Last Modified: 9 Feb 2022
This policy describes the type of information Spare (“Spare”, “We” or “Us”) may collect from you or that you may provide when you visit and utilize the services available through our Site and the App. This includes our practices for collecting, using, maintaining, protecting, and disclosing that information and the basis for doing so.
This policy applies to information we collect on the Site and App, in email, text and other electronic messages between you and Spare and, through mobile and desktop applications you download so as to access the Services (such as the iOS App Store or Google Play Store), which provide dedicated non-browser-based interaction between you and Spare.
2. Personal Data
“Personal Data” is any information in any form concerning an identified individual, or an individual who can, directly or indirectly, be identified by reference, in particular, to his or her personal identification number, or by reference to one or more factors specific to his or her physical, physiological, intellectual, cultural, economic, or social identity. In determining whether an individual is identifiable, all the means that the data controller or any other person uses or may have access to should be taken into consideration.
3. Data Controller
If you are a registered Spare user, subscriber, customer or a visitor to the Services, Spare acts as the data controller (“Data Controller”) of your personal data (“Personal Data”). This means we control how and why your Personal Data is processed.
4. Collection and Use of Personal Data
We process your Personal Data for the following purposes:
- in order to provide the Services and fulfill our obligations pursuant to our Terms of Service. For example, we cannot provide our Services without an email address to sign into your account, conduct customer support, or send educational materials;
- in order to access customer accounts through ‘application program interfaces’ (APIs);
- where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
- to protect your vital interests, or those of others, such as in the case of emergencies;
- where you have made the information public;
- where necessary in the public interest;
- where necessary for the purposes of Spare’s or a third party’s legitimate interests, such as those of visitors, members or partners;
- Where you provide consent (for example, to join email mailing lists).
We also process your Personal Data based on our legitimate interest in:
- providing a quality Service and in improving that Service;
- ensuring the Services are secure;
- protection against fraud, spam, abuse, etc.; and
- Understanding how Customers and Visitors interact with our Services, so that we can continuously improve the experience and effectiveness of doing so.
5. Categories of Personal Data we collect
We collect information about you in different ways. We may do so:
- when you provide the information, through filling out forms or otherwise providing information on our Sites and Apps;
- when we connect to your financial institutions in order to retrieve transaction data on your behalf;
- when you use location services to record transactions in our mobile apps;
- when you correspond with us to receive customer support via email or chat.
- Your email address that you provide to us as a username.
- Your IP address when you interact with our Site and App.
- Your location when you record a transaction in our mobile applications and have previously activated location services.
- Records and copies of your correspondence (including email addresses different than that used to establish your account), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through our Site and/or App.
- Information that you provide by filling in forms on our Site and/or App. This includes information provided at the time of registering to use our Services, subscribing to our Service, or requesting further Services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Service.
- To provide you with customer support or service offerings, including responding to and resolving your inquiries and requests via email or text-based chat. When you request assistance from our customer support team with respect to importing third-party financial account data, to allow a customer support representative to review a limited amount of data from recent transactions for the sole purpose of facilitating technical implementation of the account aggregation services. When asked to do so by you, our customer support representative may utilize that transaction data on your behalf in interactions with third-party financial account providers intended to facilitate implementation of requested account aggregation within our Services.
6. Cookies & Similar Technologies
Spare collects information as Users, Visitors and Customers browse and interact with the Site and/or App.
a) Site Visitors
When you visit our Site, we may place a cookie on your browser so that our system can recognize you when you make a return visit. Third parties may also place cookies on your browser for targeted advertising purposes. That cookie allows us to recognize your browser on a return visit. We do not otherwise collect or process your Personal Data when you are a Visitor.
b) Signed-in Users
7. Disabling Cookies
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our Site.
8. Sharing of Personal Data
- To contractors, service providers, and other third parties we use to support our business, in particular providing infrastructure and analytics services, and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Data held by us about our Site Users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- In aggregated form, and/or information that does not identify any individual.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your Personal Data :
- To comply with any court order, law or legal process, including responding to any government or regulatory request.
- To enforce or apply our Terms of Service or terms of sale and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Spare, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
9. Categories of Third-Party Providers
Categories of services used to process data include:
a) Infrastructure & Fulfillment
Spare partners with third-parties to provide storage and server access that acts as infrastructure for our Site and Apps.
Spare partners with third-parties to help us monitor and analyze Site traffic and can be used to keep track of User behavior, helping us to improve the services and experience of using them.
c) Customer Support
Spare partners with third-parties to help us receive, process, and respond to customer support requests, as customer support and education are a core part of the services offered.
d) Performance and Logging
Spare partners with third-parties that assist us in monitoring the stability of the Site and applications and resolving issues or errors with the service.
10. Data Retention
We will retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will also keep your Personal Data for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. We retain archived copies of your information as required by law or for legitimate business purposes.
11. Third Party Sites
12. Our Policy on Children
Our Site and App are not directed to children under 18 years of age. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. If you believe we might have any Personal Data from or about a child under 18 years of age, please contact us at: email@example.com
13. Your Rights
You may exercise certain rights regarding your Personal Data processed by us. In particular, you have the following rights:
- Right to access: You have the right to request access to your Personal Data held by us. Request is to be made in writing, electronically and information will be provided in a commonly used electronic format. The request will be handled within one month of receipt of the request, and free of charge with exception of where requests are manifestly unfounded or excessive, we hold the right to charge a reasonable fee taking into account the administrative costs of providing that information.
- Right to rectification: You have the right to have Personal Data rectified if inaccurate or incomplete. Where the Personal Data in question has been disclosed to a third party, they will be made aware of the rectification where possible.
Right to erasure: You have the right to request the deletion or removal of Personal Data in the following circumstances:
a) Where the Personal Data is no longer necessary in relation to the purpose for which it was originally collected/processed.
b) When you withdraw consent.
c) When you object to the processing and there is no overriding legitimate interest for continuing the processing.
d) The Personal Data was unlawfully processed.
e) The Personal Data has to be erased in order to comply with a legal obligation. This does not provide an absolute “Right to be forgotten”.
Where the Personal Data in question has been disclosed to a third party, we will inform them about the erasure of the Personal Data, unless it is impossible or involves disproportionate effort to do so. Personal Data will be erased by removal from our internal and cloud servers.
- Right to restrict processing: You have a right to “block” or suppress processing of Personal Data if you contest its accuracy; have objected to the processing; processing is unlawful and you oppose erasure; we no longer need the Personal Data but you require the data to establish, exercise or defend a legal claim. Where the Personal Data in question has been disclosed to a third party, we will inform them about the restriction on processing of the data, unless it is impossible or involves disproportionate effort to do so.
- Right to data portability: You have the right to obtain and reuse your Personal Data for your own purposes. Requests are to be made in writing, electronically, and will be handled within a reasonable time on receipt of the request.
- Right to object: You have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics. Requests will be dealt with by immediate effect with no right for refusal.
Should a data breach occur, we have compliant procedures in place to investigate and report the matter to the individual. In the event of a breach, it will be reported to you within 72 hours of discovery. A record of any breaches will be kept by us. For this reason, make sure that if you’re subscribed to our email list you have set the emails to go to your inbox and not to be filtered to a spam folder or other folder, so that you can see them easily.
If you wish to exercise any of these rights, please contact us. In your request, please make clear: (a) what personal data is concerned; and (b) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your
request as soon as reasonably practicable and in any event, within one month of your request.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
14. International Data Transfer
We seek to use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us.
16. Contact Information