PRIVACY POLICY
The short version
01
– Information We Collect – You directly provide us with most of the
information we collect: when you register to the Site, use it, complete forms,
or register to any of our programs. We also collect information about your
communications with SAPSPACES as well as any of your posts on our blogs or
forums and your communication with other users of SAPSPACES. In addition, we
automatically collect information while you access, browse, view or otherwise
use the Site and receive information from third party vendors or other
available sources.
Our
Legal Basis for Using Your Personal Information – Where relevant
under applicable laws, all processing of your personal information will be
justified by a “lawful ground” for processing as detailed below.
How
Do We Use the Information Collected? – We use personal information to
provide you with quality service and security, to operate the Site, to perform
obligations to you and to develop, improve and personalize our service; to
ensure marketplace integrity and security; to prevent fraud; to contact you and
send you direct marketing communications; to promote and advertise the Site,
our services and the SAPSPACES marketplace; to comply with lawful requests by
public authorities and to comply with applicable laws and regulations.
How
Long Do We Keep Personal Information – We will keep personal information
only for as long as is required to fulfil the purpose for which it was
collected. However, in some cases we will retain personal information for
longer periods of time.
Children – This Site is
offered and available to users who are at least 18 years of age and of
legal age to form a binding contract. Minors under 18 and at least 13 years of
age, are only permitted to use the Site through an account owned by a parent or
legal guardian with their appropriate permission. Minors under 13 are not
permitted to use the Site or the SAPSPACES services. We do not knowingly
collect personal information from children under 13.
Sharing
Personal Information with Third Parties – We share personal information
with third parties in order to operate the Site, provide our services to you,
fulfil obligations imposed on us by applicable laws and regulations, and
prevent fraud, infringements and illegal activities.
Where
We Process Personal Information – Some of the personal information you
provide to us will be stored or processed on our behalf by third party
suppliers and data processors and may be located in other jurisdictions, such
as the United States or Erope.
Cookies – We use cookies and
similar technologies (such as web beacons, pixels, tags, and scripts) to improve
and personalize your experience, provide our services, analyze website
performance and for marketing purposes.
Do
Not Track (DNT)
– Our Site does not respond to Do Not Track (DNT) signals.
External
Links
– the Site contains links to third party sites and if you link to a third party
site from the Site, any data you provide to that site and any use of that data
by the third party are not under the control of SAPSPACES and are not subject
to this Policy.
Security – We implement technical
and organizational measures to maintain the security of the Site and your
personal information and in preventing unauthorized access, loss, misuse,
alteration, destruction or damage to it through industry standard technologies
and internal procedures.
Updating
Personal Information
– We take steps to ensure that the personal information we collect is accurate
and up to date, and we provide you with the opportunity to update your
information through your account profile settings. In the event that you
believe your information is in any way incorrect or inaccurate, please let us
know immediately.
Contact
Us
– You can exercise your rights over your personal information, by opening a
Customer Relations ticket or contacting us at admin@SAPSPACES.com.
2. Information We Collect
Information
You Provide.
When you register to the Site, use it, complete forms, participate in skills
tests or surveys, sign up for events or newsletters, use the Site as
collaborator, and/or register to our affiliate or influencer or similar
program, we ask you to provide or otherwise collect personal information
provided by you, including a valid email address, login details, name and
username, profile details (including picture, education, profession and
expertise), physical address or billing information, telephone number or other
contact details, date of birth, transactional information, payment information
(for example, your payment method and credit card number), taxpayer information
and forms (including W-9 Forms and DAC-7 Forms), details
about other social networks linked accounts, details about your listed gigs,
orders, purchases and transactions rating and reviews, information included in
user generated content and files uploaded by you to the Site, and additional
authentication information (such as copies of your government issued ID,
passport, or driving license, as detailed in our Help Center at “Verifying Your Identity”). We also collect and
process information about or contained in your communications with SAPSPACES as
well as any of your posts on our blogs or forums and your communication with
other users of SAPSPACES.
Additionally,
in order to improve your online experience at SAPSPACES, we have implemented
impression reporting. While you view our ads, we gather user Global Unique
Identifier, HTTP request data like, user agent, IP, host, URL,
country/continent from which request made, browser info, device/operating
system/operating system version.
