Updated 7th March 2022
We provide a cloud-based solution to enterprise customers. Aside from contact and account information, we generally do not have access to personal information processed by the Services unless we are providing configuration services, customer support or success services, quality assurance, testing or other professional services, or for administrative purposes. When we do have access to personal information of individuals, it is typically as a service provider or supplier to our customers, with limited exceptions, such as, for example when we collect information:
- Through our Sites.
- For our advertising, marketing, promotion, industry outreach and educational efforts (which are primarily in a business-to-business context versus direct to individual consumers).
- In our relationships with employees, contractors, applicants and administrative and operational vendors and suppliers.
In our role as a service provider and supplier, we only process personal information of our customers as necessary to fulfill our obligations under our agreements with such parties and under applicable law.
Additional terms may apply for specific Services. If such terms apply, they will control over any conflicting terms in this Policy to the extent permitted under applicable law. If you are a customer, our Data Processing Agreement also applies to our processing of your personal information in connection with providing our Services and is incorporated into your agreement for the Services.
1. Information we collect and how it is collected
As used in this Policy, ‘personal information’ or ‘personal data’ means information that relates to an identified individual or to an identifiable individual.
When you visit our Sites, our servers may automatically log data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details. Some of this information may constitute personal information in certain regions.
We may ask for personal information directly from you, such as your:
- First and last name
- Company name
Service Data refers to data that accumulates over the normal course of operation of our Service. This may include Service transaction records, stored files, user profiles, analytics data and other metrics, as well as other types of information, created or generated, as users interact with our Services. Some of this information may constitute personal information in certain regions.
Information from third parties
We may collect or receive personal information about you from third parties including from our affiliates, marketing companies, job posting websites and recruiting firms. The categories of personal information collected from third parties include the categories indicated above and below.
We may process the following categories of personal information if you submit a job application, inquire about opportunities at Spectacles, provide us your information at a recruiting event or if we receive information about you from third parties in connection with our recruiting activities:
- Name and contact information such as phone number, email address and postal address.
- Employment history such as prior employers and dates of employment.
- Education history such as degrees earned and institutions attended.
- Resume, CV, educational transcripts and any information contained in or with such documentation.
- Job qualifications and work eligibility information such as country of residence, visa and immigration status, and citizenship.
- Reference information, such as name and contact details of your references.
- Compensation information that you voluntarily provide and which may depend on your region and applicable laws and regulations.
- Background check information, subject to applicable law.
- Sensitive personal information that you provide voluntarily or which we request on a non-mandatory basis in order to comply with applicable law.
2. Collection and use of information
We may collect, hold, use and disclose information for the following purposes and personal information will not be further processed in a manner that is incompatible with these purposes:
- to provide you with our platform's core features;
- to provide customer service, technical support, consulting or other related services;
- to provide seminars and training;
- to operate, maintain, secure, and develop our Sites and Services;
- to process any transactional or ongoing payments;
- to contact and communicate with you regarding your inquiries to us;
- for internal record keeping and administrative purposes;
- for analytics, market research and business development;
- for advertising and marketing, including to send you promotional information about our Services;
- to comply with our legal obligations and resolve any disputes that we may have; and
- for other legitimate purposes as required or permitted by appliable law.
We may process recruiting information to:
- Review and evaluate an application you submit.
- Communicate with you regarding your application or other interest in Spectacles opportunities.
- Process your onboarding if you are hired.
- Operate, improve and maintain the security of our recruiting systems and platforms.
- Comply with applicable laws and otherwise operate our business.
3. Disclosure of personal information to third parties
We may disclose personal information to:
- third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators.
- our employees, contractors and/or related entities.
- market, advertise and promote our Services, including by sharing personal information with third-party service providers.
- distribute, install, operate, support, maintain and upgrade Services and related analytics.
- provide customer service, technical support, consulting or cloud-based information security services, including by sharing personal information with third-party service providers.
- provide seminars and training (whether in-person or online).
- operate, maintain and personalize our Sites for visitors and users of our Services, including providing product demonstrations and resource materials, and including sharing personal information with third-party service providers.
- work with our partners (including suppliers, vendors, resellers, OEMs, distributors and other third parties) pursuant to legal agreements.
- when we have an individual’s consent to share the information.
- as part of group or team collaborations, such as for a particular project, product or service.
- in connection with blogs, message boards, chat rooms or other similar forums, whether publicly shared or shared by or with customers, partners or end users interacting with login access, including related to feedback or suggestions for improvements to our Services.
- In connection with, or during the negotiation of, any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or to another company, including the transfer of contact information and data of customers, partners and end users.
- as part of a joint sales promotion or to pass sales leads to one of our distribution partners.
- to keep individuals up to date on the latest product announcements, product updates, special offers or other information we think they would like to hear about either from us or from our service providers and partners.
- in response to a request for information by a competent authority, if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation or legal process, including to meet national security or law enforcement requirements.
- with law enforcement officials, government authorities or other third parties as necessary to protect the rights, property or safety of Spectacles, its business partners, you or others, or as otherwise required by applicable law.
- in an aggregated and de-identified or anonymized form.
- with affiliates and subsidiaries as necessary to operate our business.
- for other legitimate purposes permitted by applicable law.
We have operations globally and may transfer your personal information on a global basis to operate our business. If personal information is transferred to a recipient in a country that does not provide an adequate level of protection for personal information, we will take measures designed to adequately protect your personal information.
Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to the same data protection laws as those in your jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.
4. Your choices
Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
6. Retention and Security
We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.
We are committed to protecting the personal information you entrust to us. We implement appropriate physical, administrative and technical security measures and technologies designed to secure your personal information on our systems. In addition, we limit access to your personal information to those employees, agents, contractors, and other third parties who have a business need to know.
We have put in place procedures to address any suspected security incident leading to the misappropriation or accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your personal information transmitted, stored or otherwise processed on our systems that compromises the confidentiality, integrity or availability of your personal information and will notify you and any applicable regulator of such an incident where we are legally required to do so.
Notwithstanding our efforts to protect your information, no security system is completely impenetrable, so we cannot guarantee the absolute security of your personal information, nor can we guarantee that information you supply to us will not be intercepted while in transit to us. Any transmission of information or data by you to or through this Site, our Services, or other means is at your sole risk.
7. Transfers of Personal Information Outside of Europe
For information on our processing of personal information of individuals located in the European Economic Area (“EEA”) and United Kingdom, please visit our European Privacy Notice.
8. Children and Minors
Our Sites do not target and are not intended to attract children or minors under the age of 16. We do not knowingly solicit personal information from children or minors under the age of 16 or send them requests for personal information. If you believe we have collected personal information from a person under 16 years old without the consent of their parent or legal guardian, please let us know immediately by contacting us as indicated in this Policy and providing sufficient information so we can act appropriately.
9. Limits of our policy
Our Sites may provide links to Third-Party Sites that are outside our control and not covered by this Policy. We are not liable for any information, content, products, services, software or other materials available on or through a Third-Party Site. The use of an external website or any information or other content found on external websites is subject to and governed by the terms and conditions of such website. We encourage you to review the privacy policies posted on such Third-Party Sites.
10. Changes to this policy
We encourage all individuals who provide personal information to us to keep their personal information accurate and up to date. Personal information may, in many cases, be updated by you online.
If you have any concerns about how we process your data or would like to exercise any of your privacy rights that may be available under applicable law, you can write to us at:
Spectacles, Attn: Legal/Privacy
228 Park Ave S, PMB 28141
New York, NY 10003
or by email to firstname.lastname@example.org.