Privacy Policy
Last Updated: February 24, 2023
This Privacy Policy is designed to help you understand how Spaero Inc. (“Spaero,” “we,” “us,” or “our”) collects, uses, and shares your personal information, and to help you understand and exercise your privacy rights.
1. SCOPE AND UPDATES TO THIS PRIVACY POLICY
2. PERSONAL INFORMATION WE COLLECT
3. HOW WE USE YOUR PERSONAL INFORMATION
4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
5. YOUR PRIVACY CHOICES AND RIGHTS
6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
7. RETENTION OF PERSONAL INFORMATION
8. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
9. CHILDREN’S INFORMATION
10. OTHER PROVISIONS
11. CONTACT US
1. SCOPE AND UPDATES TO THIS PRIVACY POLICY
This Privacy Policy applies to personal information processed by us, including on our website located at www.spaero.bio (the “Site”).
Spaero acts as controller with respect to the personal information that we collect through our Site as well as the personal information we collect from our employees and job applicants under this Privacy Policy.
Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Site after the new Privacy Policy takes effect.
2. PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect depend on how you interact with us, our Site, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Site, and information from other sources such as third-party Site and organizations, as described below.
A. Personal Information You Provide to Us Directly
We may collect personal information that you provide to us.
● Information Related to Your Communications with Us. We may collect personal information, such as your name and email address when you request information about Spaero or our services, register for our newsletter, request support, or otherwise communicate with us.
● Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
● Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
● Job Applications. We may post job openings and opportunities on our Site. If you respond to one of these postings, we may collect your personal information, such as your application, CV, cover letter, and/or any other information you provide to us.
B. Personal Information Collected Automatically
We may collect personal information automatically when you use our Site.
● Automatic Collection of Personal Information. We may collect certain information automatically when you use our Site, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Site, such as pages that you visit before, during and after using our Site, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Site.
● Cookie Policy (and Other Technologies). We, as well as third parties that provide content, advertising, or other functionality on our Site, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect information through your use of our Site.
o Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
o Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Site that collects information about engagement on our Site. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Our uses of these Technologies fall into the following general categories:
● Operationally Necessary. This includes Technologies that allow you access to our Site, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
● Performance-Related. We may use Technologies to assess the performance of our Site, including as part of our analytic practices to help us understand how individuals use our Site (see Analytics below);
● Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Site. This may include identifying you when you sign into our Site or keeping track of your specified preferences, interests, or past items viewed;
● Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Site or on third-party digital properties.
[Some of the advertising Technologies we use include:
o Facebook Connect. For more information about Facebook’s use of your personal information, please visit Facebook’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here while logged in to your Facebook account.
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
● Analytics. We may use Technologies and other third-party tools to process analytics information on our Site. These Technologies allow us to better understand how our digital Site are used and to continually improve and personalize our Site. Some of our analytics providers include:
o Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
o LinkedIn Analytics. For more information about how LinkedIn uses your personal information, please visit LinkedIn Analytics’ Privacy Policy. To learn more about how to opt-out of LinkedIn’s use of your information, please click here.
o Hotjar (Session Replay Analytics). We use Hotjar’s session replay analytics Site. This allows us to record and replay an individual’s interaction with the Site. For more information about how Hotjar uses your personal information, please visit the “Personal Data collected from a visitor of a Hotjar Enabled Site” section of Hotjar’s Privacy Policy. To learn more about how to opt-out of Hotjar’s use of your information, please click here.
o FullStory (Session Replay Analytics). We use FullStory’s session replay analytics Site. This allows us to record and replay an individual’s interaction with the Site. For more information about how FullStory uses your personal information, please visit FullStory’s Privacy Policy. To learn more about how to opt out of FullStory’s use of your information, please click here.
o [Other service providers]]
C. Personal Information Collected from Other Sources Third-Party Services and Sources. We may obtain personal information about you from other sources, including through third-party services and organizations. For example, if you access our Site through a third-party application, we may collect personal information about you from that third-party application that you have made available via your privacy settings.
3. HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information for a variety of business purposes and legal bases, including to provide our services, for administrative purposes, and to market our products and services, as described below. If your personal information is subject to EU or UK General Data Protection Regulation, our processing of your personal information may be supported by one of the following lawful bases:
● Performance of a Contract. Spaero may process your personal information to carry out our contract with you or to take steps at your request prior to entering into a contract. For a detailed list of uses for performance of contract, see Section 3(A).
● Legitimate Interest. Spaero may process your personal information to further our legitimate interests, but only where our interests are not overridden by your interests or fundamental rights and freedoms. For a detailed list of our legitimate interests, see Section 3(B).
● Compliance with Legal Obligations. Spaero may process your personal information to comply with our legal obligations as detailed in Section 4(B).
● Consent. In some cases, Spaero may also rely on your consent to process your personal information for a specific purpose.
A. Provide Our Services
We have a legitimate interest in using use your personal information to fulfill our contract with you and provide our services, such as:
● Managing your information;
● Providing access to certain areas, functionalities, and features of our Site;
● Answering requests for customer or technical support;
● Communicating with you about your activities on our Site and policy changes;
● Processing applications if you apply for a job we post on our Site; and
● Allowing you to register for events.
B. Administrative Purposes
We have a legitimate interest in using use your personal information for various administrative purposes, such as:
● Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
● Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
● Measuring interest and engagement in our Site;
● Improving, upgrading, or enhancing our Site;
● Developing new products and services;
● Ensuring internal quality control and safety;
● Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
● Debugging to identify and repair errors on our Site;
● Auditing relating to interactions, transactions, and other compliance activities;
● Sharing personal information with third parties as needed to provide the services;
● Enforcing our agreements and policies; and
● Carrying out activities that are required to comply with our legal obligations.
C. Marketing and Advertising our Products and Services We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
Some of the ways we may market to you include email campaigns.
If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.
D. With Your Consent
We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
E. Other Purposes We also use your personal information for other purposes as requested by you or as permitted by applicable law.
● De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about how you use the Site, information about the device from which you access our Site, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use, disclose, and retain such information as permitted by applicable laws including, but not limited to, for research, analysis, analytics, and any other legally permissible purposes.
4. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We disclose your personal information to third parties for a variety of business purposes, including to provide our services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your personal information are described below.
● Service Providers. We may share your personal information with our third-party service providers and vendors that assist us with the provision of our services. This includes service providers and vendors that provide us with IT support, hosting, customer service, and related services.
● Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
● Affiliates. We may share your personal information with our corporate affiliates.
● [Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Site to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other Site) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising,” “personalized advertising,” or “targeted advertising.”]
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights,property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
5. YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
● Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding us and our services, and you will not be able to opt out of those communications (e.g., communications regarding our services or updates to our Terms or this Privacy Policy).
● “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
● Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Site may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS , and others. Please note you must separately opt out in each browser and on each device.
Your Privacy Rights. In accordance with applicable law, you may have the right to:
● Request Access to and Portability of Your Personal Information, including: (i) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the “right of data portability”);
● Request Correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
● Request Deletion of your personal information;
● Request Restriction of or Object to our processing of your personal information;
● Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal; and
● Contact Supervisory Authority. If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.
▪ EEA Data Protection Authorities (DPAs)
▪ Swiss Federal Data Protection and Information Commissioner (FDPIC)
▪ UK Information Commissioner’s Office (ICO)
If you would like to exercise any of these rights, please contact us as set forth in “ Contact Us” below. We will process such requests in accordance with applicable laws.
6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your personal information consistent with the requirements of applicable laws.
If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.
For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below.
7. RETENTION OF PERSONAL INFORMATION
We store the personal information we collect as described in this Privacy Policy for as long as you use our Site, or as necessary to fulfill the purpose(s) for which it was collected, provide our Site, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
8. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Contact Us below.
9. CHILDREN’S INFORMATION
The Site is not directed to children under 18 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to our Site without your consent, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.
10. OTHER PROVISIONS
Third-Party Websites/Applications. The Site may contain links to other websites/applications and other websites/applications may reference or link to our Site. These third-party Site are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
11. CONTACT US
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:
Spaero Inc.
ATT: LEGAL
150 Hooper St. Suite 215
San Francisco, CA 94107
