The Privacy Policy

This privacy policy (“Policy”)describes how Spruce Systems, Inc. (“Spruce” “Company”, “we”,“our”, “us”) collects, uses, shares, and stores personal information of users of this website, https://www.spruceid.com/ (the “Site”).This Policy applies to the Site on or in which it is posted, linked, or referenced.

By using the Site, you accept the terms of this Policy and our Terms of Use, and consent to our collection, use,disclosure, and retention of your information as described in this Policy. If you have not done so already, please also review our terms of use. The terms of use contain provisions that limit our liability to you and require you to resolve any dispute with us on an individual basis and not as part of any class or representative action. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF USE, THEN PLEASE DO NOT USE ANY OF THE SITE.

Please note that this Policy does not apply to information collected through third-party websites or site that you may access through the Site or that you submit to us through email, text message or other electronic message or offline.

If you are visiting this site from the European Union (EU), see our Notice to EU Data Subjects for our legal bases for processing and transfer of your data.

What We Collect

We get information about you in a range of ways.

Information You Give Us. Information we collect from you includes:

  • Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with Site, receive customer support or otherwise correspond with us;
  • Anonymized usage information, such as information about how you use the Site and interact with us; and
  • Marketing information, such as your preferences for receiving marketing communications and details about how you engage with     them.

Information We Get From Others. We may get information about you from other third party sources and we may add this to information we get from your use of the Site.

Information Automatically Collected. We may automatically record certain information about how you use our Site (we refer to this information as “Log Data“). Log Data may include information such as a user’s Internet Protocol(IP) address, device and browser type, the pages or features of our Site to which a user browsed and the time spent on those pages or features, the frequency with which the Site is used by a user, search terms, the links on our Site that a user clicked on or used, referral url, and other statistics. We use this information to administer the Site and we analyze (and may engage third parties to analyze) this information to improve and enhance the Site by expanding its features and functionality and tailoring it to our users’ needs and preferences.

We may use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole.Users can control the use of cookies at the individual browser level. For more information, please see the section entitled “Cookies Policy” below.

We also use data analytics site such as Google Analytics to help us offer you an optimized user experience. You can find more information about Google Analytics’ use of your personal data here: https://www.google.com/analytics/terms/us.html.

Use of Personal Information

To comply with law
We use your personal information as we believe necessary or appropriate to comply with applicable laws,  lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.  

To communicate with you
We use your personal information to communicate about promotions, upcoming events, and other news about products and site offered by us and our selected partners.

To optimize our platform
In order to optimize your user experience, we may use your personal information to operate,maintain, and improve our Site. We may also use your information to respond to your comments and questions regarding the Site, and to provide you and other users with general customer site.

With your consent
We may use or share your personal information with your consent, such as when you instruct us to take a specific action with respect to your personal information, or you opt into third party marketing communications.

For compliance, fraud prevention, and safety
We may use your personal information to protect, investigate, and deter against fraudulent,unauthorized, or illegal activity.

Sharing of Personal Information

We do not share or sell the personal information that you provide us with other organizations without your express consent, except as described in this Privacy Policy. We disclose personal information to third parties under the following circumstances:

Affiliates. We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy.

Business Transfers. We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger,financing, acquisition, or bankruptcy transaction or proceeding.

Compliance with Laws and Law Enforcement;Protection and Safety. We may share personal information for legal, protection, and safety purposes.

  • We may share information to comply with laws.
  • We may share information to respond to lawful requests and legal processes.
  • We may share information to protect the rights and property of the Company, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
  • We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.

Professional Advisors and Site Providers. We may share information with those who need it to do work for us. These recipients may include third party companies and individuals to administer and provide the Site on our behalf (such as customer support, hosting, email delivery and database management site), as well as lawyers, bankers, auditors, and insurers.

If you are visiting this site from the European Union (EU), see our Notice to EU Data Subjects for our legal bases for processing and transfer of your data.

International Transfer

The Company has offices outside of the EU and has affiliates and site providers in the United States and in other countries.Your personal information may be transferred to or from the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

EU users should read the important information provided below about transfer of personal information outside of the European Economic Area (EEA).

How Information is Secured

We retain information we collect as long as it is necessary and relevant to fulfill the purposes outlined in this privacy policy. In addition, we retain personal information to comply with applicable law where required, prevent fraud, resolve disputes, troubleshoot problems,assist with any investigation, enforce our Terms of Use, and other actions permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

We employ industry standard security measures designed to protect the security of all information submitted through the Site.However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. In order to protect you and your data, we may suspend your use of any of the Site,without notice, pending an investigation, if any breach of security is suspected.

Information Choices and Changes

Accessing, Updating, Correcting, and Deleting your Information - You may access information that you have voluntarily provided through your account on the Site, and to review, correct, or delete it by sending a request to hello@spruceid.com. You can request to change contact choices, opt-out of our sharing with others,and update your personal information and preferences.

