Privacy Policy
Effective February 15, 2023
Spectrum AI, Inc. (“SpectrumAi,” “we,” or “us”) know that privacy is very important to you. We have created this privacy policy (the “Privacy Policy”) to describe what kinds of personal information we may obtain and process through:
Our websites located at https://spectrumai.com and https://twyll.app (the “Websites”);
Any other websites, mobile application, or digital property that links to this Privacy Policy; and
When you interact with us in person, electronically, or any other way.
By accessing or using any of the Websites, or any other website, mobile application, or digital property that links to this Privacy Policy (collectively, the “Digital Properties”), you may access and use our products and services (collectively, with the Digital Properties, the “Services”).
Acceptance of Privacy Policy
Please read this Privacy Policy carefully. In addition, please review the Terms of Use, which govern your use of our Services.
BY ACCESSING AND/OR USING OUR SERVICES, YOU SIGNIFY THAT YOU HAVE READ, UNDERSTOOD AND AGREE TO BE BOUND BY THE TERMS OF THIS PRIVACY POLICY AND THE TERMS OF USE, WHICH ARE INCORPORATED HEREIN BY REFERENCE.
If you are accepting this Privacy Policy on behalf of your employer or another organization, you hereby certify that you are authorized to bind such party to the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy or the Terms of Use, you should not use our Services.
Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.
Important Notice to All Non-U.S. Residents
SpectrumAi is a U.S.-based company whose Services are offered to domestic business customers. Information that we collect, including personal information, is stored within the U.S., so if you are located outside of the U.S. and you provide information to us, please note that we transfer that information to be processed, maintained and used on computers, servers and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use any of our Services, you consent to any transfer and processing of your personal information in accordance with this Privacy Policy and you do so at your own risk.
Information We Collect and/or Receive
When operating the Services and/or interacting with you, we will collect (and/or receive) the following types of information:
Contact Information
When you contact us via the “Contact us” feature of our Services, email or by mail, when you call us, or when you enroll in our Services, or signup to receive updates from us, you will be asked to provide certain information such as your name, email address, physical address, phone number, business contact information (including business address, telephone numbers, company name or business affiliation, and title) and information regarding your inquiry or comment (collectively, “Contact Information”). The Contact Information is used to provide the requested service or information and to contact you for purposes of direct marketing of our current and future services.
WEB LOGS AND ANALYTICS INFORMATION WE AUTOMATICALLY COLLECT WHEN YOU USE OUR SERVICES
We collect certain information about your interaction with our Services, such as visiting the Twyll website, and store that information in log files. Types of information in this category may include:
Internet Protocol (IP) address
Other device addresses or unique identifiers
Browser type
Internet Service Provider
Device Operating System
Date and time stamps of actions you perform on our websites
Your locale and language preferences
Your mobile carrier
Other configuration information about the device or system you use to access our websites
Cookies and Other Tracking Technologies We Use to Collect Information About You
We use cookies that we save to your device when you access our Services. Cookies are small data files sent to your browser when you use our Services, and they are stored on your device. We use cookies primarily to improve and customize our Services and your experience, and to improve the quality and security of your interactions with our Services. We may also associate the information we store in cookies with personal information you submit while using our Services.
Examples of cookies we use include:
Security cookies: for security purposes
Session cookies: for operating our Service
You may configure your web browser to not accept any cookies or to only accept certain ones, but such changes may prevent you from using some aspects of our Services.
ACCOUNT AND PROFILE INFORMATION
When you enroll to use our Services, you will be asked to provide us information about you and your company. Information we collect includes your name, username, mailing address, email address, phone number. This information may either be provided directly through our Services or, in some cases, via another user, such as an account or application administrator who creates an account on your behalf. You will also be able to create a profile for your account. In the event that you provide information about another individual, you confirm that you have the authority to act for them and to consent to us collecting and using their personal information, as described in this Privacy Policy. Please be careful about what information you include in your profile as your profile will be visible to other users of the Services.
CUSTOMER DATA
When you create, input, submit, post, upload, transmit, or otherwise store information while using our Services, we collect and store that information. We process such information (other than any personal information contained therein) in accordance with the terms and conditions of the services agreement we have with you for the applicable Services. Any personal information contained in the Customer Data will be used in accordance with this Privacy Policy.
INFORMATION COLLECTED AND/OR RECEIVED FROM THIRD PARTIES
We may receive personal information and other information about you from third parties that are our customers or business partners (“Third Party Information”). We will combine this Third Party Information with the other information we collect about you and from you pursuant to this Privacy Policy and use such information in accordance with this Privacy Policy. For example, a customer administrator user may provide information about you while creating an account on your behalf. When one individual provides us with information (including personal information) about another individual, we assume that the individual has permission and is authorized to do so, and that they consent on behalf of the other individual to the collection and use of personal information, as described in this Privacy Policy. Please contact us at legal@spectrumai.com, if you become aware of a third party providing us with your personal information without your authorization to do so, and we will respond in a manner consistent with this Privacy Policy.
