Privacy Policy

Last updated: 24 September 2024

Introduction

This policy applies to all the personal data (personally identifiable information) we process regardless of how it was captured by electronic means, paper records, in person or via social media and how that data is stored or whether it relates to past or present customers, supplier contacts, shareholders, website users or any other Data Subject (Individuals).

This document outlines how we protect and use your personal information, and regardless of the personal data we hold we shall process your personal data in full accordance the EU General Data Protection Regulation GDPR, the UK Data Protection Act 2018, California Online Privacy Protection Act (CalOPPA), and other relevant legislation. This document explains how we obtain, collect, process and store information about you, if we share with any third parties and details of your rights.

Full business contact information is at the end of this policy.

Spogen.ai handles your personal data according to the following guidelines:

We will never sell, rent, distribute or make public your personal data
Data is collected and processed when absolutely necessary
The rights of the data subject remain lawful and transparent

Who is responsible for managing my information?

This website is owned and maintained by spogen.ai (HMI Technologies Oy). Our company is located in Finland, in EU. All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.

We do utilise cloud computing applications such as HubSpot, which potentially means that data may be stored outside of the EU.

We are responsible for the collection and proper management of any personal information you submit. We will keep your personal details secure and use the information you provide consistently with applicable privacy and data protection laws and the terms of this Privacy Policy.

Processing of personal data

How do we receive your personal data?

We may collect or otherwise receive your Personal Data when:

you visit and interact with our website;
you provide it to us directly as a client or prospective client, including by way of contacting us via telephone, email, mail, or a contact form, or live chat service on our website;
you click on one of our advertisements, social media posts, or open one of our emails;
you register and attend one of our live events;
we receive it from other affiliates within spogen.ai or
we obtain it from publicly available sources.

On what basis do we process your information?

We collect your personal data directly from our website and via email and telephone. We maintain records of customer contact, which falls under the lawful basis of legitimate interest (GDPR Article 6(f)) and under the lawful basis of being necessary for the performance of a contract (GDPR Article 6(b)).

Personal data is processed entirely for the legitimate interest of maintaining contact between us and you (our customer, or potential customer) in order to deliver our service and fulfil any contracts, which exist between us. We do not process any special category data within the meaning of GDPR.

We may process your Personal Data for purposes of:

providing you with access to our Website;
managing our relationship with you;
selling and supporting our services to you;
responding to your requests and questions;
sending you marketing communications about our business that you have expressed interest in, or which we think may interest you;
collecting payment for our services;
measuring and improving our website, services, and marketing initiatives; and
enforcing our legal obligations and complying with applicable laws and regulations.

What information do we collect?

Personal and sensitive data is required to allow us to provide our services to our clients.

We may process the following types of Personal Data about Website visitors:

basic identifying information, such as your name and surname;
contact information, such as your email address;
professional information, such as your place of work; and
identifiers and device information, such as your IP address and associated location, device ID, operating system, and website navigational information, such as information about your interaction with the Website.

We may process the following types of Personal Data in connection with our Services:

basic identifying information, such as your name and surname;
contact information, such as your email address, postal address, and phone number;
professional information, such as your job title, position, and information about your organization; and
billing information, such as your bank account number.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. This is done via Hubspot who will capture your IP address, geographical location, details of the system you use and the pages you visit. You can opt-out of cookie tracking on our website.

Cookies - How do we use cookies on our websites?

Cookies are small text files that are placed on your computer when you access a website.

Our website stores cookies on your computer. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information in order to improve and customize your browsing experience and for analytics and metrics about our visitors both on this website and other media.

For detailed information on the cookies we use and the purposes for which we use them see our Cookies Policy.

How do we use and store your information?

We may process your Personal Data on the basis of:

your consent;
the need to perform a contract that we entered into with you;
our legitimate interests, such as our interest in marketing and selling our services;
our obligation to comply with applicable law; or
any other ground, as required or permitted by applicable law.

Where we process your Personal Data based on your consent, you may withdraw your consent at any time. However, this will not affect the lawfulness of our processing before your withdrawal of consent. It will also not affect our processing performed on any other lawful ground.

