Spot43 Privacy Policy

Last Updated: July 15, 2019

At Spot43, we strive to connect Advertisers to Hosts’ inventory with a goal of growing their businesses. In this privacy policy, we tell you what information we receive from Advertisers and Hosts, and how we use it to connect Advertisers with Hosts and continue to improve our services.

1. Scope of the Privacy Policy

Spot43 (“Spot43,” “we,” “our,” and/or “us”) values the privacy of individuals who use our application, websites, and related services (collectively, the “Platform”). This privacy policy explains how we collect, use, and share information from Spot43 users (“Users”), comprised of both Spot43 advertisers and agents acting on behalf of an advertiser (“Advertisers”) and Spot43 hosts (“Hosts”). Beyond this privacy policy, your use of Spot43 is also subject to our Advertiser Terms of Service ( www.spot43.com/terms) and/or Host Terms of Service, as applicable.

2. Information We collect

  1. Information You Provide to Us

    Registration Information. When you sign up for a Spot43 account or join the Platform, you give us your email address.

    Business Profile Information. When you join the Platform, you give us your first and last name, business name, address, phone number, and business type.

    Campaign Criteria and Placements. When you create a campaign, you tell us your campaign preferences, including timing, cities, share of voice, and specific venues.

    Payment Method. When you add a credit card or payment method to Your Spot43 account, a third party that handles payments for us will receive your card and billing information. To keep your financial data secure, we do not store full credit card information on our servers.

    Communications. If you contact us directly, we may receive additional information about you. For example, when you contact our support team, we will receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and/or other information you choose to provide.

    Advertising Creative. If you place an advertisement through the Platform, you provide us with advertising creative files.

    Agency Information. If you join the Platform as an agency, in addition to the basic registration information we ask you for your client business profile information.

    Host Information. If you join the Platform as a Host, you give us your name, email address, business name, physical address, phone number, business type, hours of operation, television(s) count and sizes, visitor traffic info, visitor demographics, length of visitor stay at your venue, venue capacity, advertiser preferences, business logo and your message or advertising creative. You may also report to us any downtime, and associated reasons, in Inventory.

    Payment Information. To ensure Hosts get paid, we keep information about Hosts’ bank routing numbers and payment account numbers, tax information, and any other payment information provided by Hosts.

  2. Information We Collect When You Use the Platform

    Device Information. Spot43 receives information from users’ devices, including IP address, web browser type and version, mobile operating system version, location data, and device identifiers.

    Usage Information. To help us understand how you use the Platform and to help us improve it, we automatically receive information about your interactions with the Platform, like the pages or other content you view, time spent on those pages, your actions within the Platform, and the dates and times of your visits.

    Information from Cookies and Similar Technologies. We collect information through the use of “cookies,” tracking pixels, and similar technologies to understand how you navigate through and interact with the Platform, to learn what content and features are popular, and to save your preferences. Cookies are small text files that web servers place on your device; they are designed to store basic information and to help websites and apps recognize your browser. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use the Platform. You should consult your web browser(s) to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, you may be missing out on certain features of the Platform and you may not be able to use some portions of it.

    Google Analytics. Our website uses Google Analytics, a service that transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google.

  3. Information We Collect from Third Parties

    Third Party Services. If you choose to register for Spot43 or otherwise link your account with a third party’s service (such as Facebook or Google), we may receive the same type of information we collect from you (described above) directly from those services.

    Third Party Partners. We may receive additional information about you, such as demographic data, payment information, or fraud detection information, from third party partners and combine it with other information that we have about you.

3. How We Use the Information We Collect

We use the information we collect from all users to:

4. How We Share the Information We Collect

5. Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), our legal basis for collecting and using the personal information described in this privacy policy depends on the personal data we collect and the specific context in which we collect it. We may process your personal data because:
  • We need to perform a contract with you

  • You have given us permission to do so

  • The processing is in our legitimate interests and it is not overridden by your rights

  • For payment processing purposes

  • To comply with the law

6. Your Choices

Email Subscriptions. You can always unsubscribe from our commercial or promotional emails but we will still send you transactional and relational emails about your account and use of the Platform.

Editing and Accessing Your Information. You can review and edit certain account information by logging in to your account settings and profile, or by contacting us directly through support@spot43.com. If you would like to terminate your Spot43 account, please contact us through support@spot43.com with your request. If You choose to terminate your account, we will deactivate it for you but may retain information from your account for a certain period of time and disclose it in a manner consistent with our practices under this privacy policy for accounts that are not closed. We also may retain information from your account to collect any fees owed, resolve disputes, troubleshoot problems, analyze usage of the Platform, assist with any investigations, prevent fraud, enforce our Terms of Service, or take other actions as required or permitted by law.

Your Data Protection Rights under the General Data Protection Regulation (GDPR) If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal data. If you wish to be informed about what personal data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:
  • The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your personal data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

  • The right to object. You have the right to object to our processing of your personal data.

  • The right of restriction. You have the right to request that we restrict the processing of your personal information.

  • The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

  • The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your personal data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Our Policy on "Do Not Track" Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the preferences or settings page of your web browser.

7. Other

Data Security. We are committed to protecting the data of Spot43 Users. Even though we take commercially reasonable precautions to protect your data, no security measures can be 100% secure, and we cannot guarantee the security of your data.

Transfer of Data. Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including personal data, to the United States and process it there. Your consent to this privacy policy followed by your submission of such information represents your agreement to that transfer. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy, and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Changes to Our Privacy Policy. We may make changes to this privacy policy from time to time. If we make any material changes, we will let you know through the Platform, by email, or other communication. We encourage you to read this privacy policy periodically to stay up-to-date about our privacy practices. As long as you use the Spot43 Platform, you are agreeing to this privacy policy and any updates we make to it.

Contact Information. Feel free to contact us at any time with any questions or comments about this privacy policy, your personal information, our use and sharing practices, or your consent choices by contacting support@spot43.com.