How We Use and Share Your Information
SpectrumAi may use and share your personal information for various purposes as set forth below:
To operate our business and provide the Services;
To provide the information you request;
To provide customer support you request with respect to the Services;
To communicate with you regarding the Services;
To fulfill our contractual obligations to you;
To monitor and analyze trends, usage, and activities in connection with our Services;
To administer, operate, and secure our Services;
To better secure our Services, including preventing fraudulent uses and unauthorized access;
To ensure compliance with our internal policies and procedures;
As part of accounting, record-keeping, backup, and Services administration;
As part of workforce education and training in data protection and customer support;
For providing, operating, maintaining, improving, personalizing, and promoting our Services;
As part of developing new products, services, features, and functionality;
To fulfill your requests for information regarding new or improved products and services;
To market our products and services;
In order to enforce our agreements, policies, and terms of service
In order to better secure SpectrumAi’s products and services
To third-party contractors and service providers that provide services to us in the operation of our business and assistance with the Services, such as marketing and advertising companies, consulting service organizations, IT and cloud service providers, among others. These third-party contractors and service providers will have access to your information only as necessary to perform their functions and to the extent permitted by law;
In an ongoing effort to better understand our users and our Services, we might analyze your information in aggregate form in order to operate, maintain, manage, and improve the Services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We 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 share with our parent company, subsidiaries, affiliates and/or other companies under common control with us;
To fulfill our legal and regulatory requirements;
To comply with applicable law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
To assess or complete a corporate sale, merger, reorganization, sale of assets, dissolution, investment, or similar corporate event where we expect that your personal information will be part of the transferred assets; and
Otherwise, with your consent.
We will take reasonable measures (e.g., by contract) to require that any party receiving any of your personal information from us, including for purposes of providing the Services, undertakes to: (i) retain and use such information only for the purposes set out in this Privacy Policy; (ii) not disclose your personal information except with your consent, as permitted by applicable law, or as permitted by this Privacy Policy; and (iii) generally protect the privacy of your personal information.
Your Access to and Control Over Your Personal Information and Communication Preferences
If the personal information we have for you changes, or if you no longer desire our Services, you may correct or update it by logging into our website, such as Twyll, by submitting the change through your company administrator, by submitting a support request, or by contacting us pursuant to the “How to Contact Us” section of this Privacy Policy.
You cannot opt out of receiving transactional emails related to your accounts. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” hyperlink located on the bottom of any of our marketing emails or by contacting us directly at legal@spectrumai.com. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our databases. We will retain and use your information as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.
Information Security
We take the security of your information very seriously and employ various organizational and technical safeguards to protect the information we collect, including encryption of data in-transit and at-rest, taking into account the risks involved in processing and the nature of such data, and in compliance with applicable laws and regulations. We also require our service providers to employ safeguards that are at least equivalent to those we have in place for protecting any information we share with them. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, email sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via email.
If you have any concerns or questions about the security of your information with SpectrumAi, please contact us immediately by emailing security@spectrumai.com.
Links to Third-Party Sites
Our Services may, from time to time, contain links to external websites. We encourage you to review the privacy and security policies of any externally linked websites that may be accessed through our Services. We assume no responsibility or liability for the information collection and disclosure practices of any external websites that a user can access through our Services. Please check the privacy policies of these external websites before you submit any personal information to them.
DO NOT TRACK
We currently do not change our tracking practices in response to “do not track” settings in your browser. We may have our third-party partners, including web analytics companies, collect information about your online activities over time and across the Services. These third parties may not change their tracking practices in response to DNT settings in your browser.
Data Retention
We retain your personal information only for as long as it is necessary to fulfill the purposes for which we obtained it, as further described in this Privacy Policy. We will also retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Children
SpectrumAi’s Services are not offered directly to or intended for use by children under the age of 13 (“Children”). We do not knowingly collect or receive any personal information from Children through our Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Privacy Policy by instructing their children to never provide any personal information through the Services, or any other web site without their permission. If you become aware that a child under the age of 13 has provided us with personal information, please contact us by emailing legal@spectrumai.com, and we will endeavor to delete that information from our databases.
Notice to Nevada Residents
If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties. You can exercise this right by contacting us at legal@spectrumai.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.
Changes to This Privacy Policy
This Privacy Policy may be updated from time to time. All updates are effective immediately when posted. By accessing and/or using our Services, or otherwise engaging or interacting with us following the posting of the revised Privacy Policy, you are deemed to have accepted and agreed to such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your personal information is governed by the Privacy Policy in current effect. Please refer back to this Privacy Policy on a regular basis.
How to Contact Us
If you have questions about this Privacy Policy, the ways in which we collect and use your information, your choices, and rights regarding such use, or to report a privacy issue, you may contact us by sending an email to: legal@spectrumai.com
