Privacy Policy

This Privacy Policy was last updated on May 25, 2018.

Our Policy

Welcome to the web site (the “Site”) of PredictSpring, Inc. (“PredictSpring”, “we”, “us” and/or “our”). This Site is operated by PredictSpring and has been created to provide information about our mobile commerce platform and related services (together with the Site, the “Services”) to our Service visitors (“you”, “your”). This Privacy Policy sets forth PredictSpring’s policy with respect to persona data (“Personal Data”) and other information that is collected from visitors to the Site and Services.
By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of PredictSpring and the authorized third parties referred to herein located in the United States.

Information We Collect

When you interact with us through the Services, we may collect Personal Data from you, as further described below:

Personal Data That You Provide Through the Services:
We collect Personal Data from you when you voluntarily provide such information. This includes Personal Data you provide when you complete our “Contact Us” form, correspond with us via this Site, respond to one of our surveys, register for access to the Services or use certain Services, sign-up for PredictSpring newsletters or any of our Services that require registration, or give us some feedback.
The type of data that we collect from you include your first and last name, title, contact details (including postal and email address and telephone number), your preferences in receiving marketing and your communication preferences.Wherever PredictSpring collects Personal Data we make an effort to provide a link to this Privacy Policy.

Automatically Collected Data. When you use the Services, the following information is created and automatically logged in our systems:
When you interact with us through the Services, we may collect Personal Data from you, as further described below:

  • Log data: Information (“log data”) that your browser automatically sends whenever you visit the Site. Log data includes your Internet Protocol (“IP”) address (so we understand which country you are connecting from when you visit the Site), browser type and settings, the date and time of your request, and how you interacted with the Services.
  • Cookies: As you browse PredictSpring’s website, information from cookies is stored on your device. Please see the “Tracking Technologies” section below to learn more about how we use cookies and other technologies.
  • Device information: Includes type of device you are using, operating system, settings, unique device identifiers, network information and other device-specific information. Information collected may depend on the type of device you use and its settings.

Location Information: Our Services may collect and use your location information (for example, by using the GPS on your mobile device) to provide certain functionality of our Services. If you choose to enable our location features, your location information may be publicly displayed within the Services. Please keep in mind that other users can see this information about you, and they may use it or disclose it to other individuals or entities outside of our control and without your knowledge. Your location information may be subject to abuse, misuse, and monitoring by others, so please be careful if you choose to enable location functionality. We may also use your location information in an aggregate way (for more information, see “Our use of your Personal Data” section below.

Our Use of Your Personal Data

To Provide The Services And Respond To Request. PredictSpring uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided.
For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services, maintain your account, contact you regarding your use of the Services and/or the Site or to notify you of important changes to the Services and/or the Site, and to monitor your use of such services. Such use is necessary to perform the contract we have entered into with you or to take steps prior to entering into a contract at your request, or it is necessary for our legitimate interests in responding to your requests.

For Marketing Purposes. We may use your contact details to tell you about services we believe will be of interest to you, upcoming events or other promotions. If we do so, each marketing communication we send you will contain instructions permitting you to “opt out” of receiving future marketing communications. Note however that as user of our services you cannot opt out of some administrative communications that are reasonably necessary to the services, such as billing or service notifications. In addition, if at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.Where required by applicable law (for example, if you are an individual in the EU), we will only send you marketing information by email if you consent to us doing so at the time you provide us with your Personal Data. When you provide us with your consent to be contacted for marketing purposes, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you or by contacting us as indicated below.

As Necessary For Certain Legitimate Interests, described below:

  • To send you administrative information, for example, information regarding the Site and changes to our terms, conditions, and policies.
  • To respond to your inquiries and fulfill your requests, such as to send you requested materials and newsletters, as well as information and materials regarding our products and services.
  • To conduct analytics on how the Site and our Service are being used by you for our internal purposes (namely for providing, maintaining, benchmarking and improving our offerings, identifying usage trends and determining the effectiveness of our promotional campaigns) and to inform our marketing strategy and personalize our communications with you (including providing information on our features and other marketing and service-related announcements relevant to the content and features you engage with).
  • In an ongoing effort to better understand and serve the users of the Services, to conduct research on our customer demographics, interests and behavior based on your Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and PredictSpring may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. PredictSpring may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.
  • To prevent fraud or criminal activity, misuses of our products or services, and ensure the security of our IT systems, architecture and networks.
  • To (a) comply with legal obligations and legal process, (b) respond to requests from public and government authorities including public and government authorities outside your country of residence; (c) enforce our terms and conditions; (d) protect our operations; (e) protect our rights, privacy, safety or property, and/or that of you or others; and (f) allow us to pursue available remedies or limit the damages that we may sustain.
  • If you ask us to delete your data and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing.

For individuals in the EU, please see the “European Union (EU) Users” section below for information on our legitimate interests and your rights.If PredictSpring intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

Our Disclosure of Your Personal Data and Other Information

PredictSpring is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties, as set forth below:

Agents, Consultants and Other Service Providers: PredictSpring, like many businesses, sometimes hires other companies to perform certain business-related functions. These parties include website analytics companies, providers of digital advertising services, our hosting and cloud computing service providers, providers of CRM, marketing and sales software solutions, billing and processing payments functions. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function. Pursuant to our instructions, these parties may access, process or store Personal Data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.

Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Related Companies: We may also share your Personal Data with our Related Companies for purposes consistent with this Privacy Policy. 

Legal Requirements: PredictSpring may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of PredictSpring, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.

European Union (EU) Users

Data Controller. PredictSpring is the data controller for processing Personal Data provided to us through the Services. To find out our contact details, please see the “Contact Us” section below, which also provides the contact details of our representative in the EU for purposes of the General Data Protection Regulation.  

Your Rights. Subject to applicable EU law, you have the following rights in relation to your Personal Data:

  • Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
  • Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
  • Right to erasure: You may ask us to delete or remove your Personal Data, such as where you withdraw your consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
  • Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
  • Right to data portability: You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and that is processed by us by automated means. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
  • Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
    - If we are relying on a legitimate interest to process your Personal Data -- unless we demonstrate that we have compelling legitimate grounds to continue processing it, or
    - If we are processing your Personal Data for direct marketing.
  • Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect any processing of your data before we received notice that you wished to withdraw consent.
  • Right to make a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

Please see the “Contact Us” section below for information on how to contact us to exercise your rights.

Legitimate Interest. “Legitimate interests” means our interests in conducting our business, managing and delivering the best Service to you. This Privacy Policy describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent or those activities are otherwise required or permitted to by law.

Data Transfers: PredictSpring is based in the United States and processing of your Personal Data for the purposes described above may occur in countries outside of the EU, such as the United States, which may not have data protection regulations as stringent as those in the EU. When we transfer your personal data outside the EU, we will comply with our legal and regulatory obligations in relation to such transfers, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data (such as transferring your data to entities which are certified to the Privacy Shield framework operated by the U.S. Department of Commerce or implementing standard contractual clauses). Please contact us as set out under the “Contact Us” section below for information the safeguards we have in place for such transfers.

Data Retention: We will keep your Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences until you opt out of receiving these communications and in accordance with our policies.

To determine the appropriate retention period for your Personal Data, we will consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymize your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.

Tracking Technologies

The Site uses cookies [and similar technologies] to operate and administer our Site and the Services, make it easier for you to use the Services during future visits and gather usage data on our Site. We may allow third party service providers to use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of the Services.

What Are Cookies. A “cookie” is a piece of information sent to your browser by a website you visit. By choosing to use our the Site after having been notified of our use of cookies in the ways described in this Privacy Policy, and, in applicable jurisdictions, through notice and unambiguous acknowledgement of your consent, you agree to such use.

Some cookies expire after a certain amount of time, or upon logging out (session cookies), others remain on your computer or terminal device for a longer period (persistent cookies). Our Site uses first party cookies (cookies set directly by PredictSpring) as well as third party cookies, as described below.

Type of Cookies Used. The Site uses the following technologies:

  • Strictly Necessary Cookies: Used to provide you with the Services available through our Site and to use some of their features, such as the ability to log-in and access to secure areas. These cookies are served [by PredictSpring] and are essential for using and navigating the Site. Without these cookies, basic functions of our Site would not work. Because these cookies are strictly necessary to deliver the Services, you cannot refuse them.
  • Analytics/Performance: Used to better understand the behavior of the users on our Site and improve our Site accordingly, for example by making sure users are finding what they need easily. [The Site uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). The information collected by Google (including your IP address) will be transmitted to and stored by Google on servers in the United States (Google is certified to the Privacy Shield for data transfers). How long a Google Analytics cookie remains on your computer or device depends on what it is and what it is used for. Some Google Analytics cookies expire at the end of your browser session, whilst others can remain for up to two years. You can prevent your data from being collected by Google Analytics on our Site by downloading and installing the Google Analytics Opt-out Browser Add-on for your current web browser. For more information on Google Analytics privacy practices, read here.]

Your Choices: On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

  • Google Chrome
  • Mozilla Firefox
  • Apple Safari

We recommend that you leave cookies turned on because they allow you to take advantage of some of the Site’s features.

To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit  www.allaboutcookies.org and/or or the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org, and follow the opt-out instructions there or if located in the European Union, visit the European Interactive Digital Advertising Alliance’s Your Online Choices opt-out tool here. If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

Do Not Track Signals
Our Services currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

Exclusions

This Privacy Policy does not apply to any Personal Data collected by PredictSpring other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to PredictSpring through the Services or through any other means (without prejudice to your rights under the applicable law). This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and PredictSpring shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Children

Company does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Company through the Services, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Web Sites

This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by PredictSpring (the “Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy practices and policies.

Security

PredictSpring takes reasonable and appropriate steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to PredictSpring via the Internet.

Changes to PredictSpring’s Privacy Policy

The Services and our business may change from time to time. As a result, at times it may be necessary for PredictSpring to make changes to this Privacy Policy. PredictSpring reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice, unless otherwise required by the applicable law. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy or after we notified you if applicable, shall indicate your agreement with the terms of such revised Privacy Policy.

Access to Information

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.

Contact Us

Please also feel free to contact us if you have any questions about PredictSpring’s Privacy Policy or the information practices of the Services.
You may contact us as follows: support@predictspring.com. 

Predictspring, Inc.
Attn: Legal
5050 El Camino Real, Ste 226
Los Altos, CA 94022

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