Information
We Receive from Third Parties. We receive information from third party
vendors and/or other commercially and/or publicly available sources, such as:
• Third party vendors who provide us data
to supplement the information we collect about you, in accordance with
applicable laws. For example, we receive fraud and security warnings from
service providers for our fraud prevention and risk assessment efforts. We also
receive information about you, such as information about your organization and
job title, from enrichment service providers to enhance and personalize your
experience and offer you services that may be of interest for you as well as
from advertising and marketing partners in order to manage and measure our
campaigns.
• If you link, connect, or login to your
account with a third-party service (e.g. Google, Facebook, LinkedIn), we
receive certain information, such as your registration and profile information
from that service. This information includes, for example, your email address,
name and profile picture, but may vary and is controlled by that service or as
authorized by you via your privacy settings at that service.
• If you choose to invite contacts from
your Google Workspace directory, we will have the ability to view details of
contacts, subject to your Google Workspace permission. We will use this data to
allow you to invite your contacts to your SAPSPACES account. We will also use
aggregated anonymised information for our internal purposes.
• If you integrate into your account
information from third parties or otherwise integrate your account with third
party systems, tools or products, we will receive certain information about you
according to your permissions at such third parties.
• We also receive certain information
about you, if you are invited to SAPSPACES by another user (for example, as
part of our collaboration tools and referral program), in such case we will
receive limited information, such as your email address or other contact
information, and we will use it for the same purpose it was provided and in
accordance with this Policy.
We
combine your personal information with information we collect automatically or
obtain from other companies and use it for the purposes detailed in this
Policy.
3. Our Legal Basis for Using Your Personal
Information
Where
relevant under applicable laws, all processing of your personal information
will be justified by a “lawful ground” for processing. In the
majority of cases, processing will be justified on the legal basis that:
·
you have provided your consent for us to use your personal
information for a specific purpose;
·
our use of your personal information is necessary to perform a
contract or take steps to enter into a contract with you (e.g. to provide you
with services which you have purchased);
·
the processing is necessary to comply with a relevant legal
obligation or regulatory obligation that we have (e.g. fraud prevention); or
· the processing is necessary to support our legitimate interests as a business (e.g. to improve our services to you), subject to your overriding interests and fundamental rights and provided it is conducted at all times in a way that is proportionate.
4. How Long Do We Keep Personal Information?
We
apply a general rule of keeping personal information only for as long as is
required to fulfil the purpose for which it was collected. However, in some
circumstances, we will retain your personal information for longer periods of
time. We will retain personal information for the following purposes:
·
as long as it is necessary and relevant for our operations, e.g.
so that we have an accurate record of your dealings with us in the event of any
complaints or challenges;
·
in relation to personal information from closed accounts to
comply with applicable laws, prevent fraud, collect any fees owed, resolve
disputes, troubleshoot problems, assist with any investigation, enforce our
Site terms and take other actions as permitted by law;
·
to comply with statutory or other obligations to which SAPSPACES
is subject to; and
·
if and to the extent necessary, we need it to preserve evidence
within the statutes of limitation.
5. Children
This
Site is offered and available to users who are at least 18 years of age or
older and of legal age to form a binding contract. Minors under 18 and at least
13 years of age, are only permitted to use the Site through an account owned by
a parent or legal guardian with their appropriate permission. Minors under 13
are not permitted to use the Site or the SAPSPACES services. We do not
knowingly collect personal information from children under 13. Parents and
guardians should at all times supervise their children’s activities. If we
learn we have collected or received personal information from a child under 13,
we will delete that personal information. If you believe we might have any
information from or about a child under 13, please contact us at admin@SAPSPACES.com.
6. Sharing Personal Information with Third
Parties
We
share your personal information with third parties as detailed below:
·
With other users and Site visitors. Once you register, your username, country,
and additional information regarding your activity is made public and is
visible to all users of the Site. This information includes photos you upload,
your published portfolio, Gig information, ratings and reviews, and additional
information you may choose to add to your profile. We also offer you the
opportunity to participate and post content publicly in forums, blogs and on
other similar features. Please be aware that certain information, such as your
user name and profile, together with the content uploaded by you, will be
publicly displayed when you use such features. Your information will also be
shared with other users when you message or otherwise communicate with them.
