Spotech Privacy Policy

Last Updated: January 31, 2019

Thank you for using Spotech!

This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of the Spotech Platform and the Payment Services.

If you see an undefined term in this Privacy Policy (such as “Posting” or “Spotech Platform”), it has the same definition as in our Terms of Service

When this policy mentions “Spotech,” “we,” “us,” or “our,” it refers to the Spotech company that manages your information under this Privacy Policy (the “Data Controller”).

0. Personal Information Protection Policy

① In acquiring personal information, we will identify the purpose of use as much as possible and we will acquire personal information to the extent necessary for achieving that purpose. We will take necessary measures to protect any data we collect.

② In the case of obtaining personal information directly from the principal in writing, we will acquire personal information within the necessary range after announcing our company name, personal information protection administrator name and contact address, purpose of use etc.

③ The use of personal information is carried out within the range of purpose of use to which the users themselves have given consent. In addition, we will establish and carry out procedures and take necessary measures in order to not misuse the data for outside purpose.

④ We will manage the personal information we possess in an appropriate manner and will not disclose or provide it to third parties without your consent.

⑤ We will manage the personal information possessed within the necessary parameters according to the intended purpose of use accurately and up to date. We will also take reasonable safety measures against the risk of leakage, loss or damage of personal information and strive for prevention and correction against potential risks.

⑥ When delegating the processing of personal information to third parties, we will honor the contract to not disclose leakage or provide to unrelated parties, and we will implement appropriate management for outsourcing parties.

⑦ Complaints and consultations on personal information stored will be handled through direct contact to Spotech.

⑧ We will comply with laws regarding the handling of personal information as well as guidelines established by the government and other norms.

⑨ We will establish a personal information protection management system, review this on a regular basis and continuously improve it.

1. INFORMATION WE COLLECT

There are three general categories of information we collect.

1.1 Information You Give to Us.

1.1.1 Information that is necessary for the use of the Spotech Platform.

We ask for and collect the following personal information about you when you use the Spotech Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations. Without it, we may not be able to provide you with all the requested services.

1.1.2 Information you choose to give us.

You may choose to provide us with additional personal information in order to obtain a better user experience when using Spotech Platform. This additional information will be processed based on your consent.

1.1.3 Information that is necessary for the use of the Payment Services.

The Payments Data Controller needs to collect the following information, as it is necessary for the adequate performance of the contract with you and to comply with applicable law (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services:

1.2 Information We Automatically Collect from Your Use of the Spotech Platform and Payment Services.

When you use the Spotech Platform and the Payment Services, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Spotech Platform and Payment Services.

1.3 Information We Collect from Third Parties.

Spotech may collect information, including personal information, that others provide about you when they use the Spotech Platform and the Payment Services, or obtain information from other sources and combine that with information we collect through the Spotech Platform and the Payment Services. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

2. HOW WE USE INFORMATION WE COLLECT

We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Spotech Platform, create and maintain a trusted and safer environment and comply with our legal obligations. The use of personal information will be used within the scope of the following purpose of use, and persons with authority according to specific work within the range necessary for business. In the event that a use purpose that does not fall within the scope of the next purpose arises, in the case of direct acquisition, after acquiring the consent of the purpose of use to the person himself / herself, we will use it after publishing it.

2.1 Provide, Improve, and Develop the Spotech Platform.

Regarding personal information and client management
1. For business activities · deal management

Regarding personal information from persons making inquiries.
1. Personal information from persons receiving inquiries

Personal information on employees / ex-employees
1. For employment and personnel management

Personal information regarding all persons who apply for our recruitment screening
1. For inquiries concerning selection and acceptance / rejection

We process this information given our legitimate interest in improving the Spotech Platform and our Members’ experience with it, and where it is necessary for the adequate performance of the contract with you.

2.2 Create and Maintain a Trusted and Safer Environment.

We process this information given our legitimate interest in protecting the Spotech Platform, to measure the adequate performance of our contract with you, and to comply with applicable laws.

2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.

We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Spotech Account.

2.4 How the Payments Data Controller uses the Information Collected.

The Payments Data Controller processes this information given its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.

3. SHARING & DISCLOSURE

3.1 With Your Consent.

Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third-party application or website to access your Spotech Account or when you participate in promotional activities conducted by Spotech partners or third parties. We will notify you of the purpose of use of personal information of the person himself, correction, addition or deletion of contents, stop / erase use, suspension of provision of a third party (hereinafter referred to as "disclosure etc.") We will respond to your offer without delay. However, in the following cases, we may not disclose all or part of it.

