Last Updated: July 15, 2019
At Spot43, we strive to connect Advertisers to Hosts’ inventory with a goal of growing their businesses. In
to connect Advertisers with Hosts and continue to improve our services.
Spot43 (“Spot43,” “we,” “our,” and/or “us”) values the privacy of individuals who use our application,
use, and share information from Spot43 users (“Users”), comprised of both Spot43 advertisers and agents
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
Information You Provide to Us
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.
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.
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.
If you place an advertisement through the Platform, you provide us with advertising creative files.
If you join the Platform as an agency, in addition to the basic registration information we ask you
for your client business profile 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.
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.
Information We Collect When You Use the Platform
Spot43 receives information from users’ devices, including IP address, web browser type and version,
mobile operating system version, location data, and device identifiers.
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.
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.
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:
Connect Advertisers with Hosts;
Provide, improve, expand, and promote the Platform;
Analyze how the Platform is used;
Understand website traffic and web page usage;
Communicate with you, including for marketing and promotional purposes;
Personalize the Spot43 experience for you;
Facilitate transactions and payments;
Provide you with customer support;
Find and prevent fraud; and
Respond to trust and policy issues that may arise, including requests from government authorities.
Review and place advertisements on Inventory;
Sending communications, reports, and updates to you, including on your account, profile, campaigns,
Inventory, advertising or earnings rates (as applicable) and advertising creatives.
Issue tax statements, when applicable for Hosts
4. How We Share the Information We Collect
Sharing Between Users
Sharing between Advertisers and Hosts.
Advertisers and Hosts that have been connected for inventory are able to see basic information about
each other, such as business name, location, and profile information. Advertisers searching for
inventory can additionally see information about Hosts’ inventory, including visitor traffic info,
availability, and audience highlights. We may also share any Host inventory downtime, and associated
reasons, with connected Advertisers, respectively.
Sharing Between Spot43 and Third Parties
Third Party Services.
The Platform may allow you to connect with other websites, products, or services over which we don’t
have control (for example, we may provide you an option to have advertising creative developed by a
graphic designer firm). If you use these services, we will provide the third party with information
about you to allow them to provide the service to you (for example, we would give the graphic
designer your name, phone number, and email address to begin the engagement). We can’t speak to the
privacy practices of these third parties, and we encourage you to read their privacy policies before
deciding whether to use their services.
We work with third party service providers to perform services on our behalf, and we may share your
information with such service providers to help us provide the Platform, including all of the things
described in Section 3 above.
We may share your information with third parties in the following cases:
While negotiating or in relation to a change of corporate control such as a
merger, or sale of our assets;
If a government authority requests information and we think disclosure is required or
appropriate in order to comply with laws, regulations, or a legal process;
With law enforcement officials, government authorities, or third parties if we think
so is necessary to protect the rights, property, or safety of Spot43 Users and Inventory,
Spot43, or the public;
To comply with a legal requirement or process, including civil and criminal subpoenas,
orders, or other compulsory disclosures.
To provide information about the use of the Platform to potential business partners in
aggregated or de-identified form that can’t reasonably be used to identify you; and
Whenever you consent to the sharing.
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
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
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 email@example.com. If you would like to terminate your Spot43 account, please contact us through
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.
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.