When you publish your information and/or share your data with other SAPSPACES
users, you do so at your own risk. If you choose to share personal information
with other users, including Sellers providing you a service via SAPSPACES, such
personal information is shared with other users as separate controllers. While
our Terms of Service require Sellers to keep the information shared with them
confidential, SAPSPACES cannot ensure that all users will do so and it is your
responsibility to ensure that other users will comply with your standards;
·
With users with whom you interact. We share personal information to help
facilitate interactions between users. For example, if you are a Buyer we may
share certain information about you (such as the fact it is your first purchase
on SAPSPACES) with the Seller to ensure the services you receive from the Seller
will fit your needs; such sharing of information is limited in scope, and is
intended to improve the services provided by the Seller and your user
experience;
- With Service Providers. We share personal information for business purposes
with service providers that provide us with services for the purpose of
operating the Site, opening and operating your account as well as
providing ancillary services and solutions. These include, among others,
hosting services, billing and payment processors and vendors, fraud
detection and prevention services, CRM systems, forum hosting, community
management services, data and cybersecurity services, web analytics and
performance tools, translation tools, session recording, communication
systems, mailing systems, data optimization and marketing services, data enrichment
services, legal and financial advisors and technical consultants.
Consistent with applicable legal requirements, we take appropriate
technical and organizational measures to require third parties to
adequately safeguard personal information and only process it in
accordance with our instructions;
• For
legal reasons. We share personal information with law enforcement agencies,
public authorities or other parties in order to respond to a subpoena or court
order, judicial process or to regulatory authorities, if we believe we are
required to do so by law, or that doing so is reasonably necessary to comply
with legal processes; when we believe it necessary or appropriate to disclose
personal information to law enforcement authorities, such as to investigate
actual or suspected fraud or violations of law, breaches of security, or
breaches of this Policy; to respond to claims against us; and to protect the
rights, property, or personal safety of SAPSPACES, our customers, or the
public;
• For
payments and fraud detection. We share personal information with payment
processors, fraud detection agencies and similar third parties for the purpose
of facilitating payments done via the Site, securing the Site and protecting it
against fraud, unauthorized transactions (such as money laundering), claims or
other liabilities;
• With
social media partners. Our Site includes certain social media features,
including single sign on features. We also share limited personal information
with such social media platforms and marketing partners, such as Facebook and
Google, to promote our services or the SAPSPACES marketplace. Such features and
third party services collect certain information about you and may set a cookie
to enable their functionality. Such third parties’ features are governed by
their policies;
• With
our corporate affiliates. We share personal information with SAPSPACES’s
corporate affiliates for the purpose of operating our and our affiliates’
business and providing services to you, preventing fraud and maintaining safe
and secure services, promoting our and our affiliates’ services and for other
purposes listed herein; and
• In the context of a corporate
transaction. Personal information will also be disclosed if we go through a
business transition such as a merger, sale, transfer of all or a portion of
SAPSPACES’s assets, acquisition, bankruptcy or similar event. In the event that
we sell any business or assets, we will disclose your data to the prospective
buyer. If we or substantially all of our assets are acquired by a third party,
information held by us about our users will be one of the transferred assets.
7. Where We Process Your Personal Information
Some
of the personal information you provide to us will be stored or processed on
our behalf by third party suppliers and data processors and may be located in
other jurisdictions, such as the United States, whose laws may differ from the
jurisdiction in which you live. Whether to third parties or internally, there
are also transfers of personal information from the European Economic Area
(“EEA”) to countries outside of the EEA not deemed to provide an adequate level
of data protection from a European data protection perspective, such as the
United States. With regard to data transfers to such recipients outside of the
EEA we provide appropriate safeguards, in particular, by way of entering into
European Union (EU) standard contractual clauses as amended from time to time,
and/or equivalent data transfer safeguards. We will take all steps reasonably
necessary to ensure that your personal information is treated securely and in
accordance with this Policy.
8. Cookies
We
use cookies and similar technologies (such as web beacons, pixels, tags, and
scripts) to improve and personalize your experience, provide our services,
analyze website performance and for marketing purposes. Where the use of
cookies on our Site involves the processing of your personal information, this
Policy applies. The types of cookies used by us and our partners in connection
with the Site and our service can be classified into the categories “essential
cookies”, “analytics cookies” and “marketing cookies”.
To
learn more about how we and our third party service providers use cookies and
your control over these Cookies, please see our Cookie Policy.
9. Do Not Track
Do
Not Track (DNT) is a privacy preference that users can set in some web
browsers, allowing users to opt out of tracking by websites and online
services. We do not honor browser requests not to be tracked online (known as
“Do Not Track”), but our Cookie Policy describes
how you can opt out of receiving cookies.