If we receive your Personal Data as part of providing our Services to you based on a contract, we require certain Personal Data to be able to carry out the contract. Without that necessary Personal Data, we will not be able to provide the services to you.

The information you provide may be used in a number of ways, for example:

To personalise visits to our website, through HubSpot we are able to understand how our clients found our website and are able to track their journey through the website which enables us to provide a better service.

When you complete a form on our website, you will enter your name, email address and other personal information. This information will be saved securely in HubSpot CRM and used for the purposes outlined on the form, you may also choose to 'opt in' to other communications.

If you have chosen to 'opt-in' we may use your personal data to tell you about other products and services we think may be of interest to you via an Email Newsletter or Marketing Emails, which are sent directly from our CRM system HubSpot. You may unsubscribe at any time by clicking the link at the bottom of the newsletter or by emailing us and asking us to remove you from this service.

By using the Contact Forms and Email links, the data you input will be entered directly into our Hubspot CRM system. Visitors to our website who have submitted data via a form or email will only be contacted for marketing purposes following their submission of explicit consent to receive such communications. You can unsubscribe from communications at any time, either directly via clicking ‘Subscription Preferences’ in our email footers, or by contacting us and asking to unsubscribe.

The website is not intended for, or targeted at children under 18, and we do not knowingly or intentionally collect information about children under 18. If you believe that we have collected information about a child under 18, please contact us at privacy@spogen.ai, so that we may delete the information.

Sharing of personal data

Do we ever share personal data?

As a HubSpot Solutions Partner, we periodically share your data (name and email, as well as company/organisation details) with HubSpot. HubSpot's Privacy Policy can be seen here: https://legal.hubspot.com/privacy-policy

We do not share your personal data with other third-parties other than data processors as listed below.

We may also disclose your personal information to third parties in the event we sell or buy business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Do you have any third-party processors?

As previously mentioned, we interact with carefully chosen third parties who also comply with the relevant regulations and legislation. These third parties are Google and HubSpot, which are both, based in the USA and are EU-U.S Privacy Shield compliant.

We transfer your personal data outside the EU if such transfer is necessary to provide the services you have requested from us; or it is otherwise required or permitted by law.

When can we contact you in the future?

We would like to send you information about our own products and services, as well as those of selected third parties. We may do this by post, telephone, email or SMS, unless you have told us that you do not wish to be contacted in this way. We will always ask you to confirm in advance that you are happy for us to allow third parties to contact you by email.

If you would like to change any of your preferences relating to the way in which we may use your information for direct marketing, then please update your user preferences or send an email to privacy@spogen.ai

How long will we hold your information for?

We have a system of retention periods in place to ensure that your information is only stored whilst it is required for the relevant purposes or to meet legal requirements. Where your information is no longer required, we will ensure it is disposed of in a secure manner from our systems.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your rights

What are your rights as a data subject?

If you are a Data Subject about whom we store Personal Data, you have certain data protection rights under applicable privacy laws.

Please note that you can only exercise these rights with respect to Personal Data that we process about you when we act as a data controller. To exercise your rights with respect to Personal Data processed by us on behalf of one of our clients, please read the privacy notice(s) of our clients.

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you wish to exercise any of the rights set out above, please contact us.

No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Does this policy apply to linked websites?

Our website contains links to other websites. If you follow links to other sites from our website, your data will be subject to the privacy policies of those sites, you should refer to these policies before providing your data. We hold no responsibility for unaffiliated linked websites or any use of those sites and their privacy practices. This privacy policy only applies to this website.

How do we update this privacy policy?

This privacy policy is reviewed on a regular basis and may be changed with any regulatory, legislation or company changes.

What happens if there is a data breach?

As per the GDP regulations all data breaches will be reported to the ICO within 72 hours.

This includes those of any 3rd parties where it's apparent that personal data stored has been compromised.

Who can we contact?

Please contact us if you have any questions about our privacy policy or information we hold about you.

By email: privacy@spogen.ai