Tracking Technologies Generally - Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. For more information, please see the section entitled “Cookies Policy” below.

Google Analytics - You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout and downloading the Google Analytics Opt-out Browser Add-on.

CONTACT INFORMATION. We welcome your comments or questions about this Policy, and you may contact us at: hello@spruceid.com.

CHANGES TO THIS PRIVACY POLICY. We may change this privacy policy at anytime. We encourage you to periodically review this page for the latest information on our privacy practices. If we make any changes, we will change the Last Updated date above.

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the changes to the Site (or as otherwise indicated at the time of posting). In all cases, your continued use of the Site or Site after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Eligibility

If you are under the age of majority in your jurisdiction of residence, you may use the Site only with the consent of or under the supervision of your parent or legal guardian. Consistent with the requirements of the Children's Online Privacy Protection Act (COPPA), if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent's verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Site and subsequently we will delete that information.

Notice to California Residents

Under California Civil Code Section 1789.3,California users are entitled to the following consumer rights notice:California residents may reach the Complaint Assistance Unit of the Division of Consumer Site of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or(800) 952-5210.

Personal Information
With respect to EU data subjects, “personal information,” as used in this Privacy Policy, is equivalent to “personal data” as defined in the European Union General Data Protection Regulation (GDPR).

Sensitive Data
Some of the information you provide us may constitute sensitive data as defined in the GDPR(also referred to as special categories of personal data).

Legal Bases for Processing
We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information,which are described in the table below. If you have questions about the legal bases under which we process your personal information, contact us at hello@spruceid.com.

Processing Purpose - Legal Basis

To communicate with you and to optimize our website. These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impacts on you and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law).

We use your personal information to comply with applicable laws and our legal obligations.

We use your personal information to comply with applicable laws and our legal obligations. Where our use of your personal information is based upon your consent, you have the right to withdraw it anytime in the manner indicated in the Site or by contacting us at hello@spruceid.com.

Use for New Purposes

We may use your personal information for reasons not described in this Privacy Policy, where we are permitted by law to do so and where the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis for that use. If we have relied upon your consent for a particular use of your personal information, we will seek your consent for any unrelated purpose.

Your Rights

Under the GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

  • Opt-out. Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Site-related and other non-marketing communications.
  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
  • Correct. Update or correct inaccuracies in your personal information.
  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
  • Restrict. Restrict the processing of your personal information.
  • Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You can submit these requests by email to hello@spruceid.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at hello@spruceid.com or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Cross-Border Data Transfer

Please be aware that your personal data will be transferred to, processed, and stored in the United States. Data protection laws in the U.S. may be different from those in your country of residence. You consent to the transfer of your information, including personal information, to the U.S. as set forth in this Privacy Policy by visiting our site or using our site.

Whenever we transfer your personal information out of the EEA to the U.S. or countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

Cookies Policy

We understand that your privacy is important to you and are committed to being transparent about the technologies we use. In the spirit of transparency, this policy provides detailed information about how and when we use cookies on our Site.

Do we use Cookies?

Yes. We and our marketing partners,affiliates, and analytics or site providers use cookies, web beacons, or pixels and other technologies to ensure everyone who uses the Site has the best possible experience.

What is a Cookie?

A cookie (“Cookie”) is a small text file that is placed on your hard drive by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. Some of the cookies will only be used if you use certain features or select certain preferences, and some cookies will always be used. You can find out more about each cookie by viewing our current cookie list below. We update this list periodically, so there may be additional cookies that are not yet listed. Web beacons, tags and scripts may be used in the Site or in emails to help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our site/analytics providers on an individual and aggregated basis.

What is a Cookie?

We generally use Cookies for the following purposes:

  • To recognize new or past customers.
  • To store your password if you are registered on our Site.
  • To improve our Site and to better understand your visits on our platforms and Site.
  • To serve you with interest-based or targeted advertising.
  • To observe your behaviors and browsing activities over time across multiple websites or other platforms.
  • To better understand the interests of our customers and our website visitors.

We also use functional Cookies and Cookies from third parties for analysis and marketing purposes. Functional Cookies enable certain parts of the site to work properly and your user preferences to remain known.

If you want to learn more about cookies, or how to control, disable or delete them, please visit http://www.aboutcookies.org for detailed guidance. In addition, certain third party advertising networks,including Google, permit users to opt out of or customize preferences associated with your internet browsing.

We may link the information collected by Cookies with other information we collect from you pursuant to this Privacy Policy and use the combined information as set forth herein.  Similarly, the third parties who serve cookies on our Site may link your name or email address together information they collect, which may include past purchases made offline or online, or your online usage information. If you are located in the European Economic Area, you have certain rights that are described above under the header “Notice to EU Data Subjects”, including the right to inspect and corrector delete the data that we have about you.

Cookies Disclosure

Identifier: Google Analytics

Function and Administration: Analytics

1st or 3rd Party and Name: 3rd –Google

Type: Persistent

Duration if not Cleared: 2 years