10. External Links
Please
note that the Site contains links to third party sites and if you navigate to a
third party site from the Site, any data you provide to that site and any use
of that data by the third party are not under the control of SAPSPACES and are
not subject to this Policy. You should consult the privacy policies of each
site you visit. This Policy applies solely to personal information collected by
our Site. If you upload content, including personal information, to a social
network and then tag the Site, your submission will be subject to that social
network’s terms of use and privacy policy, even where you post on an official SAPSPACES
page on the social network. We do not have control over these terms of use and
privacy policies and have not reviewed their adequacy. You should therefore
review these before submitting any personal information.
11. Security
We implement technical and organizational
measures in order to maintain the security of the Site, our services and
personal information and in preventing unauthorized access, loss, misuse,
alteration, destruction or damage to it through industry standard technologies
and internal procedures.
We contractually ensure that any third
party processing your personal information equally provides for confidentiality
and integrity of your data in a secure way. However, the transmission of data
via the internet is not completely secure, and although we will do our best to protect
your personal information, we cannot guarantee the security of your data
transmitted to the Site. Once we have received your data, we will use strict
procedures and security features to try to prevent unauthorized access.
Users who have registered to the Site agree
to keep their password in strict confidence and not disclose such password to
any third party.
Further information about our data security
practices can be provided on request.
12. Specific Provisions for EU, EEA and UK
Users
This
section of the Policy applies to you if you are in the EU, the European
Economic Area (EEA) or UK.
Under
applicable EU regulation, you have the following rights in respect of your
personal information:
·
to obtain information about how and on what basis your personal
information is processed and to obtain a copy;
·
to rectify inaccurate personal information;
·
to erase your personal information in limited circumstances
where (a) you believe that it is no longer necessary for us to hold your
personal information; (b) we are processing your personal information on the
basis of legitimate interests and you object to such processing, and we cannot
demonstrate an overriding legitimate ground for the processing; (c) where you
have provided your personal information to us with your consent and you wish to
withdraw your consent and there is no other ground under which we can process
your personal information; and (d) where you believe the personal information
we hold about you is being unlawfully processed by us;
·
to restrict processing of your personal information where: (a)
the accuracy of the personal information is contested; (b) the processing is
unlawful but you object to the erasure of the personal information; (c) we no
longer require the personal information for the purposes for which it was
collected, but it is required for the establishment, exercise or defence of a
legal claim or (d) you have objected to us processing your personal information
based on our legitimate interests and we are considering your objection;
·
to object to decisions which are based solely on automated
processing or profiling;
·
where you have provided your personal information to us with
your consent, to ask us for a copy of this data in a structured,
machine-readable format and to ask us to share (port) this data to another data
controller; or
·
to obtain a copy of or access to safeguards under which your
personal information is transferred outside of the EEA.
Under
certain circumstances, you may have the right to object, on grounds relating to
your particular situation, to the processing of your personal data by us and we
may be required to no longer process your personal data. Moreover, if your
personal data is processed for direct marketing purposes, you have the right to
object at any time to the processing of personal data concerning you for such
marketing, which includes profiling to the extent that it is related to such
direct marketing. In this case your personal data will no longer be processed
for such purposes by us.
To
exercise your rights please contact us as stated in the “Contact Us” section.
In
addition to the above, you have the right to lodge a complaint with a
supervisory authority for data protection. Please note that the right of access
and the right to erasure do not constitute absolute rights and the interests of
other individuals may restrict your right of access or erase in accordance with
local laws.
We will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested by you. We reserve the right to charge a fee where permitted by law. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal information for a limited period of time for record-keeping, accounting and fraud prevention purposes.
13. Specific Provisions for US Residents
This
section of the Policy applies to you, if you are a us resident, depending on
where you live and subject to certain exceptions.
During
the last twelve (12) months we have collected the following categories of
personal information from users:
·
Information that you chose to upload or otherwise provided by
you to SAPSPACES, which may include: (i) Identifiers and personal information,
such as name, postal addresses, online identifiers, email addresses, passport
number or driving license number, social security number; (ii) characteristics
of protected classifications, such as gender; facial image; audio, electronic
or similar information; (iii) professional or employment-related information;
(iv)education information; (v) commercial information; (vi) Audio or other
sensory information, for example if you provide audio-based services on SAPSPACES.