1. There is a risk of harming the life, body, property or other rights and interests of the person or the third party

2. If there is a risk of significant hindrance to our business

3. In case of violating other laws and regulations

Please contact us from the inquiries regarding the specific procedure of the request for disclosure etc.

3.2 Sharing between Members.

To help facilitate postings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of the contract between you and us, as follows:

We don’t share your billing and payout information with other Members.

3.3 Profiles, Postings, and other Public Information.

The Spotech Platform lets you publish information, including personal information, that is visible to the general public. For example:

Based on our legitimate interest to promote the Spotech Platform we may display parts of the Spotech Platform (e.g., your Posting page) on sites operated by Spotech’s business partners, using technologies such as widgets or APIs. If your Postings are displayed on a partner’s site, information from your public profile page may also be displayed.

Information you share publicly on the Spotech Platform may be indexed through third party search engines. In some cases, you may opt-out of this feature in your Account settings. We do not control the practices of third party search engines, and they may use caches containing your outdated information.

3.4 Compliance with Law, Responding to Legal Requests, Preventing Harm and Protection of our Rights.

Spotech may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Spotech, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service, the Payment Terms or other agreements with Members, or (v) to protect the rights, property or personal safety of Spotech, its employees, its Members, or members of the public.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Spotech Platform secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage.

Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon Spotech’s property, its Members and the Spotech Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

3.5 Service Providers.

Spotech uses a variety of third party service providers to help us provide services related to the Spotech Platform and the Payment Services. Service providers may be located inside or outside of the European Economic Area (“ EEA”).

For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, (v) allow the provision of the Spotech Services through third party platforms and software tools (e.g. through the integration with our APIs), or (vi) provide customer service, advertising, or payments services. These providers have limited access to your information to perform these tasks on our behalf, and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy.

Spotech will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

3.6 Social Media Platforms.

Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, to hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Spotech Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.

The social media platforms with which we may share your personal data are not controlled or supervised by Spotech. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.

3.7 Business Transfers.

If Spotech undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

3.8 Aggregated Data.

We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

4. OTHER IMPORTANT INFORMATION

4.1 Analyzing your Communications.

We may review, scan, or analyze your communications on the Spotech Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyze messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyze your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

These activities are carried out based on Spotech's legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

4.2 Linking Third Party Accounts.

You may link your Spotech Account with your account at a third party social networking service. Your contacts on these third-party services are referred to as “Friends.” When you create this link:

We only collect your information from linked third party accounts to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws, or with your consent.

4.3 Google Maps/Earth.

Parts of the Spotech Platform use Google Maps/Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and the Google Privacy Policy .

5. THIRD PARTY PARTNERS & INTEGRATIONS

The Spotech Platform may contain links to third party websites or services, such as third party integrations, co-branded services, or third party-branded services (“Third Party Partners”). Spotech doesn’t own or control these Third-Party Partners and when you interact with them, you may be providing information directly to the Third-Party Partner, Spotech, or both. These Third-Party Partners will have their own rules about the collection, use, and disclosure of information. We encourage you to review the privacy policies of the other websites you visit.

6. YOUR RIGHTS

You can send an email to info@spotech.io Please note that we may ask you to verify your identity before taking further action on your request.

6.1 Managing Your Information.

You may access and update some of your information through your Account settings. If you have chosen to connect your Spotech Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.

6.2 Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Spotech Account).

6.3 Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

6.4 Data Retention and Erasure.

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Spotech Platform to you, you can request that we erase your personal information and close your Spotech Account. Please note that if you request the erasure of your personal information:

6.5 Withdrawing Consent and Restriction of Processing.

Where you have provided your consent to the processing of your personal information by Spotech you may withdraw your consent at any time by changing your Account settings or by sending a communication to Spotech specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Spotech override your own.

6.6 Objection to Processing.

In some jurisdictions, applicable law may entitle you to require Spotech not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Spotech will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask Spotech to cease processing your data for these direct marketing purposes by sending an e-mail to info@spotech.io

7. SECURITY

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Spotech Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Spotech Account, please contact us following the instructions in the Contact Us section below.

8. CHANGES TO THIS PRIVACY POLICY

Spotech reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Spotech Platform and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Spotech Platform will be subject to the revised Privacy Policy.

9. CONTACT US

If you have any questions or complaints about this Privacy Policy or Spotech’s information handling practices, you may email us or contact us at:

Spotech, Inc.

Level 15, Cerulean Tower, 26-1 Sakuragaoka-cho,

Shibuya-ku, Tokyo, Japan

info@spotech.io