Effective as of 1/1/2023
Spoke may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.
Personal information we collect
Information provided by you to us. Personal information you may provide to us through the Service or otherwise includes:
Contact data, such as your first and last name, billing and mailing addresses, professional title and company name, business email address and phone number.
Demographic Information, such as your city, state, country of residence and postal code.
Profile data, such as the username and password that you may set to establish an online account on the Service.
Communications that we exchange with you, including when you contact us through the Service, social media, or otherwise.
Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers, payment method and transaction history.
Payment data needed to complete transactions, including payment card information or bank account number. Please note however that we process payments via our payment processing partners, such as Stripe, and we do not collect or maintain payment card information directly.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
Private sources, such as data providers, social media platforms, and data licensors.
Marketing partners, such as joint marketing partners and event co-sponsors.
Vendor partners, such as our vendors used to source items.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), language settings, and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Location data, when you authorize (our mobile application/the Service) to access your device’s location.
Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:
Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked.
Data about others. We may offer features that help users invite their colleagues or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery. We may use your personal information to:
provide, operate and improve the Service and our business;
personalizing the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
establish and maintain your user profile on the Service;
facilitate your invitations to your employees or colleagues who you want to invite to join the Service;
enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in ;
communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
understand your needs and interests, and personalize your experience with the Service and our communications; and
provide support for the Service, and respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.
Marketing and advertising. We, our service providers and our third-party advertising partners, may collect and use your personal information for marketing and advertising purposes:
Direct marketing. We may send you direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
To send marketing and promotional communications. We may send you marketing communications as permitted by law. You will have the ability to opt out of our marketing and promotional communications as described in the Your Choices section below.
Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.
Compliance and protection. We may use your personal information to:
comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:
Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
Functionality. To enhance the performance and functionality of our services.
Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.
Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails.
How we share your personal information
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
Business and marketing partners. Third parties with whom we jointly offer products or services or whose products or services may be of interest to you.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions, for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Spoke as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and navigating to the profile tab.
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Linked third-party platforms. If you choose to connect to the Service through a third-party platform, you may be able to use the settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.
Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.
Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
California Residents’ Data Protection Rights, including CCPA and CalOPPA
If you are a California resident, California law may provide you with additional rights regarding our use of your personal data.
We do not meet the minimum requirements obligating us to abide by the provisions of the California Consumer Privacy Act (“CCPA”). However, we voluntarily offer many of the protections of the CCPA. The categories of personal data that we collect are name, phone number, mailing address, e-mail address, payment card information (not including identifying card details), and employment information. We use these categories of personal data to fulfill orders made on our Website or Apps and to promote and provide our own goods and services to you.
We currently do not sell any of your personal data to third parties. We do disclose personal data as necessary to provide our services.
If you wish to opt out of any such disclosure of your personal data, please contact us at email@example.com. However, please note that any such opt out may prevent us from fulfilling our obligations to you or otherwise providing services to you.
We do not currently disclose personal data to third parties for their direct marketing purposes. However, if you wish to request information about our disclosure of personal data to third parties for their direct marketing purposes in compliance with California’s “Shine the Light” law (Civil Code Section §1798.83), please email us at firstname.lastname@example.org. Please allow us 30 days for a response.