·
Information we collect when you use SAPSPACES, including (i)
Identifiers and personal information, such as online identifiers, internet
protocol (IP) addresses, access device and connection information such as
browser type, version, and time zone setting and browser plug-in types and
versions; (ii) commercial information, including products or services
purchased, obtained, or considered, or other purchasing or consuming histories
or tendencies; (iii) Internet or other electronic network activity information,
including, but not limited to log-in and log-out time, the duration of
sessions, the content uploaded and downloaded, viewed web-pages or specific
content on web-pages, activity measures; (iv) Location information.
·
Information that we collect or receive from third parties, such
as service providers, advertisers, and third-party accounts you link with SAPSPACES,
including: (i) Identifiers and personal information, such as name, online
identifiers, email addresses, internet protocol (IP) addresses, access device
and connection information such as browser type, version, and time zone setting
and browser plug-in types and versions; (ii) Professional or employment-related
information; (iii) Internet or other electronic network activity information,
including, but not limited to log-in and log-out time, the duration of
sessions, the content uploaded and downloaded, viewed web-pages or specific
content on web-pages, activity measures; (iv) Commercial information; and (v)
Location information.
·
Inferences drawn from any of the information identified above to
create a profile about you.
We
use the personal information that we collect or receive for the business
purposes as described above under the Section titled “How Do We Use the
Information Collected?”.
We
may disclose the above listed categories of personal information to third
parties for business purposes as described above under the Section titled
“Sharing Personal Information with Third Parties” in the Privacy Policy. In the
preceding twelve (12) months, we have disclosed all the categories of personal
information detailed above for business purposes.
You
are entitled to the following rights subject to certain exceptions, in relation
to personal information related to you:
·
You have a right to request access to the personal information
we have collected about you over the past 12 months, including: (i) the
categories of personal information we collect about you; (ii) the categories of
sources from which the personal information is collected; (iii) the business or
commercial purpose for collecting your personal information; (iv) the
categories of third parties with whom we have shared your personal information;
(v) the specific pieces of personal information that we have collected about
you.
·
You have a right to request that we delete personal information
related to you that we collected from you under certain circumstances and
exceptions.
·
You have a right to correct the personal information you
provided us with.
·
You have a right to opt out of selling your personal
information.
·
You have a right to opt out of targeted advertisement.
·
You also have a right not to be discriminated against for
exercising your rights.
·
You also have a right to submit your request via an authorized
agent. If you use an authorized agent to submit a request to access or delete
your personal information on your behalf, the authorized agent must: (1) be a
person or business entity registered with the relevant Secretary of State to
conduct business in relevant state; (2) provide proof of such registration; and
(3) provide documentation or other proof indicating that they are authorized to
act on your behalf. We may also require you to verify your identity directly
with us, and directly confirm with us that you provided the authorized agent
permission to submit the request.
To
make such requests, we kindly ask that you open a Customer
Relations ticket. If you do not have an active SAPSPACES account,
please contact us at admin@SAPSPACES.com.
14. Updating Personal Information
We
take steps to ensure that the personal information we collect is accurate and
up to date, and we provide you with the opportunity to update your information
through your account profile settings. In the event that you believe your
information is in any way incorrect or inaccurate, please let us know
immediately. We will make sure we investigate the matter and correct any
inaccuracies as quickly as possible where necessary or give you ways to update
it quickly or to delete it – unless we have to keep that information for
legitimate business or legal purposes. When updating your personal information,
we will ask you to verify your identity before we can act on your request. If
for any reason you have a problem with deleting your personal information, please
contact SAPSPACES’s Customer Support and we will make reasonable efforts to
delete any such information pursuant to any applicable privacy laws.
You
can review and change your personal information by logging into the Site and
visiting your account profile page.
If
you delete your User Generated Content (“UGC”), as defined in
the SAPSPACES Terms of Service, from the Site, copies of your UGC may
remain viewable in cached and archived pages, or might have been copied or
stored by other Site users. Proper access and use of information provided on
the Site, including UGC, is governed by our Terms of Service.
15. Contact Us
To
exercise any of your rights in connection with your personal information, we
kindly ask that you open a Customer Relations ticket. Please include all the
relevant details, so your ticket can be handled correctly. We will process any
requests in line with any local laws and our policies and procedures. You may
also contact us at admin@SAPSPACES.com