco, CA 94108.

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14. CHANGES TO THIS PRIVACY POLICY

If Sperta makes changes to this Privacy Policy, these changes will be posted on the Site in a timely manner. Sperta reserves the right to modify this Privacy Policy at any time, so please review it frequently. You can determine when this Privacy Policy was last revised by referring to the "Last Updated" legend at the top of this page. Any changes to this Privacy Policy will become effective upon our posting of the revised Privacy Policy on the Site or within the Services. If we make any material changes we may notify you by email (sent to the e-mail address specified in your account) or by means of a notice on the Site prior to the change becoming effective. Use of the Services or Site following such changes constitutes your acceptance of the revised Privacy Policy then in effect.